Date: January 25, 2016

Issue: Systemic Risk

To: International Association of Insurance Supervisors 

Filing Type: International

Description: The Chamber appreciates the steps that the IAIS has taken to clarify and enhance the G-SII assessment methodology but believes that significant changes are needed. The lack of clarity in Phases II and III and potential confusion between risks to an insurer and risks to the broader financial system counsel a deliberate and thorough review of the currently proposed changes to the assessment methodology.

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