IIF Authors

Status: Will be live at 02/03/2016 00:00

IIF/GA Response to IAIS G-SII and NTNI Consultation

Wednesday, February 3, 2016

On January 25, The Institute of International Finance (IIF) and the Geneva Association (GA) submitted a response letter to the International Association for Insurance Supervisors (IAIS) consultation documents dated November 25, 2015 regarding the "Proposed Updated Assessment Methodology for Global Systemically Important Insurers" and "Non-traditional Non-insurance Activities and Products".

In our response we encouraged the IAIS to develop an effective systemic risk framework that is sensitive to the features of insurance, including its long-term, premiums-funded character. The IIF also argued that the framework for systemic designations should be significantly revised in order to conclusively address systemic risk in a way that is compatible with the distinctive characteristics of insurance. While we think that the general intent of the proposed changes in both the G-SII and the NTNI methodologies is directionally appropriate, we provided feedback in our joint consultation response to a number of areas where we would like the IAIS to consider improvements.'