Property Casualty Insurers Association of America Property Casualty Insurers Association of America
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Cliston Brown



(847) 553-3671








October 17, 2012



PCI Statement on IAIS Global Systemically Important Insurers Proposal


WASHINGTON—Today, the International Association of Insurance Supervisors (IAIS) announced its proposed policy measures for “global systemically important insurers” (G-SIIs). The Property Casualty Insurers Association of America (PCI) is pleased that the IAIS recognizes that traditional property and casualty insurance activities do not pose a systemic risk and that insurers should be regulated differently than banks, but remains concerned that the implementation of this proposal may create unintended consequences. David Snyder, PCI’s vice president for international insurance policy, issued the following statement:


“We strongly agree with the IAIS’ view that the traditional insurance business model does not pose systemic risk and that insurers should be regulated differently than banks. However, as international regulators attempt to draw distinctions between what constitutes traditional insurance activities and what should be considered non-insurance financial activities there is significant risk of overreach.


“If insurers that do not pose a systemic risk (including property and casualty insurers) are swept into the definition of G-SIIs, these measures will unfairly and inappropriately impose on them restrictions, increased capital requirements and other burdens not shared by their competitors. The result will be an uneven playing field, less competition and higher costs, thereby actually harming consumers in the name of consumer protection.


“The unique existing regulatory infrastructure for U.S. insurers provides significant protections that already address many of the goals of international regulations. U.S. property and casualty insurers performed extraordinarily well during the recent financial crisis and are subject to regulatory requirements at the state level including capital requirements, limitations on risky investments, and resolution regimes funded by industry and not taxpayers. We look forward to working with the IAIS to ensure that the existing system of protections in the United States that has worked so well is not undermined and that America’s insurers can compete fairly in the global insurance marketplace.”


PCI represents more than 1000 insurers which write 40% of the U.S. property and casualty insurance market. Its membership includes U.S. insurers that operate internationally and the U.S. subsidiaries of global companies.