As an example of DeemedRetractible analysis, and as an aid to PrefLetter subscribers who are referred to previous issues, I am publishing the PrefLetter DeemedRetractible Review September 2016. It’s rather a large file!
This is notable for its lengthy argument justifying my belief that the NVCC rules currently applied to banks will be extended by OSFI to preferred shares issued by insurers and insurance holding companies. This argument has recently been buttressed by OSFI’s public commentary on the revision of the global insurance rules, as reported in the post OSFI Dovish on Insurance Tier 1 Eligibility Rule.
Update, 2018-11-3: Consultations continue as we slowly grind to a resolution of this issue. See Comment Period Expires for IAIS Public Consultation on ICS 2.0.
Update, 2018-12-5: The IAIS has released its November / December 2018 newsletter, which reiterates its intentions regarding ICS 2.0:
In a session moderated by Secretary General Jonathan Dixon, the Chairs of the Policy Development, Macroprudential, and Implementation and Assessment Committees [Elise Liebers, Alberto Corinti and Jose (Pepe) Lopez Hoyo, respectively] provided updates on key IAIS initiatives within their respective areas, including revisions to the ICPs and ComFrame, along with progress in developing ICS Version 2.0, and the holistic framework for systemic risk. These projects are all on track, with delivery slated for year-end 2019.
Update, 2018-12-26: ‘Deemed Maturity’ Date for Insurance Issues Changed to 2030-1-31.
Update, 2019-3-22: The International Association of Insurance Supervisors has announced:
The CSFWG will host an ICS Stakeholder Meeting in Orlando on 10 April. The stakeholder meeting is intended to provide a forum for constructive feedback on ICS Version 2.0. Stakeholders who wish to provide presentations on key issues related to the ICS should contact danita.pattemore@bis.org and becky.easland@bis.org by 22 March 2019 indicating the topics they wish to cover. Presentation materials should be provided no later than 29 March 2019. To register, please click here.
Update, 2019-4-6: Responses to the 2018 call for comments on the IAIS Public Consultation on ICS 2.0 have been released.
Update, 2019-5-27: Schedule update consistent with previous estimates.
Update, 2019-11-17: The IAIS has decided against requiring a Principal Loss Absorbency Mechanism in its testing phase. Although such a requirement is still within the bounds of possibility once the testing has been completed and final adjustments are made to the capital requirements rules, such a reversal should not be considered likely without additional supporting evidence.