ComFrame: Supervision of International Insurance Groups

Following the 2008 financial crisis, the International Association of Insurance Supervisors (IAIS) began development of ComFrame, to address the group-wide risks and activities of Internationally Active Insurance Groups (IAIGs). They were considered to require tailored and more coordinated supervision, due to their complexity and international activities.

ComFrame therefore seeks to encourage global convergence of regulatory and supervisory measures, providing a basis for comparability of IAIG regulation and supervision processes. It is intended to increase co-operation between national supervisors and close regulatory gaps. Ultimately, the IAIS believes that ComFrame will reduce compliance and reporting demands on IAIGs.

Background

IAIS development of this initiative began in 2010 with the backing of the G20 and the Financial Stability Board (FSB).

ComFrame includes criteria for the identification of the IAIGs to which the regime will apply. These are:

• International activity: premiums written in not fewer than three jurisdictions and percentage of premiums written outside the home jurisdiction not less than 10% of total gross written premiums.
• Size: total assets of not less than USD 50bn or GWP not less than USD 10bn (based on rolling 3-year averages).

The IAIS itself will not develop a list of IAIGs, but will rely on national supervisors involved in supervision of groups to identify them, based on ComFrame’s criteria. The IAIS expects around 50 IAIGs to be identified.

Whilst ComFrame will not be legally binding, the IAIS membership comprises regulators from more than 200 jurisdictions and the IAIS expects them to ensure implementation of IAIS standards (including ComFrame) at national level.

ComFrame is structured in three modules:

Module 1: Scope of ComFrame – includes the criteria and process for identifying IAIGs, the legal entities included and the identification of a group-wide supervisor.

Module 2: The IAIG – the requirements that an IAIG must meet.

Module 3: The Supervisors – the process of supervision and supervisors’ responsibilities.

Details of ComFrame requirements continue to evolve. The latest draft includes obligations for IAIGs to:

• Establish and implement group-wide governance framework;
• Establish and implement a group-wide enterprise risk management framework;
• Develop group-wide underwriting, claims management, reinsurance, insurance liability and asset liability valuation policies; and
• Report on their overall strategy and intra-group transactions.

ComFrame will include a single insurance capital standard, the ICS (please see separate page on Global Capital Standards).

IAIGs will co-ordinate their regulatory efforts and proactively exchange supervisory information through “supervisory colleges”. They will be responsible for developing plans and tools to deal with crises within particular IAIGs.

Lloyd’s considers that the ComFrame framework should not apply to internationally active solo entities which are not part of a group. Supervision of solo entities is undertaken by home supervisors in relation to all operations on a holistic basis, so the same need for coordination between supervisors does not arise as for a group made up of subsidiaries trading and authorised in different jurisdictions. ComFrame has been framed for application to groups and some of its provisions cannot easily be applied to solo entities.

Development update

The IAIS carried out field testing of the regime from 2014 up until its official application. This involved testing qualitative and quantitative elements with volunteer IAIGs. Lloyd’s was not involved in this exercise, since it does not consider that the regime should apply to solo entities.

On 14 November 2019, ComFrame was adopted by the IAIS, establishing supervisory standards and guidance focusing on the effective group-wide supervision of Internationally Active Insurance Groups (IAIGs). After an initial stage of ComFrame implementation, the IAIS will shift its focus to assessment of implementation of ComFrame. The assessment methodology for ComFrame was adopted in November 2019 as part of the overall framework.