Our Positions | ComFrame
The Common Framework for the Supervision of Internationally Active Insurance Groups, or ComFrame, is a set of international supervisory requirements focusing on groupwide supervision of internationally active insurance groups, which are known as IAIGs. The International Association of Insurance Supervisors intends to apply ComFrame by 2020. To implement the agreement every participating country will need to enact laws and regulations applicable to their IAIGs.
IAIGs are global companies that write insurance business in more than three countries, exceed $50 billion in total assets and have at least 10 percent of their business outside of their home country. These insurance groups are not labeled as systemically important in the U.S., which are referred to SIFIs, or at the global level, where they are referred to as GSIIs. They are simply large companies, active in more than three countries, that have been designated as a group subject to special regulatory attention at the international level. The IAIS is attempting to provide more tailored and coordinated supervision across jurisdictions due to their perceived complexity and international activity. They believe that the IAIGs require a specific framework to assist supervisors in collectively addressing group-wide activities and risks, identifying and avoiding regulatory gaps, and coordinating supervisory activities under the aegis of a group-wide supervisor.
ComFrame will expand the high-level requirements and guidance currently set out in the IAIS Insurance Core Principles, which generally apply on both a legal entity and group-wide level. ComFrame is more specific than the ICPs but is not intended to be a highly prescriptive set of rules. Where existing regulation and supervisory processes limit comparability, ComFrame is intended to foster commonality. ComFrame sets out a comprehensive range of qualitative and quantitative requirements specific to IAIGs, as well as the supervisory processes and prerequisites for supervisors to implement ComFrame. The definition of an Insurance Group and the Insurance Capital Standard are major parts of the ComFrame requirements.
In the U.S., there is no precedent for state regulators treating IAIGs differently, other than a section of the holding company act that has a provision for designating a state regulator as a group-wide supervisor for these large international insurance groups.
NAMIC Position
NAMIC would like to see ComFrame completely stopped, and will oppose any attempt to adopt ComFrame for IAIGs or all holding companies in the U.S., unless the provisions are significantly revised. The association is also opposing specific portions of ComFrame, including the ICS and the resolution and recovery provisions, as these provisions are often released as consultations separate from ComFrame.
