On February 6, 2023, the IIF responded to the IAIS’s Public Consultation on the Review of the Individual Insurer Monitoring (IIM) Assessment Methodology. The IIF commended the IAIS continued efforts to evolve the Holistic Framework and Global Monitoring Exercise, of which the IIM is a part, through a review of the IIM assessment methodology. However, the response also noted the IIF’s long-standing position that the insurance sector poses considerably less potential systemic risk than other financial services sectors. The IIF advocated for a proportionate approach that considers the numerous tools already employed by the insurance industry to manage its risks.

The IIF’s comment letter focused on high-level messages that were generally agreed upon across the IIF insurance membership. The IIF emphasized the need to further focus the data fields contained in the IIM assessment methodology to those that are clearly linked to the IAIS’s ultimate objective of identifying and assessing systemic risk. While the response praised the IAIS’s work in developing liquidity metrics, it encouraged a more focused approach to the IIM assessment methodology that better reflects the economics of the underlying insurance product design.

Other key messages included the importance of greater clarity around timelines and advance notice of deadlines and/or changes to the template so insurers can enhance their internal processes and ultimately provide better quality data to the IAIS. The IIF also encouraged the IAIS to leverage information already subject to public disclosure, and to ensure that any non-public data that is collected remains confidential. The IIF welcomed further opportunities for dialogue with IAIS members on these issues.