The International Association of Insurance Supervisors (IAIS) is participating in a global initiative, with the Financial Stability Board (FSB) and the G20, to identify potential global systemically important insurers (G-SIIs). As part of this initiative, the IAIS has issued a public consultation on proposed measures to identify any insurers whose distress or disorderly failure, because of their size, complexity and interconnectedness, would cause significant disruption to the global financial system and economic activity. The CRO Forum responded to the IAIS draft policy measures. This paper provides some additional background to the response provided.

In this paper we discuss the idea behind currency risk. If the guidance for the required capital calculation for FX risk is based on a shock applied to the Net Asset Value of the entities in their respective reporting currencies, then this can create hedge incentives that endanger the solvency of the group and hence policyholder benefits.