Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame)
Last Updated 04/11/14

Issue: Insurance markets have become increasingly global and interconnected and this trend is likely to continue. In response to the increasing globalization in the insurance sector combined with the key lessons learnt from the financial crisis, the International Association of Insurance Supervisors (IAIS) began developing a Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame) in July 2010. The IAIS is the international standard-setting body for the prudential supervision of the insurance industry.

Overview: ComFrame is a set of international supervisory requirements focusing on the effective group-wide supervision of internationally active insurance groups (IAIGs). An IAIG is a large, internationally active group that includes at least one sizeable insurance entity. ComFrame sets out a comprehensive range of qualitative and quantitative requirements specific to IAIGs, as well as the supervisory processes and prerequisites for supervisors to implement ComFrame. ComFrame is built and expands upon the high level requirements and guidance currently set out in the IAIS Insurance Core Principles (ICPs) which generally apply on both a legal entity and group-wide level.

ComFrame is structured in three Modules with each module made up of a number of elements. Module 1, Scope of ComFrame, includes the criteria and process for the identification of IAIGs by supervisors, the breadth of supervision of IAIGs (which legal entities are included) and the identification of the group-wide supervisor. Module 2, The IAIG, contains the requirements that an IAIG will need to meet. Module 3, The Supervisors, covers the process of supervision, highlighting the role of the group-wide supervisor and other relevant supervisors’ responsibilities within the process. The module covers the supervisory process, enforcement, cooperation and interaction requirements.

The Development Phase of ComFrame began in 2010 and concluded at the end of 2013. Beginning in 2014, field testing will begin wherein ComFrame will be evaluated in practice so that it can be modified as necessary prior to formal adoption. The IAIS is currently scheduled to formally adopt ComFrame at the end of 2018, with its members to begin implementing ComFrame thereafter.

The IAIS issued its first exposure draft of the Concept Paper on ComFrame in July 2011. The Concept Paper composed of five primary work streams called “Modules,” with each Module further broken down into elements prioritized for purposes of development and exposure. Since the Concept Paper was released, there has been much progress made on the development of ComFrame. In March 2012, a new structure for ComFrame was proposed and subsequently approved by the IAIS Technical Committee. The new structure consisted of four Modules (replacing the five Modules of the previous structure). In July 2012 the IAIS released a Draft ComFrame ("2012 ComFrame Draft") for public consolation. The 2012 ComFrame Draft marked the completion of the second step in its three-year Development Phase. A third Draft ComFrame was issued for public consultation in October 2013 (“2013 Draft ComFrame”).

It was also announced in October 2013 that the IAIS will develop a risk-based global insurance capital standard (ICS) to include it within ComFrame, which has always included a capital component within its solvency assessment. This component will be used as a starting point for development of the ICS. In 2014, the IAIS will also develop the basic capital requirements (BCR), which is planned to be finalized and ready for implementation by G-SIIs in late-2014. The BCR will serve as the foundation for higher loss absorbency (HLA) requirements for global systemically important insurers, which are to be implemented in 2019; it is anticipated that their development and testing will also inform development of the ICS.

Status: In 2013, state insurance regulators, working through the NAIC, released a position paper on ComFrame titled, “U.S. Insurance Regulators’ Views: IAIS Common Framework for the Supervision of Internationally Active Insurance Groups “ComFrame.” The purpose of the position paper is to articulate the views of U.S. state insurance regulators toward ComFrame and to identify the characteristics of ComFrame that are necessary for U.S. state insurance regulators to support its implementation in the national system of state-based insurance regulation. A position paper on the International Capital Proposals was also released in 2013.

The NAIC’s international involvement has been increasingly focused on strengthening the supervision of insurers that operate in multiple countries, or IAIGs. The ComFrame Development and Analysis (G) Working Group provides ongoing review and technical as well as expedited strategic input on ComFrame. In addition, the NAIC's International Insurance Relations (G) Committee supports the work of the IAIS by participating in Executive, Technical and other relevant Committee meetings, and by drafting and commenting on papers to represent the views of U.S. insurance regulators.
Committees Active on This Topic
ComFrame Development and Analysis (G) Working Group
International Insurance Relations (G) Committee
Testimony and Speeches
Testimony Before the Subcommittee on Housing and Insurance Committee on Financial Services Regarding: The Impact of International Regulatory Standards on the Competitiveness of U.S. Insurers
Senator Ben Nelson, NAIC CEO

Podcast: NAIC International Insurance Relations Committee Chair and Connecticut Insurance Commissioner Tomas B. Leonardi and NAIC CEO Ben Nelson discuss U.S. regulators' concerns about the direction of ComFrame
May 2013

Testimony Before the Subcommittee on Securities, Insurance, and Investment Committee on Banking, Housing, and Urban Affairs regarding: “Emerging Issues in Insurance Regulation”
Therese M. Vaughan, Ph.D.
Speech: Group Supervision and the IAIS Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame)
Therese M. Vaughan, Ph.D.
Speech: Supervising Internationally Active Insurance Groups
Therese M. Vaughan, Ph.D.
Additional Resources
IAIS Resources

IAIS ComFrame Overview Presentation
March 29, 2014

IAIS ComFrame FAQs
October 2013
IAIS 2012 Draft ComFrame 
July 2012
IAIS: ComFrame Update
April 2012, IAIS Newsletter
NAIC/CIPR Resources
ComFrame Position Statements
December 2013

Capital Position Statements
December 2013

International Activities: Legislative Issues Brief

Key Issue: International Insurance Supervision/IAIS
Key Issue: Internationally Active Insurance Group (IAIG)
NAIC Symposium on Supervision of Internationally Active Insurance Groups
CIPR Staff
Media queries should be directed to the NAIC Communications Division at 816-783-8909 or