Insurance Europe: ComFrame: European insurers call for clarity and proportionality

06 November 2018

Europe’s insurers have welcomed changes made by the International Association of Insurance Supervisors (IAIS) to its proposals for a Common Framework (ComFrame) for the supervision of Internationally Active Insurance Groups (IAIGs).

In particular, the IAIS’ efforts to clarify how requirements apply across an IAIG are welcome. However, additional guidance is needed on what approach should be taken if the group-wide and legal entity supervisors have different expectations.

In its response to an IAIS consultation on ComFrame, Insurance Europe said it generally supports the ComFrame material and the IAIS’ proposed guidance, however a number of concerns were raised with respect to overlapping issues and lack of consistency between specific insurance core principles (ICPs), overly detailed and prescriptive governance requirements and requests for further clarification.

Insurance Europe reiterated the need for proportionality to be an overarching principle in ICPs and ComFrame, adding that proportionality needs to be introduced to several provisions throughout the ICPs.

Full response

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