Status: Draft -- Not PublishedWill be live at 10/30/2018 00:00
Joint IIF/GA Response Letter to the IAIS ICS Version 2.0 Consultation
Tuesday, October 30, 2018
The ICS response letter covers a number of important elements of the ICS including MOCE, market-adjusted valuation, deferred tax assets, capital requirements under the standard method, management actions, capital resources and, last but not least, the Monitoring Period. With appreciation for the time and effort the IAIS has devoted to the development of the ICS, and the progress already achieved, the Joint Task Force aims to provide constructive comments and suggestions for the IAIS to consider before the start of the Monitoring Period in 2020. Given that there are a number of unresolved issues, we seek assurance from the IAIS that the Monitoring Period will serve to finalize outstanding items through a well-governed and transparent process that will include full testing and discussion and involve volunteer companies alongside their supervisors and the IAIS. Our comments focused on these unresolved issues as well as on an effective process to address them during the Monitoring Period.'