On Friday July 14, SFA—along with 5 other trade associations—signed on a letter to the NAIC on their exposure draft proposal that would grant to the NAIC Securities Valuation Office discretion in assigning ratings for purposes of calculating risk-based capital. The letter notes that the proposal suffers from procedural deficiencies (including a lack of an adequate appeals procedure), concentrates risk within the NAIC SVO, lacks transparency, and does not include proper checks and balances. The letter also makes recommendations that would improve transparency and alleviate concerns related to the proposed NAIC process in the exposure draft.