• In paragraph 34, it is noted that some products offered by insurers (which contain provisions whereby a policyholder can withdraw cash from the policy with little notice or penalty) contain high liquid liability; however, this description is too simplified and inappropriate since it does not properly take into account the reality of insurers' business.
• According to the IAIS' policy document "Systemic Risk from Insurance Product Features" released on 16 June 2016 states, in subsection 4.24. 
• The liquidity of surrender value should be assessed in a holistic manner where due consideration is paid to broader aspects including purpose of the insurance contracts and substantial economic penalties embedded in high guaranteed rate contracts.
• The matrix of Table 5 in Annex 1 does not explicitly reflect such holistic assessment.
• In addition, the weightings are excessive. Moreover, as described in paragraph 34, it is possible that insurers face liquidity risk where they do not adequately match liquid liabilities with illiquid assets; however, this is not a source of systemic risk if insurers have invested sufficiently in liquid assets.  (Page 10 of 264)

--  Global Federation of Insurance Associations

2019 06 - IAIS - Comments November 2018 Holistic Framework - 264p