Regulatory Requirements

12 Months Ended

Dec. 31, 2011

Regulatory Requirements

Regulatory Requirements

19. Regulatory Requirements

Restrictions on the transfer of funds exist under regulatory requirements applicable to certain of the Company's subsidiaries. At December 31, 2011, the aggregate amount of unrestricted net assets was approximately $1.6 billion.

The National Association of Insurance Commissioners ("NAIC") defines Risk-Based Capital ("RBC") requirements for insurance companies. The RBC requirements are used by the NAIC and state insurance regulators to identify companies that merit regulatory actions designed to protect policyholders. These requirements apply to both the Company's life and property casualty insurance companies. In addition, IDS Property Casualty is subject to the statutory surplus requirements of the State of Wisconsin. The Company's life and property casualty companies each met their respective minimum RBC requirements.

State insurance statutes also contain limitations as to the amount of dividends and distributions that insurers may make without providing prior notification to state regulators. For RiverSource Life, dividends or distributions in excess of statutory unassigned surplus, as determined in accordance with accounting practices prescribed by the State of Minnesota, require advance notice to the Minnesota Department of Commerce, RiverSource Life's primary regulator, and are subject to potential disapproval. In addition, dividends whose fair market value, together with that of other dividends or distributions made within the preceding 12 months, exceeds the greater of (i) the previous year's statutory net gain from operations or (ii) 10% of the previous year-end statutory capital and surplus are referred to as "extraordinary dividends." Extraordinary dividends also require advance notice to the Minnesota Department of Commerce, and are subject to potential disapproval. Government debt securities of $7 million and $6 million at December 31, 2011 and 2010, respectively, held by the Company's life insurance subsidiaries were on deposit with various states as required by law and satisfied legal requirements. Statutory capital and surplus for RiverSource Life were $2.7 billion, $3.7 billion and $3.4 billion for the years ended December 31, 2011, 2010 and 2009, respectively.

Ameriprise Certificate Company ("ACC") is registered as an investment company under the Investment Company Act of 1940 (the "1940 Act"). ACC markets and sells investment certificates to clients. ACC is subject to various capital requirements under the 1940 Act, laws of the State of Minnesota and understandings with the Securities and Exchange Commission ("SEC") and the Minnesota Department of Commerce. The terms of the investment certificates issued by ACC and the provisions of the 1940 Act also require the maintenance by ACC of qualified assets. Under the provisions of its certificates and the 1940 Act, ACC was required to have qualified assets (as that term is defined in Section 28(b) of the 1940 Act) in the amount of $2.8 billion and $3.1 billion at December 31, 2011 and 2010, respectively. ACC had qualified assets of $2.9 billion and $3.4 billion at December 31, 2011 and 2010, respectively. Ameriprise Financial and ACC entered into a Capital Support Agreement on March 2, 2009, pursuant to which Ameriprise Financial agrees to commit such capital to ACC as is necessary to satisfy applicable minimum capital requirements, up to a maximum commitment of $115 million. For the years ended December 31, 2011 and 2010, ACC did not draw upon the Capital Support Agreement and had met all applicable capital requirements.

Threadneedle's required capital is predominantly based on the requirements specified by its regulator, the Financial Services Authority, under its Capital Adequacy Requirements for asset managers.

The Company has four broker-dealer subsidiaries, American Enterprise Investment Services Inc., Ameriprise Financial Services, Inc., RiverSource Distributors, Inc. and Columbia Management Investment Distributors, Inc. The broker-dealers are subject to the net capital requirements of the Financial Industry Regulatory Authority ("FINRA") and the Uniform Net Capital requirements of the SEC under Rule 15c3-1 of the Securities Exchange Act of 1934.

Ameriprise Trust Company is subject to capital adequacy requirements under the laws of the State of Minnesota as enforced by the Minnesota Department of Commerce.

Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the responsibility for ongoing examination, supervision and regulation of federal savings associations, including Ameriprise Bank, transferred from the Office of Thrift Supervision ("OTS") to the Office of the Comptroller of Currency ("OCC") effective July 21, 2011. Ameriprise Bank is required to maintain sufficient capital in compliance with the OCC regulations and policies. Typically, the OCC requires savings banks to maintain a Tier 1 (core) capital requirement based upon 4.00% of total adjusted assets, total risk-based capital based upon 8.00% of total risk-weighted assets, as well as Tier 1 risk-based capital based upon 4.00% of total risk-weighted assets and a tangible capital ratio of at least 1.50%. Ameriprise Bank agreed with the regulators to maintain its Tier 1 capital-to-assets leverage ratio at or above 7.50%, rather than the OCC-regulated Tier 1 (core) capital requirement of 4.00% and keep its total risk-based capital ratio at or above 12.00%. As a thrift, Ameriprise Bank is also required to maintain 65.00% of its portfolio assets in qualified thrift investments, which include mortgage and consumer-related loans and investments. As of December 31, 2011 and 2010, Ameriprise Bank had met all applicable capital requirements.