R E P O R T T O T H E C O N G R E S S 

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 

September 2019 

Steven T. Mnuchin 

Secretary of the Treasury 

Jerome H. Powell 

Chairman, 

Board of Governors of the Federal Reserve System 
R E P O R T T O T H E C O N G R E S S 

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 

September 2019 

Steven T. Mnuchin 

Secretary of the Treasury 

Jerome H. Powell 

Chairman, 

Board of Governors of the Federal Reserve System 
This and other Federal Reserve Board reports and publications are available online at 

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Washington, DC 20551 

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(email) Publications-BOG@frb.gov 
iii 

Contents 

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

International Insurance Issues, Positions, and Effects ................................................. 3 

International Forums ................................................................................................................... 3 

IAIS Overview ............................................................................................................................. 4 

FSB and OECD Overview ............................................................................................................ 4 

IAIS Activities ............................................................................................................................. 7 

ICPs and ComFrame ................................................................................................................... 7 

ICS Development and Status ....................................................................................................... 9 

Holistic Framework for Mitigation of Systemic Risk ..................................................................... 10 

IAIS Strategic Plan and Financial Outlook Task Force .................................................................. 12 

Other IAIS Work ........................................................................................................................ 12 

IAIS Cross-Border Resolution Planning Activities ........................................................................ 14 

FSB Cross-Border Resolution Planning Activities ........................................................................ 14 

Transparency Efforts ............................................................................................................. 17 

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

Introduction 

On May 24, 2018, President Donald J. Trump signed 

into law the Economic Growth, Regulatory Relief, 

and Consumer Protection Act, Pub. L. No. 115-174, 

132 Stat. 1296 (the Act). This report is submitted 

pursuant to section 211(c)(1) of the Act, which 

directs the Chairman of the Board of Governors of 

the Federal Reserve System (Federal Reserve) and 

the Secretary of the U.S. Department of the Treasury (Treasury), or their designee, to submit an annual 

report to Congress on the efforts of Treasury and the 

Federal Reserve, in coordination with the National 

Association of Insurance Commissioners (NAIC), 

“with respect to global insurance regulatory or 

supervisory forums.” Specifically, 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 [FIO] in international insurance discussions”; and 

4. “the efforts by the Secretary of the Treasury, the 

[Federal Reserve], and the Director of [FIO] to 

increase transparency at the Financial Stability 

Board [FSB] with respect to insurance proposals 

and the International Association of Insurance 

Supervisors [IAIS], including efforts to provide 

additional public access to working groups and 

committees of the [IAIS].” 

The report begins, in the section entitled “International Insurance Issues, Positions, and Effects,”

structure, governance, and role in insurance supervision. This section also includes an overview of the 

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.

 by 

describing in general terms the efforts of the Federal 

Reserve and Treasury in global insurance regulatory 

and supervisory forums. This section continues with 

a short overview of the IAIS, the international insurance standard-setting body. It explains the IAIS’s 

1 The report then discusses key international insurance standard-setting initiatives, such as 

the development of the Insurance Core Principles 

(ICPs) and the Common Framework for the Supervision of Internationally Active Insurance Groups 

(ComFrame); the Insurance Capital Standard (ICS); 

the Holistic Framework for Mitigation of Systemic 

Risk; and other international discussions. 

The section entitled “Transparency Efforts” provides 

a summary of Treasury and Federal Reserve efforts 

to increase transparency at the FSB and at the IAIS 

as well as coordination with other members of 

“Team USA” in undertaking these efforts.2 This 

report thus supplements the November 2018 report 

issued by the Federal Reserve and the Treasury on 

increasing transparency at the IAIS.3 

As highlighted throughout this report and emphasized in the conclusion, 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 

1 Other standard-setting bodies include the Basel Committee on 

Banking Supervision, which is the primary standard-setting 

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. 2 The U.S. members of the IAIS—Treasury/FIO, the Federal 

Reserve, the NAIC, and the state and territory insurance regulators who represent the individual sovereign jurisdictions 

within the United States—are informally known, collectively, as 

“Team USA.” 3 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://www.treasury.gov/ 

initiatives/fio/reports-and-notices/Documents/2018_IAIS_ 

Transparency_Report.pdf. 
2 Global Insurance Regulatory or Supervisory Forums in 2018 

to Congress on their efforts. Team USA members’ 

leadership and involvement in the IAIS and other 

international forums discussed in this report ensure 

that the United States is able to influence international standards for insurance supervision and regulation that may affect the U.S. insurance industry 

and consumers. It is important to recognize, however, that international standard-setting bodies do 

not have the power to effect direct legal changes in 

the United States. Any standards developed in the 

IAIS or in any other standard-setting bodies are not 

binding on the United States or any other jurisdiction and are effective in a jurisdiction only to the 

extent that the jurisdiction has separately implemented the standards in accordance with domestic 

law. In the United States, then, no international standards would be operational unless implemented 

through the relevant state or federal legislative or 

administrative process, as appropriate.4 

This report covers activities within the IAIS, the 

FSB, and the OECD, and generally addresses the 

period between May 24, 2018 (when the Act became 

law) and December 31, 2018. Future annual reports 

under the Act will cover relevant developments during the preceding calendar year. 

This report discusses topics that are also discussed in 

the 2018 Transparency Report and in FIO’s 2018 

Annual Report, which includes a detailed description 

of FIO’s international (and domestic) activities from 

2017 to 2018.5 

4 For an overview of the IAIS and information on the membership of U.S. federal agencies in various international bodies, see 

A Financial System That Creates Economic Opportunities: Asset 

Management and Insurance (2017) (Insurance EO Report) 

(Washington: U.S. Department of the Treasury, October 2017), 

130-131, https://www.treasury.gov/press-center/press-releases/ 

Documents/A-Financial-System-That-Creates-EconomicOpportunities-Asset_Management-Insurance.pdf. 5 Federal Insurance Office (FIO), Annual Report on the Insurance 

Industry (2018) (2018 Annual Report) (Washington: FIO, 2018), 

https://www.treasury.gov/initiatives/fio/reports-and-notices/ 

Documents/2018_FIO_Annual_Report.pdf. 

United Kingdom); and information exchanges that 

do not involve standard setting (such as the EU-U.S. 

Insurance Project).

FIO intends to address international 

activities in its 2019 Annual Report, including those 

outside of global insurance regulatory and supervisory forums. FIO’s annual reports typically discuss 

not only IAIS, FSB, and OECD work, but also oneon-one regulatory dialogues (such as the U.S.–India 

Financial Regulatory Dialogue); bilateral and/or 

multilateral discussions and agreements (such as 

those which led to the covered agreement with the 

European Union and the covered agreement with the 

6 Future FIO annual reports also 

may include material based upon input from the 

Federal Advisory Committee on Insurance (FACI), 

which has provided advice and recommendations to 

assist FIO in carrying out its statutory authority 

since 2012. FACI members represent a cross-section 

of the insurance industry, including state regulators, 

insurers, reinsurers, brokers, and consumer advocates. FACI recently formed a subcommittee on 

international developments.7 

The Federal Reserve also will report to Congress on 

the implementation of the Insurance Policy Advisory 

Committee (IPAC), as established by the Act.8 The 

IPAC will provide information, advice, and recommendations to the Federal Reserve on insurance topics.9 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.”10 To facilitate a transparent member selection process that would allow 

individuals from the public to apply to be part of the 

IPAC, the Federal Reserve established a records 

system and conducted a Privacy Impact Assessment 

of the IPAC systems.11 The Federal Reserve has 

solicited applications for membership on the IPAC.12 

6 See, e.g., 2018 Annual Report. 7 “Federal Advisory Committee on Insurance (FACI),” U.S. 

Department of the Treasury, last modified April 11, 2019, 

https://www.treasury.gov/initiatives/fio/Pages/faci.aspx. 8 See Act section 211(b) (establishing the Insurance Policy Advisory Committee). 9 See “Insurance Policy Advisory Committee,” Board of Governors, last modified January 25, 2019, https://www.federalreserve 

.gov/aboutthefed/ipac.htm. 10 Act section 211(b)(2). 11 Privacy Act of 1974; System of Records, 84 Fed. Reg. 2866 

(February 8, 2019), https://www.federalregister.gov/documents/ 

2019/02/08/2019-01639/privacy-act-of-1974-system-of-records; 

see also “Privacy Impact Assessment of the Insurance Policy 

Advisory Committee Systems,” Board of Governors 

(March 20, 2019), https://www.federalreserve.gov/files/pia_ipac 

.pdf. 12 Solicitation of Statements of Interest for Membership on the 

Insurance Policy Advisory Committee, 84 Fed. Reg. 33,264 

(July 12, 2019), https://www.federalregister.gov/documents/ 

2019/07/12/2019-14873/solicitation-of-statements-of-interestfor-membership-on-the-insurance-policy-advisory-committee. 
3 

International Insurance Issues, Positions, and 

Effects 

This section of the report addresses efforts of Treasury, including FIO, and the Federal Reserve—in 

coordination with the NAIC and the U.S. states and 

territories—“with respect to global insurance regulatory or supervisory forums.” After providing brief 

overviews of the IAIS, as the international insurance 

standard-setting body, and then the FSB and OECD, 

this section describes the insurance issues under discussion in those forums.13 

The Act also requires a “description of any position 

taken” by the Secretary of the Treasury, the Federal 

Reserve, and the Director of FIO in international 

insurance discussions at global insurance regulatory 

or supervisory forums.14 In discussions at global 

insurance regulatory and supervisory forums, Treasury and the Federal Reserve promote robust engagement to ensure that U.S. insurance stakeholders and 

the federal government are well represented.15 The 

Federal Reserve and Treasury advocate for positions 

in international insurance discussions to help ensure 

that international standards reflect the U.S. insurance regulatory regime, and that U.S. insurance sector remains competitive internationally. In particular, 

FIO’s “mission at the IAIS [is] to, among other 

things, (1) advocate for the U.S. state-based insurance regulatory system, U.S. consumers, the U.S. 

insurance sector, and growth in the broader U.S. 

economy, (2) coordinate the views of Team U.S.A., 

and (3) promote greater transparency and stakeholder engagement in international standard-setting 

forums.”16 Treasury and the Federal Reserve are 

involved at all levels within these forums. 

The Act also requests discussion of the possible 

effects that proposals at these forums could have on 

U.S. consumers and insurance markets.17

13 See Act section 211(c)(1)(A)(i). 14 See Act section 211(c)(1)(A)(iii). 15 See, e.g., Treasury, Insurance EO Report, 105. 16 Treasury, Insurance EO Report, 136. 17 See Act section 211(c)(1)(A)(ii). 

depending on how they are finalized, they could in 

the future have effects on U.S. insurers operating in 

foreign markets, as well as effects on the U.S. insurance regulatory system. For example, Treasury is 

working to improve the design of the ICS so that it 

more appropriately reflects the business model of 

insurers. In particular, Treasury identified “the ICS’s 

market valuation approach and the negative effects it 

could have on the ability of insurance companies to 

provide long-term savings products, which are 

important to insurers and policyholders in the 

United States.”

While 

many IAIS standards remain under development, 

18 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 consumer and markets in the United 

States before supporting or consenting to the adoption of any final international insurance capital standard.”19 In all of their international engagement, 

Treasury and the Federal Reserve work to promote 

the interests of U.S. consumers and the well-being of 

U.S. insurance markets. To that end, Treasury and 

the Federal Reserve coordinate with each other and 

with the other members of Team USA. 

International Forums 

This section of the report provides an overview of 

the IAIS, the FSB, and the OECD. The IAIS is the 

international standard-setting body for insurance. 

The FSB is an international forum that coordinates 

among international standard-setting bodies, including the IAIS, to promote international financial stability. The FSB makes recommendations pertaining 

to the global financial system, monitors financial sector vulnerabilities, and promotes adherence to inter18 Treasury, “Remarks by Treasury Secretary Steven T. Mnuchin 

at the National Association of Insurance Commissioners International Forum,” press release, May 13, 2019, https://home 

.treasury.gov/news/press-releases/sm688. 19 Act section 211(c)(3). 
4 Global Insurance Regulatory or Supervisory Forums in 2018 

national standards.20 Like the FSB, the OECD covers a broad range of financial services and other 

issues, including issues pertaining to insurance. 

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 supervision of the insurance sector.21 The IAIS additionally 

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.22 

The IAIS itself emphasizes 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.”23 

The IAIS operates through five key mechanisms: 

(1) the General Meeting, which ultimately oversees 

matters before the IAIS, has the authority “to adopt 

principles, standards, and guidance developed by the 

[IAIS] or other persons or entities not already 

adopted by the” Executive Committee;24 (2) the 

Executive Committee (ExCo), which serves as the 

principal decisionmaking body of the IAIS, is tasked 

with taking “all decisions necessary to achieve the 

mission of the [IAIS] in accordance with the directions given by the General Meeting”;25

20 Treasury, Insurance EO Report, 58 (Figure 9: Selected International Bodies Comprising the International Financial 

Architecture). 21 See International Association of Insurance Supervisors (IAIS), 

2017 IAIS Annual Report (Basel: IAIS, November 2018), 8, 

https://www.iaisweb.org/page/about-the-iais/annual-report//file/ 

77857/iais-ar-2017-digital-pdf-def-dp. See also FIO, 2018 

Annual Report, 36-37. 22 2017 IAIS Annual Report, 8. 23 2017 IAIS Annual Report, 10. 24 See “IAIS By-Laws,” Art. 11(1)(c), https://www.iaisweb.org/ 

page/about-the-iais/by-laws/file/74644/2017-by-laws. 25 See “IAIS By-Laws,” Art. 14(2). 

sible for assessments and assistance in implementing 

IAIS principles, standards, and guidance.

(3) the Policy 

Development Committee, which is responsible for 

standard-setting activities; (4) the Macroprudential 

Committee, which oversees the work on issues 

related to financial stability; and (5) the Implementation and Assessment Committee, which is respon26 

Multiple working groups and task forces, focused on 

a range of prudential regulation and supervision topics, report to these committees.27 All of the committees and subcommittees (the collective term for IAIS 

working groups and task forces) are composed of 

IAIS members. Hosted by the Bank for International 

Settlements (BIS) in Basel, Switzerland, the IAIS 

operates with the support of a Secretariat under the 

direction of a Secretary General.28 Figure 1 illustrates the IAIS organizational structure. 

In 2017, Treasury recommended that any future 

organizational changes to the IAIS’s existing structure should ensure appropriate and geographically 

balanced representation and committee leadership 

among the IAIS members.29 At the 2018 IAIS 

Annual General Meeting, the IAIS members 

approved important governance changes, which 

increased the ExCo’s size.30 As a result of these 

changes, FIO became a permanent ExCo member.31 

FSB and OECD Overview 

FSB 

The G-20 established the FSB in 2009 as its financial 

regulatory reform implementation organization, 

tasked 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.”32 As a general matter, the 

FSB is not responsible for setting international standards on insurance regulation. Other forums, includ26 See, e.g., “IAIS Organisational Structure Updated January 2018,” IAIS, https://www.iaisweb.org/page/about-the-iais/ 

organisational-structure. 27 See, e.g., FIO 2018 Annual Report, 36–37. See also “IAIS 

Organisational Structure Updated January 2018,” IAIS, https:// 

www.iaisweb.org/page/about-the-iais/organisational-structure. 28 See IAIS, 2017 IAIS Annual Report, 8. 29 Treasury, Insurance EO Report, 133. 30 IAIS, “Key Achievements Mark Week of IAIS Committee 

Meetings, Annual General Meeting and 25th Annual Conference,” press release, November 13, 2018, https://www.iaisweb 

.org/page/news/press-releases//file/77872/press-release-iaisconcludes-annual-conference-and-agm. 31 See IAIS, “Newsletter,” https://www.iaisweb.org/page/news/ 

newsletter/file/80574/iais-newsletter-february-2019. 32 See Treasury, Insurance EO Report, 57–59, 130. See also Financial Stability Board (FSB), “History of the FSB,” http://www 

.fsb.org/history-of-the-fsb/ and FSB, “About the FSB,” http:// 

www.fsb.org/about/#history. 
Source: Federal Insurance Office. See also “IAIS Organisational Structure,” https://www.iaisweb.org/page/about-the-iais/organisational-structure. 

Insurance Insurance 

Capital 

Standard Standard 

Task Force 

Strategic Plan 

& Financial 

Outlook 

Task Force 

Implementation 

& Assessment 

Committee 

FinTech 

Forum 

Supervisory 

Forum 

Financial 

Inclusion 

Working Group 

Signatories 

Working Group 

Standards 

Assessment 

Working Group 

Member 

Assessment 

Process Expert 

Team (2019, Q3) 

G-SII 

Implementation 

Monitoring 

Expert Team 

Core 

Curriculum 

Task Force 

General 

Meeting 

Executive 

Committee 

Policy 

Development 

Committee 

Chairs of Accounting 

Working Parties & Auditing 

of the PDC Working Group 

Capital Insurance Solvency & Groups Field Testing Working Group Working Group 

Market Conduct Resolution 

Working Group Working Group 

Supervisory Governance Material Working Group Review *IAC* Task Force 

Financial Crime 

Task Force 

*IAC* 

Macroprudential Budget Coordination 

Committee Committee Group 

Macroprudential 

G-SII Analysts Policy & 

Working Group Surveillance 

Working Group 

Systemic Risk 

Assessment 

Drafting Group 

Task Force on 

Systemically 

Important Banks Committees 

& Insurers 

Working Groups 

Task Forces 

Forums 

Expert Teams 

September 2019 5 

Figure 1. IAIS organizational structure 

ing the IAIS, are responsible for international standard setting. Further, the FSB also has no legal 

authority or jurisdiction over the United States. The 

FSB notes that “[t]he policies developed in pursuit of 

[the FSB’s] agenda are implemented by jurisdictions 

and national authorities,” and that “[t]he FSB’s decisions are not legally binding on its members – 

instead the [FSB] operates by moral suasion and peer 

pressure, in order to set internationally agreed policies and minimum standards that its members commit to implementing at a national level.”33 

The FSB’s membership consists of 68 institutions 

from 25 jurisdictions and ten international organizations and standard-setting bodies, including the 

IAIS.34

33 “About the FSB,” FSB, http://www.fsb.org/about/#history. 34 FSB, 5th Annual Report: 1 April 2017–31 March 2018 (Basel: 

FSB, December 2018) 38, http://www.fsb.org/wp-content/ 

uploads/P011218.pdf. 

U.S. members.

Treasury, the Federal Reserve, and the U.S. 

Securities and Exchange Commission are the FSB’s 

35 Treasury’s Office of International 

Affairs represents Treasury at the FSB. The current 

FSB Chair—as of December 2018—is the Federal 

Reserve Governor and Vice Chair for Supervision, 

Randal K. Quarles.36 

The FSB has created a compendium of standards 

that have been developed in other forums. The compendium includes standards considered by the FSB 

to be “key for sound financial systems and deserving 

of priority implementation depending on country 

circumstances.”37 The compendium includes standards that pertain to insurance, including the Insurance Core Principles, Standards, Guidance, and 

Assessment Methodology (discussed later in “ICPs 

and ComFrame”), the Key Attributes of Effective 

35 FSB, 5th Annual Report, 37; FSB, “Randal K. Quarles,” http:// 

www.fsb.org/profile/randal-k-quarles/. 36 FSB, “Organisational Structure and Governance,” http://www 

.fsb.org/organisation-and-governance/. 37 FSB, “The Compendium of Standards,” http://www.fsb.org/ 

work-of-the-fsb/about-the-compendium-of-standards/. 
6 Global Insurance Regulatory or Supervisory Forums in 2018 

Resolution Regimes for Financial Institutions (discussed later in “IAIS Cross-Border Resolution Planning Activities”), and the G20/OECD Principles of 

Corporate Governance.38 

OECD 

The OECD in its present form was created in 1961 to 

promote policies that improve the economic and 

social well-being of people around the world. The 

OECD provides a forum in which its 36 member 

countries work together to share experiences and 

seek solutions to common problems.39 The OECD 

collects and publishes statistical data and analyses on 

economics, trade, employment, education, health, 

social issues, migration, the environment, and many 

other fields, and it aspires to serve as a source of 

advice on various policymaking and implementation 

matters. By working with governments to understand 

the drivers of economic, social, and environmental 

changes, the OECD attempts to measure productivity and global flows of trade and investment. 

The OECD operates through more than 200 committees and working groups, composed of national 

experts and supported by a secretariat. Within this 

structure, insurance matters are the purview of 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. Representatives from 

the U.S. Departments of Commerce, Labor, and the 

Treasury, along with state insurance regulators, represent the views of the United States at the IPPC and 

WPPP. 

The OECD develops legal instruments to express 

policies that its membership have developed. Over its 

history, the OECD has developed approximately 450 

instruments—decisions, recommendations, declarations, international agreements, and others—covering a wide array of financial, economic, social, scientific, and other matters. Since 1961, the IPPC has 

helped develop 22 of these legal instruments, 10 of 

which—all recommendations—remain in force (see 

table 1).40 There were no new insurance-related recommendations or other standards under discussion 

in the IPPC or WPPP in 2018. 

Recent work at the IPPC and WPPP has included 

developing guidance on the institutional structure of 

insurance regulation;41 studying long-term care and 

health insurance;42 and collecting data on insurance 

38 FSB, “Key Standards for Sound Financial Systems,” http:// 

www.fsb.org/work-of-the-fsb/about-the-compendium-ofstandards/key_standards/. 39 Organisation for Economic Co-Operation and Development 

(OECD), “About the OECD,” http://www.oecd.org/about/. 40 OECD, “OECD Legal Instruments involving the Insurance and 

Private Pensions Committee,” https://legalinstruments.oecd.org/ 

en/instruments?mode=advanced&committeeIds=1651& 

dateType=adoption. The OECD describes “recommendations” 

as “instruments [that] are not legally binding but practice 

accords them great moral force as representing the political will 

of [a]dherents.” See OECD, “OECD Legal Instruments,” 

https://www.oecd.org/legal/legal-instruments.htm. 41 OECD, The Institutional Structure of Insurance Regulation and 

Supervision (2018), http://www.oecd.org/daf/fin/insurance/TheInstitutional-Structure-of-Insurance-Regulation-andSupervision.pdf. 42 OECD, “Long-term Care,” http://www.oecd.org/els/healthsystems/long-term-care.htm. 

Table 1. OECD in-force insurance-related recommendations from IPPC 

Recommendations Date adopted 

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 

Good Practices on Financial Education and Awareness Relating to Credit May 25, 2009 

Good Practices for Financial Education relating to Private Pensions Mar. 28, 2008 

Good Practices for Enhanced Risk Awareness and Education on Insurance Issues Mar. 28, 2008 

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. 
7 

statistics.43 U.S. representatives participated in this 

work as well as in preparing a 2018 report prepared 

by the IPCC, The Contribution of Reinsurance Markets to Managing Catastrophe Risk.

44 

IAIS Activities 

This section of the report describes the following 

“insurance regulatory or supervisory standardsetting issues under discussion” predominantly at the 

IAIS: (1) the ICPs and ComFrame; (2) the ICS; 

(3) the holistic framework for the mitigation of systemic risk; (4) the development of the IAIS strategic 

plan and financial outlook for 2020–24; (5) other 

IAIS work such as assessments and development of 

guidance and other written materials; and (6) crossborder resolution planning. Much of the work 

described below is ongoing and is expected to continue through 2019 and beyond. 

ICPs and ComFrame 

Team USA has worked within the IAIS to advocate 

for international standards for insurance supervision 

that are appropriate for the U.S. insurance sector, 

both within the United States and globally. The 

international insurance standards of broadest potential applicability are the ICPs developed through the 

IAIS. 

The IAIS’s mission 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.”45 To support that mission, the 

IAIS has developed a three-tier approach to insurance supervision: (1) a first tier of ICPs applicable to 

all insurers within a jurisdiction; (2) a second tier, 

under which certain insurers are subject to additional 

supervisory standards known as ComFrame;46 

43 OECD, “Statistics: Insurance,” https://www.oecd-ilibrary.org/ 

finance-and-investment/insurance/indicator-group/english_ 

ead4dc70-en. 44 OECD, The Contribution of Reinsurance Markets to Managing 

Catastrophe Risk (2018), http://www.oecd.org/finance/thecontribution-of-reinsurance-markets-to-managing-catastropherisk.pdf. 45 IAIS, 2017 IAIS Annual Report, 10. 46 IAIS, Draft Overall ComFrame for Public Consultation (clean 

version), 9-10 (paragraph 18 et seq.) (Basel: IAIS, July 2018) 

(Draft Overall ComFrame),

September 2019 

of Global Systemically Important Insurers (G-SIIs), 

as discussed further in the section entitled “

and 

(3) a third tier of policy measures for a smaller group 

Holistic 

Framework for Mitigation of Systemic Risk.” The 

IAIS explains: 

This three-tier approach reflects the proportionate response of the IAIS; that is, that supervisors should have the flexibility to tailor certain 

supervisory requirements and actions in accordance with the nature, scale[,] and complexity of 

individual insurers and exercise ‘supervisory 

common sense’ – that is, to fit solutions to the 

risk in a flexible and evolving way that achieves 

IAIS objectives but does not impede stable business development.47 

The ICPs, which are at the foundation of this threetier system, are a set of standards and supporting 

guidance intended as a supervisory framework for 

insurers. The ICPs “seek to encourage the maintenance of consistently high supervisory standards in 

IAIS member jurisdictions.”48 

ComFrame applies to internationally active insurance groups (IAIGs)—those with a certain form and 

degree of international activity that meet criteria set 

out by the IAIS49—and consists of an enhanced set 

of supervisory standards, encompassing both entitylevel and group-wide supervisory standards. As 

stated by the IAIS, “ComFrame seeks to assist 

supervisors in addressing group-wide activities and 

risks; identifying and avoiding supervisory gaps; 

[and] coordinating supervisory activities efficiently 

and effectively between the group-wide and other 

involved supervisors.”50 Since 2016, the IAIS has 

been directly integrating ComFrame material alongoverall-comframe-for-public-consultation

https://www.iaisweb.org/page/ 

supervisory-material/common-framework/file/76143/draft-

. See also FIO, 2018 

Annual Report, 39. 47 IAIS, 2017 IAIS Annual Report, 12. 48 IAIS, Draft Revised ICP Introduction and Assessment Methodology, 2 (paragraph 2), (Basel: IAIS, November 2017), https:// 

www.iaisweb.org/page/supervisory-material/insurance-coreprinciples/file/69883/draft-revised-introduction-andassessment-methodology. 49 “ComFrame identifies an IAIG as being an insurance group 

that has total assets of at least USD 50 billion or gross written 

premiums of at least USD 10 billion (on a rolling three year 

average basis). In addition, its premiums are written in three or 

more jurisdictions and at least 10 percent of the group’s total 

gross written premium is written outside the home jurisdiction.” See IAIS, Common Framework for the Supervision of 

Internationally Active Insurance Groups: Revised Draft, (Basel: 

IAIS, September 2014), 2, https://www.iaisweb.org/page/ 

supervisory-material/common-framework//file/58726/revisedcomframe-draft-2014. 50 IAIS, Draft Overall ComFrame, 9 (paragraph 19). 
ICP 2 (Supervisor) 2017 

ICP 3 (Information Sharing and Confidentiality Requirements) 2017 

ICP 4 (Licensing) 

ICP 5 (Suitability of Persons) 2017, 2018 

ICP 6 (Changes in Control and Portfolio Transfers) 2018 

ICP 7 (Corporate Governance) 2017, 2018 

ICP 8 (Risk Management and Internal Controls) 2018 2017, 2018 

ICP 9 (Supervisory Review and Reporting) 2017 2017, 2018 

ICP 10 (Preventative and Corrective Measures) 2017 2017, 2018 

ICP 11 (Enforcement) (incorporated into ICP 10) 2017 2017, 2018 

ICP 12 (Exit from the Market and Resolution) 2017 2017 

ICP 13 (Reinsurance and Other Forms of Risk Transfer) 2017 

ICP 14 (Valuation) 

ICP 15 (Investments) 2018 2018 

ICP 16 (Enterprise Risk Management for Solvency Purposes) 2018 2018 

ICP 17 (Capital Adequacy) 

ICP 18 (Intermediaries) 2017 

ICP 19 (Conduct of Business) 2017 

ICP 20 (Public Disclosures) 2018 

ICP 21 (Countering Fraud in Insurance) 

ICP 22 (Anti-Money Laundering and Combating the Financing of Terrorism) 

ICP 23 (Group-wide Supervision) 2018 

ICP 24 (Macroprudential Surveillance and Insurance Supervision) 2017 

ICP 25 (Supervisory Cooperation and Coordination) 2017 2017, 2018 

ICP 26 (Cross-Border Cooperation and Coordination on Crisis Management) (eliminated and incorporated 

into other ICPs) 2017 2017 

Proposed definitions of Enterprise Risk Management-related terms 2018 2018 

Overall ComFrame 

ICP ComFrame 

Introduction and Assessment Methodology 2017 2017 

ICP 1 (Objectives, Powers, and Responsibilities of the Supervisor) 2017 

2018 

Source: Federal Insurance Office. 

8 Global Insurance Regulatory or Supervisory Forums in 2018 

side the relevant ICPs to clarify the presentation of 

the two complementary sets of standards.51 

From March 2017 through October 2018, the IAIS 

engaged in a series of public consultations covering 

revisions to the ICPs and ComFrame, including the 

integration of ComFrame material within the relevant ICPs. Over the course of the consultations, 

proposed revisions in both the ICPs and ComFrame 

reflected developments since the publication of the 

2014 versions. Additionally, many previously undeveloped elements of ComFrame (in the 2014 version) 

were addressed as part of the 2017–18 revision process. Table 2

51 IAIS, “Consultation: Revised Insurance Core Principles (ICPs) 

and ComFrame Material Integrated with ICPs (for consultation period March 3, 2017, to June 1, 2017),” https://www 

.iaisweb.org/page/consultations/closed-consultations/2017/ 

revision-of-icps-and-comframe. 

sions, including the consultation for overall 

ComFrame. 

lists the public consultations in 2017 

and 2018 related to the ICPs and ComFrame reviAs a result of the proposed revisions and consultations, some changes to the ICPs are already in effect. 

The IAIS plans to adopt and publish all ICPs 

together with ComFrame, reflecting all revisions, by 

the close of 2019.52 

Team USA has engaged in the IAIS process of revising the ICPs and ComFrame to advocate for stan52 See IAIS, “All Adopted ICPs (updated November 2018),” 

https://www.iaisweb.org/page/supervisory-material/insurancecore-principles/file/77910/all-adopted-icps-updated-november2018. The status of each of the ICPs is also available on the 

IAIS website. IAIS, “Timelines and Status of ICPs,” https:// 

www.iaisweb.org/page/supervisory-material/insurance-coreprinciples/file/77876/timelines-and-status-of-icps. See also IAIS, 

“Timeline of ComFrame Development and ICPs Revision,” 

https://www.iaisweb.org/page/supervisory-material/insurancecore-principles/file/78064/timeline-of-comframe-developmentand-icps-revision. 

Table 2. Public consultations related to ICP and ComFrame revisions, 2017-18 
September 2019 9 

dards that are appropriate for the United States. 

Team USA members have conferred and collaborated regularly in efforts to advocate for appropriate 

standards in the ICPs and ComFrame, resulting in 

improvements to these standards. Provisions 

reflected in the draft ICPs and ComFrame, expected 

to go into effect in 2019, are generally consistent with 

the current U.S. insurance supervisory system. 

ICS Development and Status 

The ICS—which aims to be the first groupwide, riskbased capital standard broadly applicable to 

IAIGs—is part of ComFrame under development at 

the IAIS.53 The ICS should 

recognize the diverse approaches to solvency 

regulation taken by various jurisdictions around 

the globe. A core goal should be to ensure that 

the ICS initiative accommodates the U.S. insurance business model and the existing state-based 

[insurance] regulatory system. Such standards 

should also be developed in a manner that recognizes the variety of supervisory approaches to 

valuation and accounting requirements, and 

definitions of what constitutes capital.54 

Team USA members are participating in the ICS 

Task Force, the mandate of which is to provide strategic steering on the development and practical 

implementation of ICS Version 2.0. Team USA 

members also participate on the Policy Development 

Committee, which is responsible for standard-setting 

activities, as well as subcommittees involved in ICS 

development, monitoring, and field testing. 

53 See IAIS, Draft Overall ComFrame, 9 (paragraph 20). See also 

IAIS, Risk-based Global Insurance Capital Standard Version 2.0: 

Public Consultation Document, 12 (section 2.1) (July 31, 

2018)(ICS Version 2.0 Consultation), https://www.iaisweb.org/ 

page/supervisory-material/insurance-capital-standard/file/ 

76133/ics-version-20-public-consultation-document ; IAIS, 

Risk-Based Global Insurance Capital Standard Version 1.0 for 

Extended Field Testing (July 21, 2017)(ICS Version 1.0 Extended 

Field Testing), https://www.iaisweb.org/page/supervisorymaterial/insurance-capital-standard/file/67651/ics-version-10-

for-extended-field-testing . 54 Treasury, Insurance EO Report, 102. 

sion 1.0 also established a standard method for calculating the ICS capital requirement and indicated 

that other methods would be considered in the calculation of the ICS capital requirement, including the 

use of internal models, external models, and variations of the standard method.

To date, there have been two significant milestones of 

the ICS project. The first milestone was in July 2017 

when the IAIS adopted ICS Version 1.0 for extended 

field testing. ICS Version 1.0 identified two valuation 

approaches for the ICS: (1) market-adjusted valuation (MAV); and (2) Generally Accepted Accounting 

Principles with adjustments (GAAP Plus). ICS Ver55 

Furthermore, the IAIS decided to assist with the 

data collection and analysis of an “aggregation 

method,” an alternative approach for determining 

capital resources and capital requirements for a consolidated capital assessment that leverages the group 

capital calculation work that is being conducted by 

U.S. state regulators and the Building Block 

Approach being developed by the Federal Reserve.56 

Treasury and the Federal Reserve continue to advocate that the aggregation method, as with the ICS, 

would provide a consolidated capital standard for an 

insurance group. 

The second milestone was in November 2017, when 

the IAIS decided that the next steps for the ICS project would have two phases: (1) a five-year monitoring phase beginning in 2020, followed by (2) an 

implementation phase.57 During the first phase, the 

monitoring period, the ICS would not be used as a 

prescribed capital requirement, i.e., the ICS results 

would not be used as a basis for triggering supervisory action. Rather, the five-year monitoring period 

would be used for confidential reporting to groupwide supervisors and discussion in supervisory colleges. The IAIS stated that confidential reporting 

would be mandatory for all IAIGs during this 

period, and would involve the reporting of a reference ICS based on MAV with a single discounting 

approach, the standard method for calculating capital requirements, and converged criteria for qualifying capital resources.58 A reference ICS solvency 

ratio would provide a basis for comparison across 

IAIGs and with GAAP Plus and internal model generated results. The monitoring period would allow 

group-wide supervisors and host supervisors to discuss and assess the ICS as well as to compare ICS 

results against existing group capital standards and 

55 IAIS, ICS Version 1.0 Extended Field Testing. 56 See IAIS, ICS Version 2.0 Consultation, 17 (section 2.5, paragraph 34). 57 IAIS, ICS Version 2.0 Consultation, 16 (section 2.5). 58 See IAIS, Implementation of ICS Version 2.0, 1 (November 2, 

2017), https://www.iaisweb.org/file/69796/implementation-ofics-version-20. Again, it is important to note that IAIS standards are not self-executing in the United States. The IAIS’s use 

of the term “mandatory” applies only within the context of 

IAIS member commitments, and not the U.S. insurance regulatory regime. 
10 Global Insurance Regulatory or Supervisory Forums in 2018 

calculations, or those under development. Finally, 

additional reporting of the ICS based on GAAP 

Plus valuation and internal model-based capital 

requirement calculations would be permitted at the 

option of the groupwide supervisor. The second 

phase of implementation envisions the use of the 

ICS as a groupwide prescribed capital requirement. 

Throughout the development of the ICS, the IAIS 

has been undertaking a multiyear quantitative fieldtesting process with volunteer insurance groups. 

Four ICS field-testing exercises have been conducted 

between 2015 and 2018. The fifth and final field testing exercise before the second phase of implementation was launched on April 30, 2019. Each quantitative ICS field testing exercise has built upon the previous year’s analysis of submitted data and feedback 

received from volunteer groups. In 2018, approximately 50 volunteer groups, including U.S. firms, 

participated in the ICS field-testing exercise. The 

annual data submitted by volunteer firms have 

helped the members of Team USA to advocate for 

development of the ICS in ways that make it more 

suitable for the United States. 

In addition to voluntary field testing exercises, the 

IAIS has conducted three public ICS consultations, 

including one released on July 31, 2018, which solicited feedback on ICS Version 2.0.59 The Federal 

Reserve and Treasury encourage the IAIS to continue seeking public feedback on the development of 

the ICS. The comments received in the public consultations have been helpful for Team USA’s efforts at 

the IAIS to develop positions that support an ICS 

that is more appropriate for the United States. 

The IAIS’s ultimate goal is a single ICS that includes 

a common methodology through which one ICS 

achieves comparable, or substantially the same, outcomes across jurisdictions. ICS Version 2.0 is 

intended to attain an improved level of comparability relative to ICS Version 1.0. 

59 See, e.g., IAIS, ICS Version 2.0 Consultation. 

cerning comparability and outcome equivalence by 

the end of the monitoring period. 

Aspects of the ICS that remain under development 

include the current construct and calibration of certain risks to be reflected in the ICS. In addition, 

IAIS members continue to negotiate the process and 

timing to assess whether the various approaches 

under consideration (including the use of internal 

models, GAAP Plus, and the aggregation method) 

produce outcomes equivalent to the ICS reference 

method. The IAIS intends to make decisions conAs a first step towards developing criteria for assessing comparability, the IAIS issued a survey to its 

members in late 2018, asking for their views on what 

constituted appropriate criteria for evaluating the 

various proposed appproaches against the ICS reference method. However, significant work still remains 

ahead at the IAIS to address issues regarding comparability. Prior to the planned adoption of the ICS 2.0 

for the monitoring period in November 2019, IAIS 

members will continue working on (1) defining the 

meaning of “outcomes-equivalent”; (2) establishing 

the criteria and processes to evaluate comparability; 

(3) determining the expectations and use of the ICS 

by supervisors during the monitoring period; and 

(4) resolving significant technical design issues 

regarding the reference ICS. 

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 consumers and U.S. markets. In the interim, the Federal 

Reserve and Treasury continue to advocate for an 

ICS that would be appropriate for the U.S. insurance 

sector and for the IAIS to continue its efforts to 

develop the criteria and processes such that an aggregation method can be deemed comparable to the 

ICS. Treasury and Federal Reserve consider that, in 

order for any form of an ICS to be implementable 

globally, it must be suitable for the U.S. insurance 

market. 

60 

Holistic Framework for Mitigation of 

Systemic Risk 

In November 2018, the IAIS released for public consultation the Holistic Framework for Systemic Risk in 

the Insurance Sector.

61 Previous approaches for 

assessing systemic risk centered on identifying individual firms as potentially global systemically impor60 Act section 211(c)(3)(A). 61 IAIS, Holistic Framework for Systemic Risk in the Insurance 

Sector, (2018) (Holistic Framework Consultation Document) 

(Basel: IAIS, November 2018), https://www.iaisweb.org/page/ 

consultations/closed-consultations/2019/holistic-frameworkfor-systemic-risk-in-the-insurance-sector/file/77862/holisticframework-for-systemic-risk-consultation-document.
tant insurers (the G-SIIs).62 The proposed holistic 

framework would shift the IAIS approach away from 

entity-specific identification. The holistic framework 

focuses more on the collective activities and exposures of insurers, while also recognizing that systemic 

risk in the insurance sector may arise from the failure 

or distress of a single insurer. The proposed holistic 

framework takes into account both relevant sources 

of systemic risk, addresses cross-sectoral aspects of 

systemic risk, and proportionately applies enhanced 

policy measures to the relevant portions of the insurance sector.63 The proposed framework’s key elements are (1) an enhanced set of macroprudential 

supervisory policy measures; (2) a global monitoring 

exercise by the IAIS; (3) supervisory powers of intervention; (4) mechanisms that help ensure the global 

consistent application of the framework; and 

(5) assessment of implementation.64 

The proposed holistic framework draws together 

three activities from the IAIS’s Systemic Risk 

Assessment and Policy Workplan:65 

1. Developing of an “Activities-Based Approach 

(ABA) to mitigate systemic risk in insurance 

through the identification, and (further) development, as needed, of relevant macroprudential 

policy measures”; 

2. “Addressing cross-sectoral aspects in systemic 

risk assessment”; and 

3. “Revising the Entity-Based Approach (EBA), 

namely the 2016 Updated G-SII Assessment 

Methodology.”66 

As described by the IAIS, the ABA seeks to mitigate 

systemic risk in insurance through the “assessment 

across firms of the risk transmission of activities 

that either in themselves or as a result of common 

behaviors of firms cause significant disruption to the 

wider financial system and economic activity.”67 

62 IAIS, Holistic Framework Consultation Document 

(paragraphs 6–7). 63 See IAIS, Holistic Framework Consultation Document (paragraphs 29–48). 64 IAIS, Holistic Framework Consultation Document (paragraph 2). 65 IAIS, “IAIS Announces Systemic Risk Assessment and Policy 

Workplan,” press release, February 28, 2017, https://www 

.iaisweb.org/file/65229/iais-press-release-systemic-riskassessment-workplan;IAIS, Holistic Framework Consultation 

Document, (paragraph 12). 66 IAIS, Holistic Framework Consultation Document, (paragraph 8). 67 IAIS, Holistic Framework Consultation Document, 12 (paragraph 23). 

September 2019 11 

framework builds upon the IAIS’s interim consultation paper on the ABA, which was published in 

December 2017 and was open for public comment 

until February 15, 2018.

The 

68 That paper set forth a 

four-step conceptual approach for developing ABA 

policy measures: (1) identify insurer activities that 

could potentially threaten global financial stability; 

(2) evaluate existing IAIS policy measures (such as 

ICPs, the draft ComFrame including ICS Version 

1.0, and the G-SII policy framework) that may help 

mitigate the potential systemic risk stemming from 

the identified activities; (3) perform a gap analysis to 

identify risks that are not sufficiently mitigated by an 

existing policy measure; and (4) develop new policy 

measures, or enhance existing ones, to address any 

residual systemic risk.69 To receive stakeholder input, 

the IAIS also held two stakeholder meetings on the 

ABA approach to systemic risk—the first in Nashville, Tennessee, on January 13, 2018, and the second 

in London, U.K., on February 1, 2018.70 

The proposed holistic framework could eliminate the 

need to distinguish the ABA from the EBA. The 

IAIS is of the view that the framework implementation also “should remove the need for an annual 

G-SII identification by the FSB and national 

authorities.”71 The FSB has similarly encouraged the 

IAIS’s work to develop an ABA to systemic risk in 

the insurance sector and announced that it would 

not identify G-SIIs in 2018.72 

68 See FIO, 2018 Annual Report, 19; IAIS, “IAIS Releases Interim 

Consultation Paper on an Activities-Based Approach to Systemic Risk,” press release, December 8, 2017, https://www 

.iaisweb.org/page/news/press-releases//file/70446/iais-pressrelease-interim-public-consultation-on-an-activities-basedapproach. 69 See FIO, 2018 Annual Report, 19; IAIS, Activities-Based 

Approach to Systemic Risk, (December 8, 2017), 10-11, https:// 

www.iaisweb.org/page/consultations/closed-consultations/2018/ 

activities-based-approach-to-systemic-risk//file/70440/interimaba-cp-final-for-launch. 70 See FIO, 2018 Annual Report, 19; IAIS, “Newsletter” (February 2018): 5, https://www.iaisweb.org/page/news/newsletter/file/ 

72356/iais-newsletter-february-2018. 71 IAIS, Holistic Framework Consultation Document, 58 (paragraph 174). Presently the G-SII data collection exercise continues with the support of the G-SII Analyst Working Group 

(G-AWG). In 2017, the IAIS, together with the Basel Committee on Banking Supervision (BCBS), created the Task Force on 

Systemically Important Banks and Insurers (TFBI). The TFBI 

was charged with addressing inconsistencies between the assessment methodology frameworks for global systemically important banks and G-SIIs. The TFBI’s work also feeds into the 

development of the holistic framework. See also FIO, 2018 

Annual Report. 72 See FIO, 2018 Annual Report, 19; FSB, Review of the List of 

Global Systemically Important Insurers (G-SIIs) (November 21, 

2017), http://www.fsb.org/wp-content/uploads/P211117-2.pdf; 

FSB, “FSB Welcomes IAIS Proposed Insurance Systemic Risk 
12 Global Insurance Regulatory or Supervisory Forums in 2018 

Treasury and the Federal Reserve support the continued development of the holistic framework. Treasury 

and the Federal Reserve have advocated for the IAIS 

to develop a more appropriate framework for assessing potential systemic risk in the insurance sector. 

Entity-based systemic risk evaluations of insurance 

companies generally are not the best approach for 

mitigating risks arising from the insurance industry. 

Insurance regulators should focus on potential risks 

arising from insurance products and activities, and 

on implementing regulations that strengthen the 

insurance industry as a whole.73 

While the proposed holistic framework remains a 

work in progress, it represents a meaningful evolution from the approach focused on G-SII identification. The goals of the holistic framework are also 

generally consistent with the Macro-Prudential Initiative undertaken by the NAIC.74 

IAIS Strategic Plan and Financial 

Outlook Task Force 

Treasury and the Federal Reserve continue to advocate for robust engagement and strong U.S. representation at the IAIS. Continued engagement by Treasury and the Federal Reserve is critical and will 

remain so in the future. To that end, FIO participates 

in the IAIS Strategic Plan and Financial Outlook 

Task Force (SPFOTF). 

The SPFOTF’s mandate is to develop a draft strategic plan and financial outlook for the IAIS. This 

plan aims to include (1) a proposal whether to add or 

remove IAIS subcommittees; (2) the most effective 

governance framework for strategic plan implementation, including appropriate representation of different types of insurance markets and different geographic areas in the ExCo, and membership and 

leadership of IAIS committees and subcommittees; 

and (3) a proposal for IAIS funding arrangements.75 

Framework and Decides Not to Engage in an Identification of 

G-SIIs in 2018,” press release, November 14, 2018, http://www 

.fsb.org/2018/11/fsb-welcomes-iais-proposed-insurancesystemic-risk-framework-and-decides-not-to-engage-in-anidentification-of-g-siis-in-2018/. See also FSB, 5th Annual 

Report, 8. 73 See Treasury, Insurance EO Report, 97. 74 See generally National Association of Insurance Commissioners (NAIC), “Macroprudential Initiative (MPI),” https://www 

.naic.org/cipr_topics/topic_macro.htm. 75 See IAIS, “Newsletter” (November/December 2018): 9, https:// 

www.iaisweb.org/page/news/newsletter-archive/file/78223/iaisnewsletter-november-december-2018. 

The SPFOTF convened on a regular basis during 

2018, discussing IAIS priorities and stakeholder 

input. As noted earlier in the section entitled “IAIS 

Overview,” FIO gained permanent membership status on the ExCo as a result of these changes. 

The proposed strategic plan for 2020–24 recognizes 

that the IAIS will be moving toward different priorities in the next five years as it largely completes its 

package of post-financial crisis reforms. As the IAIS 

recently noted, “There is a clear sense that IAIS core 

functions are not in need of an overhaul. Rather, 

what is being discussed is a shift in the focus or 

emphasis of these activities to take into account the 

fast-changing global context in which the IAIS operates.”76 The draft strategic plan therefore shifts the 

IAIS focus toward higher-level work; implementation and monitoring; and addressing current and 

evolving issues. Specifically, three key IAIS messages 

in the strategic plan will be to 

1. Finalize the post-crisis reforms, including the 

ICS, ComFrame, and the holistic framework for 

mitigating systemic risk; 

2. Pivot towards implementation of IAIS standards 

and effective supervisory practices; and 

3. Meet the challenges, risks, and opportunities 

around emerging trends such as fintech, cyber 

risk, climate risk, and sustainable finance.77 

The strategic plan for 2020–24 is scheduled to be 

finalized and approved in 2019. 

Other IAIS Work 

Implementation and Assessment 

Committee 

With substantial policy development milestones 

planned for 2019, the IAIS anticipates pivoting from 

the development of standards to supporting the 

implementation and assessment of standards.78 

Team USA continues to advocate for practices at the 

76 IAIS, “Newsletter” (September 2018): 2, https://www.iaisweb 

.org/page/news/newsletter-archive/file/76947/iais-newsletterseptember-2018. 77 Jonathan Dixon, “Important Years Ahead for the IAIS” 

(speech at the PROGRES Seminar, Zurich, Switzerland, February 28, 2019), https://www.iaisweb.org/page/news/speeches//file/ 

81000/secretary-general-jonathan-dixon-geneva-associationaddress-28-february-2019. 78 Jose Lopez Hoyo, “IAIS Major Projects Update – Implementation and Assessment Committee” (presented at the IAIS 

Annual Conference, Luxembourg, November 8–9, 2018), https 
September 2019 13 

IAIS, including assessment activities that are appropriate for U.S. interests and the U.S. insurance supervisory system. 

The IAIS’s Implementation and Assessment Committee (IAC) is tasked with facilitating the conformance of IAIS members with IAIS supervisory 

material through assessments of, and assistance with, 

the implementation of IAIS standards.79 To achieve 

its mandate, the IAC may liaise on standards implementation and assessment matters with external bodies, such as the International Monetary Fund, World 

Bank, FSB and its Standing Committee on Standards Implementation, BIS, BCBS, and the International Organization of Securities Commissions. It 

also may support supervisory discussion and sharing 

of best practices, addressing implementation challenges, and discussing emerging issues. 

In 2017, the IAIS approved a revised approach to its 

assessment activities. Building upon the existing selfassessment peer review (SAPR) process, the new 

approach will expand the SAPR process into (1) the 

Peer Review Process (PRP); (2) the Self-Assessment 

Process (SAP); and (3) the Member Assessment Process (MAP), which incorporates an on-site review of 

the member jurisdiction.80 The primary difference 

between the SAPR and PRP processes for members 

is “the inclusion of recommendations on how to 

strengthen observance and increased disclosure of 

assessment results.”81 A new IAC subcommittee, the 

Standards Assessment Working Group (SAWG), will 

oversee the assessment of the implementation of the 

IAIS’s supervisory material. 

The SAWG met for the first time in 2018 and initiated a PRP on supervisors and supervisory powers 

(ICPs 1 and 2).82 

://www.iaisweb.org/page/events/annual-conference/annualconference-2018/highlight=annual%20conference%202018##. 79 See IAIS, IAIS 2017 Annual Report, 9. 80 IAIS, “Newsletter” (April 2018), https://www.iaisweb.org/page/ 

news/newsletter-archive/file/74202/iais-newsletter-april-2018; 

see also NAIC, “Insurance Core Principles” (last updated January 22, 2019), https://www.naic.org/cipr_topics/topic_ 

insurance_core_principles.htm. 81 IAIS, “Peer Review Process Questionnaire: ICPs 4, 5, 7, and 8,” 

https://www.iaisweb.org/page/supervisory-material/ 

implementation-and-capacity-building/assessments/file/80791/ 

questionnaire-for-prp-on-icps-4-5-7-8-final. Members may opt 

out of disclosing assessment results to other IAIS members. 82 See IAIS, “Newsletter” (September 2018): 7. 

IAIS Work Product 

Treasury and the Federal Reserve participate in 

many of the committees and subcommittees that 

develop and draft IAIS written materials. In preparing these materials, Treasury and the Federal Reserve 

advocate for inclusion of information and guidance 

reflective of U.S. experience or otherwise relevant to 

U.S. consumers and insurance markets. 

As part of its macroprudential policy and surveillance framework, the IAIS publishes annually the 

Global Insurance Market Report (GIMAR), a 

report that reflects insurer and reinsurer performance and supervisory developments as well as key 

risks in the global insurance market.83 Together with 

the GIMAR, the IAIS undertakes the Key Insurance 

Risks and Trends (KIRT) survey of IAIS members 

in different jurisdictions throughout the world based 

on 22 broad risk indicators.84 

The IAIS also regularly produces “supporting materials”—Issues Papers and Application Papers—as 

well as other materials, such as correspondence and 

proposals. Issues Papers provide background on particular topics; describe current practices, examples, 

or case studies on a topic; or identify related regulatory and supervisory issues and challenges. They are 

“not meant to create expectations on how supervisors should implement supervisory material” but 

may form part of the preparatory work for developing future standards or recommend future work by 

the IAIS.85 Application Papers are intended to “help 

with the practical application of supervisory material” through “advice, illustrations, recommendations 

or examples of good practice to supervisors on how 

supervisory material [ICPs, ComFrame, and/or 

G-SII policy measures] may be implemented.”86 As 

with supervisory materials, supporting material 

undergoes a public consultation process. IAIS materials published between May 24, 2018, and December 31, 2018, include 

83 IAIS, “Global Insurance Market Report (GIMAR),” https:// 

www.iaisweb.org/page/supervisory-material/financial-stabilityand-macroprudential-policy-and-surveillance/global-insurancemarket-report-gimar. See also IAIS, 2017 IAIS Annual 

Report, 14. 84 IAIS, 2017 IAIS Annual Report, 29. See also IAIS, “Newsletter” (May 2018): 4, https://www.iaisweb.org/page/news/ 

newsletter-archive/file/74724/iais-newsletter-may-2018. 85 IAIS, 2017 IAIS Annual Report, 12. 86 IAIS, 2017 IAIS Annual Report, 12. 
14 Global Insurance Regulatory or Supervisory Forums in 2018 

Issues Papers87 

• IAIS, Issues Paper on Index-based Insurances Particularly in Inclusive Insurance Markets 

(June 2018). 

• IAIS and Sustainable Insurance Forum, Issues 

Paper on Climate Change Risks to the Insurance 

Sector (July 2018). 

• IAIS, Issues Paper on Increasing Digitalization in 

Insurance and its Potential Impact on Consumer 

Outcomes (November 2018). 

Application Papers88 

• IAIS, Application Paper on the Use of Digital Technology in Inclusive Insurance (November 2018). 

• IAIS, Application Paper on Supervision of Insurer 

Cybersecurity (November 2018). 

• IAIS, Application Paper on the Composition and the 

Role of the Board (November 2018). 

Other Materials 

• Response to Monitoring Group Consultation on 

Strengthening the Governance and Oversight of the 

International Audit-Related Standards-Setting 

Boards in the Public Interest (January 2018).89 

• Holistic Framework for Systemic Risk in the Insurance Sector (November 2018).90 

IAIS Cross-Border Resolution 

Planning Activities 

As with other topics, Treasury and the Federal 

Reserve maintain that cross-border resolution planning must take into account existing U.S. supervisory 

practices. At the IAIS, such planning occurs through 

the Resolution Working Group (ReWG). 

87 IAIS, “Issues Papers,” https://www.iaisweb.org/page/ 

supervisory-material/issues-papers. 88 IAIS, “Application Papers,” https://www.iaisweb.org/page/ 

supervisory-material/application-papers. 89 Letter from IAIS to Gerben Everts, Chair of the Monitoring 

Group (January 29, 2018), https://www.iaisweb.org/page/ 

supervisory-material/comment-letters/file/73427/iais-commentson-mg-consultation-january-2018. 90 IAIS, Holistic Framework Consultation Document, 58. 

ReWG also represents the IAIS at relevant FSB bodies, such as the Resolution Steering Group (ReSG) 

and its subcommittee, the Cross-Border Crisis Management Group for Insurers (iCBCM). 

The IAIS formed the ReWG in late 2013 to develop 

and maintain supervisory guidance on the resolution 

of insurers, including G-SIIs, and to contribute to 

the resolution-related content of ComFrame and 

related ICPs. FIO currently chairs the ReWG. The 

In furtherance of its supervisory guidance mission, 

in 2017 the ReWG proposed and developed significant revisions to ICP 12 (Exit from the Market and 

Resolution).91 Also in 2017, the ExCo endorsed ICP 

12 as revised, which will likely be adopted (along 

with the rest of the revised ICPs) in November 2019. 

Additionally, newly drafted ComFrame material 

related to resolution will be incorporated into ICP 

12; this material (along with other ComFrame material) was the subject of public consultation in late 

2018.92 The IAIS also released for public consultation new sections in ICP 16 (Enterprise Risk Management for Solvency Purposes) to provide guidance 

on recovery planning.93 Since recovery planning was 

a completely new topic, and to reflect comments 

received in its public consultation, the ReWG drafted 

an Application Paper on Recovery Planning and 

released it for public consultation in November 2018.94 

FSB Cross-Border Resolution 

Planning Activities 

The FSB oversees some insurance resolution planning work through the iCBCM. In 2014, the FSB 

released its Key Attributes for Effective Resolution 

Regimes for Financial Institutions, which covers 

financial institutions overall and is not specific to 

insurers.95 The FSB’s iCBCM assists and supports 

regulatory authorities in the development and implementation of resolution-related policy measures for 

insurance. Specifically, the iCBCM collaborates with 

the ReWG in developing guidance for resolution 

91 IAIS, “Draft Revised ICP 12,” https://www.iaisweb.org/page/ 

supervisory-material/insurance-core-principles//file/69884/draftrevised-icp-12. 92 IAIS, Draft Overall ComFrame, 43. 93 IAIS, “Revised ICP 16 and ComFrame material in ICP 16 for 

public consultation (clean version),” 31-36 (showing revised 

ICP 16.13), https://www.iaisweb.org/page/consultations/closedconsultations/2018/revision-icps-8-15-and-16//file/69914/ 

revised-icp-16-and-comframe-material-in-icp-16-forconsultation-clean. 94 IAIS, Draft Application Paper on Recovery Planningfor Public 

Consultation (Basel: IAIS, November 2018), https://www 

.iaisweb.org/page/consultations/closed-consultations/2018/ 

application-paper-on-recovery-planning//file/77804/draftapplication-paper-on-recovery-planning. 95 FSB, “Key Attributes of Effective Resolution Regimes for 

Financial Institutions” (October 15, 2014), http://www.fsb.org/ 

wp-content/uploads/r_141015.pdf. 
September 2019 15 

powers and tools regarding insurers as well as 

addressing issues relating to their application.96 In 

addition, the IAIS also works on the development of 

resolution-related policy standards for a broad range 

of insurance firms as noted above. 

96 FSB, FSB 2018 Resolution Report: Keeping the Pressure Up, 

(Basel: FSB, November 2018), 10, https://www.fsb.org/wpcontent/uploads/P151118-1.pdf. 

tions in the insurance sector.

In March 2018, the FSB completed a consultation 

on the Key Attributes Assessment Methodology for 

the Insurance Sector, which is a proposed approach 

for assessing implementation of the Key Attributes of 

Effective Resolution Regimes for Financial Institu97 In November 2018, 

the FSB issued its seventh report on the implementation of resolution reforms, which noted that the 

iCBCM intends to continue to serve as a forum for 

authorities to share views, exchange experiences, and 

discuss challenges in relation to orderly resolution of 

insurers.98 

97 See FSB, “Public responses to the consultation on Key Attributes Assessment Methodology for the Insurance Sector” 

(March 5, 2018), http://www.fsb.org/2018/03/public-responsesto-the-consultation-on-key-attributes-assessment-methodologyfor-the-insurance-sector/; http://www.fsb.org/wp-content/ 

uploads/P211217.pdf; FSB, “Key Attributes Assessment Methodology for the Insurance Sector: Consultative Document” 

(December 2017), http://www.fsb.org/2017/12/key-attributesassessment-methodology-for-the-insurance-sector-consultativedocument/. 98 FSB, FSB 2018 Resolution Report, 10. 
17 

Transparency Efforts 

In November 2018, Treasury and the Federal 

Reserve issued a report on Efforts to Increase Transparency at Meetings of the International Association 

of Insurance Supervisors.

99 Some stakeholders have 

commented that the standard-setting process at the 

IAIS is not sufficiently transparent, as stakeholders 

generally are not able to participate until late in the 

policy development process. Although the IAIS has 

taken initial steps to improve transparency, Treasury 

and the Federal Reserve support the objective of further increasing transparency and stakeholder input 

into IAIS’s policy development process. As detailed 

in the report, Treasury and the Federal Reserve are 

committed to transparency in the international insurance standard-setting process at the IAIS. 

The governing documents of the IAIS include guiding principles for stakeholder engagement and transparency. In particular, the IAIS by-laws state that the 

IAIS “will operate in an open and transparent manner[,] setting an appropriate example of transparency, administrative due process[,] and governance, 

while maintaining the ability for supervisors to 

exchange information in confidence.”100 The IAIS 

has recognized effective stakeholder engagement as 

an institutional priority. Its Stakeholder Engagement 

Plan, adopted in March 2017, recognizes past 

engagement efforts and recommends additional 

engagement commitments, policies, and strategies.101 

There are several means by which the IAIS fosters 

transparency through engagement with stakeholders. 

Since 2016, the IAIS’s annual conference has been 

open to stakeholders and the general public.102 

99 Federal Reserve and Treasury, Transparency Report. 100“IAIS By-Laws,” Art. 2(3). 101See IAIS, Stakeholder Engagement Plan (Basel: IAIS, 

March 2017), https://www.iaisweb.org/page/about-the-iais/ 

policies-and-procedures//file/65579/iais-stakeholderengagement-plan-2017. See also IAIS, 2017 Annual Report, 10 

(referencing the “commitments contained in the IAIS Stakeholder Engagement Plan”). 102See, e.g., IAIS, “International Association of Insurance Supervisors 25th Annual Conference,”

committee and subcommittee activity, and listing 

upcoming meetings. The IAIS has expanded steps to 

make its newsletter more userfriendly for stakeholders by highlighting stakeholder engagement opportunities and providing more hyperlinks to referenced 

materials.

The 

IAIS routinely publishes newsletters summarizing 

103 Before finalizing and issuing any revised 

ICPs or ComFrame material (i.e., standards), issue 

papers, or application papers (i.e., guidance), the 

IAIS publishes draft versions for public comment, 

allows a reasonable period for submission of feedback, and then presents a record of how such input 

from stakeholders has been addressed or resolved by 

the relevant IAIS committees or subcommittees. All 

current and closed consultations, from 2012 through 

2018, are available through the IAIS website.104 To 

enhance public consultation on major policy documents (e.g., ICS Version 2.0 and overall ComFrame 

revisions), the IAIS holds dedicated public background sessions.105 Finally, the IAIS organizes other 

stakeholder events for projects, such as the ICS and 

public consultations through which Team USA has 

additional opportunities to solicit stakeholder comments and feedback. 

.iaisweb.org/2018/welcome.html

https://annualconference 

; IAIS, Stakeholder Engagement 

Plan, section I(J). 103See, e.g., IAIS, “Newsletter,” https://www.iaisweb.org/page/ 

news/newsletter; IAIS, Stakeholder Engagement Plan, 

section I(K). 104IAIS, “Consultations,” https://www.iaisweb.org/page/ 

consultations. See also FIO, 2018 Annual Report (providing 

table listing, by ICP, all public consultations related to ICP and 

ComFrame revisions in 2017 and 2018, as of July 31, 2018; an 

updated version of the table is reproduced in this report as 

table 2). 105See, e.g., IAIS, “IAIS nears the final stages in the development 

of a Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame) with publication of 

a consultation package,” press release, July 31, 2018, (noting the 

release of the overall ComFrame, including ICS Version 2.0 for 

public consultation as well as date, time, and registration process for public background session), https://www.iaisweb.org/ 

page/news/press-releases//file/76161/31-july-2018-iais-pressrelease-iais-publishes-comframe-ics-consultation-package. Note 

that all consultations are commenced both by publication of 

the relevant materials and at least a telephonic background session open to the public. 
Table 3. IAIS stakeholder meetings in 2018 

Meeting date Session topic 

Jan. 13, 2018 ICS ABA Stakeholder Meeting in Nashville 

Feb. 1, 2018 ABA Stakeholder Meeting in London 

Mar. 2, 2018 Public Background Session on Draft Application Paper on the Use of Digital Technology in Inclusive Insurance 

Mar. 27, 2018 Public Discussion Session on ComFrame Material (ICP 10.3 and ComFrame Material Integrated with ICPs 5, 7, 8, 9, 10, 12 and 25) 

Apr. 10, 2018 Public Background Session on the Draft Issues Paper on Climate Change Risks to the Insurance Sector 

Public Background Session on Supervisory and Supporting Material Published for Consultation on 29 June 2018: draft Application Paper on the 

Jul. 16, 2018 Composition and the Role of the Board; draft Application Paper on Supervision of Insurer Cybersecurity; draft revised ICPs 6, 20 

Jul. 31, 2018 Session on Climate Change Risks to the Insurance Sector Issues Paper 

Aug. 1, 2018 Public Background Session on draft Issues Paper on the Increasing Use of Digital Technology in Insurance 

Aug. 2, 2018 Session on Index-Based Insurances Issues Paper 

Aug. 29, 2018 Public Background Session on Draft Overall ComFrame and ICS Version 2.0 Consultation Document, Public Discussion on ComFrame in ICPs 8, 15, and 16 

Basel Stakeholder Event on Recovery Planning and Resolution: Revised ICP 16; ComFrame Material integrated with ICPs 12 and 16; draft Application Paper 

Sep. 12, 2018 on Recovery Planning 

Public Background Session and Public Discussion Session on IAIS Supporting Material: draft Application Paper on Proactive Supervision of Corporate 

Nov. 15, 2018 Governance; Application Paper on the Use of Digital Technology in Inclusive Insurance 

Public Discussion and Public Background Session on IAIS Supervisory and Supporting Material: Revised ICPs 6, 8, 15, 16, and 20; Application Paper on the 

Composition of the Board; Application Paper on Supervision of Insurer Cybersecurity; Issues Paper on Increasing Digitalisation in Insurance and its Potential 

Nov. 21, 2018 Impact on Consumer Outcomes 

Nov. 29, 2018 Public Background Session on the Holistic Framework for Systemic Risk in the Insurance Sector 

Dec. 5, 2018 Accounting and Auditing Working Group 

Source: IAIS, “Stakeholder Meetings,” https://www.iaisweb.org/page/events/stakeholder-meetings/previous-meetings 

18 Global Insurance Regulatory or Supervisory Forums in 2018 

Individual IAIS committees or subcommittees also 

may conduct stakeholder outreach. For example, the 

IAIS ReWG, which FIO currently chairs, typically 

holds one stakeholder session each year to discuss 

recovery and resolution matters (see table 3).106 

Because much of the ICP and ComFrame material 

on recovery planning and resolution developed over 

the past few years is new, ReWG has sought stakeholder engagement in the development process, finding such input to be a valuable piece of the overall 

process for developing new supervisory standards 

and guidance. ReWG conducts these sessions as an 

open forum for the mutual exchange of ideas, suggestions, insights, and concerns; stakeholder sessions 

are open to all interested parties. Similarly, the 

Accounting and Auditing Working Group has 

engaged with interested stakeholders.107 These sessions have received positive feedback from 

stakeholders. 

106See, e.g., IAIS, “Newsletter” (May 2018): 4 (announcing September 12 stakeholder meeting). 107IAIS, “Newsletter” (May 2018): 4. 

updates on its IAIS work at open meetings of the 

FACI.

Treasury and the Federal Reserve strongly support 

transparency and stakeholder engagement in the 

policy development process at the IAIS. To that end, 

Team USA routinely hosts meetings and active 

working sessions with U.S. insurance industry stakeholders for open dialogue regarding policy matters 

currently before the IAIS. In addition, FIO provides 

108 FIO also details IAIS developments in its 

Annual Reports to Congress, which are publicly 

available on Treasury’s website.109 The Federal 

Reserve meets with interested parties and will engage 

with its IPAC to maintain a robust appreciation for 

stakeholder views regarding matters before the IAIS 

and other international insurance issues. 

Treasury and the Federal Reserve continue to believe 

that the IAIS, its members, and stakeholders can 

benefit from increased transparency in the international standard-setting process. Treasury and the 

Federal Reserve, along with state insurance commissioners and the NAIC, therefore will continue to provide formal and informal opportunities for U.S. 

stakeholders to engage with Team USA members on 

issues arising before the IAIS. These include the 

types of activities and opportunities described above 

as well as other opportunities that Team USA or 

stakeholders may propose. Further, Treasury and the 

Federal Reserve will continue to advocate for greater 

108Treasury, “Federal Advisory Committee on Insurance (FACI),” 

https://www.treasury.gov/initiatives/fio/Pages/faci.aspx. 109See, e.g., FIO, 2018 Annual Report, 18-19 (explaining the 

activities-based approach to assessing and measuring systematically risky activities); 20-22 (providing updates on ICS development); 22-23 (discussing IAIS liquidity management and liquidity stress testing efforts); 36-37 (describing recent structural 

changes within the IAIS); 38-39 (detailing FIO’s role within the 

IAIS); and 39-40 (outlining recent public consultations on ICP 

and ComFrame revisions). 
September 2019 19 

transparency and stakeholder engagement at the 

IAIS. 

Insurance sector stakeholder engagement at the FSB 

has been shaped by the FSB’s limited direct involvement in insurance matters. To date, the FSB’s 

involvement in the insurance sector has been largely 

limited to the publishing an annual G-SII list (until 

2016) and recovery planning and resolution matters. 

In the recovery planning and resolution area, the 

iCBCM has held several stakeholder sessions. These 

sessions focus on invited stakeholders, seeking their 

input to the iCBCM on specific topics. Future insurance stakeholder engagement will need to be evaluated in the context of evolving forms of involvement 

in insurance matters. 

the FSB. The FSB Plenary agreed in October 2017 to 

a review of the FSB’s processes, procedural guidelines, and transparency to ensure effective operation 

as it becomes more focused on the implementation 

and effects of the G-20 financial regulatory reforms. 

The FSB completed its review in November 2018.

Treasury and the Federal Reserve also support transparency and appropriate stakeholder engagement at 

110 

This review encouraged the FSB to enhance both 

internal and external transparency, reinforce the 

member-driven character of FSB initiatives, and 

streamline FSB processes. 

110FSB, “FSB Completes a Review of Its Processes and Transparency to Maximise its Effectiveness,” press release, November 27, 2018, https://www.fsb.org/2018/11/fsb-completes-areview-of-its-processes-and-transparency-to-maximise-itseffectiveness/. 
21 

Conclusion 

In 2018, Treasury and the Federal Reserve—in coordination with other Team USA members—advocated for the continued 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. While many of the 

IAIS standards are not yet final, they could in the 

future have effects on U.S. insurance companies 

operating in foreign markets as well as effects on the 

U.S. insurance regulatory system. 

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 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. 
home.treasury.gov 

www.federalreserve.gov 

0919