2018 - IAIS - Risk-based Global Insurance Capital Standard Version 2.0
- 2018 - IAIS - Risk-based Global Insurance Capital Standard Version 2.0
- 2018 0731 - IAIS - Risk-based Global Insurance Capital Standard Version 2.0, Public Consultation Document - 158p
- 2018 - IAIS - Summary of main comments received during the 2018 public consultation on ICS Version 2.0 and their resolution - 30p
- Resolution of Comments
- 2.8 Incremental costs and benefits - 68p
- 3.1 Role of the group-wide supervisor - 21p
- 3.2 Role of the IAIS - 42p
- 3.3 Role of Supervisory colleges - 8p
- 4 Scope of Group: Perimeter of the ICS Calculation - 11p
- 5.1 MAV approach - 143p
- 5.2 MOCE - 56p
- 6 Reference ICS: Capital resources - 89p
- 7.3 Risk mitigation - 29p
- 7.4 Look-through - 3p
- 7.5 Management actions - 10p
- 7.6 Mortality and Longevity risks - 8p
- 7.7 Morbidity / Disability - 14p
- 7.8 Lapse risk - 7p
- 7.9 Expense risk - 6p
- 7.10 Premium and Claims Reserve risk - 25p
- 7.11 Catastrophe risk - 14p
- 7.12 Interest Rate risk - 28p
- 7.17 Asset Concentration risk - 11p
- 7.13 Non-Default Spread risk - 36p
- 7.14 Equity risk - 17p
- 7.16 Currency risk - 7p
- 7.18 Credit risk - 36p
- 7.19 Operational risk - 21p
- 7.20 Aggregation / Diversification of ICS risk charges - 10p
- 8 Tax Treatment - 46p
- 9.1 GAAP with Adjustments - 36p
- 9.2 Internal models - 36p
- Comments:
- 2019 0912 - GOV (Senate) - Testimony of Steven E. Seitz, Director, Federal Insurance Office - U.S. Department of the Treasury - Senate Committee on Banking, Housing, and Urban Affairs “Developments in Global Insurance Regulatory and Supervisory Forums” - 5p
6 Reference ICS: Capital resources - 89p
- (p9) - ACLI - Surplus Notes - While we are grateful that mutual companies will have access to at least one source of Tier 1 capital (surplus notes), it is not clear to us why the same instrument should be relegated to Tier 2 for stock companies.
- Nevertheless, we acknowledge that the recognition of surplus notes as Tier 1 capital for mutual notes was the result of a lengthy negotiation.
- In any case, the IAIS should not undo this recognition of surplus notes as Tier 1 for mutual companies by including a criteria (PLAM) that would eliminate the ability of U.S. mutual companies to get Tier 1 credit for their surplus notes.
- (p19) - ACLI - Surplus Notes - For example, in the US, regulators strictly control the amount of
surplus notes that a company is able to issue.- Typically, they will limit issuance below the level currently permitted for Tier 1 credit (and thus Tier 2) under ICS 2.0.
- Besides a prudent desire to limit leverage, regulators keep the level low in order to preserve potential market access to sell surplus notes in the event an insurer encounters financial distress and regulators want to prevent or initiate a rehabilitation of the insurer.
- Ironically, the tier 1 limit on surplus note issuance under ICS 2.0 as designed could constrain regulatory options to preserve insurer solvency, by not (fully) counting the benefit of surplus note issuance ordered by the regulator.