Joint IIF/GA Response to the IAIS ICS Consultation

On February 16, the Joint IIF/Geneva Association (GA) ICS Task Force submitted a response letter to the IAIS Risk-based Global Insurance Capital Standard (ICS) consultative document released on December 17, 2014. In general, the IIF/GA ICS Task Force supports the IAIS' efforts in exploring various possible solutions to accommodate differences across markets, business models and product offerings across jurisdictions.

The IIF/GA ICS Task Force continues to be supportive of a principles-based framework, while expressing a range of views as to what a principles-based ICS would mean in practice. Considering the existing and evolving insurance capital regimes across jurisdictions, the IIF/GA ICS Task Force provided specific inputs on the very fundamental elements of the ICS, including but not limited to, the valuation basis or bases, the use of internal models and the appropriate metric for calibration as well as how jurisdictional differences could be accommodated in a principles-based framework that advances the goals of policyholder protection and financial stability.

The ICS is a multi-stage development that will eventually function as the capital component of ComFrame. The responses of this consultation will provide inputs for the following quantitative field testing at which will be launched at the end of April. The IIF/GA ICS Task Force is strongly committed to continuing the constructive dialogue and cooperation with the IAIS.