The U.S. Chamber of Commerce Center for Capital Markets Competitiveness (“CCMC”) is pleased to respond to the International Association of Insurance Supervisors (“IAIS”) on the draft criteria that will be used to assess whether the aggregation method (“AM”) provides comparable outcomes to the insurance capital standard (“ICS”).

The Chamber has a diverse membership including purely domestic, as well as internationally active insurance companies headquartered both inside and outside of the United States. In addition, we have member companies that rely on insurance products and the larger role insurers play as investors in our global economy— providing security for policyholders and creating stability in the capital markets. As such, we are broadly supportive of the goal of safeguarding our financial system.

The Chamber issued a report in March 2019 describing how the insurance sector invests in the U.S. economy. Insurance companies invest in a unique set of assets as a direct result of their business models, and they invest for different purposes than other institutional investors. Insurers are primarily concerned with matching long-term liabilities and, as a result, hold appropriate assets to achieve this goal. The unique investment strategy of insurance companies results in tangible, long-term projects being financed by these firms and, indirectly, by policyholders. Insurers make up a sizable share of asset classes such as corporate bonds (21%) and municipal bonds (20%), investing enough in education projects through municipal bond purchases to build about 1,000 elementary schools every year. At the end of 2020, insurers licensed in the United States held approximately $10.9 trillion in total assets