American Council of Life Insurers (ACLI)

Summary: The American Council of Life Insurers (ACLI) supports the proposed revisions to the Basel III Endgame capital framework, commending the agencies' responsiveness to stakeholder feedback. They request three specific refinements to improve risk sensitivity: providing flexibility for Category III and IV banks regarding investment-grade corporate exposures, recalibrating the CVA risk framework to distinguish between regulated and unregulated financials, and clarifying the treatment of insurer separate accounts as corporate exposures.