On June 25, 2024, the IIF and its insurance members responded to the International Association of Insurance Supervisors (IAIS) consultation on the Draft Revisions to Supervisory Material Related to the Holistic Framework in ICPs 12 and 16 and related ComFrame standards. In its response, the IIF commended the IAIS's integrated approach to monitoring systemic risk but found the revisions overly prescriptive and unsuitable for all jurisdictions. The IIF instead advocates for a more proportionate, principles-based approach, emphasizing flexibility and contingency planning over immutable formal resolution plans. The IIF encourages supervisors to focus on activities-based assessments of systemic risk that takes a ‘whole of business’ view of the insurer, its activities and available risk mitigants, which would better allow for a determination of the extent to which the company should engage in resolution planning or develop a formal plan. The suggestion that resolution plans could be required for all insurers, a minimum share of the jurisdiction’s insurance sector, or for all IAIGs promotes an arbitrary approach that is not consistent with a holistic, risk-based and proportionate approach to systemic risk. Moreover, reverting to an entity-based approach could lead to significant inconsistencies across jurisdictions, including a return to entity designation in some jurisdictions. Lastly, the IIF encourages close coordination among supervisors, insurers, and relevant authorities in order to develop effective resolution planning, which should be tailored to reflect the specific risk profiles and structures of individual insurers.