29 November 2013

GFIA comments on IAIS restructuring

The GFIA would like to thank the IAIS for this chance to provide feedback on its reorganisation. These improvements are intended to enhance the efficiency of its work, and the GFIA stands ready to contribute to this in any manner it can. The GFIA would like to work very closely with the IAIS secretariat throughout this restructuring process to ensure Observers play a constructive role in the international standard setting process.

In the past, strong Observer involvement has contributed substantially to the quality, applicability and timeliness of IAIS work as Observers have a wealth of insurance technical expertise to contribute. With the rise in prominence of global standard-setting initiatives such as the Insurance Capital Standard, the Backstop Capital Requirement and ComFrame to name just a few, the need for all stakeholders in the regulatory process to contribute their expertise and experience has even increased. The GFIA therefore hopes that this restructuring will truly enhance the way Observer feedback is taken into account in the policy-making process.

Given the more limited number of opportunities for direct contact between the IAIS and Observers under the new structure, it is essential that these opportunities be leveraged to their full potential, allowing for the most focused and substantial feedback possible. For this, Observers need to be provided with adequate background documentation, and given sufficient time to prepare for dialogues. Also, it is important to ensure that a sufficient consultation period (for example, 60 days) is given for all Members and Observers. After closed meetings take place, Observers would welcome the publication of detailed minutes, so we can correctly follow the IAIS strategic direction on projects.

When consulting with Observers, all Observers should be equally provided with an opportunity to contribute, without limitation by region or line of business. It should be recognised that all Observers bring a different perspective to the table, given the substantial diversity of insurers globally.

Although the GFIA supports the IAIS’s proposal to limit its number of Working Groups and Taskforces, it has some concerns relating to the establishment of the Coordination Group. It is not fully clear to the GFIA whether the Coordination Group is intended to be a permanent part of the IAIS structure. If so, the GFIA would urge caution against establishing an additional coordination level which may end up slowing down the decision-making process, especially as it has the responsibility to confirm each paper of the Working Groups before it is submitted to the Executive Committee for approval or further consideration.

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