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The Common framework for internationally active insurance groups (COMFRAME) aims to achieve more consistency in, and better comparability of, the supervision of insurance groups.
Though the European Insurance and Reinsurance Federation (CEA) supports effective group supervision, it believes that the concept paper is far too prescriptive — including proposals for reporting templates, for example. It thus runs the risk of creating a two-tier regulatory system under which a small number of internationally active groups would be subject to more intensive supervisory practices.
CEA suggests that COMFRAME should be developed through a step-by-step approach, starting from ensuring a common understanding of the aims of the project and setting principles which would meet those aims
Lastly, the CEA believes an expert group should be established to provide input to the COMFRAME Project, which should consist of experts from the industry alongside representatives of supervisors who deal with the supervision of major insurance groups. The group will also then be in a good position to highlight areas of duplication and propose practical solutions to streamline the supervisory and reporting process.