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Lead Manager, IAIS Policy and Coordination
Director, International Policy
Last Updated 1/22/19
Issue:The regulation of insurance groups 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 as ComFrame (Common Framework for the Supervision of Internationally Active Insurance Groups). As part of ComFrame, the IAIS is also developing a global, risk-based insurance capital standard (ICS).
Overview: ComFrame is a set of international standards focusing on the effective group-wide supervision of internationally active insurance groups (IAIGs). ComFrame sets out a comprehensive range of quantitative and qualitative standards and guidance specific to IAIGs, as well as for supervisors of IAIGs. ComFrame is built and expands upon the high level standards and guidance currently set out in the IAIS Insurance Core Principles (ICPs), which generally apply on both a legal entity and group-wide level.
To provide better context for ComFrame with respect to the ICPs, ComFrame will be presented under the relevant ICPs. According to the IAIS, "the ICPs and ComFrame are inextricably linked, with ComFrame designed to build and expand upon the high-level requirements in the ICPs. ComFrame's new structure will better reflect this while also helping to ensure that ComFrame and the ICPs are developed by themes in a parallel and complementary manner that avoids unintended duplication."
In October 2013 the IAIS announced the development of the ICS, with the goal of creating a common language for supervisory discussions of group solvency to enhance global convergence among group capital standards. Once adopted, the ICS will apply to IAIGs as part of ComFrame. In November 2017, the IAIS announced details on how ICS Version 2.0 will be implemented. The first phase consists of a 5-year monitoring period during which a reference ICS will be used for confidential reporting to group-wide supervisors and discussion in supervisory colleges, and additional reporting collected at the option of the group-wide supervisor, including ICS based on a GAAP Plus valuation approach and/or an internal model-based capital requirement calculation. The second phase will be implementation of the ICS as a group-wide prescribed capital requirement (PCR).
As part of this ongoing work, the IAIS has recognized the U.S. work on an aggregation approach and will assess by the end of the monitoring period whether such an approach reaches comparable outcomes to the ICS. Discussions on how to assess comparable outcomes began internally amongst IAIS members towards the end of 2018 and will continue into 2019.
Status: Further development of ComFrame and the ICS are informed by an annual field-testing process that involves both supervisors and volunteer insurers. A public consultation on ComFrame and ICS Version 2.0 was launched by the IAIS in July 2018 and the NAIC submitted comments by the October 30 deadline. According to the current IAIS workplan, ComFrame, including ICS Version 2.0, should be finalized and adopted towards the end of 2019 and ready for implementation by IAIS members in 2020.
The ComFrame Development and Analysis (G) Working Group provides ongoing technical review as well as expedited strategic input on ComFrame and the ICS.