Public

Application Paper on Supervisory
Colleges

November 2021

PublicApplication Paper on Supervisory Colleges
Adopted by the Executive Committee on 9 November 2021

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About the IAISThe International Association of Insurance Supervisors (IAIS) is a voluntary membershiporganisation of insurance supervisors and regulators from more than 200 jurisdictions. The
mission of the IAIS is to promote effective and globally consistent supervision of the insurance
industry in order to develop and maintain fair, safe and stable insurance markets for the benefit
and protection of policyholders and to contribute to global financial stability.
Established in 1994, the IAIS is the international standard setting body responsible fordeveloping principles, standards and other supporting material for the supervision of theinsurance sector and assisting in their implementation. The IAIS also provides a forum forMembers to share their experiences and understanding of insurance supervision andinsurance markets.
The IAIS coordinates its work with other international financial policymakers and associationsof supervisors or regulators, and assists in shaping financial systems globally. In particular,
the IAIS is a member of the Financial Stability Board (FSB), member of the Standards Advisory
Council of the International Accounting Standards Board (IASB), and partner in the Access to
Insurance Initiative (A2ii). In recognition of its collective expertise, the IAIS also is routinely
called upon by the G20 leaders and other international standard setting bodies for input on
insurance issues as well as on issues related to the regulation and supervision of the global
financial sector.
Application Papers provide supporting material related to specific supervisory material (ICPsor ComFrame). Application Papers could be provided in circumstances where the practicalapplication of principles and standards may vary or where their interpretation andimplementation may pose challenges. Application Papers do not include new requirements,
but provide further advice, illustrations, recommendations or examples of good practice tosupervisors on how supervisory material may be implemented. The proportionality principle
applies also to the content of Application Papers.
International Association of Insurance Supervisors
c/o Bank for International Settlements
CH-4002 Basel
Switzerland
Tel: +41 61 280 8090 Fax: +41 61 280 9151
www.iaisweb.org
This document was prepared by the Insurance Groups Working Group in consultation with
IAIS Members.
This document is available on the IAIS website (www.iaisweb.org).
© International Association of Insurance Supervisors (IAIS), 2021.
All rights reserved. Brief excerpts may be reproduced or translated provided the source isstated.
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Contents
Acronyms .............................................................................................................................. 4
1

Introduction .................................................................................................................... 52

Establishment of supervisory colleges ........................................................................... 5

3

4

5

2.1

Role of the group-wide supervisor in establishing a supervisory college ................. 5

2.2

Approaches to supervisory college structures and membership .............................. 6

Supervisory college procedures and tools ...................................................................... 7
3.1

Coordination agreements ........................................................................................ 7

3.2

Information exchange and confidentiality protection ................................................ 7

3.3

IT Tools................................................................................................................... 9

Functions and activities of a supervisory college ............................................................ 9
4.1

Supervisory college as a forum for ongoing cooperation ......................................... 9

4.2

Supervisory college planning cycle and workplan ................................................... 9

4.3

Supervisory college activities related to the group-wide risk assessment .............. 10

4.4Supervisory cooperation in planning for crisis management.................................. 11

Organisation of supervisory college meetings .............................................................. 12
5.1

Purpose and objective of supervisory college meetings ........................................ 12

5.2

Frequency and form of supervisory college meetings ........................................... 12

5.3

Involvement of group-wide Senior Management in supervisory college meetings . 12

5.4

Follow-up actions .................................................................................................. 13

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Acronyms
CMG

Crisis Management Group

ComFrame

Common Framework for the Supervision of Internationally Active InsuranceGroups

IAIG

Internationally Active Insurance Group

IAIS

International Association of Insurance Supervisors

ICP

Insurance Core Principle

MMoU

Multilateral Memorandum of Understanding

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1

Introduction

1.
This Application Paper describes the processes and practices related to theestablishment and functioning of supervisory colleges for insurance groups with cross-borderactivities, as described in the Insurance Core Principles (ICP) and ComFrame (CF). In
particular, the Application Paper supports observance of ICP 3 (Information Sharing andConfidentiality Requirements) and ICP 25 (Supervisory Cooperation and Coordination).
2.
The objective of this Application Paper is to foster an understanding of the work ofsupervisory colleges and to explain the role and involvement insurers may have in supervisory
colleges. This Application Paper, as a publicly available document, focuses on those aspectsof supervisory college operations that are most relevant from the perspective of the insurance
industry.
3.
The original version of this Application Paper was adopted in October 2014. 1 The
Application Paper has now been revised and updated to reflect subsequent developments of
IAIS supervisory material, including revision of ICPs 3 and 25 and the adoption of ComFrame,
which took place in November 2019.
4.
Coordination arrangements are mechanisms to foster cooperation and coordination
between involved supervisors with regard to the supervision of insurance groups, as well as
to promote a common understanding, communication and information exchange. 2 One formof coordination arrangements is a supervisory college. In practice, a supervisory college often
is the preferred form of coordination arrangements.
5.
Supervisory colleges support the development of a common understanding of risks
within an insurance group and promote a shared agenda for addressing these risks andvulnerabilities by coordinated activities or actions at the insurance legal entity and group level.
6.
IAIS Application Papers should be read in the context of the proportionality principle,
as described in the Introduction to the ICPs: “Supervisors have the flexibility to tailor theirimplementation of supervisory requirements and their application of insurance supervision toachieve the outcomes stipulated in the Principle Statements and Standards.” Where
appropriate, this Paper provides practical examples of the application of the proportionality
principle.
7.
In this Application Paper, all terms have the same meaning as set out in the IAIS
Glossary and the Introduction to the ICPs. 3 Explanations of frequently used terms that are notpart of the IAIS Glossary are provided as necessary.

2

Establishment of supervisory colleges

2.1

Role of the group-wide supervisor in establishing a supervisory college

8.
At the initial stage of establishing group-wide supervision, involved supervisors discussand agree which of them is the group-wide supervisor for a cross-border insurance group. 4
1 That version reflected, among others, the outcome of the IAIS Thematic Self Assessment and Peer Review

Supervisory Cooperation and Information Exchange (January 2012) and the discussions held at the Supervisory
Forum in 2013.
2 ICP 25.4.1.
3 For example, the IAIS Glossary provides for definitions of the following terms: supervisory college, group-wide
supervisor, involved supervisor, IAIS MMoU, home supervisor, host supervisor, insurance legal entity.
4 ICP 25.1.
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The group-wide supervisor facilitates and leads the cooperation and coordination amongst
other involved supervisors and is ultimately responsible for delivering effective and efficientgroup-wide supervision. 5
9.
The group-wide supervisor sets out the coordination arrangements in a written
coordination agreement and puts such arrangements in place. 6 The establishment of thesupervisory college is not obligatory for all insurance groups, but it is obligatory for an
Internationally Active Insurance Group (IAIG). 7 For a cross-border group that is not an IAIG,
the group-wide supervisor and other involved supervisors discuss and agree whether toestablish a supervisory college, and if so, how to structure and operate the supervisory
college. 8 Where it is not determined necessary to establish a supervisory college for a crossborder group that is not an IAIG, this decision should be reassessed periodically, and upon
any significant changes in the group, by the group-wide supervisor together with other involved
supervisors.
10.
As stated in ICP 23.2, the group-wide supervisor, in cooperation and coordination withother involved supervisors, determines the scope of group-wide supervision. 9 As a first step,
the group-wide supervisor, also in cooperation and coordination with other involved
supervisors, identifies all legal entities that are part of the insurance group. 10 Further, thegroup-wide supervisor would also request that the insurance group provide relevant
information to enable the identification of its legal entities.
11.
Once the relevant legal entities have been identified, the group-wide supervisor, incooperation with other involved supervisors, determines whether the group is an IAIG after
considering whether it meets both the international activity and size criteria, as provided in CF
23.0.a. 11 As set out in CF 23.0.b, in limited circumstances the group-wide supervisor has
discretion to determine that a group is not an IAIG even if it meets the criteria or that a groupis an IAIG even if it does not meet the criteria.
2.2

Approaches to supervisory college structures and membership12.
A supervisory college is typically composed of representatives of each of thesupervisors responsible for the day-to-day supervision of the insurance legal entities, including
material or relevant branches, which are part of the group and, as appropriate, any supervisorsof other material non-insurance entities. 12
13.
The group-wide supervisor, in cooperation and coordination with the involved
supervisors, should carefully consider the structure of the supervisory college (for example,
5 ICP 25.0.3.
6 ICP 25.5.

7 CF 25.6.a.
8 ICP 25.6.

9 See also ICP 25.2.2.

10 See ICP 23.1 and supporting guidance. In addition, as stated in ICP 23.2.5, the exclusion or inclusion of entities

within the scope of the group-wide supervision should be regularly re-assessed.

11 As stated in CF 23.0.a.4, although an insurance legal entity that has no parent or subsidiaries is not an insurancegroup, it should be regarded as an IAIG if it operates on a branch basis in foreign jurisdictions and meets thecriteria. The supervisor of this entity, in cooperation with other involved supervisors, would determine whether the
IAIG criteria are met. References to a “group” in this context would include such entities operating through branches
which are identified as IAIGs.
12 ICP 25.6.3. In addition, ICP 25.6.4 states that clear criteria should be established for defining the basis ofmembership in the supervisory college and provides a non-exhaustive list of issues which should be considered inestablishing these criteria.
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inclusive, tiered or regional). 13 The decision on the structure of the supervisory college should
ensure the effective and efficient use of resources to reduce the potential duplication of workand avoid the creation of any unnecessary additional burden on both supervisors and insurers.
14.
A tiered structure of the supervisory college may be chosen for different reasons, suchas to comply with the applicable legislation or to improve the efficiency and effectiveness ofsupervisory college work. Examples of a tiered structure can be a global supervisory college
and regional colleges.
15.
As part of the tiered structure of the supervisory college, some group-wide supervisors
establish core colleges, which include only the supervisory college members responsible forthe supervision of insurance legal entities, including branches, most material for the insurancegroup and/or the local market of that entity.
16.
The broader supervisory college should be informed of the topics and discussions
within the tiers of the supervisory college.
17.
The structure of and membership in the supervisory college should be reviewed on aregular basis to reflect changing circumstances in the insurance group. 14

3Supervisory college procedures and tools

18.
Supervisory colleges use a variety of procedures and tools to facilitate their operations
and enhance supervisory cooperation and coordination. In this regard, coordinationagreements are used to establish a framework for supervisory college operations as well as
the procedures for information exchange, confidentiality protection and use of IT tools that
support the good functioning of supervisory colleges.
3.1

Coordination agreements

19.
The purpose of a supervisory college coordination agreement 15 is to establish an
operational framework for the supervisory college. The coordination agreement is not legallybinding and does not create enforceable obligations from one supervisor to another. However,jurisdictions may be subject to an obligation to establish such an agreement. 16
20.
Involved supervisors remain subject to their jurisdictional legal and regulatory
frameworks and their requirements for entering into coordination agreements. Even though
coordination agreements are not legally binding, they confirm the commitment of thesupervisory college members to cooperation within the supervisory college.
3.2

Information exchange and confidentiality protection

21.
Information exchange is an important aspect of supervisory cooperation andcoordination within supervisory colleges. The group-wide supervisor should be responsible forcoordination of information sharing procedures amongst the other involved supervisors as well

13 ICP 25.6.2.
14 ICP 25.6.5.

15 In practice, different terms may be used by supervisors to describe such a document, for example: college
agreement, memorandum of understanding. The content of a document should be decisive in determining whether
it should be considered as “a coordination agreement” as described above.
16 ICP 25.6.6.

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as the aggregation of group-wide information and dissemination of the relevant information toother involved supervisors. 17
22.
The supervisor obtains information from, and shares information with, supervisory
college members subject to confidentiality, purpose and use requirements. 18 In this regard,
the supervisor shares information, including non-public information, with relevant supervisors
and authorities at its sole discretion and subject to appropriate safeguards. 19 Informationexchange under confidentiality requirements, including conditions of professional secrecy 20,
is a vital precondition for successful cooperation within supervisory colleges.
23.
Information exchange amongst supervisory college members is subject to the legal
requirements of each jurisdiction. The individual jurisdictional requirements of supervisory
college members should be assessed to ensure they are able to exchange and protect
confidential information for supervisory college purposes. The process includes anassessment of the present jurisdictional regime and practices and its observance of relevantinternational standards. 21 The supervisory college may conduct this assessment in two ways:•

Rely on the assessment performed by the IAIS on the robustness of a jurisdiction’s
confidentiality regime as a part of the validation process to become a signatory to the
IAIS Multilateral Memorandum of Understanding (MMoU); or•Supervisors that have not yet undergone this procedure should be subject to a caseby-case assessment performed by the supervisory college members before
participating in supervisory college activities.

24.
All signatories to the IAIS MMoU undergo a validation of their laws and regulations todemonstrate compliance with the MMoU’s strict confidentiality regime based on theconfidentiality requirements in ICP 3. For this reason, if all relevant parties are signatories tothe IAIS MMoU, it is the preferred framework for multilateral information exchange. 22 However,a supervisory college may include both IAIS MMoU signatories and non-signatories. Membersof a supervisory college who are not signatories to the IAIS MMoU should enter into a similar
long-term agreement covering information exchange and confidentiality, which could be
included in the college coordination agreement. 23
25.
The circumstances of supervisory college members may change during the course of
their collaboration, which may alter the original assessment of the ability to exchange
information under conditions of professional secrecy with other supervisory college
members. 24 When circumstances change, the supervisory college member should inform the
17 ICP 25.2.2. See also ICP 25.2.5, which states that group-wide supervisor should make relevant information
available to the other involved supervisors on a proactive basis and in a timely manner.
18 See the Principle Statement of ICP 3. See also ICP 2.7.
19 ICP 3.2.
20 The obligation of professional secrecy means that – as a basic rule – all confidential information received may
not be divulged to any person or authority. A jurisdiction’s professional secrecy requirements should apply to any
person currently or previously employed by or acting on behalf of a regulatory authority.
21 For all supervisory colleges, ICPs 3 and 25 are applicable. ComFrame material in ICP 25 also applies tosupervisory colleges of IAIGs. The requirements laid down in the IAIS MMoU apply to the supervisory college
members who are signatories to the IAIS MMoU. Annex B of the IAIS MMoU sets out the requirements for the strict
confidentiality regime.
22 ICP 3.2.2.
23 ICP 25.6.8.
24 The examples include changes in law or in supervisory practices in particular jurisdiction, which may decrease
the level of protection of information received from other supervisors and thus may affect the original assessment
in a negative way.

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group-wide supervisor. The group-wide supervisor should, in turn, inform other members of
the supervisory college. A subsequent assessment may need to be conducted to ensure
continuity of the information exchange amongst supervisory college members.
26.
Depending on the terms of the coordination agreement, if an assessment of therelevant jurisdictional requirements of the other involved supervisor is not successful, thatsupervisor would not be admitted as a supervisory college member. Such a supervisor may
still be included, to a certain extent, in supervisory college work. As a default option, the groupwide supervisor and other supervisory college members may share publicly available
information with the said supervisor. In turn, this supervisor may share information withsupervisory college members, including the group-wide supervisor.
3.3

IT Tools

27.
The group-wide supervisor should give careful attention to confidentiality
requirements when choosing or developing the IT tools that support the work and functioningof the supervisory college. In particular, password-protected websites, secure e-mailexchange and IT platforms are commonly used within supervisory colleges. The group-wide
supervisor may also want to consider how to leverage IT tools to facilitate in-person, virtual aswell as hybrid meetings.

4

Functions and activities of a supervisory college

28.
Supervisory colleges facilitate cooperation between the group-wide supervisor andother involved supervisors and provide important functions and activities as part of the groupwide supervisory process.
4.1

Supervisory college as a forum for ongoing cooperation

29.
This Application Paper consistently speaks of supervisory colleges as a permanent
platform for supervisory cooperation and coordination. In this context, the term “supervisory
college” needs to be distinguished from “supervisory college meetings”, which refers tosituations where the involved supervisors convene in-person or virtually.
30.
Supervisory college members may exchange information and coordinate theirsupervisory activities, including the application of supervisory measures. Supervisorydecisions remain the responsibility of each of the involved supervisors and remain subject tojurisdictional legislation.
4.2

Supervisory college planning cycle and workplan

31.
In the same way that supervisors set up planning cycles for supervisory activities, thegroup-wide supervisor typically establishes a planning cycle for activities to be carried out by
the supervisory college. This process usually begins with the draft of a workplan and ends withan evaluation of the supervisory college activities. During the cycle, a number of activities
revolve around planning, conducting and follow-up of supervisory college meetings, ad hoc or
regular information exchange and other supervisory college activities.
32.
Key elements of the supervisory college planning cycle are displayed below, some ofwhich may involve the supervised group. Additional elements may be added, either as plannedor ad hoc activities.
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Figure 1. Key elements of the supervisory college planning cycle

Annual workplan

Feedback toevaluate college
activities

Other scheduled
and ad hoc
College activities

Regular dialogue
and informationexchange

College meetings(in-person or
virtual),preparation andfollow up

33.
Supervisory college workplans are living documents and are regularly updated toreflect changes to a supervised group. Workplans should also reflect the nature andcircumstances of the group; for example, the workplan for a less complex group with nosignificant supervisory concerns may be simpler when compared to a workplan for a more
complex group or one with ongoing supervisory concerns. The group-wide supervisor
establishes the workplan for the following year and includes input from supervisory college
members. The workplan is usually discussed in a college meeting and typically includes
college activities such as meetings, joint on-site inspections, specific key areas or focus topics
that the supervisory college would like to review and the coordination activities of crisis
management preparations. Workplans detail the activities to be conducted and the
responsible college member(s), including the target date for completion.
4.3

Supervisory college activities related to the group-wide risk assessment

34.
Information exchanges and discussions within supervisory colleges commonly cover
key risk areas and concerns applicable in each jurisdiction that is represented in the
supervisory college. As stated in ComFrame, the group-wide supervisor should use
information gathered on legal entities within the IAIG from other involved supervisors as oneof the bases for the assessment of group-wide risk. 25
35.
Risk assessments are conducted at the insurance legal entity and group-wide level ona regular basis and are usually a main focus of the supervisory college. Such risk assessments
can help the group-wide supervisor and other supervisory college members enhance theirunderstanding of the group as well as identify and coordinate appropriate supervisory actions
and activities, if necessary. 26 As stated in ComFrame, where other involved supervisors

25 CF 9.2.a.3.

26 In some cases, supervisory colleges also consider the risk assessments of branches, for example if the branch

is material for the group or the local market.

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identify risks that may be relevant to the supervision of the IAIG at the group level, they shouldshare their individual risk assessment with the group-wide supervisor. 27
36.
A broad range of quantitative and qualitative data is used for risk assessments. In thisrespect, the group-wide supervisor and other members of a supervisory college may agree on
selected data, such as a list of ratios, to be exchanged within the supervisory college on aregular basis.
37.
Discussing issues and exchanging information related to the group-wide risk
assessment in a supervisory college aims to establish a common understanding among thesupervisory college members of the risks to which the group and its legal entities are exposed.
Different views and perspectives enrich the discussion within the supervisory college.
Therefore, members of the supervisory colleges should be given an opportunity to reach aconsensus view. The group-wide risk assessment is an ongoing process and the assessment
should be updated to reflect the exchange of information within the supervisory college.
38.
As regards the group-wide supervision of IAIGs, the group-wide supervisor
communicates the results of the group-wide supervisory review, including the group-wide risk
assessment, to the supervisory college and, as appropriate, to the Head of the IAIG. 28
39.
The results of the group-wide supervisory review and the risk assessment may bepresented to representatives of the head of the group in an appropriate way. Most relevant
aspects might also be discussed with members of the group-wide Senior Management during
the supervisory college meeting. 29
4.4

Supervisory cooperation in planning for crisis management40.
The responsibilities of the group-wide supervisor include coordinating crisis
management preparations with other involved supervisors and relevant authorities. 30 In thisregard, ICP 25 also recognises the role of a supervisory college, which should plan in advancethe process for cooperation and coordination during crisis situations in order to benefit fromwell-established information and cooperation channels and procedures should a crisis occur. 31
41.
ComFrame requires the establishment of an IAIG Crisis Management Group (CMG)
with the objective of enhancing preparedness for, and facilitating the recovery and resolutionof, the IAIG. 32
42.
Authorities may also decide to extend these cooperation platforms to other insurers
with cross-border operations that are not classified as IAIGs. Alternatively, where the setup ofsuch a body is not deemed necessary, another type of arrangement could be considered, suchas the IAIS MMoU or the supervisory college. The supervisory college may qualify as an IAIG
CMG if the supervisory college’s coordination arrangements address recovery and resolution;and membership includes those authorities which would otherwise be members of the IAIG
CMG. 33

27 CF 9.2.a.3.
28 CF 9.7.a.

29 For more about involvement of group-wide Senior Management in supervisory college meetings, see Section 5.3.
30 ICP 25.7.

31 ICP 25.7.8.

32 CF 25.7.a. More details about the functioning of IAIG CMGs can be found in the Application Paper on Resolution

Powers and Planning.
33 CF 25.7.a.3.

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5

Organisation of supervisory college meetings

43.
Supervisory college meetings should be well organised to support the effectiveness ofthe supervisory college, including identifying the agenda in advance of and the need for any
actions following a meeting. The frequency of meetings and the role of the group itself in a
meeting should also be identified in advance.
5.1

Purpose and objective of supervisory college meetings

44.
The purpose and objective of a supervisory college meeting should be defined by thegroup-wide supervisor and communicated to the supervisory college members prior to themeeting.
5.2

Frequency and form of supervisory college meetings

45.
In practice, most supervisory colleges meet at least annually either in-person or
virtually. In the case of supervisory colleges for IAIGs, ComFrame states that those
supervisory colleges should meet at least annually. Supervisory college meetings arecommonly in-person, however, when an in-person meeting is not practical, meetings shouldtake place by virtual means. 34
46.
Supervisory colleges of bigger or more complex groups tend to meet more frequently.
For example, some supervisory colleges meet twice per year: once in-person and once
virtually. In addition to regular meetings, ad hoc (in-person or virtual) meetings of thesupervisory college may be required to facilitate information exchange in the case of eventsor changes that are material to the group.
5.3

Involvement of group-wide Senior Management in supervisory college meetings

47.
A supervisory college provides a forum for involved supervisors to interact with theinsurer’s group-wide Senior Management. 35 In this respect, group-wide Senior Management
may be invited to participate in part of the supervisory college meeting to present and provide
their views on relevant developments and receive feedback from supervisory college
members. Depending on the scope of the issues being discussed, other staff from the group
may attend the supervisory college meeting as well.
48.
The group-wide supervisor is responsible for deciding whether to invite group-wide
Senior Management and for coordinating their involvement in the supervisory college meeting.
The group-wide supervisor should also be the point of contact for group-wide Senior
Management.
49.
When asking group-wide Senior Management to attend a supervisory college meeting,the group-wide supervisor is expected to communicate the objective and scope of issues tobe covered in a clear and transparent manner. For example, group-wide Senior Management
can be asked to provide a presentation on the group’s situation and specific developments
within the group. The presentation and the discussion between group-wide Senior
Management and the supervisory college members may also focus on certain specific issues.
50.
The discussion between the supervisory college members and group-wide Senior
Management provides each of them with an opportunity to better understand the situation of
the insurance group and relevant developments, to share their respective points of view, and
34 See ICP 25.6.7 as well as CF 25.6.a and supporting guidance CF 25.6.a.3.
35 ICP 25.6.10.

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to better understand each other’s concerns. These discussions allow group-wide Senior
Management to provide explanations directly and efficiently to all relevant supervisors. Thisshould enable supervisory college members to have more informed discussions, for example
on the group-wide risk assessment. For this reason, sufficient time should be allocated forquestions from supervisory college members to group-wide Senior Management and for
discussion on the views of the group.
51.
The discussion with group-wide Senior Management also provides supervisory college
members with an opportunity to discuss identified issues at the level of the insurance legal
entity that affects the whole group. 36 Such discussions are mutually beneficial as they allow
supervisory college members to hear the view of group-wide Senior Management on theissues identified and to obtain relevant explanations. They also allow group-wide Senior
Management to better understand the issue identified and the concerns of supervisory college
members.
5.4

Follow-up actions

52.
A supervisory college meeting will typically conclude with clear output regarding thefollowing issues:•

Key observations and conclusions on topics discussed during the meeting;•Main outcome of the discussions of the supervisory college on the group-wide risk
assessment; and•Follow-up actions, including coordination of supervisory activities and joint supervisory
actions.

53.
After the supervisory college meeting, the group-wide supervisor may provide theinsurance group with verbal or written feedback (eg in the form of a letter), aimed at enabling
the group to better understand and appreciate the activities of the supervisory college that
result from the supervisory college workplan. This feedback aims to improve the overall
communication and exchange of information between the group and the supervisory college
and deepen their constructive cooperation. The feedback can cover issues such as:•

Relevant outcome of supervisory college discussions, including potential concerns of
the supervisory college;•

Potential improvements within the group; and•The group’s contributions to the supervisory college meeting as well as interaction
between the group’s representatives and the supervisory college during the meeting.

36 See ICP 25.6.10.

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