Of the Dodd-Frank Act's sundry requirements, few have caused as much consternation among bank regulators as the mandate to evaluate capital without the help of credit ratings.

However, state insurance regulators aren't struggling with the issue like their banking counterparts. The National Association of Insurance Commissioners (NAIC) replaced ratings-based capital determinations for mortgage-backed and other structured securities with a centralized, third-party loss-modeling system — voluntarily and more than a year ago. The association and others say their method could readily translate to banking.

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