International Insurance Relations (G) Committee
Tuesday, August 13, 2024
3:30 PM CDT
McCormick Place Convention Center—Grand Ballroom—Level 1
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Internationally Active Insurance Group
Background
Last Updated: 12/21/2023
Issue: The supervision of internationally active insurance groups (IAIGs) has garnered considerable discussion following the 2008 global financial crisis. Insurance markets have evolved over the years to become increasingly global and interconnected. In response to the increasing globalization in the insurance sector as well as key lessons learned from the financial crisis, the International Association of Insurance Supervisors (IAIS) began developing a major project called ComFrame (Common Framework for the Supervision of Internationally Active Insurance Groups). ComFrame is a set of international standards focusing on the effective group-wide supervision of IAIGs.
Overview: ComFrame is built on the premise that IAIGs should be supervised in a collaborative fashion by home and host supervisors, thereby resulting in more effective and efficient supervision. It contains qualitative and quantitative requirements for IAIGs and for home and host supervisors intended to foster greater cooperation and coordination among supervisors. ComFrame expands upon the high level standards and guidance 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 is presented under the relevant ICPs.
What is an IAIG?
ComFrame provides the two criteria for an insurance group to be identified as an IAIG: 1) International Activity — premiums are written in three or more jurisdictions, and percentage of gross premiums written outside the home jurisdiction are at least 10% of the group's total gross written premium; and 2) Size —based on a three-year rolling average, total assets of at least $50 billion USD, or gross written premiums of at least $10 billion USD.
Process of Identifying an IAIG
In general, the group-wide supervisor, in cooperation with other involved supervisors through a supervisory college, determines whether an insurance group or an insurance legal entity operating through branches is an IAIG after considering whether it meets the criteria outlined above. Supervisory colleges are intended to coordinate oversight of IAIGs at the group level. The process also allows a degree of supervisory discretion on whether a particular group should, or should not, be considered an IAIG, with ComFrame providing guidance on factors that supervisors may want to consider.
Actions
Status: Over the past decade, the NAIC's international involvement has been increasingly focused on strengthening the supervision of insurers that operate internationally. U.S. state insurance regulators support the objectives of ComFrame to the extent that it results in an outcomes-focused framework that enhances supervision of IAIGs.
While the IAIS is not responsible for identifying IAIGs, in July 2020 it began publishing and updating annually a register of IAIGs that have been publicly disclosed by their group-wide supervisor (GWS). As of July 2022, 49 IAIGs have been identified by GWSs from 17 jurisdictions. All 49 IAIGs have been publicly disclosed.
In March 2023, the NAIC published a Position Statement on Final IAIS Criteria to assess whether the Aggregation Method (AM) provides comparable outcomes to the Insurance Capital Standard (ICS). The NAIC states the issuance of final criteria is an important milestone for the global insurance sector. Finalization of these criteria fulfills the Financial Stability Board’s charge to develop a comprehensive, group-wide supervisory and regulatory framework for Internationally Active Insurance Groups (IAIGs), including a quantitative capital standard.
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