GFIA Response to FSB Consultation on Critical FunctionsRelease Date: 12/17/2014 Staff Reference: Janice Hilchie
The GFIA welcomes the opportunity to respond to this consultation by the FSB on the identification of critical functions and critical shared services in the context of recovery and resolution planning for systemically important insurers. We support the FSB’s encouragement of cross-border supervisory co-operation on resolution and trying to develop a common understanding of critical services.
We also welcome the recognition by the FSB that critical functions would differ according to jurisdiction and to particular market conditions and the implication that a one-size fits-all approach would therefore not be appropriate.
The GFIA agrees with the FSB’s conclusion that, after applying the proposed methodology, very few critical functions are likely to be identified. We concur and would therefore question whether this approach is proportional to the outcome envisaged.