Insurance Europe response to IAIS Consultation on ComFrame

31 August 2012

For many years, Insurance Europe has supported the introduction of comprehensive and efficient group supervision and therefore appreciates the International Association of Insurance Supervisors' (IAIS) efforts in launching the ComFrame initiative.

A global framework for group supervision is an appropriate response to the increasing globalisation of insurance markets to ensure that policyholders are appropriately protected and confidence in insurance markets is promoted.

ComFrame is an ambitious project which we can still see potential benefits in for both supervisors and the industry:

• Convergence of supervisory practises – work is underway in a number of jurisdictions to improve and further develop domestic approaches to group supervision, therefore it is important these efforts build off and converge towards some common supervisory principles.
• Greater consistency in supervisory requirements – it is important that supervisors and industry agree on basic and indispensable elements that should be included in a global framework for group supervision. This should help to foster a common understanding of groups among supervisors and reduce duplication of regulatory efforts for internationally active insurance groups.
• Coordination and cooperation – greater understanding is fundamental to the ultimate success of ComFrame. To achieve this goal, efficient and effective coordination and cooperation between supervisors is vital.

Through improving the quality and consistency of group supervision globally through improved cooperation and coordination between supervisors, ComFrame should foster enhanced policyholder protection, facilitate competition for the benefit of policyholders, strengthen financial stability and contribute to a level playing field for insurance groups.

Full response

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