|
|
Overall, GFIA warned that the IAIS has been too ambitious in its timeline for the project. It recommended that the IAIS reconsiders its timeline and implementation objectives, to ensure that the standard that is adopted is fit for purpose.
GFIA said that local regimes which are consistent with the ICS framework should ultimately be recognised as a suitable implementation of the ICS. GFIA added that a situation where companies must manage business based on two or more parallel, potentially different and conflicting regulatory regimes, should be avoided.
GFIA also said that it is very important that the ICS approach towards valuing liabilities works across diverse geographic markets, and does not conflict with existing regulatory or accounting valuation bases.