The 175-page paper sets out the IAIS's proposed roadmap for determining an "insurance capital standard", or ICS, for "internationally active insurance groups", or IAIGs, and discusses the IAIS's "field testing" of data provided by a pilot group of insurers over 2015-16.
The ICS section contains a detailed discussion of a range of risks faced by IAIGs including:
Then the question arises: How can a standard be "a consolidated group-wide with a globally comparable risk-based measure of capital adequacy for IAIGs and G-SIIs" when insurer groups may be part of a consolidated group that has various and different non-insurer components?
the promotion of sound risk management by IAIGs and G-SIIs.
In identifying a company as an IAIG
, consideration should also be given to a company's market share and its new business activity relative to other insurers in a particular jurisdiction," Swedlove's group, the Canadian Life & Health Insurance Association, has stated in its comments, for example.
The goal is to identify potential or developing material risks in IAIGs, which potentially could have an adverse impact on the IAIG and individual insurers and its policyholders and address those risks though certain supervisory actions.
The intention is that at least those groups which meet the criteria to be an IAIG will be supervised according to ComFrame.
state regulator opposition, in October 2013, the IAIS responded to the July 18, 2013 FSB directive and began development of a quantitative capital standard for IAIGs, generally described as a risk-based global Insurance Capital Standard as part of ComFrame, utilizing the development of Basic (formerly "Backstop") Capital Requirements as a basis for the formulation of Higher Loss Absorbency requirements and the eventual formulation of an Insurance Capital Standard.
members of the FSB that directed the IAIS in July 2013 to implement a "quantitative capital standard" for IAIGs in ComFrame.
Leonardi also said the ComFrame process should not create an unleveled playing field nor have unintended consequences with the IAIGs
versus all other entities.
Leonardi also said the process should not create an unlevel playing field and have unintended consequences with the IAIGs versus all other entities.
insurers joined sovereign nations and other parties weighing in on the supervisory architecture that will have a great deal of impact on the global regulation of anywhere from 50 to 100 IAIGs expected to be identified worldwide.