AIA Urges IAIS to Tackle Key Issues Impeding the Development and Implementation of an Appropriate International Capital Standard

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The American Insurance Association (AIA) believes that the International Association of Insurance Supervisors (IAIS) should confront and resolve a number of fundamental issues that will impact the ability to develop and implement a group international capital standard (ICS) that works for affected U.S. internationally active insurance groups (IAIGs).

The American Insurance Association (AIA) believes that the International Association of Insurance Supervisors (IAIS) should confront and resolve a number of fundamental issues that will impact the ability to develop and implement a group international capital standard (ICS) that works for affected U.S. internationally active insurance groups (IAIGs). Those issues include: (a) the relationship and interaction between an IAIG’s local jurisdictional capital framework and accounting standards and the framework envisioned by the ICS; (b); how the ICS should address the lack of fungibility of capital across jurisdictions, and (c) the juxtaposition of ICS principles governing comparability of outcomes and those advocating a balance between risk sensitivity and simplicity. AIA has submitted comments to the IAIS in response to its July 19, 2016 Public Consultation Document that raise these broad issues and responds to the IAIS Consultation’s questions.    

A brief statement from J. Stephen “Stef” Zielezienski, AIA Senior Vice President and General Counsel follows:

“AIA appreciates the opportunity to comment and work with the IAIS on the development of an international capital standard. We believe that it is critical for the IAIS to confront and resolve key foundational issues so that the ICS works for all insurance groups, including those that are based in the U.S. and are subject to the state-based regulatory system. Of particular importance is the relationship between the solvency and accounting framework of an insurance group’s home jurisdiction and the approaches advanced in this ICS Consultation Document. Resolving these issues in a manner that harmonizes incongruous accounting and financial regulatory approaches will be essential to the successful development and implementation of an appropriate internationally acceptable group capital standard. Today’s comments are consistent with AIA’s previous statements to the IAIS, as well as our comments to the Federal Reserve on its advance notice of proposed rulemaking on group capital.”

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