2018年-FSB全球金融稳定委员会_Public_responses_to_the_consultation_on_Key_Attributes_Assessment_Methodology_for_the_Insurance_Sector_6页_416kb

AIA Group Limited Comments on FSB Consultation Papers

Core Content

AIA Group Limited, a Hong Kong-based insurance group with significant operations across 17 Asia Pacific jurisdictions, has submitted detailed comments to the Financial Stability Board (FSB) on two consultation documents: one from 2015 on developing effective resolution strategies for systemically important insurers and another from 2017 on the Key Attributes Assessment Methodology for the Insurance Sector.

AIA emphasizes the importance of tailoring resolution frameworks to the unique characteristics of the insurance sector, rather than adopting a one-size-fits-all, bank-centric approach. The group argues that insurance and banking are fundamentally different in terms of risk profiles, business models, and systemic relevance.

Main Views

1. Tailoring Resolution Frameworks for Insurance

• AIA supports the development of effective and proportionate regulatory and supervisory measures to enhance financial stability.
• The Key Attributes should not be prescriptive but flexible, allowing for adjustments that avoid adverse or unintended consequences.
• The insurance sector should not be treated as a subset of banking; its distinct risk profile must be acknowledged.

2. Liquidity and Risk Management

• Insurers, particularly life insurers, have a different approach to liquidity compared to banks.
• Life insurance underwriting requires matching the term of assets with policy terms, resulting in lower liquidity risk.
• Policyholder contracts often span decades, making premature redemption unlikely and reducing the need for immediate resolution tools.

3. Applicability of Resolution Regimes

• Resolution regimes should apply only to insurers engaged in systemically risky activities.
• AIA highlights that traditional insurers, especially those focused on life insurance, do not typically pose systemic risks due to their low interconnectedness with the financial system.
• The risk of contagion from insurers is limited, and resolution should be based on the local entity approach rather than a consolidated one.

4. Use of Resolution Powers

• Traditional resolution tools such as run-off and transfer of business are sufficient and should be prioritized.
• New resolution powers (e.g., bridge insurer, bail-in) should be used only as a last resort, after traditional methods have been exhausted.
• These powers must be proportionate and not cause undue harm to the insurer or its stakeholders.

5. Legal and Regulatory Safeguards

• There should be safeguards to ensure equity of treatment when resolution powers are exercised.
• Resolution decisions should be reasonable and subject to judicial review to protect affected parties.
• AIA recommends that the legal framework prohibit disclosure of non-public company information unless agreed by both the recipient and the relevant authority.

Key Information

• AIA is not classified as a Global Systemically Important Insurer (G-SII) but remains a significant player in the Asia Pacific insurance market.
• The group advocates for a more nuanced and sector-specific approach to systemic risk assessment and resolution strategies.
• AIA emphasizes the importance of preserving long-term value over expedited resolution, especially in the context of insurance.
• The group supports cross-border cooperation but stresses the need for local interests to be prioritized in resolution processes.
• AIA suggests that the legal framework for resolution should be aligned with existing insolvency laws and include judicial oversight to ensure fairness and transparency.

Conclusion

AIA Group Limited urges the FSB to consider the distinct characteristics of the insurance sector when developing resolution strategies and methodologies. The group believes that a flexible, proportionate, and sector-specific approach is necessary to avoid unintended consequences and ensure the long-term stability of the insurance industry in Asia Pacific.