|
|
While Insurance Europe said that the proposed changes to ICP 13 were broadly positive, it asked for several clarifications and urged the IAIS to refrain from being over-prescriptive in certain provisions.
Insurance Europe said it appreciated the inclusion of content on geographical diversification in the introductory guidance that reflects the specificities of the reinsurance business model.
Insurance Europe also said that the regulatory framework must grant the cedant sufficient flexibility in the implementation of its risk strategy (eg, regarding approval of the reinsurance programme).
Insurance Europe asked the IAIS to clarify language that implied that catastrophe reinsurers presented lack of willingness to pay claims in the past.