Morag Fullilove, of Fullilove consulting in Brussels, who made a presentation on behalf GNAIE, said IAIS is in the process of developing disclosure standards somewhat similar to National Association of Insurance Commissioners model acts.

"We told them their main obligation is to focus on their needs as supervisors and the needs of the policyholders," she said. "It's nice to have disclosure to investors, but no one looks after the policyholders. That was where we said they should be focusing their efforts."

The IAIS, in addition to investment performance, is examining standards for risk assessment.

In a letter to the IAIS Enhanced Disclosure Subcommittee, the GNAIE group said that "high-quality disclosure standards assist companies, regulators and key stakeholders in better understanding operating performance and in making more informed business and investment decisions."

GNAIE said it is the only trade association which focuses exclusively on financial reporting and accounting issues. It is currently a provisional Observer Member of the IAIS, pending acceptance at the group's October annual meeting.

In its response to the subcommittee's request for comments on a draft of standard disclosures concerning investment performance and risks for insurers and reinsurers, GNAIE pointed out in its letter that the draft did not describe the holistic risk analysis process that underscores the inter-relationships of risk management practiced by insurers.

For example, GNAIE noted that companies that take little risk in their product profile might prudently take risk in their investment operations and vice versa. Further, certain risk profiles may offset another within an investment portfolio.

"We believe that all standards regarding disclosures and investment performance measurement should emphasize that the overall risk profile is paramount, and the parsing of risk and the subsequent assessment thereof--while perhaps convenient from a logistical point of view--will often lead to injudicious conclusions both by supervisors and their constituencies," the group said.

GNAIE also observed that the center of the insurance market on which regulatory requirements should focus is the consumer, "since it is the protection of the policyholder that lies at the heart of the regulator's role."

The organization cautioned against diminishing the focus on policyholders by including a broader and more diverse group of audiences, such as shareholders, equity analysts, rating agencies and the media.

"Such a broad objective creates the risk of developing excessive disclosure that makes it difficult for each user to extract the most critical information they seek from disclosure," said GNAIE.

The group also expressed concern that disclosure requirements may force insurers to reveal proprietary information that either has the potential to be used by other insurers to gain a competitive advantage, or could be misunderstood by readers and thus have unintended, adverse consequences to the company.

GNAIE also suggested that in developing its regulations, the IAIS clarify what information is to be provided at the entity level when investments are managed at a group or conglomerate level.

In addition, GNAIE commented that the draft standard does not recognize the differing investment practices of life and non-life insurers based on the diverse products they sell.

"Given these anticipated differences in investment management by product line, it seems appropriate to consider separate requirements by insurance product line, especially with respect to the asset-liability management area and interest rate stress testing," said GNAIE.

GNAIE's members are the chief financial officers of ACE Ltd., American International Group, Allstate, GE Insurance Solutions, Genworth Financial, The Hartford, Liberty Mutual, MetLife, New York Life, Prudential Financial and XL Capital.

The listed goal of GNAIE is "to influence the development of international accounting standards to ensure that they result in robust, high-quality standards for insurance enterprises," as well as to increase communication between insurers doing business in North America and the International Accounting Standards Board and the United States Financial Accounting Standards Board.