On 4 January 2016, Insurance Europe published its response to the Financial Stability Board (FSB) consultation on proposed guidance for supervisors concerning effective resolution strategies and plans for G-SIIs.  This welcomes the FSB's flexible approach to resolution strategies/triggers and its preference for portfolio transfers as a resolution mechanism.  However, it called for further clarity in relation to 'critical functions' provided by insurers and (amongst other matters) stressed the importance of recognising the difference between (a) designation of an insurer as a G-SII and (b) identification of that insurer's functions as critical.