On 25 January 2016, Insurance Europe published its response to the IAIS' consultation on defining non-traditional, non-insurance activities and products.  Insurance Europe identified a number of issues with the proposals.  Amongst other matters, Insurance Europe disagrees with the IAIS' proposed approach to derivatives (pointing out that the IAIS should recognise that systemic risk concerns associated with derivatives have already been addressed by reforms launched by the G-20 in 2009).