Date: February 13, 2015

Issue: Capital Standards

To: International Association of Insurance Supervisors

Filing Type: International

Description: The Chamber continues to be concerned that the IAIS’ desire to develop an ICS is being done as a rushed exercise. IAIS should be focused on the core of the FSB mandate to address G-SIIs and beyond that should take time to more deeply appreciate how an ICS will be used for IAIGs, while also seeking to understand the compounding effect multiple capital market initiatives have on the unique and valuable role insurance plays in protecting policyholders and being a source of financial capital.

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