On June 20, the IIF sent a letter on behalf of the Insurance Working Group to the FSB regarding its ongoing effort of evaluating the implication of regulatory reform on the supply of long-term investments. As much as we support this effort, our insurance membership would like to raise the point to the FSB that ensure that the design by the IAIS of a global risk-based Insurance Capital Standard (ICS), which is being developed in response to the FSB's request to create a "comprehensive group-wide supervisory and regulatory framework for Internationally Active Insurance Groups", does not inhibit the ability of insurers to perform their vital financial and social functions. We would like to urge the IAIS and the FSB, to carefully evaluate the ICS and make sure that the current volatility and pro-cyclicality are properly addressed and unintended adverse consequences on the ability of insurers to invest long-term, including in infrastructure finance, are avoided.'