On January 31, the Joint IIF/GA ICP Working Group submitted its response to the public consultation on revised ICP 15 and 16, covering important topics including investment, ERM and ORSA.
In line with our overarching comment to previous consultations, we would like to emphasize the importance of consistency among IAIS' policy frameworks including the ICPs, ComFrame, and the ICS as well as guidance for systemic risk management. Working Group members believe that as the IAIS develops the quantitative measure for solvency for IAIGs (ICS), it should continue to recognize that in addition to adequate capital, sound risk management and investment practices are foundational and effective micro-prudential tools and deserve an important place within solvency frameworks, reducing reliance on capital and producing a more transparent and comprehensive evaluation of a firm's solvency position.
In addition to the overarching message, the Joint Working Group continues to argue that the The ICPs and ComFrame should focus on providing outcome-based principles and avoid prescriptive rules that does not take into account jurisdictional specificities, different corporate structures, or varying features of products. The response also emphasized the importance of recognition of current ALM practice and urged the IAIS to keep in mind the difference between insurance liabilities and bank liabilities when it comes to investment-related policies. The full response letter can be found on the IIF website.'