Using publicly available statutory data, the authors explore trends in variable annuity (VA) risk exposure among the leading VA life insurers, including trends in the use of affiliated captives for VA risk transfer. While the risk remains within the organization, the use of affiliated reinsurance captives provides opportunities for regulatory capital arbitrage by allowing the transfer of reserves to a regulatory regime with lower capital requirements. The authors estimate the capital relief achieved by the top 10 VA life insurers and raise potential policy implications for consideration.