GFIA responds to IAIS consultation on comparability of Aggregation Method to ICS
23 August 2022
GFIA welcomed the launch of the consultation but indicated that it would not be possible to submit a response to the detailed questions in the consultation, in light of the different views that remain between jurisdictions on the Insurancec Capital Standard (ICS) project.
GFIA has responded
to a consultation conducted by the International Association of
Insurance Supervisors (IAIS) on draft criteria to assess whether the
Aggregation Method (AM) provides comparable outcomes to the Insurance
Capital Standard (ICS), in the form of a letter to the IAIS secretariat.
Nonetheless, GFIA underlined some key points in its letter, namely:
- The
fact that the ICS version 2.0 is not final. GFIA expects the standard
to have evolved after the monitoring period ends in 2024 in response to
any identified current and future shortfalls. As the ICS itself is still
subject to change, GFIA questions the appropriateness of conducting a
comparability assessment using an unfinished standard as a benchmark or
reference.
- Some of the wording used in the draft criteria could be deemed open to wide ranging interpretation.
- The
fact that the short timeframe available to respond to the consultation
proved to be a challenge. Responding to this complex exercise is a
significant undertaking and GFIA’s members would have welcomed extra
time to engage meaningfully with their member companies, other
stakeholders and ultimately with the consultation itself.
- Finally,
GFIA has concerns about the comparability assessment timeline, as it
may not give enough time to complete the exercise and does not
appropriately account for the planned consultation and economic impact
assessment of the ICS expected to be launched in mid-2023.
GFIA
© GFIA - Global Federation of Insurance Associations
