The IIF, in cooperation with the Geneva Association, has submitted comments to the IAIS on its consultation of the Risk-based Insurance Capital Standard 1.0. In the letter, IIF/GA members write that the IAIS should take a sequential approach in the development of the ICS, as a number of fundamental and technical issues remain to be dealt with. These include:

1. Promoting consistency with regional circumstances and capital regimes
2. Improving the compatibility between the ICS and other elements of the ComFrame program
3. Building the ICS on a valuation framework that, through a coherent treatment of assets and liabilities, is tailored to the insurance business model. This should lead to more stable and comparable valuation outcomes across jurisdictions.