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While Insurance Europe said it welcomes the IAIS efforts on supervisory convergence, it stressed that the intended nature of IAIS application papers was not to set any new standards for insurers.
As such, Insurance Europe pointed out where the draft nevertheless introduced new requirements, directly or implicitly, and asked for their removal.
Regarding flexibility, Insurance Europe warned that at times the draft application paper was too granular and should maintain sufficient flexibility for supervisors to apply regulatory requirements proportionally.