IAFI has published its response to a consultation conducted by the International Association of Insurance Supervisors (IAIS) on its issues paper on operational resilience.

IAFI generally welcomes the IAIS’ intention to promote good practices in operational resilience and agrees with the need for greater convergence in cyber governance and resilience.

Reporting requirements from regional and/or national supervisors could be further aligned. However, it is important to avoid imposing new requirements in jurisdictions where the IAIS’ objectives have already been met, such as in the EU with the Digital Operational Resilience Act.

Digital operational regulations should be principle- and risk-based, as well as proportionate, to be flexible enough to stay in line with technological developments. They should also consider the size, business, and risk profiles of financial entities.

IAFI has published a set of dos and don’ts on the concept of open insurance.

In recent years, several initiatives to open up insurance-related data have been announced or rolled out across the world, while other jurisdictions have yet to consider open insurance. While the insurance industry sees possible opportunities from the concept, there are also risks that need to be carefully considered.

With so many different jurisdictions, approaches also differ. As a consequence, thoughts on this new and developing topic of data sharing vary amongst IAFI’s members. Nevertheless, if the issue of open insurance is to be considered by policymakers, there is agreement on recommended dos and don’ts for them to ponder on a range of issues related to this topic.

They highlight the need to ensure:

• Purpose-driven data-sharing
• Clarity for data owners
• Appropriate open insurance frameworks and scopes that account for the insurance business model
• A level playing field between entities sharing data
• Adequate data security

IAFI has written to the Argentinian insurance supervisor (SSN) to express concerns about the fact that recently implemented rules have begun causing serious issues with the payment of reinsurance premiums to foreign companies.

The issuance of the Joint General Resolution of the Federal Administration of Public Revenues and the Secretary of Commerce No. 5271; and Communication "A" 7622 of the Central Bank of Argentina, has resulted in major restrictions and delays in the payment of reinsurance premiums abroad.

IAFI warned that these restrictions risk seriously affecting the functioning and continuity of the Argentine (re)insurance market and its relationship with the international reinsurance market.

IAFI called on the SSN to, therefore, urgently remove any regulatory barriers to the payment of reinsurance premiums to foreign firms.

IAFI has responded to a consultation by the OECD on its inclusive framework. IAFI focused its responses on the OECD’s request for suggestions for simplified income or tax calculations and for cases where groups should not be required to collect all the data points.

IAFI agreed that incorporating the simplified compliance procedures associated with safe harbors in the development of the Globe Information Return is an efficient and effective manner of administering this new tax regime.

IAFI also agreed that incorporating the safe harbors is consistent with the OECD’s view that requiring the disclosure of significant amounts of financial and tax information, especially in respect of those jurisdictions that do not give rise to a GloBE tax liability, may increase compliance costs.

IAFI also outlined a range of suggested refinements to the framework.

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.

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AFAD (Disaster Management Body)

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KIZILAY (Red Crescent)

The Turkish Red Crescent is the largest humanitarian organisation in Türkiye and is part of the International Red Cross and Red Crescent Movement.

Diversity, equity and inclusion (DEI) are priorities for the global (re)insurance industry, and IAFI and its members are committed to encouraging and promoting them across the sector. With that in mind, IAFI has published a set of principles on DEI.

Various IAFI members are undertaking efforts to support DEI and financial education; to raise insurance penetration to help build developing economies; and to share best practices and resources with interested markets. Their initiatives are developed with specific national features in mind, such as the regulatory frameworks, demographics, legal systems and local consumer needs, which can all differ significantly between jurisdictions.

IAFI welcomes the commitment of the International Association of Insurance Supervisors (IAIS) to continue its work on DEI. IAFI stands ready to engage on this topic with the IAIS and other international organisations and standard-setters, such as the G20. IAFI recognises that, while financial inclusion and access to insurance have been a subject of considerable work by the IAIS and numerous other international organisations, the development of policy on DEI will necessitate broad consideration and consensus, at both national and international levels.

IAFI has responded to a consultation undertaken by the International Association of Insurance Supervisors (IAIS) on policyholder protection schemes (PPS).

IAFI welcomes the opportunity to provide its input and appreciates the work already undertaken by the IAIS on PPS. This consultation is a welcome addition to the IAIS’ previous work on the topic.

In its response, IAFI highlighted four key aspects:

• The importance of having a jurisdiction-specific approach.
• The need for clear roles and responsibilities of supervisors, resolution authorities and PPS.
• The need to have an overall balance of a prudential framework including any PPS.
• The importance of appropriate funding requirements.