2019 0614 - IAIS - Compiled Comments on Holistic Framework for Systemic Risk in the Insurance Sector

  • (p175) - 484. Institute of International Finance
    • Altering a company's sales practices, imposing large exposure limits, restricting the transfer of assets, restricting the activities of a subsidiary, freezing assets, imposing stays on surrenders, or lowering the maximum rate of guarantees would likely result in grave harm to an insurer's franchise and to the entire industry through the abrogation of contracts and reduced market and policyholder confidence
  • (p180) - 501. International Actuarial Association International
    • The IAA notes that the exercise of any power to implement a stay on surrenders may have a cost to the reputation of the insurance industry and may result in conflicting positions between the prudential and conduct supervisors if they are separate.