REPORT TO CONGRESS 

Engagement in Global Insurance 

Regulatory or Supervisory Forums 

in 2021 

December 2022 

Jerome H. Powell Janet Yellen 

Chair, Secretary, 

Board of Governors of the U.S. Department of 

Federal Reserve System the Treasury 
ii 

Contents 

Introduction ...................................................................................................................... 1 

International Insurance Issues, Positions, and Effects ............................................. 4 

International Forums: the IAIS, the FSB, and the OECD ......................................................... 4 

IAIS Activities .................................................................................................................... 8 

FSB Cross-Border Resolution ............................................................................................ 15 

Transparency Efforts at the IAIS and the FSB .......................................................... 16 

IAIS Transparency Efforts .................................................................................................. 16 

FSB Transparency Efforts .................................................................................................. 18 

Federal Advisory Committee on Insurance .......................................................................... 19 

Insurance Policy Advisory Committee ................................................................................. 19 

Conclusion ...................................................................................................................... 21 
1 

Introduction 

This report is submitted by the Secretary of the U.S. Department of the Treasury (Treasury) and 

the Chair of the Board of Governors of the Federal Reserve System (Federal Reserve) pursuant to 

section 211(c)(1) of the Economic Growth, Regulatory Relief, and Consumer Protection Act, Pub. L. 

No. 115-174, 132 Stat. 1296, 1317–18 (the Act). The Act directs the Secretary of the Treasury 

and the Chair of the Federal Reserve, or their designee, to submit an annual report to Congress on 

their efforts with the National Association of Insurance Commissioners (NAIC) “with respect to 

global insurance regulatory or supervisory forums.” The Act requires the report to include 

descriptions of 

1. “the insurance regulatory or supervisory standard-setting issues under discussion at international standard-setting bodies”;

2. “the effects that proposals discussed at international insurance regulatory or supervisory

forums of insurance could have on consumer and insurance markets in the United States”;

3. “any position taken by the Secretary of the Treasury, the [Federal Reserve], and the Director of

the Federal Insurance Office in international insurance discussions”;1 and

4. “the efforts by the Secretary of the Treasury, the [Federal Reserve], and the Director of the Federal Insurance Office to increase transparency at the Financial Stability Board with respect to

insurance proposals and the International Association of Insurance Supervisors, including

efforts to provide additional public access to working groups and committees of the International Association of Insurance Supervisors.”

This fourth annual report follows the same format as prior reports.2 This report covers activities 

and developments during calendar year 2021. Specifically, the report begins, in the section 

1 Title V of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) established the Federal 

Insurance Office (FIO) within Treasury. In addition to advising the Secretary of the Treasury (Secretary) on major domestic 

and prudential international insurance policy issues, FIO is authorized to monitor all aspects of the insurance industry, 

including identifying issues or gaps in the regulation of insurers that could contribute to a systemic crisis in the insurance industry or the U.S. financial system, and coordinate federal efforts and develop federal policy on prudential 

aspects of international insurance matters, including representing the United States, as appropriate, in the International 

Association of Insurance Supervisors and assisting the Secretary in negotiating covered agreements, among other functions. See 31 U.S.C. § 313. 2 Treasury and Federal Reserve, Engagement in Global Insurance Regulatory or Supervisory Forums in 2020 (2022) (2020 

Fed-FIO Annual Report) (Washington: U.S. Department of the Treasury and Board of Governors of the Federal Reserve 

System, February 2022), https://www.federalreserve.gov/publications/files/global-insurance-forums-20220201.pdf; 

Treasury and Federal Reserve, Report to Congress: Efforts of the U.S. Department of the Treasury and the Board of Governors of the Federal Reserve System with respect to Global Insurance Regulatory or Supervisory Forums in 2019 (2020) 

(2019 Fed-FIO Annual Report) (Washington: U.S. Department of the Treasury and Board of Governors of the Federal 

Reserve System, December 2020), https://home.treasury.gov/system/files/311/Treasury-FRB-Report-2020.pdf; 

Treasury and Federal Reserve, Report to Congress: Efforts of the U.S. Department of the Treasury and the Board of Governors of the Federal Reserve System with respect to Global Insurance Regulatory or Supervisory Forums in 2018 (2019) 

(2018 Fed-FIO Annual Report) (Washington: U.S. Department of the Treasury and Board of Governors of the Federal 

Reserve System, September 2019), https://www.federalreserve.gov/publications/files/Report-on-global-insuranceregulatory-or-supervisory-forums2019.pdf. 
2 Engagement in Global Insurance Regulatory or Supervisory Forums in 2021 

“International Insurance Issues, Positions, and Effects,” by describing in general terms the efforts 

of the Federal Reserve and Treasury (specifically, the Federal Insurance Office or FIO) in global 

insurance regulatory and supervisory forums, including a short overview of the International Association of Insurance Supervisors (IAIS), the international insurance standard-setting body. It 

explains the IAIS’s structure, governance, and role in insurance supervision. This section also 

includes an overview of the Financial Stability Board (FSB), which coordinates among the different 

standard-setting bodies, and the Organisation for Economic Co-Operation and Development 

(OECD), which has a limited role in international insurance discussions.3

In the subsection “IAIS Activities,” the report outlines key international insurance standard-setting 

initiatives in 2021, such as monitoring and responding to COVID-19’s impacts on the insurance 

industry; activities related to climate risk; the work on the Insurance Capital Standard (ICS), implementation of the Holistic Framework for Systemic Risk in the Insurance Sector (Holistic Framework); activities related to Diversity, Equity, and Inclusion; and other initiatives. 

The report continues, in the section “Transparency Efforts at the IAIS and the FSB,” by providing a 

summary of ongoing efforts by FIO and the Federal Reserve to increase transparency at the FSB 

and at the IAIS as well as coordination with the NAIC and the U.S. state and territory insurance 

regulators (together with FIO and the Federal Reserve, collectively referred to as Team USA).4 This 

section also provides an update on the Insurance Policy Advisory Committee (IPAC), which was 

established by the Act to advise the Federal Reserve on insurance issues.5 Additionally, it provides 

an update on the Federal Advisory Committee on Insurance (FACI), which provides non-binding 

advice and recommendations to FIO to assist it in carrying out its duties and authorities.6

The “Conclusion” of the report emphasizes that FIO and the Federal Reserve will continue to advocate for insurance regulatory and supervisory standards that are appropriate for the United States 

and will continue to report to Congress on their efforts. Team USA members’ leadership and 

involvement in the IAIS and other international forums, as discussed in this report, are intended to 

ensure that the United States continues to be able to influence international standards for insurance supervision and regulation. It remains important to recognize, however, that international 

standard-setting bodies, such as the IAIS, do not have the power to establish standards that would 

be binding in the United States. In the United States, no international insurance standards are 

3 Other standard-setting bodies include the Basel Committee on Banking Supervision, which is the primary standardsetting body for the prudential regulation of banks, and the International Organization of Securities Commissions, which 

is the primary standard-setting body for the securities sector. 4 See, e.g., 2018 Fed-FIO Annual Report; Treasury and Federal Reserve, Report to the Congress: Efforts to Increase Transparency at Meetings of the International Association of Insurance Supervisors (2018) (Transparency Report) (Washington: 

U.S. Department of the Treasury and Board of Governors, November 2018), https://home.treasury.gov/system/files/ 

311/Treasury_FRB_Report_2019.pdf. 5 See Act § 211(b) (establishing the Insurance Policy Advisory Committee), 31 U.S.C. § 313 note. 6 The FACI was formed in 2011 pursuant to 31 U.S.C. § 313(h). 
Introduction 3 

operational unless implemented through the relevant state or federal legislative or administrative 

process, as appropriate. 

This report discusses topics that are also discussed in the 2018 Transparency Report as well as in 

FIO’s 2020 and 2021 annual reports.7 These annual reports include detailed descriptions of FIO’s 

international and domestic activities in 2020 and in the first half of 2021. FIO’s annual reports also 

discuss international activities outside of the global insurance regulatory and supervisory forums 

addressed here; these activities include bilateral and/or multilateral discussions and agreements 

(such as those that led to the covered agreement with the European Union and the covered agreement with the United Kingdom) as well as information exchanges that do not involve setting standards (such as the EU–U.S. Insurance Project). In addition, FIO’s annual reports discuss input 

received from the FACI, including through its subcommittee on international developments.8 

7 FIO, Annual Report on the Insurance Industry (2020) (2020 Annual Report) (Washington: FIO 2020), https:// 

home.treasury.gov/system/files/311/2020-FIO-Annual-Report.pdf; FIO, 2021 Annual Report on the Insurance Industry 

(2021) (2021 Annual Report) (Washington: FIO, September 2021), https://home.treasury.gov/system/files/311/FIO2021-Annual-Report-Insurance-Industry.pdf. 8 “Federal Advisory Committee on Insurance (FACI),” U.S. Department of the Treasury, https://www.treasury.gov/ 

initiatives/fio/Pages/faci.aspx. 
4 

International Insurance Issues, Positions, 

and Effects 

The Act requires that this report include, among other things, a “description of the insurance regulatory or supervisory standard-setting issues under discussion at international standard setting 

bodies,” and a “description of any position taken” by the Secretary, the Federal Reserve, and the 

director of FIO in international insurance discussions at global insurance regulatory or supervisory 

forums.9 As previously reported, in discussions at global insurance regulatory and supervisory 

forums, FIO and the Federal Reserve promote robust engagement to ensure that U.S. insurance 

stakeholders and the federal government are well represented.10 The Federal Reserve and FIO 

continue to advocate for positions in international insurance discussions to help ensure that international standards reflect the U.S. insurance regulatory regime, and that the U.S. insurance sector 

remains competitive internationally. 

The Act also requires that this report describe the effects that proposals discussed at international insurance regulatory or supervisory forums of insurance could have on U.S. consumers and 

insurance markets.11 While certain IAIS standards remain under development, depending on how 

they are finalized, they could affect U.S. insurers operating in foreign markets, regardless of 

whether the standards are implemented in the United States. Treasury and the Federal Reserve 

acknowledge that they are required, in consultation with the NAIC, to “complete a study on, and 

submit to Congress a report on the results of the study, the impact on consumers and markets in 

the United States before supporting or consenting to the adoption of any final international insurance capital standard.”12 In their international engagement on insurance issues, FIO and the Federal Reserve continue to coordinate closely with each other and with the other U.S. members of 

the IAIS. 

International Forums: the IAIS, the FSB, and the OECD 

IAIS Overview 

Established in 1994, the IAIS is the international standard-setting body responsible for developing 

and assisting in the implementation of principles, standards, and other supporting material for 

9 See Act § 211(c)(1)(A)(i), (iii), 31 U.S.C. § 313 note. 10 See, e.g., 2018 Fed-FIO Annual Report. 11 See Act § 211(c)(1)(A)(ii), 31 U.S.C. § 313 note. 12 Act § 211(c)(3)(A), 31 U.S.C. § 313 note. 
International Insurance Issues, Positions, and Effects 5 

supervision of the insurance sector.13 The IAIS also serves as a forum for members to exchange 

ideas and share experiences about insurance supervision and insurance markets. IAIS members 

include insurance supervisors and regulators from more than 200 jurisdictions, accounting for 

97 percent of worldwide insurance premium volume. 14 

The IAIS has stated that it is “a stand[ard]-setter, not a legislature. Members do not pass laws; 

through agreement, they recommend principles and standards and provide supervisory guidance. 

It is the prerogative of the appropriate sovereign authorities to implement or not implement IAIS 

core principles, standards or policies.” 15 

The IAIS operates through five key mechanisms: (1) the General Meeting, which ultimately oversees all matters before the IAIS; (2) the Executive Committee, which serves as the principal decisionmaking body of the IAIS; (3) the Policy Development Committee, which is responsible for 

standard-setting activities; (4) the Macroprudential Committee, which oversees the IAIS work on 

financial stability issues; and (5) the Implementation and Assessment Committee, which is 

responsible for assessments and assistance in implementing IAIS principles, standards, and guidance.16 Outside of its standard-setting and policymaking activities, the IAIS has an Audit and Risk 

Committee that monitors and evaluates its risk exposures and a Budget Committee that oversees 

its financial condition and management. 17 

Multiple working groups and task forces, focused on a range of prudential regulation and market 

supervision topics, report to these committees.18 All of the committees and subcommittees (“subcommittees” includes both IAIS working groups and IAIS task forces) are composed of and chaired 

by IAIS members. Hosted by the Bank for International Settlements in Basel, Switzerland, the IAIS 

operates with the support of a secretariat under the direction of a secretary general. Figure 1 illustrates the IAIS organizational structure in 2021. FIO, the Federal Reserve, and the states are represented on the IAIS Executive Committee. 

In line with its 2020-24 Strategic Plan and Financial Outlook, the IAIS has increased its focus on 

assessing the implementation of standards and applying best practices as well as increasing its 

13 See, e.g., IAIS, 2020 IAIS Annual Report (Basel: IAIS, November 2021), 8, https://www.iaisweb.org/uploads/2022/01/ 

211115-IAIS-AR-2020-Digital-PDF-Def.pdf. 14 2020 IAIS Annual Report, 8. See also IAIS, IAIS Organisation Members (February 23, 2022), https://www.iaisweb.org/ 

uploads/2022/02/List-of-IAIS-Members.pdf. 15 IAIS, 2017 IAIS Annual Report (Basel: IAIS, November 2018), 10, https://www.iaisweb.org/uploads/2022/01/181113-

IAIS-AR-2017-Digital-PDF-Def-SP.pdf. 16 See, e.g., IAIS, “IAIS By-Laws,” https://www.iaisweb.org/uploads/2022/01/181207-2018-By-Law-Amendments-8-

November-2018.pdf; IAIS, “IAIS Organisational Structure,” https://www.iaisweb.org/about-the-iais/organisationalstructure. 17 2020 IAIS Annual Report (Basel: IAIS, November 2021),https://www.iaisweb.org/uploads/2022/01/211115-IAIS-AR2020-Digital-PDF-Def.pdf. 18 The structure and operation of the IAIS, as well as FIO’s role at the IAIS, are discussed in FIO’s 2020 Annual Report, 

74-78. See also IAIS 2020 Annual Report, 44, https://www.iaisweb.org/publications/annual-reports. 
FinTech

Forum

Retirement 

Income & 

Pension Forum

Signatories 

Working Group

Financial 

Inclusion

Forum

Supervisory 

Forum

Standards 

Assessment 

Working Group

Holistic 

Framework

Targeted 

Jurisdictional 

Assessments

Accounting & 

Auditing

Working Group

Insurance 

Groups

Working Group

Governance 

Working Group

Financial

Crime

Task Force

Capital,

Solvency & 

Field Testing 

Working Group

Market

Conduct 

Working Group

Resolution 

Working Group 

Infrastructure 

Task Force

Executive

Committee

Policy 

Development 

Committee

Implementation 

& Assessment 

Committee

Coordination 

Group

Audit & Risk 

Committee

Insurance

Capital

Standard & 

Comparability 

Task Force

Macroprudential

Committee

Operational 

Resilience 

Task Force

Committees

Working Groups

Task Forces

Forums

Expert Teams

Macroprudential

Supervision 

Working Group

Macroprudential 

Monitoring 

Working Group

6 Engagement in Global Insurance Regulatory or Supervisory Forums in 2021 

Figure 1. IAIS organizational structure, 2021 

Note: The IAIS committee structure illustrated above captures only those IAIS committees and working groups that are 

directly involved in policymaking, macroprudential monitoring, and assessment of the implementation of standards. 

Source: FIO. See also IAIS 2020 Annual Report, https://www.iaisweb.org/uploads/2022/01/211115-IAIS-AR-2020-

Digital-PDF-Def.pdf, 44. 

efforts to help its members understand the challenges posed by climate risk, cyber risk, technological innovation, inclusiveness, and sustainable development. 19 

FSB Overview 

The G-20 established the FSB in 2009 to promote international financial regulatory reform and 

financial stability, and tasked it with coordinating the work of national financial authorities and 

international standard-setting bodies, including the IAIS, “as they work toward developing strong 

regulatory, supervisory and other financial sector policies.”20 The FSB’s decisions are not legally 

binding on its members; the FSB “operates by moral suasion and peer pressure, in order to set 

19 IAIS, The IAIS Strategic Plan 2020-2024 (June 2019), https://iaisweb.org/uploads/2022/01/190613-2020-2024-

Strategic-Plan.pdf. 20 2018 Fed-FIO Annual Report. See also Treasury, Insurance EO Report, 57–59, 130; FSB, “History of the FSB,” https:// 

www.fsb.org/history-of-the-fsb/; FSB, “About the FSB,” https://www.fsb.org/about/. 
International Insurance Issues, Positions, and Effects 7 

internationally agreed policies and minimum standards that its members commit to implementing” 

in their jurisdictions through the relevant financial authorities.21 

The FSB’s current membership consists of 71 institutions from 24 jurisdictions and 13 international organizations and standard-setting bodies, including the IAIS.22 Treasury, the Federal 

Reserve, and the Securities and Exchange Commission are the FSB’s U.S. members.23 Randal K. 

Quarles’ term as the FSB Chair ended at the beginning of December 2021. 

The FSB has created a compendium of standards that have been developed by various standardsetting bodies, including the IAIS. The compendium includes standards considered by the FSB to 

be “key for sound financial systems and deserving of priority implementation depending on 

country circumstances.”24 The compendium includes standards that pertain to insurance, 

including the Insurance Core Principles, Standards, Guidance, and Assessment Methodology; the 

Key Attributes of Effective Resolution Regimes for Financial Institutions (discussed later in the 

“FSB Cross-Border Resolution” section); and the G-20/OECD Principles of Corporate Governance.25 

OECD Overview 

The OECD operates through more than 300 committees, experts, and working groups, supported 

by a secretariat.26 Within this structure, insurance matters are addressed by the OECD Insurance 

and Private Pensions Committee (IPPC). In addition, the Working Party on Private Pensions (WPPP) 

engages on certain issues closely related to insurance. The U.S. delegation to the OECD varies by 

committee. For the IPPC and WPPP, delegates from FIO and the U.S. Departments of Commerce 

and Labor, along with state insurance regulators, represent the views of the United States. 

The OECD develops legal instruments to express policies that its membership has developed. Typically, these instruments are non-legally binding recommendations and declarations. As of 

December 31, 2021, the IPPC has helped develop 22 of these legal instruments since 1961, 

eight of which were in force as non-legally binding recommendations.27 Table 1 shows the in-force 

recommendations developed and adopted by the IPPC as of December 31, 2021. 

21 FSB, “About the FSB,” https://www.fsb.org/about/. 22 FSB, “Members of the FSB,” https://www.fsb.org/about/organisation-and-governance/members-of-the-financial-stabilityboard/. 23 FSB, Annual Report April 2020–31 March 2021 (Basel: FSB, August 2021), 19, https://www.fsb.org/wp-content/ 

uploads/P300821.pdf. 24 FSB, “The Compendium of Standards,” http://www.fsb.org/work-of-the-fsb/about-the-compendium-of-standards/. 25 FSB, “Key Standards for Sound Financial Systems,” https://www.fsb.org/work-of-the-fsb/about-the-compendium-ofstandards/key_standards/. 26 OECD, “Organisational Structure,” https://www.oecd.org/about/structure/. 27 OECD, “OECD Legal Instruments involving the Insurance and Private Pensions Committee,” https:// 

legalinstruments.oecd.org/en/instruments?mode=advanced&committeeIds=1651&dateType=adoption. 
8 Engagement in Global Insurance Regulatory or Supervisory Forums in 2021 

Table 1. OECD in-force insurance-related recommendations from the IPPC as of December 31, 2021 

Recommendations Date adopted 

Financial Literacy Oct. 29, 2020 

Disaster Risk Financing Strategies Feb. 23, 2017 

Core Principles of Private Pension Regulation Sep. 27, 2016 

Policy Framework for Effective and Efficient Financial Regulation Nov. 26, 2009 

Guidelines on Insurer Governance Apr. 28, 2005 

Establishment of a Check-List of Criteria to define Terrorism for the Purpose of Compensation Dec. 9, 2004 

Good Practices for Insurance Claim Management Nov. 24, 2004 

Common Classification of the Classes of Insurance Recognised by the Supervisory Authorities of the Member Countries May 30, 1984 

Source: OECD, “OECD Legal Instruments,” https://legalinstruments.oecd.org/en/instruments?mode=advanced&committeeIds= 

1651&dateType=adoption. 

In 2021, the IPPC contributed to several OECD publications, including Global Insurance Market 

Trends 2020, Public and Private Sector Relationships in Long-term Care and Healthcare Insurance, 

Insurance Markets in Figures, and Enhancing Financial Protection Against Catastrophe Risks.

28 It 

also updated its prior analysis on policy responses to the COVID-19 pandemic and the pandemic 

protection gap in insurance.29 

Over the next few years, the IPPC is expected to continue to address issues relating to, among 

other things, digitalization and innovation, long-term care insurance, and catastrophe risk insurance programs. Many of these issues relate to significant U.S. policy initiatives being led by 

Treasury and therefore, as FIO noted in its 2021 Annual Report, it plans to continue to take a leadership role on insurance matters at the OECD.30 

IAIS Activities 

The key issues under discussion at the IAIS include issues related to (1) climate risk; (2) the ICS; 

(3) the Holistic Framework and macroprudential work; (4) assessment work; (5) diversity, equity, 

and inclusion; (6) other IAIS activity; and (7) FSB cross-border resolution. Much of the work 

described below is ongoing and is expected to continue through 2022 and beyond. 

28 OECD, Global Insurance Market Trends 2020 (January 2021), https://www.oecd.org/daf/fin/insurance/Global-InsuranceMarket-Trends-2020.pdf; OECD, Public and Private Sector Relationships in Long-term Care and Healthcare Insurance (February 2021), http://www.oecd.org/daf/fin/insurance/Public-and-Private-Sector-Relationships-in-Long-term-Careand-Healthcare-Insurance.pdf; OECD, Insurance Markets in Figures (June 2021), https://www.oecd.org/daf/fin/ 

insurance/Insurance-Markets-in-Figures-2021.pdf; OECD, Enhancing Financial Protection Against Catastrophe Risks: The 

Role of Catastrophe Risk Insurance Programmes (October 2021), https://www.oecd.org/daf/fin/insurance/enhancingfinancial-protection-against-catastrophe-risks.htm. 29 “Responding to the COVID-19 and Pandemic Protection Gap in Insurance,” OECD, last modified March 16, 2021, 

https://www.oecd.org/coronavirus/policy-responses/responding-to-the-covid-19-and-pandemicprotection-gap-in-insurance-35e74736/. 30 FIO, 2021 Annual Report, 113. 
International Insurance Issues, Positions, and Effects 9 

Climate Risk 

During 2021, the IAIS increased work on climate risks in the insurance sector by finalizing an 

application paper for supervision of climate risks in insurance,31 publishing a climate special edition topic for the Global Insurance Market Report (GIMAR),32 creating a Climate Risk Steering 

Group (CRSG), issuing a statement of IAIS commitment to a climate change response,33 and participating in the Climate Training alliance, which launched a training website.34 

In May 2021, the IAIS and the Sustainable Insurance Forum (SIF) issued the Application Paper on 

Supervising Climate-related Risks in the Insurance Sector following its 2020 consultation. The 

paper provides supervisors with guidance on how to apply the Insurance Core Principles when considering climate risk. The 2021 paper covered six supervisory areas: role of supervisor; corporate 

governance; risk management and internal controls; enterprise risk management for solvency purposes; investments; and public disclosures. 

In September 2021, the IAIS issued the GIMAR 2021 special topic edition on climate risks.35 This 

initial report focused on insurers’ assets and drew on quantitative and qualitative data gathered 

on a standalone, voluntary data call from 32 IAIS Members. This initial IAIS analysis faced certain 

methodological, analytical, and data challenges, such as the lack of a globally consistent taxonomy and a globally accepted framework for measuring climate-related risks. The IAIS quantitative data analysis relied on scenario analysis developed by the Network for Greening the Financial 

System (NGFS). In addition, the IAIS noted that there were substantial data gaps and a lack of 

consistency and quality of the submitted data. 

During the same month, the IAIS established the CRSG to coordinate IAIS work on climate risk. 

The CRSG set up three dedicated workstreams to develop a gap analysis of IAIS’ global standards 

for insurance supervision, develop educational materials for supervisors on effective practices in 

developing insurance-sector climate scenario analysis, and integrating climate-related financial 

risks into the Holistic Framework annual Global Monitoring Exercise data collection. 

31 IAIS, “Application Paper on the Supervision Climate-related Risks in the Insurance Sector,” https://www.iaisweb.org/ 

uploads/2022/01/210525-Application-Paper-on-the-Supervision-of-Climate-related-Risks-in-the-Insurance-Sector.pdf. 32 IAIS, “Global Insurance Market Report-Special Topic Edition: The Impact of Climate Change on the Financial Stability of 

the Insurance Sector,” https://www.iaisweb.org/uploads/2022/01/210930-GIMAR-special-topic-edition-climatechange.pdf. 33 IAIS, “IAIS Commitment to Amplify Response to Climate Change,” https://www.iaisweb.org/uploads/2022/01/211028-

IAIS-Statement_Commitment-to-amplify-response-to-climate-change_October-2021.pdf. 34 BIS, “International Financial Organisations Unite with the Central Bank and Financial Supervisory Community to Launch 

the Central Banks' and Supervisors' Climate Training Alliance (CTA) ahead of COP26,” https://www.bis.org/press/ 

p210709a.htm. 35 IAIS, “Global Insurance Market Report, GIMAR Special Topic Editions, The Impact of Climate Change on the Financial 

Stability of the Insurance Sector,” https://www.iaisweb.org/uploads/2022/01/210930-GIMAR-special-topic-editionclimate-change.pdf. 
10 Engagement in Global Insurance Regulatory or Supervisory Forums in 2021 

In October 2021, the IAIS issued a statement in advance of the 2021 United Nations Climate 

Change Conference (commonly referred to as COP26) confirming its commitment to advance work 

addressing the risks and opportunities associated with climate change and supporting an orderly 

transition to net-zero and global initiatives. The IAIS also worked with other organizations (Financial Stability Institute, NGFS and SIF) to launch the Climate Training Alliance e-learning portal, 

which is a web portal that provides a range of climate risk training resources for central banks and 

supervisors responding to climate risks. 

ICS 

The IAIS is developing the ICS, a risk-based global insurance capital standard for internationally 

active insurance groups (IAIGs), which will represent the quantitative component of the Common 

Framework for the Supervision of Internationally Active Insurance Groups (ComFrame).36 The ICS 

aims to provide a comparable measure of group solvency, facilitating a common understanding of 

IAIG capital adequacy that is expected to enhance cooperation and coordination among supervisors around the world. As a groupwide, consolidated approach, the ICS is planned to be adopted 

by the IAIS as a prescribed capital requirement for IAIGs at the end of the monitoring period in 

2024.37 

The IAIS’s ultimate goal is a single ICS that includes a common methodology through which the 

ICS achieves comparable outcomes across jurisdictions. In reaching that objective, the IAIS will 

make certain key decisions during the monitoring period on whether other approaches will be part 

of the final structure of the ICS. An alternative valuation methodology (GAAP Plus) and other 

methods of calculating the ICS capital requirement—such as with the use of internal models—will 

be under consideration for inclusion in the ICS in its final form. 

The IAIS continued confidential reporting of the ICS for the second year of the monitoring period in 

2021. Although the effects of COVID-19 were still evident in 2021 with ongoing travel restrictions, 

the IAIS was able to return to normal ICS reporting deadlines and obtain more feedback from 

supervisory colleges on the performance of the ICS and any additional reporting allowed by groupwide supervisors. In 2021, 42 insurance groups from around the world participated in the ICS confidential reporting exercise, seven of which were from the United States. For the second year, IAIS 

members—not able to access ICS data due to the travel restrictions—had to rely on highly aggregated analysis provided by the IAIS secretariat, preventing them from effectively analyzing and 

addressing ICS’ critical flaws. 

36 ComFrame, adopted in November 2019, establishes supervisory standards and guidance focusing on the effective 

groupwide supervision of IAIGs. IAIS, “Frequently Asked Questions: IAIS Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame),” https://www.iaisweb.org/uploads/2022/01/191120-ComFrameFrequently-Asked-Questions.pdf. 37 See IAIS, Risk-Based Global Insurance Capital Standard Version 2.0 (Public Consultation Document), https:// 

www.iaisweb.org/uploads/2022/01/180731-ICS-Version-2.0-Public-Consultation-Document.pdf. 
International Insurance Issues, Positions, and Effects 11 

While the ICS monitoring period is intended to be a period of stability, where the overall structure 

remains unchanged to allow for monitoring the performance of the ICS, the IAIS is not prevented 

from correcting major flaws or unintended consequences. The IAIS made changes to the ICS 

design in 2021, addressing a limited number of concerns identified in the 2020 ICS results. It is 

the position of U.S. members that the ICS methodology continues to be unaligned with U.S. markets, business practices, and products and contains major flaws, including related to calibration, 

that must be addressed prior to the end of the monitoring period. The Federal Reserve and FIO 

have concerns with the ability to address these flaws and still produce a credible global standard 

in the time remaining. 

In fulfilling its mandate to recommend whether the IAIS should pursue a differentiated capital 

treatment under the ICS for infrastructure and/or strategic equity investments, the Infrastructure 

Task Force (ITF) made further progress in 2021. ITF members refined the definitions and criteria 

for eligible investments in 2021, drawing on feedback received from the surveys issued to the 

public and groupwide supervisors as well as from data collected in the 2021 ICS confidential 

reporting submissions from volunteers. In addition to undertaking analyses of relevant studies, 

the ITF engaged with groups of stakeholders with specific subject matter expertise, including credit 

rating agencies, academia, supervisors, and international organizations, to further determine the 

appropriateness of applying a differentiated capital treatment to these types of investments. 

FIO and the Federal Reserve will continue to engage with the IAIS to better reflect U.S. insurance 

practices and markets in the ICS framework, also endeavoring to inform both the public consultation of the ICS as a prescribed capital requirement and the economic impact assessment planned 

for later in the monitoring period. Team USA continues to advocate for an ICS that is appropriate 

for the United States. 

As set out in the Act, before supporting or consenting to the adoption of any final ICS, Treasury 

and the Federal Reserve—in consultation with the NAIC—are required to complete a study, and 

provide a report to Congress, on the impact on U.S. consumers and markets.38 Treasury and the 

Federal Reserve consider that, in order for any form of an ICS to be considered a global standard, 

it must be appropriate for the U.S. insurance market. 

Aggregation Method 

The United States, along with other interested jurisdictions, is developing an Aggregation Method 

(AM) that builds on existing jurisdictional capital regimes. The AM is being developed with the aim 

for it to be considered an outcome-equivalent approach for implementation of the ICS as a prescribed capital requirement. The IAIS has agreed to conduct an assessment to determine whether 

the AM produces comparable outcomes to the ICS prior to the end of the monitoring period. 

38 Act § 211(c)(3)(A), 31 U.S.C. § 313 note. 
12 Engagement in Global Insurance Regulatory or Supervisory Forums in 2021 

In 2021, the United States and other interested jurisdictions continued developing the AM. The 

IAIS continued working on the comparability assessment criteria, having finalized the definition of 

comparable outcomes and high-level principles that guide the development of the criteria in 

May 2021. The public consultation on the criteria was delayed until 2022. The timing to determine 

whether the AM will be considered an outcome-equivalent approach by the end of the monitoring 

period, however, remains on track. As with the ICS work, FIO and the Federal Reserve will continue 

to take an active part in the ongoing comparability discussions at the IAIS. 

Holistic Framework and Macroprudential Work 

In 2021, the IAIS, for the first time, completed the Global Monitoring Exercise (GME), covering two 

years of data.39 The GME is a risk assessment framework to monitor key risks and trends and to 

detect the potential build-up of systemic risk in the global insurance sector. The IAIS held collective discussions on the outcome of the GME, based on a defined scope of individual insurers and 

three sectorwide macroprudential themes, which were identified as supervisory priorities: (1) lowyield environment and private-equity ownership, (2) credit risk, and (3) cyber risk. Findings from the 

2021 GME showed that, on aggregate, insurers’ solvency ratios remained below their pre-COVID 

levels with uncertainties and vulnerabilities remaining. In 2021, the IAIS continued to develop metrics to monitor the global insurance industry’s liquidity position. On November 18, 2021, the IAIS 

published for public comment a draft paper on the second phase of the project that explores other 

liquidity metrics.40 This draft includes a company projection approach that utilizes insurers’ projections of cash flows to assess liquidity risk. The metrics being developed would not be a requirement or have the potential to result in any identification of an insurer as systemically important. 

Instead, they would help the IAIS form a comprehensive assessment about the potential build-up 

of systemic risk in the insurance sector. 

Assessment Work 

Throughout 2021, the IAIS continued its pivot from the development of standards to supporting 

the implementation and assessment of implementation of standards. The IAIS also continued its 

assessment of insurance supervisors’ implementation of the Holistic Framework supervisory 

material. This assessment builds on existing IAIS assessment methodologies to promote globally 

consistent and effective implementation of the Holistic Framework supervisory material. As agreed 

in 2020, the IAIS started the second phase of the implementation assessment, Targeted Jurisdictional Assessments of the Holistic Framework (TJA), scheduled to end in 2022, which featured 

more intensive assessments by the IAIS of implementation of the Holistic Framework supervisory 

material. 

39 IAIS, Global Insurance Market Report [GIMAR] (November 2021), https://www.iaisweb.org/uploads/2022/01/211130-

IAIS-GIMAR-2021.pdf. 40 IAIS, Development of Liquidity Metrics: Phase 2 – Development of Liquidity Metrics (Public Consultation Document) (Basel: 

IAIS, November 2021), https://www.iaisweb.org/2021/11/public-consultation-on-the-development-of-liquidity-metricsphase-2/. 
International Insurance Issues, Positions, and Effects 13 

The TJA project started in March 2021 for 10 participating jurisdictions: Canada, China, Hong 

Kong SAR, France, Germany, the Netherlands, Japan, Switzerland, the United Kingdom, and the 

United States. 

On-site jurisdiction visits began during Q4:2021, to be followed by drafting the individual assessment report for each jurisdiction. The reports will act as the basis for an aggregate report on the 

implementation of the Holistic Framework, which itself will form a central part of the Comprehensive report to the FSB on the overall state of implementation of the Holistic Framework. 

Diversity, Equity, and Inclusion 

In 2021, the IAIS “intensified its work and focus on issues of Diversity, Equity and Inclusion (DE&I) 

in the insurance sector.”41 The IAIS released a statement in November 2021 underscoring the 

importance of DE&I considerations in insurance supervision.42 The statement explained how DE&I 

“touched on several strategic themes identified in the IAIS Strategic Plan” for 2020-24 and committed the IAIS to prioritizing DE&I work. The IAIS also asserted, in the same statement, that it 

was committed to strengthening and deepening its DE&I work through 

• undertaking exploratory work on the insurance sector’s efforts and steps taken by supervisors 

in support of DE&I objectives, including via engagement with stakeholders; 

• incorporating relevant DE&I aspects into ongoing IAIS projects and activities, in particular, those 

related to corporate governance, culture, and conduct; and 

• exploring opportunities to cooperate with other international organizations and partners, such 

as the IAIS’s implementation partner, the Access to Insurance Initiative (A2ii), to encourage 

supervisory dialogue and sharing of good practices. 

Finally, the statement highlighted that the IAIS itself “operates as a global, inclusive organisation 

with Members from more than 200 jurisdictions, over 60 [percent] of which are from emerging 

markets and developing economies.” The statement concluded that “the IAIS will also be taking 

actions to further build DE&I into its own internal governance and processes.” 

Also in 2021, the IAIS created the Financial Inclusion Forum, replacing the former Financial Inclusion Working Group. This forum, jointly coordinated by the IAIS and A2ii, focused in 2021 on the 

impact of the COVID-19 pandemic on inclusive insurance, digitalization, and consumer protection.43 

41 IAIS, Newsletter (November 2021), https://www.iaisweb.org/uploads/2022/01/211201-IAIS-Newsletter-November2021.pdf. 42 IAIS, Statement: The Importance of Diversity, Equity and Inclusion (DE&I) Considerations in Insurance Supervision 

(November 16, 2021), https://www.iaisweb.org/uploads/2022/01/211116-IAIS-Statement-on-Diversity-Equity-andInclusion.pdf. 43 IAIS, “Financial Inclusion,” https://www.iaisweb.org/activities-topics/financial-inclusion/, last visited on April 8, 2022. 
14 Engagement in Global Insurance Regulatory or Supervisory Forums in 2021 

Other IAIS Activity 

Monitoring and Responding to the Effects of the COVID-19 Pandemic 

During 2021, the IAIS held all meetings virtually and discussed processes and procedures of 

future in-person and hybrid events with expectations of a return to on-site activities some time in 

2022. For the IAIS 2021-22 Roadmap, the association established an underlying theme of the 

leadership role insurers, supported by supervisors, have to play in the recovery from the COVID-19 

pandemic.44 The IAIS also planned ongoing assessment of potential vulnerabilities arising from 

the impact of COVID-19 and the sharing of good supervisory practices.45 On April 9, 2021, the IAIS 

with the Financial Stability Institute published a joint note that examines measures taken by insurance supervisors to help them adapt to remote working and accelerated digitalization demands 

during the COVID-19 crisis.46 

Cyber Risk and IT Third-Party Outsourcing 

The IAIS committed in 2021 to developing supervisory supporting guidance and material in the 

field of operational resilience, specifically on information technology (IT) third-party outsourcing 

and insurance sector cyber resilience and having the Operational Resilience Task Force (ORTF) 

look at integrating lessons on ensuring business continuity (over an extended period) into supervisory guidance.47 In addition, the IAIS also actively engaged in the FSB’s work on cyber resilience, 

participating on the FSB’s Cyber Incident Reporting Working Group. The IAIS has also provided 

input to the FSB’s work on outsourcing and third-party relationships.48 

Published Supervisory Material 

In June 2021, the IAIS published an application paper on resolution powers and planning providing 

guidance for supervisors and resolution authorities in implementing a resolution framework and an 

application paper on supervision of control functions providing best practices.49 In November, the 

IAIS published three papers: (1) an issue paper exploring the topic of insurer culture, (2) an application paper describing the processes and practices related to the establishment and functioning 

of supervisory colleges, and (3) an application paper on combating money laundering and terrorist 

financing, providing information and advice on how money laundering and terrorist financing can 

44 IAIS, Newsletter (January 2021), https://www.iaisweb.org/uploads/2022/01/210201-IAIS-Newsletter-January-2021.pdf. 45 IAIS, The IAIS Strategic Plan 2020-2024 (June 2019), https://iaisweb.org/uploads/2022/01/190613-2020-2024-

Strategic-Plan.pdf. 46 IAIS, Redefining Insurance Supervision for the New Normal (April 2021), https://www.iaisweb.org/uploads/2022/01/ 

210409-IAIS-FSI-Note-on-redefining-insurance-supervision-for-the-new-normal.pdf. 47 IAIS, 2021-2022 IAIS Public Road Map (February 23, 2021), https://www.iaisweb.org/uploads/2022/01/210223-2021-

2022-IAIS-Public-Roadmap.pdf. 48 IAIS, Newsletter (June 2021), https://www.iaisweb.org/uploads/2022/01/210706-IAIS-Newsletter-June-2021.pdf. 49 IAIS, Application Paper on Resolution Powers and Planning (Basel: IAIS, June 2021), https://www.iaisweb.org/uploads/ 

2022/01/210623-Application-Paper-on-Resolution-Powers-and-Planning.pdf, and Application Paper on Supervision of Control Functions, https://www.iaisweb.org/uploads/2022/01/210623-Application-Paper-on-Supervision-of-ControlFunctions1.pdf. 
International Insurance Issues, Positions, and Effects 15 

occur within the life insurance sector and on which measures could mitigate the associated 

risks.50 

A2ii 

In November 2021, the IAIS and the A2ii signed and published a partnership agreement, formalizing the long-standing working relationship and confirming their mutual commitment to supporting 

each other’s work through a variety of activities.51 

FSB Cross-Border Resolution 

The FSB oversees some insurance resolution-planning work through the CrossBorder Crisis Management Group for Insurers (iCBCM).52 The FSB’s iCBCM assists and supports regulatory authorities in the development and implementation of resolution-related policy measures for global systemically important insurers (G-SIIs). Specifically, the iCBCM works under the direction of the FSB’s 

Resolution Steering Group and in coordination with the IAIS’s Resolution Working Group, to 

develop guidance for resolution powers and tools regarding G-SIIs as well as addressing issues 

relating to their application.53 Both FIO and the Federal Reserve are members of the iCBCM. 

In December 2021 the FSB issued its tenth report on the implementation of resolution reforms, 

which was informed by results of the fourth annual resolvability monitoring survey undertaken by 

the iCBCM.54 The report noted mixed progress on resolution planning for systemic insurers, and 

additional progress on implementation of the Key Attributes for Insurers.55 Further, the FSB noted 

that it will review the scope of application of G-SII-specific requirements in the Key Attributes in 

consultation with the IAIS in light of the potential discontinuation of the G-SII designation process 

in late 2022; FIO and the Federal Reserve are engaged in this work. The iCBCM also engaged in 

the mapping and assessment of interconnectedness as it affects resolution, and the identification 

of funding sources in resolution. 

50 IAIS, Issues Paper on Insurer Culture (Basel: IAIS, November 2021), https://www.iaisweb.org/uploads/2022/01/ 

211111-Issues-Paper-on-Insurer-Culture.pdf; Application Paper on Supervisory Colleges, https://www.iaisweb.org/ 

uploads/2022/01/211111-Application-Paper-on-Supervisory-Colleges.pdf; and Application Paper on Combatting Money 

Laundering and Terrorist Financing, https://www.iaisweb.org/uploads/2022/01/211111-Application-Paper-onCombating-Money-Laundering-and-Terrorist-Financing.pdf. 51 IAIS, “Partnership Agreement between the International Association of Insurance Supervisors and the Access to Insurance Initiative,” https://www.iaisweb.org/uploads/2022/01/211122-IAIS-A2ii-Partnership-Agreement.pdf. 52 2019 Fed-FIO Annual Report. 53 FSB, FSB 2019 Resolution Report: Mind the Gap (Basel: FSB, November 2019), 

https://www.fsb.org/wp-content/uploads/P141119-3.pdf, 16. 54 FSB, FSB 2021 Resolution Report: Glass Half-Full, or Still Half-Empty? (Basel: FSB, December 2021), 

https://www.fsb.org/wp-content/uploads/P071221.pdf, 18. 55 FSB, Key Attributes of Effective Resolution Regimes for Financial Institutions (Basel: FSB, October 2014), https:// 

www.fsb.org/wp-content/uploads/r_141015.pdf. 
16 

Transparency Efforts at the IAIS and 

the FSB 

FIO and the Federal Reserve promote efforts to increase transparency at the IAIS and the FSB, 

including as described below in this section. In addition, FIO enhances transparency by engaging 

with stakeholders through the FACI, which provides non-binding advice and recommendations to 

FIO. At each FACI meeting, the FIO Director typically delivers a public update on both domestic and 

international activities of FIO.56 The Federal Reserve performs a similar function through the IPAC. 

IAIS Transparency Efforts 

Under its bylaws, the IAIS undertakes to “operate in an open and transparent manner.”57 Among 

other ways, it seeks to accomplish this through a range of engagement opportunities as outlined 

in the 2017 IAIS Stakeholder Engagement Plan,58 such as its annual conference, which is open to 

all stakeholders and to the general public.59 

The key means by which IAIS engages with stakeholders and the public is through its various and 

wide-ranging stakeholder consultations and events, through which the work of its committees and 

working groups is shared with the public while under development, providing stakeholders and the 

public with opportunities to comment and share input on the work. Development of all IAIS supervisory and supporting material incorporates public consultation. 

In general, such consultation, at a minimum, consists of the following components:60 

• launch of public consultation, that is, a public session providing background on the project and 

the specific issues for which the IAIS is seeking targeted input. 

• publication of comments received through the public consultation process, noting the resolution 

of or response to them after consideration by the relevant working group or committee. 

• publication and presentation of the final version of the supervisory or supporting material, 

through a public discussion session at which the outcome of the public consultation is discussed. 

56 Additional information regarding FACI, including links to videos of past meetings, is available on FIO’s website at https:// 

home.treasury.gov/policy-issues/financial-markets-financial-institutions-and-fiscal-service/ 

federal-insurance-office/federal-advisory-committee-on-insurance-faci. 57 See “IAIS By-Laws,” Art. 2(3). 58 IAIS, 2017 Annual Report, 10 (referencing the “commitments contained in the IAIS Stakeholder Engagement Plan”). 59 IAIS, Stakeholder Engagement Plan, https://www.iaisweb.org/uploads/2022/01/IAIS-Stakeholder-Engagement-Plan2017.pdf?msclkid=fb737296d0ae11ecbe148156d5aa9f53, section I(J). 60 IAIS, “Closed Consultations,” https://www.iaisweb.org/consultations/. 
Transparency Efforts at the IAIS and the FSB 17 

• some projects include multiple consultations prior to publication, which may consist of surveys, 

information sessions, and targeted interactions with relevant stakeholders (for example, expert 

round table meetings). 

Table 2 provides a compilation of IAIS public consultations during 2021. During 2021 the IAIS continued operating without in-person sessions and instead made use of alternatives, primarily videoTable 2. IAIS stakeholder consultations, meetings, and other public events in 2021 

Date Consultations and meetings 

January 25, 2021 Draft Application Paper on Supervision of Control Functions, and Questions for Application Paper on Supervision of 

Control Functions 

January 29, 2021 IAIS Comment Letter to IAASB Consultation on Fraud and Going Concern 

February 10, 2021 Public Session on activities of the Governance Working Group, addressing Issues Paper on Insurer Culture and 

Application Paper on Supervision of Control Functions 

March 8, 2021 Draft Application Paper on Macroprudential Supervision 

March 23, 2021 Public Information Session on Draft Application Paper on Macroprudential Supervision 

May 3, 2021 Compiled Comments on the Comparability Public Consultation; and Summary and Resolution of Comments for the 

Comparability Public Consultation 

May 17, 2021 Revised Application Paper on Combating Money Laundering and Terrorist Financing 

May 25, 2021 Resolution of Consultation Comments on Application Paper on the Supervision of Climate-related Risks 

June 2, 2021 Public Background Session on revised Application Paper on Combating Money Laundering and Terrorist Financing. 

June 9, 2021 Webinar on Climate-related risks in the insurance sector 

June 23, 2021 Draft Issues Paper on Insurer Culture, and Questions for Draft Issues Paper on Insurer Culture 

June 23, 2021 Draft Revised Application Paper on Supervisory Colleges, and Questions for Draft Revised Application Paper on 

Supervisory Colleges 

June 23, 2021 Resolution of Public Consultation Comments on Application Paper on Supervision of Control Functions 

June 23, 2021 Resolution of Public Consultation Comments on Application Paper on Resolution Powers and Planning 

June 23, 2021 IAIS Global Seminar 

June 24, 2021 Chief Risk Officer Roundtable 

June 30, 2021 Stakeholder Session, for presentation and discussion of the June 23, 2021, materials noted above 

June 30, 2021 Liquidity Metrics Phase 1 – Resolution of Comments 

July 5, 2021 Questions and Answers covered at the IAIS Global Seminar 2021 

August 30, 2021 Resolution of Consultation Comments on Application Paper on Macroprudential Supervision 

September 6, 2021 Presentation on Application Paper on Macroprudential Supervision, including public discussion session 

November 11, 2021 Resolution of Consultation Comments on Issues Paper on Insurer Culture 

November 11, 2021 Resolution of Consultation Comments on Application Paper on Supervisory Colleges 

November 11, 2010 Resolution of Consultation Comments on Application Paper on Combating Money Laundering and Terrorist 

Financing 

November 16 – 18, IAIS Annual General Meeting and Annual Conference (virtual)1 

2021 

November 18, 2021 Public Consultation on the Development of Liquidity Metrics: Phase 2, including questions for written comment 

November 30, 2021 Public background session – Liquidity Metrics: Phase 2 

1 IAIS, “2021 Annual Conference,” https://www.iaisweb.org/news-and-events/2021-annual-conference (agenda & videos). 

Source: IAIS, “Stakeholder Events,” https://www.iaisweb.org/news-and-events/stakeholder-events; “Closed Consultations,” https:// 

www.iaisweb.org/consultations. 
18 Engagement in Global Insurance Regulatory or Supervisory Forums in 2021 

conferences. Team USA continued to be engaged in all IAIS workstreams during 2021, with members thereof chairing many of them. 

During 2021, the IAIS expanded the content of its public newsletters61 and began a revamp of its 

website to improve accessibility of IAIS material.62 The IAIS Secretary General has continued to 

participate in relevant events, including the May 2021 International Insurance Forum organized by 

the NAIC.63 Team USA members will advocate for continued transparency by the IAIS and will continue to consult among themselves and with U.S. stakeholders in support of such efforts. 

Finally, with increased emphasis on “hybrid” collaboration perhaps becoming a global norm, it is 

notable, that in June 2021, the IAIS Executive Committee, emphasizing that transparent and inclusive collaboration are essential to the way in which the IAIS progresses its work, approved a 

framework “that considers the benefits of in-person meetings, particularly the social capital built 

by groups being able to meet in-person, tempered with the recognition that meetings might still be 

difficult for some.”64 The Executive Committee also noted its commitment in terms of the Environmental Policy of the IAIS to reduce the amount of travel for in-person meetings over time.65 

FSB Transparency Efforts 

Treasury and the Federal Reserve have also worked to increase transparency at the FSB, including 

through the Federal Reserve’s leadership role in the FSB. From December 2, 2018, to 

December 2, 2021, former Federal Reserve Governor and Vice Chair for Supervision, Randal K. 

Quarles, served as FSB Chair, and during that period he made increasing FSB transparency and 

stakeholder engagement a key part of that body’s agenda. Partially as a reflection of those efforts, 

for example, in 2019, for the first time in its history, the FSB publicly disseminated its comprehensive work program. The FSB has continued to do so, and its work program was again published in 

both 2020 and 2021. 

The Federal Reserve and Treasury also have advocated for increased transparency on IAIS matters 

at the FSB. This includes engagement by the Federal Reserve and Treasury at both the IAIS and 

FSB in support of a public consultation as part of the FSB’s planned 2022 review of G-SII designations. To accommodate this public consultation after the delays in implementation of the Holistic 

61 IAIS, “News and Events,” https://www.iaisweb.org/news-and-events/newsletter/. 62 IAIS, “IAIS Introduces Refreshed Visual Identity and Upgraded Website,” news release, March 3, 2022, https:// 

www.iaisweb.org/2022/03/iais-introduces-refreshed-visual-identity-and-upgraded-website/. 63 NAIC, “Resource Center Newsroom,” https://content.naic.org/article/naics-2021-international-insurance-forum-startstodaymore-500-scheduled-attend. 64 IAIS, “IAIS Concludes Mid-Year Committee and Stakeholder Meetings, Noting Solid Progress In Delivering on the IAIS 

Strategy 2020-2024 and Sharing Key Learnings from the COVID-19 Crisis,” news release, June 28, 2021, https:// 

www.iaisweb.org/uploads/2022/01/210628-IAIS-concludes-mid-year-Committee-and-Stakeholder-Meetings.pdf. 65 IAIS, IAIS Environmental Policy (Basel: IAIS, December 2020), https://www.iaisweb.org/uploads/2022/01/201202-IAISEnvironmental-Policy.pdf. 
Transparency Efforts at the IAIS and the FSB 19 

Framework due to COVID-19, the Federal Reserve and Treasury have suggested postponing this 

review until 2023. 

Federal Advisory Committee on Insurance 

FIO receives non-binding advice and recommendations from FACI, which includes a cross-section of 

members who represent the views of state and non-government persons having an interest in 

FIO’s duties and authorities, including state insurance regulators, industry experts, and consumer 

advocates. FACI had four subcommittees in 2021, which prepared draft recommendations for 

FACI’s consideration.66 The Subcommittee on FIO’s International Work presented a draft recommendation related to international market access to FACI at the February 2021 meeting. FACI continued discussion on a white paper addressing key market access challenges for international 

insurers, which elaborated on the proposed recommendations.67 

Following discussion, FACI adopted the following recommendation:68 

• FIO should advocate for Treasury and the Office of the U.S. Trade Representative to pursue 

actions to ensure financial services are not exempt from commitments in trade agreements 

that promote the free flow of data consistent with consumer data privacy and protection. Such 

trade agreements should prevent unwarranted data localization, recognizing that such commitments do not restrict a government’s right to adopt or maintain measures to protect personal 

data, personal privacy and the confidentiality of individual records and accounts, provided that 

such measures are not used to circumvent the data flow and localization commitments. 

FACI also heard a dissenting view on the recommendation.69 The adopted recommendation was 

taken into consideration by FIO and helped inform Treasury’s position on a variety of market 

access topics. 

Insurance Policy Advisory Committee 

In 2021, the IPAC, which was established by Congress in 2018 through the Act, advised the Federal Reserve primarily on capital standards and the impact of low interest rates and COVID-19 on 

the industry.70 The IPAC has been studying any impact of a hypothetical adoption of the IAIS ICS 

66 FACI disbanded two of its subcommittees in 2021. The Subcommittee on COVID-19 was disbanded in September 2021 

and the Subcommittee Addressing the Protection Gap was disbanded in December 2021. 67 FACI International Subcommittee, “Market Access/Level Playing Field: Key Challenges for International Insurers,” 

(2021), https://home.treasury.gov/system/files/311/faci-white-paper-market-access-12-20.pdf. 68 FACI, “Minutes – 18 February 2021,” 6, https://home.treasury.gov/system/files/311/FACI-Minutes-2-21.pdf. See also, 

Treasury, “FACI Recommendations,” https://home.treasury.gov/policy-issues/financial-markets-financial-institutions-andfiscal-service/federal-insurance-office/federal-advisory-committee-on-insurance-faci/faci-recommendations. 69 Center for Economic Justice, “Dissenting View of Birny Birnbaum, FACI International Subcommittee Recommendations,” 

https://home.treasury.gov/system/files/311/FACI-Dissent-Birnbaum-2-21.pdf. 70 See Act § 211(b), 31 U.S.C. § 313 note (establishing the Insurance Policy Advisory Committee). 
20 Engagement in Global Insurance Regulatory or Supervisory Forums in 2021 

on the U.S. industry, markets, and consumers.The IPAC provided information on how a long period 

of low interest rates affects U.S. life insurance and retirement security.71 

The Federal Reserve also solicited applications for seven IPAC members.72 The Act provides that the 

IPAC may have up to 21 members, “represent[ing] a diverse set of expert perspectives from the 

various sectors of the United States insurance industry, including life insurance, property and casualty insurance and reinsurance, agents and brokers, academics, consumer advocates, or experts on 

issues facing underserved insurance communities and consumers.”73 In 2021, the Federal Reserve 

reappointed one of the inaugural IPAC members, who had served an initial two-year term, and 

appointed six new IPAC members.74 These IPAC members will serve three-year terms commencing in 

January 2022. The Federal Reserve continues to build a diverse IPAC membership. 

71 Federal Reserve, “Records of the Meetings of the Insurance Policy Advisory Committee” (2021), https:// 

www.federalreserve.gov/aboutthefed/ipac.htm. 72 Solicitation of Statements of Interest for Membership on the Insurance Policy Advisory Committee, 86 Fed. Reg. 42,828 

(August 5, 2021), https://www.federalregister.gov/documents/2021/08/05/2021-16669/solicitation-of-statements-ofinterest-for-membership-on-the-insurance-policy-advisory-committee. 73 Act § 211(b)(2). See also 31 U.S.C. § 313 note. 74 Board of Governors of the Federal Reserve System, “Federal Reserve Board Announces members of its Insurance Policy 

Advisory Committee,” news release, November 24, 2021, https://www.federalreserve.gov/newsevents/pressreleases/ 

bcreg20211124a.htm. 
21 

Conclusion 

In 2021, Treasury and the Federal Reserve—in coordination with other Team USA members— 

continued to advocate for the development of international insurance standards that are appropriate for the United States. Treasury and the Federal Reserve will continue to strengthen their 

engagement in the work of the IAIS, FSB, and OECD, including, but not limited to, the ongoing 

development of the ICS and implementation of the IAIS’s Holistic Framework. 

Going forward, Treasury and the Federal Reserve will continue to advocate for insurance regulatory 

and supervisory standards that are appropriate for the United States and will continue to report to 

Congress on their efforts. In addition, Treasury and the Federal Reserve will continue their efforts 

to increase transparency at the IAIS and the other relevant standard-setting bodies. 
www.federalreserve.gov | www.treasury.gov