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To the editor: Your bias with respect to risk retention groups was exemplified again in your Oct. 6 opinion, "Averting Death by 1,000 Fees."

It is obvious that little research exists behind such opinions. In fact, risk retention groups continue to demand a disproportionate amount of state regulators' attention on matters of financial solvency. While there are a number of well-managed RRGs operating with sufficient capital, there is an even larger group that requires close scrutiny from regulators not only because of solvency concerns but also the added discomfort of regulators knowing that RRGs provide no guaranty fund protection for their residents, who may become RRG claimants.

It is appropriate to think of RRGs as loose confederations of insureds with similar risks who have entered into joint and several liability relationships. Those relationships are only as strong as their weakest links, and in the current competitive marketplace, where traditional insurers are cherry-picking the better risks out of RRGs, the solvency concerns are only aggravated.

It would be easy for state regulators to look the other way and blame the federal government every time an RRG failed, but it would not be the responsible thing to do. State regulators have valid added concerns with out-of-state RRGs that do business in their jurisdictions, and to address those concerns costs money.

Your editorial makes it appear that the regulatory process imposes fees for punitive purposes rather than to recover the higher costs associated with RRGs.

Robert C. Quigley

Quigley & Associates

Hatboro, Pa.