The CEA got busy this week with a double release, covering their feedback on the IAIS's ComFrame proposals for group supervision, and feedback on ongoing discussions on SIFIs.
As far as ComFrame goes, they express that they feel it is too prescriptive, and potentially onerous for some groups ahead of others. They do not agree with the introduction of "living wills" for insurance companies (in the same way that banks are being obliged to document 'orderly wind-down' strategy in the UK for example). They also highlight that it does not address minimum standards at national level, so could be viewed as an additional layer of compliance for groups.
The CEA go on to countersign a separate letter with a number of other insurance associations to highlight these viewpoints.
The response to the ongoing SIFI work of the Financial Stability Board reaffirms the position of the CEA (and indeed the Geneva Association who have been vociferous on the matter) that insurers, by nature of their long term and less portable liabilities, should not be subjected to the same categorisation and timeframes as the banking industry. Cognisance of the ladder of intervention afforded by Solvency II is also requested.