7.
Reinsurance The Company reinsures a portion of the insurance risks associated with its traditional life, DI and LTC insurance products through reinsurance agreements with unaffiliated reinsurance companies.
Reinsurance contracts do not relieve the Company from its primary obligation to policyholders.
The Company generally reinsures 90% of the death benefit liability for new term life insurance policies beginning in 2001 and new individual fixed and variable universal life insurance policies beginning in 2002.
Policies issued prior to these dates are not subject to these same reinsurance levels.
However, for IUL policies issued after September 1, 2013 and VUL policies issued after January 1, 2014, the Company generally reinsures 50% of the death benefit liability.
Similarly, the Company reinsures 50% of the death benefit and morbidity liabilities related to its universal life product with long term care benefits.
The maximum amount of life insurance risk the Company will retain is $10 million on a single life and $10 million on any flexible premium survivorship life policy; however, reinsurance agreements are in place such that retaining more than $1.5 million of insurance risk on a single life or a flexible premium survivorship life policy is very unusual.
Risk on fixed and variable universal life policies is reinsured on a yearly renewable term basis.
Risk on most term life policies starting in 2001 is reinsured on a coinsurance basis, a type of reinsurance in which the reinsurer participates proportionally in all material risks and premiums associated with a policy.
For existing LTC policies, the Company has continued ceding 50% of the risk on a coinsurance basis to subsidiaries of Genworth Financial, Inc.  (‘‘Genworth’’) and retained the remaining risk.
For RiverSource Life of NY, this reinsurance arrangement applies for 1996 and later issues only.
Generally, the Company retains at most $5,000 per month of risk per life on DI policies sold on policy forms introduced in most states in 2007 and reinsures the remainder of the risk on a coinsurance basis with unaffiliated reinsurance companies.
The Company retains all risk for new claims on DI contracts sold on other policy forms.
The Company also retains all risk on accidental death benefit claims and substantially all risk associated with waiver of premium provisions.
At December 31, 2015 and 2014, traditional life and UL insurance in force aggregated $196.3 billion and $195.5 billion, respectively, of which $144.2 billion and $143.4 billion were reinsured at the respective year ends.
Life insurance in force is reported on a statutory basis.
The effect of reinsurance on premiums for the Company’s traditional long-duration contracts was as follows:
## Table 0 ##
Cost of insurance and administrative charges for non-traditional long-duration products are reflected in other revenues and were net of reinsurance ceded of $107 million, $94 million and $87 million for the years ended December 31, 2015, 2014 and 2013, respectively.
The Company also reinsures a portion of the risks associated with its personal auto, home and umbrella insurance products through three types of reinsurance agreements with unaffiliated reinsurance companies.
The Company purchases reinsurance with a limit of $5 million per loss and the Company retains $750,000 per loss.
For 2015, the Company’s catastrophe reinsurance had a limit of $155 million per event and the Company retained $20 million per event.
For 2016, the Company’s catastrophe reinsurance has a limit of $180 million per event of which the Company retains $20 million per event.
The Company also cedes 80% of every personal umbrella loss with a limit of $5 million per loss.
These assessments are generally based on a member insurer’s proportionate share of all premiums written by member insurers in the state during a specified period prior to an insurer’s insolvency.
See Note 23 to our Consolidated Financial Statements included in Part II, Item 8 of this Annual Report on Form 10-K for additional information regarding guaranty association assessments.
Certain variable annuity and variable life insurance policies offered by the RiverSource Life companies constitute and are registered as securities under the Securities Act of 1933, as amended.
As such, these products are subject to regulation by the SEC and FINRA.
Securities regulators have recently increased their focus on the adequacy of disclosure regarding complex investment products, including variable annuities and life insurance, and have announced that they will continue to review actions by life insurers to improve profitability and reduce risks under in force annuity and insurance products with guaranteed benefits.
The Dodd-Frank Act created the Federal Insurance Office (‘‘FIO’’) within the Department of Treasury.
The FIO does not have substantive regulatory responsibilities, though it is tasked with monitoring the insurance industry and the effectiveness of its regulatory framework and providing periodic reports to the President and Congress.
RiverSource Life owns a block of residential mortgage loans.
As an owner and servicer of residential mortgages, RiverSource Life must comply with applicable federal and state lending and foreclosure laws and is subject to the jurisdiction of the federal Consumer Finance Protection Bureau and certain state regulators relative to these mortgage loans.
Each of our insurance subsidiaries is subject to risk-based capital (‘‘RBC’’) requirements designed to assess the adequacy of an insurance company’s total adjusted capital in relation to its investment, insurance and other risks.
The National Association of Insurance Commissioners (‘‘NAIC’’) has established RBC standards that all state insurance departments have adopted.
The RBC requirements are used by the NAIC and state insurance regulators to identify companies that merit regulatory actions designed to protect policyholders.
Our RiverSource Life companies and Property Casualty companies are subject to various levels of regulatory intervention should their total adjusted statutory capital fall below defined RBC action levels.
At the ‘‘company action level,’’ defined as total adjusted capital level between 100% and 75% of the RBC requirement, an insurer must submit a plan for corrective action with its primary state regulator.
The level of regulatory intervention is greater at lower levels of total adjusted capital relative to the RBC requirement.
RiverSource Life, RiverSource Life of NY, IDS Property Casualty and Ameriprise Insurance Company maintain capital levels well in excess of the company action level required by state insurance regulators as noted below as of December 31, 2015:
## Table 1 ##
Ameriprise Financial, as a direct and indirect owner of its insurance subsidiaries, is subject to the insurance holding companies laws of the states where its insurance subsidiaries are domiciled.
These laws generally require insurance holding companies to register with the insurance department of the insurance company’s state of domicile and to provide certain financial and other information about the operations of the companies within the holding company structure.
As part of its Solvency Modernization Initiative, in 2010 the NAIC adopted revisions to its Insurance Holding Company System Regulatory Act (‘‘Holding Company Act’’) to enhance insurer group supervision and create a new Risk Management and Own Risk and Solvency Assessment (‘‘ORSA’’) Model Act.
The Holding Company Act revisions focus on the overall insurance holding company system, establish a framework of regulator supervisory colleges, enhancements to corporate governance, and require the annual filing of an Enterprise Risk Management Report.
The ORSA Model Act requires that an insurer create and file, annually, its Own Risk Solvency Assessment, which is a complete self-assessment of its risk management functions and capital adequacy.
These laws have now been enacted by the domiciliary states of RiverSource Life and the Property Casualty companies: Minnesota, New York and Wisconsin.
The reports have been completed and filed as required by the laws and regulations of those states.
Federal Banking Regulation In January 2013, Ameriprise Bank received approval for and completed the conversion from a federal savings bank to a limited powers national trust bank, which was renamed Ameriprise National Trust Bank.
As a limited powers national association, Ameriprise National Trust Bank remains subject to supervision under various laws and regulations enforced by the OCC, including those related to capital adequacy, liquidity and conflicts of interest, and to a limited extent, by the FDIC.
PART II.
Item 5.
Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities Our common stock trades principally on The New York Stock Exchange under the trading symbol AMP.
As of February 12, 2016, we had approximately 15,429 common shareholders of record.
Price and dividend information concerning our common shares may be found in Note 26 to our Consolidated Financial Statements included in Part II, Item 8 of this Annual Report on Form 10-K.  Information regarding our equity compensation plans can be found in Part III, Item 12 of this Annual Report on Form 10-K.  Information comparing the cumulative total shareholder return on our common stock to the cumulative total return for certain indices is set forth under the heading ‘‘Performance Graph’’ provided in our 2015 Annual Report to Shareholders and is incorporated herein by reference.
We are primarily a holding company and, as a result, our ability to pay dividends in the future will depend on receiving dividends from our subsidiaries.
For information regarding our ability to pay dividends, see the information set forth under the heading ‘‘Management’s Discussion and Analysis of Financial Condition and Results of Operations — Liquidity and Capital Resources’’ contained in Part II, Item 7 of this Annual Report on Form 10-K.  Share Repurchases The following table presents the information with respect to purchases made by or on behalf of Ameriprise Financial, Inc.  or any ‘‘affiliated purchaser’’ (as defined in Rule 10b-18(a)(3) under the Securities Exchange Act of 1934), of our common stock during the fourth quarter of 2015:
## Table 2 ##
N/A Not applicable.
(1) On April 28, 2014, we announced that our Board of Directors authorized us to repurchase up to $2.5 billion worth of our common stock through April 28, 2016.
On December 7, 2015, we announced that our Board of Directors authorized us to repurchase up to an additional $2.5 billion worth of our common stock through December 31, 2017.
The share repurchase programs do not require the purchase of any minimum number of shares, and depending on market conditions and other factors, these purchases may be commenced or suspended at any time without prior notice.
Acquisitions under the share repurchase programs may be made in the open market, through privately negotiated transactions or block trades or other means.
(2) Includes restricted shares withheld pursuant to the terms of awards under the Company’s share-based compensation plans to offset tax withholding obligations that occur upon vesting and release of restricted shares.
The value of the restricted shares withheld is the closing price of common stock of Ameriprise Financial, Inc.  on the date the relevant transaction occurs.
Also includes shares withheld pursuant to the net settlement of Non-Qualified Stock Option (‘‘NQSO’’) exercises to offset tax withholding obligations that occur upon exercise and to cover the strike price of the NQSO.
The value of the shares withheld pursuant to the net settlement of NQSO exercises is the closing price of common stock of Ameriprise Financial, Inc.  on the day prior to the date the relevant transaction occurs.
Cash amounts for future minimum rental commitments under existing non-cancelable leases with a remaining term of more than one year, along with minimum sublease rental income to be received under non-cancelable subleases are shown in the following table.

<table><tr><td></td><td colspan="3">Years Ended December 31,</td></tr><tr><td></td><td>2015</td><td>2014</td><td>2013</td></tr><tr><td></td><td colspan="3">(in millions)</td></tr><tr><td>Direct premiums</td><td>$629</td><td>$645</td><td>$650</td></tr><tr><td>Reinsurance ceded</td><td>-223</td><td>-222</td><td>-220</td></tr><tr><td>Net premiums</td><td>$406</td><td>$423</td><td>$430</td></tr></table>
<table><tr><td>Entity</td><td>Company Action Level RBC</td><td>TotalAdjusted Capital</td><td>% of Company Action Level RBC</td></tr><tr><td></td><td colspan="3">(in millions, except percentages)</td></tr><tr><td>RiverSource Life</td><td>$589</td><td>$3,800</td><td>645%</td></tr><tr><td>RiverSource Life of NY</td><td>44</td><td>333</td><td>748</td></tr><tr><td>IDS Property Casualty</td><td>121</td><td>684</td><td>563</td></tr><tr><td>Ameriprise Insurance Company</td><td>1</td><td>46</td><td>8,701</td></tr></table>
<table><tr><td>Period</td><td>(a)(b) Total Number of Shares Purchased</td><td>Average Price Paid Per Share</td><td>(c)(d) Total Number of Shares Purchased as part of Publicly Announced Plans or Programs<sup>(1)</sup></td><td>Approximate Dollar Value of Shares that May Yet Be Purchased Under the Plans or Programs<sup>-1</sup></td></tr><tr><td>October 1 to October 31, 2015</td><td></td><td></td><td></td><td></td></tr><tr><td>Share repurchase program<sup>-1</sup></td><td>1,224,152</td><td>$111.86</td><td>1,224,152</td><td>$416,551,831</td></tr><tr><td>Employee transactions<sup>-2</sup></td><td>9,567</td><td>$114.05</td><td>N/A</td><td>N/A</td></tr><tr><td>November 1 to November 30, 2015</td><td></td><td></td><td></td><td></td></tr><tr><td>Share repurchase program<sup>-1</sup></td><td>1,215,928</td><td>$115.10</td><td>1,215,928</td><td>$276,592,969</td></tr><tr><td>Employee transactions<sup>-2</sup></td><td>14,615</td><td>$116.21</td><td>N/A</td><td>N/A</td></tr><tr><td>December 1 to December 31, 2015</td><td></td><td></td><td></td><td></td></tr><tr><td>Share repurchase program<sup>-1</sup></td><td>1,599,649</td><td>$108.08</td><td>1,599,649</td><td>$2,603,697,324</td></tr><tr><td>Employee transactions<sup>-2</sup></td><td>1,709</td><td>$110.79</td><td>N/A</td><td>N/A</td></tr><tr><td>Totals</td><td></td><td></td><td></td><td></td></tr><tr><td>Share repurchase program<sup>-1</sup></td><td>4,039,729</td><td>$111.34</td><td>4,039,729</td><td></td></tr><tr><td>Employee transactions<sup>-2</sup></td><td>25,891</td><td>$115.05</td><td>N/A</td><td></td></tr><tr><td></td><td>4,065,620</td><td></td><td>4,039,729</td><td></td></tr></table>

Question: In the month in the Fourth Quarter where Total Number of Shares Purchased for Share repurchase program is the most, what's the Total Number of Shares Purchased for Employee transactions?
Answer: 1709