Key takeaways:

• On July 23, 2015, the NAIC’s ComFrame Development and Analysis (G) Working Group released a Discussion Draft on Approaches to a Group Capital Calculation focusing on three different RBC-based approaches.
• The NAIC’s decision to begin developing a U.S. group capital measure was not broadly expected and the release of the Discussion Draft at minimum suggests continued pressure on the NAIC to further explore group regulatory capital standards for U.S. insurers.
• The high-level nature of the Discussion Draft creates a host of unanswered questions regarding implementation and administration of a group-wide capital standard.