Anant Bhalla
Analyst · Suneet Kamath with Citi
Sure, thanks for that question. As Eric mentioned, the dialogue and comment period will take a little bit of time to work its way through 2018 over here. However, to your specific point on the variable, there are 28 specific recommendations, if memory serves me right, which I would group into, one, 3 to 4 structural categories and the last category being how people are calibrating or parameterizing the methodology. So on the structural categories, first, it's about managing to a total asset requirement or TAR based on a high CTE requirement, just like our CTE95. So we're aligned with that. Second, it's the use of the standard scenario not as a binding requirement over the high CTE standard, but more as a validation on the impact of different companies' actuarial assumptions and models. So it's almost a validation point and where it's going to work. There's prescribed assumptions anchored in industry data like what we did in our assumption update last quarter, but at a lower CTE like I think we're talking about CTE65, so it's a validation point. And third, incentivizing long-term hedging, not just short term, and increasing disclosure, all which is congruent with the way we've designed our strategy, the way we are executing our strategy and now growing the buffer. So I rarely then go structurally. Those are my comments on the 28 proposals. Finally, it boils down to the last category of calibration of a model or parameterization of a model and that will be the focus of dialogue over the coming year, how do you calibrate scenario definitions, whether it's equity returns or interest rates? Do you look from 1955 to now? Do you go back to the '20s? Do you go back to the 1800s? And then this is a long-term business and you have to look at the long-term nature of the business and what that means for these definitions and then what CTE you pick, 93, 95, 98. That was a mouthful so I'm going to pause, but hopefully you got what you're looking for.