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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.