Asked for comment yesterday, an NAIC spokesperson had no immediate comment. A message seeking comment from Raymond Spudeck, the SVO research manager in New York, drew no response.

NAMIC's statement, describing its latest advocacy report, "Rationalizing the NAIC Securities Valuation Office," said SVO ratings add "no value to the regulatory process"

The NAMIC report further suggested that the SVO's monopoly perpetuates duplicative "ratings," which "typically amount to no more than affirmations of ratings previously performed by nationally recognized statistical ratings organizations," said William Boyd, NAMIC's financial regulation manager.

Mr. Boyd added, "Where NRSRO ratings exist, the SVO does not belong." SVO's "ratings" activities, according to NAMIC, serve only to create superfluous cost to insurers.

The NAMIC report questions why, despite what it said was the insurance industry's plea for exemption from unneeded ratings already available from national rating firms, the NAIC has been reluctant to desist from the ratings business "where the SVO adds no value."

The group suggested that this question must be considered with attention to financial results and product of the SVO.

Rationalizing the SVO, NAMIC said, involves, at least, greatly diminishing its scope of operations:

? Removing all duplicative "ratings" activity and the personnel and facilities associated with that work.

? Allowing ratings of securities that are not rated by NRSROs only to the extent that the SVO successfully competes with national rating organizations.

? Providing research and advice to state regulators on an as-needed rather than an unlimited basis.

? Making the SVO's revenues, expenses and product fully transparent, with revenues based on expenses.

Roger Schmelzer, NAMIC vice president-regulatory affairs, said the organization's Advocacy Reports will be issued on a periodic basis to create "more frank discussion between the regulatory community and NAMIC on issues that affect the property-casualty insurance industry."

The latest Advocacy Report is on the Web at http://www.namic.org/regulatory/securvaloffice.asp.

NAMIC counts as members more than 1,300 large and small companies that it says underwrite 40 percent, or $123 billion, of the property-casualty insurance premiums in the United States.