On 25 August 2015, Insurance Europe published its response to the IAIS consultation on higher loss absorbency (HLA) requirements for globally systematically important insurers (G-SIIs).  Suggested improvements made by Insurance Europe to address concerns in this regard include (a) the need to focus on activities that give rise to systemic risk, (b) changes to the proposed calibration target so that it is relative to the level of systemically risky activities undertaken, (c) non-application of HLA to activities in other regulated areas (unless the activities would separately qualify for HLA under that sector's systemic regulation) and (d) review of the scoring methodology to properly reflect the systemic riskiness of an insurance entity.