1. IAIS Global Seminar ComFrame: Update on Qualitative and Quantitative Standards Tom Crossland, Chair of the Insurance Groups Working Group (GWG) Old Windsor, 29 June 2017

2. ComFrame material integrated with ICPs 9 and 10
Changes in style and structure resulting from the integration exercise and revision of ICPs 9 and 10.
Clarity and consistency of language and terminology improved.
More structured requirements regarding the supervisory process of the IAIGs:
Group-wide risk assessment conducted at least annually (CF9.2a);
Minimum list of elements of the group-wide risk assessment of the IAIG (CF9.2b).
New requirement to develop a recovery plan (CF10.3a):
Application of supervisory measures and imposition of sanctions directly to the Head of the IAIG within the group-wide supervisor’s jurisdiction, even when the Head of the IAIG is an unregulated financial holding company (CF10.0a, 10.6a).
Tom

3. High-level summary of the comments received
ComFrame in ICP 9
Concerns about peer analysis as part of the group-wide risk assessment (CF 9.2a.5).
Request for more clarity on how the group-supervisor will assess within the supervisory process the IAIG’s relationships with non-regulated and non-financial entities (CF 9.2b).
Concerns about ability of involved supervisors to join on-site inspections at the level of the Head of the IAIG without the IAIG’s consent.
Field testing-related questions (cost-benefit analysis): Limited participation by stakeholders and members. Lack of cost estimations, and vague assertions of benefit or lack of benefit
ComFrame in ICP 10
As regards direct powers over the head of the IAIG, respondents preferred this to be guidance only so as to avoid any legislative changes to extend supervisors’ powers. No desire to specify powers in any more detail other than where the head is an insurer rather than a financial holding company (CF 10.0a).
Request for clarification of indirect powers to be used by the group-wide supervisor if the Head of the IAIG is not located in its jurisdiction and how they would work.
Questions on cost-benefit analysis: Lack of participants. No estimations but general expectations depending on intensity of fulfillment of the standard

4. Revised ICPs 3 and 25, ComFrame in ICP 25
Consistency of language and terminology improved.
Some overlaps between ICPs 3 and 25 removed (e.g. confidentiality requirements included only in ICP 3 and removed from ICP 25).
The concepts of a legitimate interest and a valid supervisory purpose explained (guidance to ICP 3.3).
ICP 25 significantly reorganised and shortened; duplications eliminated.
Much of the current ICP 26 (Cross-border cooperation and coordination on crisis management) moved to ICP 25.
ComFrame in ICP 25
Clarity and consistency of language and terminology improved, overlaps with ICP 25 removed.
Having regard to the direct powers over the Head of the IAIG when agreeing who is the group-wide supervisor.
The establishment of the colleges for IAIGs maintained as a requirement (CF25.6a).
The need for ongoing communication and information exchange in the IAIG colleges highlighted (CF25.6b).
New standards and guidance addressing crisis management for IAIGs, which should take place within crisis management groups (CMG) (CF25.7a).
Tom

5. High-level summary of the comments received
ICP 3
Comments are generally supportive of revisions with requests for clarification (eg definitions of “information” and “supervisors and authorities”).
ICP 3 should more clearly apply to all information exchange circumstances.
Concerns about broadness of information that can be shared between regulators or requested from the group.
ICP 25
Information sharing under ICP 25 should be governed by ICP 3.
Inclusion of emergency or crisis management plans in the college coordination agreement should also apply to groups which are not IAIGs. 
More proportionate approach regarding information flows from the involved supervisors to the group supervisor.
Decision-making process: involved supervisors should be consulted and informed, but group supervision decisions should rest with the group-wide supervisor.
ComFrame in ICP 25
The IAIG’s management should be consulted and involved in supervisory coordination and cooperation.
Questions on cost-benefit analysis: Limited participation by stakeholders or members. No cost estimations, and vague assertions of benefit or lack of benefit.