Status: Draft -- Not PublishedWill be live at 10/29/2024 14:21
IIF Response to IAIS on Macroprudential Supervision and Climate Risk
On October 28, 2024, the Institute of International Finance (IIF) submitted its response to the International Association of Insurance Supervisors' (IAIS) Fourth Climate Package, 'Draft supporting material on macroprudential and group supervisory issues and climate risk.' While the IIF appreciates the IAIS's efforts, the letter emphasizes that any supervisory measures should be evidence-based, proportionate, and carefully tailored to address specific identified needs while avoiding negative impacts on insurance markets and policyholders. The IIF recommends that the IAIS adopt a more flexible "toolbox" approach that can accommodate different jurisdictional contexts. The IAIS needs to better distinguish between broader macroeconomic climate risks and specific insurance sector financial stability implications, and better recognize the insurance sector's positive contributions to climate resilience through underwriting, reinsurance, and investment activities. The IIF emphasizes that supervisory actions should avoid unintended consequences, particularly those that might increase protection gaps or reduce insurance availability. Lastly, the letter notes that existing prudential capital frameworks already account for climate-related financial risks, and that additional capital requirements should be limited to specific solvency concerns.