GFIA Global Federation of Insurance Associations

Responding to the IAIS consultations on the Insurance Capital Standard (ICS) as a Prescribed Capital Requirement (PCR) and the Insurance Core Principles 14 (valuation) and 17 (capital adequacy), GFIA acknowledges the extensive work the IAIS has done over the past 10 years and that resulted in these consultations.

Overall, GFIA supports the changes to the draft ICPs 14 and 17 as they generally enhance the readability of the texts.

On the ICS:

• GFIA recognises the effort of the IAIS and the remaining challenges in trying to harmonise the views of many jurisdictions to create a comprehensive global standard and to implement it.
• GFIA supports the inclusion of internal models in the ICS and advocates for the IAIS not to introduce any provisions that would undermine their fundamentals;