Date: August 21, 2015

Issue: International

To: International Association of Insurance Supervisors

Filing Type: Regulatory

Description: The Chamber respectfully requests that the IAIS delay finalization of the HLA standard until after there has been an opportunity to comment on and finalize a revised definition of non-insurance or non-traditional (“NTNI”) activities and the revised assessment methodology for G-SIIs. Failure to do so will ignore the importance of properly sequencing new and important capital requirements for G-SIIs, which impact not only the regulated entities but also insurance policyholders and those that benefit from investment by G-SIIs in the capital markets.

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