Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame)
Last Updated 9/29/15

Issue: The regulation of insurance groups has garnered considerable attention following the global financial crisis of 2008, with various regulatory agencies developing new guidelines and requirements for the supervision of financial holding companies. In the U.S., the Solvency Modernization Initiative (SMI), initiated in June 2008, led to substantive changes regarding how insurance groups will be monitored and regulated in the coming years, including amendments to the Insurance Holding Company System Regulatory Act (#440) and the Insurance Holding Company System Model Regulation (#450). Globally, however, the most significant development regarding group supervision is a major project initiated at the International Association of Insurance supervisors (IAIS) known colloquially as ComFrame (Common Framework for the Supervision of Internationally Active Insurance Groups).

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 quantitative requirements specific to IAIGs, and requirements for supervisors of IAIGs. 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 standards (referred to as 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. This 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, with several ComFrame drafts released for public consultation during this period. ComFrame is currently being field tested to assess the value and practicality of the various requirements, so it can be modified as necessary prior to formal adoption. The IAIS is currently scheduled to formally adopt ComFrame in 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. 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), due to be developed by the end of 2016, with full implementation expected in 2019 after two years of testing and refinement with supervisors and global insurance groups. The ICS will be developed within ComFrame and apply to all IAIGs. The IAIS hopes the ICS will provide a more comparable measure of capital across jurisdictions and allow host supervisors to have greater confidence in the group-wide supervisor’s decisions and analysis.

Status: State insurance regulators, working through the NAIC, recently 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 2015.

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
Michael F. Consedine

Remarks at the Brookings Institution: Global Capital Standards: Implications for the U.S.
Michael F. Consedine

NAIC Statement on the Global Insurance Capital Standard

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 FAQs
June 2015

ComFrame Revised Draft
September 2014
Insurance Capital Standard Principles (ICS)
September 12, 2014
IAIS ComFrame Overview Presentation
March 29, 2014
NAIC/CIPR Resources
ComFrame Position Statements
April 2015

Capital Position Statements
April 2015

International Activities: Legislative Issues Brief

Navigating the Regulatory Alphabet Soup
July 2014, CIPR Newsletter
CIPR Key Issue: International Insurance Supervision/IAIS
CIPR Key Issue: Internationally Active Insurance Group
NAIC Symposium on Supervision of Internationally Active Insurance Groups
NAIC Center for Insurance Policy and Research (CIPR)
CIPR Homepage
Media queries should be directed to the NAIC Communications Division at 816-783-8909 or