Joint IIF/GA Response to the IAIS HLA Consultation

On August 21, the Joint IIF/Geneva Association (GA) HLA Working Group submitted a response letter to the IAIS Higher Loss Absorbency capacity for Global Systemically Important Insurers consultative document released on June 25, 2015. In summary, a number of members disagree with the proposed methodology, and believe it is too blunt a tool, built on still uncertain foundations and that the entire G-SII framework as currently proposed does not provide appropriate incentives for systemic risk mitigation.

In our joint response we noted:

• HLA should focus on systemic risks and activities that contribute to or amplify such risks;
• the current HLA proposal is based on moving targets;
• a necessary link between non-traditional and non-insurance (NTNI) activities and (systemic) risk still needs to be demonstrated;
• HLA calibration is disproportionate and unlikely to contribute to financial stability; and,'
• the BCR + HLA is a blunt capital requirement and may provide ambivalent incentives to de-risk.'

The IAIS will analyze the consultation responses with field testing data collected in July, and present the finalized HLA proposal to the FSB in October. The G20 endorsement is expected to follow in November, 2015. The IIF and Geneva Association is strongly committed to continuing constructive dialogue and cooperation with the IAIS, and looks forward to further opportunities to discuss the HLA, BCR and broader ICS and Comframe context in the run-up to the November G20 meeting in Antalya.