The Long Term Care Insurance Multistate Rate Review Subgroup (“the Subgroup”) exposed a Long Term Care Insurance (LTCI) Multistate Rate Review Framework (“the Framework”) which covers a potential approach to increase consistency of LTCI rate review actions across states and improve efficiency of LTCI rate reviews for insurers. RRC appreciates the opportunity to offer our comments. Should you have any questions, we would be glad to discuss our comments with you and the Subgroup members.