On August 15, IIF submitted a response letter to the IAIS consultation Revisions related to the Holistic Framework for Systemic Risk in the Insurance Sector. In the response letter, IIF members reinforce their support for the direction of travel on systemic risk related issues concerning the insurance sector. the letter encourages the IAIS to continue its movement towards an activities-based approach to systemic risk (ABA) based on more absolute measures of risk and clear linkages among activities and the potential for the propagation of material levels of systemic risk to the global financial system or real economy through the transmission channels of asset liquidation and counterparty exposure. In addition, the letter raises important issues such as the role of supervisors and the data collection exercise. 

After the consultation period, the IAIS will start to review and resolve comments received. The holistic framework, revised ICPs and ComFrame are expected to be adopted in November 2019.