GFIA has responded to a consultation by the International Association of Insurance Supervisors (IAIS) on its draft revised application paper on supervisory colleges. Overall, the draft provides a helpful overview of the purpose of supervisory colleges and the procedures that can make them effective.
Regarding the role of group-wide senior
management, the draft makes several important points about the benefits
and necessity of including group-wide senior management in some aspects
of supervisory colleges. GFIA appreciates those points and agrees that
including group-wide management in supervisory colleges can increase
their effectiveness and improve communication between supervisors and
the groups they supervise.
GFIA suggests that the IAIS
expands the involvement of senior management in the planning stage of
supervisory colleges, particularly by urging group-wide supervisors to
consult the senior management of a group. GFIA also urges the IAIS to
recognize that the group should be consulted as necessary in the process
of identifying the group-wide supervisor.
GFIA
appreciates the clear reference to proportionality in the draft, which
will ensure that a “one-size fits all” approach will be avoided, if
supervisors embrace the principle.
GFIA also appreciates
the focus in the draft on the importance of confidentiality in
information exchange. GFIA hopes that the IAIS and group-wide
supervisors will continue to stress the importance of confidentiality of
information in the implementation of the final application paper when
forming and conducting supervisory colleges.
response
© GFIA - Global Federation of Insurance Associations
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