In his letter to Congress on Dec. 13, J. Robert Hunter, president of the Consumer Federation of America, told lawmakers that the American Academy of Actuaries TRIA Subgroup "is not independent" from the insurance industry because of member business affiliations.

In addition, he attacked some of the particulars of the analysis itself, contending that the actuaries' report:

o Ignored the availability of a 35 percent federal tax write-off for a $170 billion terrorism event referenced in the study.

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