Under an agreement secured by Leslie Jones, chairman of the task force and an actuary in the South Carolina Department of Insurance, changes in current language of the reinsurance waiver guidelines will be drafted based on comments from commissioners, and a conference call will be held in mid-October to win approval for the final language.

That will set the stage for final approval of the accreditation standards for risk retention groups at the winter meeting of the NAIC, scheduled for December. Specifically, the conference call would secure approval of an exposure draft that would then go to the parent committee, the Accreditation E-Committee.

A consensus on the new standards was arrived at during a task force session convened in connection with the NAIC's fall meeting here.

Most of the concerns of task force members focused on a provision dealing with solvency of the reinsurer, and whether claims are enforceable and money is available to pay them.

One of the factors in the task force's decision to stick to its original plan was a letter from Mr. Myers, a partner with the law firm of Morris Manning & Martin LLP in Washington.

His letter was sent to members of the task force three days before the meeting. Mr. Myers also testified at the task force meeting on the issue.

"The Task Force has been working on credit for reinsurance [for captive RRGs] for at least six months," he said. "The proposal voted on favorably at the last conference call is a product of all that work."

In the letter, he added that "a decision by the task force at this late date not to deviate in any respect from the NAIC Model would be a repudiation of all the task force's work in the past six months and an unwillingness to even consider the substance of what has been accomplished."

In his letter, he explained that RRGs chartered as captives are subjected to a different regulatory scheme from traditional property-casualty insurers.

Specifically, he said, "Captive regulation of RRGs is a more 'hands on' contemporaneous form of regulation than traditional regulation."

He also noted that while traditional insurers are only required to bring to the attention of regulators material transactions that trigger the Holding Company Systems Act benchmarks, "RRGs regulated as captives must obtain prior approval of any deviation from the business plan approved by the commissioner.

"This means that any change in reinsurance would have to receive prior approval," he explained.

Mr. Myers also said that the captive manager serves as the "eyes and ears" of the commissioner and has a duty to immediately report any deviation from the business plan or any indication that the RRG may be taking actions that could result "in a hazardous financial condition."