Comments to the International Association of Insurance Supervisors Regarding Requirements for Global Systemically Important Insurers (January 2014)
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REPORT
General Comments on Executive Summary
The Committee on Insurance Law (“Committee”) of the New York City Bar Association (“Association”) is pleased to provide this response to the IAIS’s comment solicitation on its BCR proposal. The Committee’s comments are intended to share a U.S. perspective on the BCR proposal for G-SIIs, particularly in light of ongoing developments in insurance regulation in this country affecting capital standards, systemic risk and group solvency. These developments can, we believe, inform the process of regulating internationally active insurers more broadly. The Association is a not-for-profit, voluntary association of 24,000 lawyers practicing in New York City, which provides members the opportunity to meet and consult on various legal and public policy issues, acquire continuing education
and professional development and advocates for equal administration of justice, among its many activities. The Committee comprises lawyers representing a diverse cross-section of the insurance community, including lawyers in private practice, in-house counsel at insurance carriers and producers across multiple lines of insurance business, trade association officials, regulators, policyholder lawyers, insurance arbitrators and other types of insurance professionals. This letter represents the views of the Committee as a whole and not necessarily those of any particular member thereof. (Committee members Robert Easton, Executive Deputy Superintendent of Financial Services for the State of New York, and Joana Lucashuk, Senior Attorney with the Department of Financial Services for the State of New York, have recused themselves from all Committee deliberations on these comments.)
