GFIA provides comments to IAIS on its extended field testing of the ICS version 1.0
Overall, GFIA warned that the IAIS has been too ambitious in its timeline for the project and 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.
On 9 October 2013, the IAIS announced its plan to develop a risk-based global insurance capital standard (ICS). This was in response to the request by the Financial Stability Board (FSB) that the IAIS produce a work plan to create "a comprehensive group-wide supervisory and regulatory framework for Internationally Active Insurance Groups (IAIGs)." Since its announcement in October 2013, the IAIS has been undertaking a multi-year quantitative Field Testing process with Volunteer Insurance Groups (Volunteer Groups) including potential IAIGs and current Global Systemically Important Insurers (G-SIIs).
The IAIS has conducted two quantitative Field Testing exercises in the development of the ICS - one in 2015 and another in 2016. IAIS development of subsequent quantitative ICS Field Testing exercises was informed by IAIS analysis of the submitted data as well as additional feedback and comments provided by Volunteer Groups as part of their submissions or through dedicated workshops. The IAIS conducted its third quantitative ICS Field Testing exercise, with data submitted in September 2017. In addition to the Field Testing process, the IAIS has reached out to the broader group of stakeholders during dedicated physical stakeholder meetings and by engaging in public consultation on ICS matters.