With few constraints on how high surplus can go, many health insurers have amassed millions or even billions of dollars in surplus, far beyond the required minimums. Even as they have become financially strong and able to weather a potential underwriting loss with minimal danger of insolvency, many insurers have continued to seek doubleYdigit rate increases on individual market or small business consumers, and have continued to build even larger surpluses with premium dollars. In the face of the ever increasing cost burden on consumers, the question arises: how much surplus is too much?