On December 18, the Joint IIF/Geneva Association (GA) Resolution for Insurers Working Group submitted a response letter to the FSB consultation document dated November 3, 2015 on "Developing Effective Resolution Strategies and Plans for Systemically Important Insurers."

In our response we congratulated the FSB for proposing a flexible, insurer-specific approach to resolution planning that recognizes the different business models of insurers. The FSB has also reconsidered its approach to Critical Functions, greatly limiting the scope and in doing so responding to IIF feedback.

Further refinement is however required and in particular we request that resolution measures be: proportionate; founded on an appropriate legal basis; and provide sufficient benefit to justify the costs borne by market participants including policyholders. Further, we note that without strong cross-border regulator liaison any resolution strategies for multinational insurers is of questionable efficacy.