NAIC Submits Comments on Global Risk Insurance Capital Standards In Advance of March 20 IAIS Rome Meeting

Feb 18, 2015

Florida Tallahassee Insurance Lobbyist

Above:  G. Donovan Brown of Colodny Fass notes IAIS seeks suggested topics and presentations for March 20 Insurance Capital Standards event

In advance of the International Association of Insurance Supervisors’ (“IAIS”) second meeting on global risk insurance capital standards (“ICS”) scheduled for March 20, 2015 in Rome, Italy, the National Association of Insurance Commissioners (“NAIC”) submitted comments on the IAIS Insurance Capital Standards Public Consultation Document in advance of its February 16 deadline this week. 

Chaired by Florida Insurance Commissioner Kevin McCarty, the NAIC’s International Insurance Relations Committee approved the comments, which will be considered among other technical issues planned for discussions during the IAIS’ interactive-themed March 20 Rome event.  To view the NAIC comment markup approved last week, click here.

To view the complete IAIS public consultation document, which contained more than 160 specific questions, click here.

Prior to the Rome meeting, the IAIS is inviting stakeholders to make short presentations based on comments submitted during the ICS consultation period.  Stakeholders are also invited to suggest specific topics for discussion and offer presentations on suggested topics.  The meeting is the second of six stakeholder events to be held during 2015 in locations around the world focusing on the ICS and related capital standards development.  Additional stakeholder engagement opportunities involving the development of both the capital standards and IAIS’ Common Framework for the Supervision of Internationally Active Insurance Groups (also known as ComFrame) will be announced.

  • To suggest a topic or request the opportunity to make a presentation at the event, please contact G. Donovan Brown at Colodny Fass +1 850 545 8864.

Of note, the IAIS has adopted new policies and procedures following the resolution of comments received during the second insurance capital standards public consultation.  To view these and related documents, click here.

The public consultation is the first step in a multi-year process to develop and finalize the ICS through stakeholder feedback on valuation, qualifying capital resources, and examples of standard or other methods for determining the ICS capital requirement.  Further consultations on ICS will occur as part of consultations on ComFrame.

ICS field testing, which began in 2014, will continue to play a critical role in this process.

The following table summarizes key activities leading to the IAIS’ adoption of the ICS in end-2018, after which its implementation would begin as part of ComFrame.




April-June 2015

Second quantitative field testing exercise

December 2015

Public consultation on ComFrame and the ICS

April-June 2016

Third quantitative field testing exercise

December 2016

ICS finalized

From 2017

Start of confidential ICS reporting to supervisors

December 2017

Public consultation on ComFrame and the ICS

Late 2018

Adoption of ComFrame, including ICS




Should you have any questions or comments, please contact G. Donovan Brown at Colodny Fass (+1 850 545 8864 or


Click here to follow Colodny Fass on Twitter (@ColodnyFassLaw)


To unsubscribe from this newsletter, please send an e-mail to