This document discusses modeling underwriting premium risk for motor third party liability (MTPL) insurance under Italy's direct compensation (CARD) system. It provides an overview of the CARD system and the challenges it poses for pricing and risk modeling. Specifically, it notes that negative claim amounts are possible under CARD, the frequency and costs of both caused and suffered claims must be modeled, and historical experience is limited. It then describes the CARD forfeit structure and rules in more detail. The goal is to develop an internal model for assessing underwriting premium risk capital charges on an MTPL portfolio under the CARD system.