GFIA has published its response to a consultation on the cyber lexicon. GFIA welcomes the efforts of the Financial Stability Board (FSB) to enhance cross-border cooperation in addressing cyber risk and, as part of that effort, the FSB’s work on a cyber lexicon.
Such a lexicon would provide consistency for FSB work streams such as information-sharing and cross-border guidance.
In a letter to the FSB, Steve Simchak, chair of the GFIA cyber risks working group, writes: “GFIA also appreciates the statement in the lexicon that it is not intended for use in the legal interpretation of any international arrangement or agreement, or private contract. The property and casualty insurance community has a unique voice in the cyber dialogue due to the cyber risk insurance products they offer. At times, there are suggestions that a common lexicon or glossary could be leveraged for standardising insurance contract terms. GFIA strongly takes the view that a taxonomy should not pre-empt insurance contract language. While alignment in terminology of risks may be beneficial to help companies and consumers better understand cyber insurance, such alignment is occurring organically, where appropriate, in the market today. Additionally, forced terminology for this nascent industry could prevent innovative product development that will naturally converge with changing cyber risks.”
GFIA also appreciates that the FSB does not intend the lexicon for use in the legal interpretation of any international arrangement, agreement or private contract.
A taxonomy should, however, not pre-empt insurance contract language. While aligning risk terminology may help companies and consumers better understand cyber insurance, such alignment is already occurring organically, where appropriate. Forcing standardised terminology could also hamper innovation in the development of insurance products.
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© GFIA - Global Federation of Insurance Associations
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