While recognising the improvements made in the latest draft of a common framework for the supervision of international insurance groups (ComFrame), GFIA has put forward a number of issues that still need to be addressed.
In its response to an International Association of Insurance Supervisors (IAIS) public consultation, GFIA expressed concerns about the level of prescriptiveness of certain provisions and the structure of cooperation in supervisory colleges.
GFIA believes that it is vitally important that ComFrame does not create an additional and prescriptive layer of regulation that disregards local regimes. Instead it should provide a principles-based framework that can promote better understanding and —
through coordination and cooperation among supervisors — facilitate reliance on and recognition of the group supervision conducted by jurisdictions that meet the ComFrame standard.
GFIA welcomes the inclusion of "cornerstones” that set out fundamental principles important to the success of ComFrame, such as proportionality, the approach to group-wide supervision, operational structures and the allocation of roles. It emphasises the importance of ComFrame's standards, parameters and guidance being consistent with those principles.