On 25 January 2016, Insurance Europe issued a position paper setting out its responses to the recent IAIS Consultation on NTNI activities and products. Insurance Europe welcomes and recognises the importance of the identification of NTNI activities and products for the macroprudential supervisory measures that IAIS is currently developing. However, it is concerned that a clear distinction between macro and micro prudential tools should be made in the framework being devised by IAIS. Insurance Europe recommends that IAIS should focus on not overestimating vulnerabilities that are already addressed by micro prudential regulation and supervision (for example, market and liquidity risks are in many cases already addressed by the micro prudential framework). Insurance Europe feels IAIS work should focus on residual risk which is not addressed by the micro prudential framework. Insurance Europe also recommends that in the development of a framework, IAIS should not ignore risk mitigation tools and management and supervisory actions such as derivatives etc. The document sets out Insurance Europe’s key messages at the start together with sixteen individual Insurance Europe responds to questions posed by IAIS at consultation.

A link to the Consultation Document is here.