IAFI has responded to a consultation conducted by the IAIS on its review of the Individual Insurer Monitoring (IIM) assessment methodology.

IAFI raised concerns about further potential increases in the data reporting burden in the next round of data collection, including the expansion of liquidity risk-related data.

In reviewing the IIM methodology, the IAIS should carefully select data that is truly necessary to identify systemic or macroprudential risks. It should also consider using publicly available data to the maximum extent possible, taking into account the overall increase in the burden on insurers.

IAFI also highlighted the following key points:

• Stability and streamlining of data collection is paramount. New data fields and qualitative components have been added every year with little notice before the changes were implemented. Many of the new data fields are not available from the financial statement and must be produced specifically for the IIM.
• The overall principle of IIM data collection should be for it to be required on a best-effort basis and that proportionality should be ensured.
• The need to significantly expand data collection on reinsurance businesses is questionable. The combination of the IIM quantitative template, the IIM qualitative questionnaire, and the reinsurance component of the Sector Wide Monitoring (SWM) provides a lot of information on reinsurance exposures and cross-border reinsurance activities.
• More time should be given to participants to complete the IIM. The timeline should also be provided well in advance, along with the data template and technical specifications.