R EPORT TO THE C ONGRESS 

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 

December 2020 

Steven T. Mnuchin 

Secretary

U.S. Department of the Treasury 

Jerome H. Powell 

Chair 

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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(email) Publications-BOG@frb.gov 
iii 

Contents 

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

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

International Forums: the IAIS, the FSB, and the OECD ................................................................ 3 

IAIS Activities ............................................................................................................................. 6 

FSB Cross-Border Resolution Planning Activities ........................................................................ 12 

Transparency Efforts at the IAIS and the FSB ............................................................ 15 

IAIS Transparency Efforts .......................................................................................................... 15 

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

Federal Advisory Committee on Insurance ................................................................................. 17 

Insurance Policy Advisory Committee ........................................................................................ 18 

Conclusion ............................................................................................................................... 19 
1 

Introduction 

This report is submitted by the Secretary of the U.S. 

Department of 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, which 

was signed into law by President Donald J. Trump on 

May 24, 2018, directs the Secretary of the Treasury 

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

efforts of Treasury and the Federal Reserve, 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 is the second annual report and follows the 

same format as the first annual report.2 Specifically, 

the report begins, in the section “International Insurance Issues, Positions, and Effects,” by describing in 

general terms the efforts of the Federal Reserve and 

Treasury 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 standardsetting initiatives, such as the development of the 

Insurance Core Principles (ICPs) and the Common 

Framework for the Supervision of Internationally 

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, 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://home.treasury.gov/system/files/311/ 

Treasury_FRB_Report_2019.pdf. For reader convenience, 

some background material from the 2018 Fed-FIO Annual 

Report is repeated in this report. 3 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 Global Insurance Regulatory or Supervisory Forums in 2019 

Active Insurance Groups (ComFrame), the Insurance Capital Standard (ICS), the Holistic Framework for Systemic Risk in the Insurance Sector, and 

other initiatives. 

The report continues, in the section “Transparency 

Efforts at the IAIS and the FSB,” by providing a 

summary of Treasury and Federal Reserve efforts 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 Treasury and the Federal Reserve, collectively 

called “Team USA”).4 This section also provides an 

update on the implementation by the Federal 

Reserve of the Insurance Policy Advisory Committee 

(IPAC), established pursuant to the Act’s requirements.5 It also 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 

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. Team USA members’ leadership and involvement in the IAIS and other international forums, as 

discussed in this report, ensure that the United States 

continues to be able to influence international standards for insurance supervision and regulation that 

may affect the U.S. insurance industry and consumers. 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. Any 

standards developed in the IAIS or in any other 

standard-setting bodies are intended to be implemented in accordance with domestic law. In the 

United States, therefore, no international standards 

are 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 

2019 Annual Report and 2020 Annual Report.

7 FIO’s 

2019 Annual Report and 2020 Annual Report include 

detailed descriptions of FIO’s international and 

domestic activities in the first half and second half of 

2019, respectively. FIO’s annual reports also discuss 

international activities outside of global insurance 

regulatory and supervisory forums (e.g., IAIS, FSB, 

and OECD); these activities include 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 

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 2020 

Annual Report discusses input received from the 

FACI, including through its subcommittee on international developments.8 

This report covers activities within the IAIS, the 

FSB, and the OECD, and generally addresses developments during the preceding calendar year—i.e., 

2019. This report, therefore, does not address the 

substantial effects of the COVID-19 global pandemic 

on international supervisors’ agendas and activities, 

which will be covered in next year’s annual report.9 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://www.treasury.gov/initiatives/fio/reports-andnotices/Documents/2018_IAIS_Transparency_Report.pdf; 

FIO, Annual Report on the Insurance Industry (2019) (2019 

Annual Report) (Washington: FIO, 2019), https://home.treasury 

.gov/system/files/311/2019_FIO_Annual_Report.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). 

7 FIO, 2019 Annual Report, FIO, Annual Report on the Insurance 

Industry (2020) (2020 Annual Report) (Washington: FIO 2020), 

https://home.treasury.gov/system/files/311/2020-FIO-AnnualReport.pdf. 8 “Federal Advisory Committee on Insurance (FACI),” U.S. 

Department of the Treasury, https://www.treasury.gov/ 

initiatives/fio/Pages/faci.aspx. 9 The IAIS, FSB, and OECD are examining the impact of the 

COVID-19 pandemic on the insurance sector, as is Team USA. 

FIO discusses the pandemic in its 2020 Annual Report. 
3 

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.10 As previously reported, 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.11 The Federal 

Reserve and Treasury 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. 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 USA, 

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

forums.”12 

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.13 While certain IAIS standards remain 

under development, depending on how they are 

finalized, they could affect U.S. insurers. U.S. insurers operating in foreign markets could be affected 

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.”14 In their international engagement on 

insurance issues, 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 

closely with each other and with the other members 

of Team USA. 

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 supervision of the insurance sector.15 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 210 jurisdictions accounting for 97 percent of worldwide 

insurance premium volume. 10 16 See Act § 211(c)(1)(A)(i), (iii), 31 U.S.C. § 313 note. 11 See, e.g., 2018 Fed-FIO Annual Report; Treasury, A Financial 

System That Creates Economic Opportunities: Asset Management and Insurance, 105 (2017) (Insurance EO Report) (Washington: U.S. Department of the Treasury, October 2017), 

https://www.treasury.gov/press-center/press-releases/ 

Documents/A-Financial-System-That-Creates-EconomicOpportunities-Asset_Management-Insurance.pdf. 12 Treasury, Insurance EO Report, 136. See also 

31 U.S.C. § 313(c)(1) (listing FIO’s authorities and responsibilities under the Dodd-Frank Act). 13 See Act § 211(c)(1)(A)(ii), 31 U.S.C. § 313 note. 

14 Act § 211(c)(3), 31 U.S.C. § 313 note. 15 See IAIS, 2018 IAIS Annual Report (Basel: IAIS, 2019), 10, 

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

87195/iais-2018-annual-report-single-page

Annual Report, 47-48. 

. See also FIO, 2019 

16 2018 IAIS Annual Report, 6. See also IAIS, IAIS Organisation 

Members (September 20, 2019), https://www.iaisweb.org/list/ 

iaismembers.
4 Global Insurance Regulatory or Supervisory Forums in 2019 

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.”17 

The IAIS operates through five key mechanisms: 

(1) the General Meeting, which ultimately oversees 

all matters before the IAIS; (2) the Executive Committee (ExCo), 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 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.18 The IAIS also 

has an Audit and Risk Committee and a Budget 

Committee.19 

Multiple working groups and task forces, focused on 

a range of prudential regulation and supervision topics, report to these committees.20 All of the committees and subcommittees (where “subcommittees” 

include 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.21 

Figure 1 illustrates the IAIS organizational structure 

in 2019.22 As Secretary Mnuchin observed, the governance changes that became effective in 2019— 

which added FIO as a permanent member, and 

increased the ExCo’s size, among other things— 

“should help us advance the best interests of the U.S. 

insurance sector, as all members of Team USA will 

now have a voice at the most senior levels of the 

IAIS. Treasury will continue to work with the IAIS 

on these governance issues and appropriate geographic representation for the United States at the 

IAIS.”23 

FSB and OECD Overview 

FSB 

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.”24 

The FSB’s decisions are not legally binding on its 

members; 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” in their jurisdictions 

through the relevant financial authorities.25 

The FSB’s membership consists of 68 institutions 

from 25 jurisdictions and 10 international organizations and standard-setting bodies, including the 

IAIS.26 Treasury, the Federal Reserve, and the Securities and Exchange Commission are the FSB’s U.S. 

members.27 The current FSB Chair—as of December 2018—is the Federal Reserve Governor and Vice 

Chair for Supervision, Randal K. Quarles.28 

The FSB has created a compendium of standards 

that have been developed by various standard-setting 

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

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

file/77857/iais-ar-2017-digital-pdf-def-dp. 18 See “IAIS By-Laws,” https://www.iaisweb.org/page/about-theiais/by-laws/file/74644/2017-by-laws; “IAIS Organisational 

Structure,” IAIS, https://www.iaisweb.org/page/about-the-iais/ 

organisational-structure. See also 2018 Fed-FIO Annual Report. 19 2018 IAIS Annual Report, 7. 20 See, e.g., FIO 2019 Annual Report, 47-49. See also IAIS, “IAIS 

Organisational Structure,” https://www.iaisweb.org/page/aboutthe-iais/organisational-structure. 21 See IAIS, 2017 IAIS Annual Report, 8. 22 The IAIS agreed in 2019 that, as of January 2020, three of the 

existing Macroprudential Policy Committee subcommittees— 

the Macroprudential Policy and Surveillance Committee, the 

Systemic Risk Assessment Drafting Group, and the G-SII Analysts Working Group—will be replaced by two new subcommittees: the Macroprudential Supervision Working Group 

(MSWG) and the Macroprudential Monitoring Working 

Group (MMWG). See IAIS, IAIS Newsletter December 2019-

January 2020, https://www.iaisweb.org/page/news/newsletter/ 

file/88456/iais-newsletter-december-2019-january-2020. 

23 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. For further detail 

about the changes, see 2018 Fed-FIO Annual Report, 4. 24 See 2018 Fed-FIO Annual Report. See also Treasury, Insurance 

EO Report, 57–59, 130; 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. 25 “About the FSB,” FSB, http://www.fsb.org/about/#history. 26 FSB, 5th Annual Report: 1 April 2017–31 March 2018 (Basel: 

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

uploads/P011218.pdf. 27 FSB, 5th Annual Report, 37; FSB, “Randal K. Quarles,” http:// 

www.fsb.org/profile/randal-k-quarles/. 28 FSB, “Organisational Structure and Governance,” http://www 

.fsb.org/organisation-and-governance/. 
December 2020 5 

Figure 1. IAIS organizational structure, 2019 

Insurance

Capital

Standard

Task Force

Committees

Working Groups

Expert Teams

Forums

Task Forces

Insurance

Capital

Standard

Task Force

Strategic Plan

& Financial

Outlook

Task Force

Implementation

& Assessment

Committee

General

Meeting

Executive

Committee

Policy

Development

Committee

FinTech

Forum

Financial

Inclusion

Working Group

Standards

Assessment

Working Group

Member

Assessment

Process Expert

Team (2019, Q3)

Supervisory

Forum

Signatories

Working Group

G-SII

Implementation

Monitoring

Expert Team

Core

Curriculum

Task Force

Chairs of

Working Parties

of the PDC

Capital,

Solvency &

Field Testing

Working Group

Market Conduct

Working Group

Governance

Working Group

Financial Crime

Task Force

Accounting

& Auditing

Working Group

Insurance

Groups

Working Group

Resolution

Working Group

Supervisory

Material

Review

Task Force

Task Force on

Systemically

Important Banks

& Insurers

Systemic Risk

Assessment

Drafting Group

G-SII Analysts

Working Group

Macroprudential

Policy &

Surveillance

Working Group

Macroprudential

Committee

Budget

Committee

Coordination

Group

Source: FIO. See also IAIS, “IAIS Organisational Structure,” https://www.iaisweb.org/page/about-the-iais/organisational-structure. 

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.”29 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 Resolution Regimes for Financial Institutions (discussed 

later in “FSB Cross-Border Resolution Planning 

Activities”), and the G-20/OECD Principles of Corporate Governance.30 

OECD 

The OECD in its present form was created in 1961 

with a mission of promoting policies that improve 

the economic and social well-being of people around 

the world. The OECD provides a forum in which its 

37 member countries work together to share experiences and seek solutions to common problems.31 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. 29 FSB, “The Compendium of Standards,” http://www.fsb.org/ 

work-of-the-fsb/about-the-compendium-of-standards/. 30 FSB, “Key Standards for Sound Financial Systems,” http:// 

www.fsb.org/work-of-the-fsb/about-the-compendium-ofstandards/key_standards/. 

31 See Organisation for Economic Co-Operation and Development (OECD), “About the OECD,” http://www.oecd.org/ 

about/. 
6 Global Insurance Regulatory or Supervisory Forums in 2019 

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 

FIO and the U.S. Departments of Commerce and 

Labor, 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 has developed. Since 

1961, the IPPC has helped develop 22 of these legal 

instruments, 10 of which—all non-legally-binding 

recommendations—remain in force (see table 1).32 

These recommendations from the IPPC are set forth 

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

in the IPPC or WPPP in 2019. 

Over the next few years, the IPPC is expected to continue to address issues relating to long-term care 

insurance, reinsurance, best practices for insurance 

regulation, international insurance standards, and 

terrorism insurance. All of these issues touch on significant U.S. policy initiatives currently being led by 

Treasury. FIO noted in both its 2019 Annual Report 

and 2020 Annual Report that it is important that FIO 

take an active leadership role in the international 

work on insurance matters at the OECD. 

IAIS Activities 

The key “insurance regulatory or supervisory 

standard-setting issues under discussion” at the IAIS 

include (1) the ICPs and ComFrame, (2) the ICS, 

(3) the Holistic Framework for the assessment and

mitigation of systemic risk, (4) the IAIS strategic

plan and financial outlook for 2020–24, and

(5) other IAIS work such as assessments and development of guidance and other written materials as

well as cross-border resolution planning. Much of

the work described below is ongoing and is expected

to continue through 2020 and beyond.

ICPs and ComFrame 

Team USA continues to work within the IAIS to 

advocate for international standards for insurance 

supervision that are appropriate for the U.S. insurance sector. The international insurance standards of 

broadest potential applicability are the ICPs. 

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.”33 To support that mission, the 

IAIS has developed a three-tier approach to insurance supervision: (1) a first tier of supervisory standards, known as ICPs, applicable to all insurers 

within a jurisdiction; (2) a second tier of additional 

supervisory standards known as ComFrame, which 

includes the insurance capital standard (ICS), and to 

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. 

32 OECD, “OECD Legal Instruments involving the Insurance and 

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

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

dateType=adoption. 

33 IAIS, 2017 IAIS Annual Report, 10. See also 2018 Fed-FIO 

Annual Report. 

Table 1. OECD in-force insurance-related recommendations from the IPPC
7 

which only certain insurers are subject;34 and (3) a 

third tier of policy measures for a smaller group of 

organizations previously identified by the FSB as 

global systemically important insurers (G-SIIs), as 

discussed further in the section “Holistic Framework.” As the IAIS has explained 

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.35 

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.”36 

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

degree of international activity that meet criteria 

established by the IAIS37—and consists of an 

enhanced set of supervisory standards, encompassing both entity-level and groupwide supervisory 

standards. The IAIS has explained that “ComFrame 

seeks to assist supervisors in addressing groupwide 

activities and risks; identifying and avoiding supervisory gaps; [and] coordinating supervisory activities 

efficiently and effectively between the groupwide and 

other involved supervisors.”38 Since 2016, the IAIS 

has been directly integrating ComFrame material 

alongside the relevant ICPs to clarify the presentation of the two complementary sets of standards.39 

In 2019, the IAIS continued to release major revisions to the ICPs and ComFrame for public consultation as part of the IAIS’s ongoing thematic effort 

(begun in September 2015) to develop supervisory 

materials more efficiently. Additionally, because 

there were elements of ComFrame that had not been 

fully developed in the 2014 version, the IAIS 

addressed many of these elements as part of the revision process. The IAIS also revised all relevant ICPs 

and ComFrame sections to accommodate, and comport with, the Holistic Framework for Systemic Risk 

(Holistic Framework). IAIS consultations in 2019 

included the following: 

• Draft revised IAIS Glossary, 

• Draft ComFrame Assessment Methodology, 

• Changes in the Introduction to ICPs and ICP 7 

(Corporate Governance) made for consistency 

with ComFrame, and 

• Draft Revised ICP 22 (Anti-Money-Laundering 

and Combatting the Financing of Terrorism).40 

The IAIS also released for public consultation, on 

June 14, 2019, revisions related to the Holistic 

Framework (discussed below in the section, “Holistic 

Framework”), including revisions to 

• ICP 9 (Supervisory Review and Reporting) and 

ComFrame in ICP 9, 

• ICP 10 (Preventive Measures, Corrective Measures 

and Sanctions), 

• ICP 16 (Enterprise Risk Management for Solvency 

Purposes) and ComFrame in ICP 16, 

• ICP 20 (Public Disclosure), and 

• ICP 24 (Macroprudential Supervision).41 

34 IAIS, Draft Overall ComFrame for Public Consultation (clean 

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

(Draft Overall ComFrame), https://www.iaisweb.org/page/ 

supervisory-material/common-framework/file/76143/draftoverall-comframe-for-public-consultation. See also FIO, 2018 

Annual Report, 39. 35 IAIS, 2017 IAIS Annual Report, 12. 36 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. 37 “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. 

December 2020 

38 IAIS, Draft Overall ComFrame, 9 (paragraph 19). 39 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. 40 See IAIS, Public Consultation: IAIS Supervisory Material, 

https://www.iaisweb.org/page/consultations/closedconsultations/2019/iais-supervisory-material. 41 “Public Consultation: Revisions related to the Holistic Framework for Systemic Risk in the Insurance Sector,” IAIS, last 
8 Global Insurance Regulatory or Supervisory Forums in 2019 

At its Annual General Meeting in November 2019, 

the IAIS adopted all of these revisions, including 

ICP revisions consulted upon in 2017 and 2018, the 

entirety of ComFrame, and ICS Version 2.0 (discussed below in the section, “ICS Development and 

Status”).42 With the adoption of the ICS by the IAIS 

for the monitoring period, work will begin in 2021 

on revising ICPs 14 (Valuation) and 17 (Capital 

Adequacy). 

Team USA has engaged in the IAIS process of revising the ICPs and ComFrame to advocate for standards that are appropriate for the United States. 

Team USA members have coordinated their advocacy for appropriate standards in the ICPs and 

ComFrame, resulting in improvements to these standards. Revised ICP and ComFrame provisions, as 

adopted in 2019, are generally consistent with the 

current U.S. insurance supervisory system. 

ICS Development and Status 

As one component of ComFrame, a risk-sensitive 

ICS is under development by the IAIS, which if 

adopted would measure the capital adequacy of an 

entire insurance group.43 The ICS is intended to provide a harmonized capital standard across jurisdictions and create a common language for supervisory 

discussions of group solvency.44 

At its meetings in November 2019, the IAIS 

advanced version 2.0 of the ICS into a five-year 

monitoring period from 2020 through 2024. This followed five years of field testing the ICS with volunteer insurance groups—with each year building upon 

the previous year’s analysis and discussions—and 

three separate public ICS consultations over that 

same period. The compromise agreement reached by 

IAIS members consisted of the following three parts: 

• the design of the reference ICS being developed by 

the IAIS;45 

• the parameters around the operationalization of 

the ICS monitoring period; and 

• the IAIS’s approach to assessing the comparability 

of the ICS and the Aggregation Method (AM), an 

alternative group capital approach to the ICS, 

under development by the U.S. and other interested jurisdictions. 

At the IAIS meetings in November 2019, FIO registered its official objection to the IAIS’s advancement 

of version 2.0 of the ICS into a five-year monitoring 

period.46 The Federal Reserve, along with the NAIC 

and state representatives, supported the IAIS’s compromise.47 Additionally, while the reference ICS 

would recognize a limited number of national discretions, Team USA will continue to advocate for even 

greater jurisdictional flexibility in order to ensure 

that the ICS in its final form accommodates the business model and market practices of the U.S. insurance industry. The Federal Reserve has proposed 

using an aggregation method in its own supervision 

of depository institution holding companies significantly engaged in insurance activities.48 FIO and the 

Federal Reserve will continue their efforts to improve 

the ICS. 

Team USA members participate in the ICS and 

Comparability Task Force, which reports directly to 

the IAIS ExCo. The Task Force provides strategic 

updated June 15, 2019, https://www.iaisweb.org/page/ 

consultations/closed-consultations/2019/revisions-related-toholistic-framework-for-systemic-risk-in-the-insurance-sector. 42 See IAIS, IAIS ICPs and ComFrame Adopted in November 2019, https://www.iaisweb.org/page/supervisory-material/ 

insurance-core-principles-and-comframe/file/89018/iais-icpsand-comframe-adopted-in-november-2019. 43 See IAIS ICPs and ComFrame Adopted in November 2019, 9 

(paragraph 22). 44 See IAIS, Public Consultation: Risk-Based Global Insurance 

Capital Standard (ICS) Version 2.0, https://www.iaisweb.org/ 

page/consultations/closed-consultations/2018/ics-version-20// 

file/76124/ics-version-20-public-consultation-document. 

45 The reference ICS is “based on market-adjusted valuation 

(MAV), the standard method for capital requirements and converged criteria for qualifying capital resources.” See also IAIS, 

Implementation of ICS Version 2.0, 1 (November 2, 2017), 

https://www.iaisweb.org/file/69796/implementation-of-icsversion-20. 46 For more information on Treasury’s position, see Treasury, 

“Readout on the International Association of Insurance Supervisors Annual Meeting,” press release, November 14, 2019, 

https://home.treasury.gov/news/press-releases/sm830. 47 For more information on the Federal Reserve’s position, see 

House Financial Services Committee Hearing on Oversight of 

Prudential Regulators: Ensuring the Safety, Soundness, Diversity, and Accountability of Depository Institutions? 116th 

Cong. (2019) (responses of Randal K. Quarles). For more 

information on the NAIC’s position, see NAIC Press Release 

November 14, 2019, https://content.naic.org/article/news_ 

release_naic_advances_us_objectives_insurance_capital_ 

standard_project.htm, and NAIC Interpretive Guidance on 

ICS Comparability Assessment Framework, https://content 

.naic.org/sites/default/files/inline-files/ICS%20Interpretive% 

20Guidance%20on%20Comparability%20Assessment% 

20Framework.pdf. 48 Federal Reserve, Regulatory Capital Rules: Risk-Based Capital 

Requirements for Depository Institution Holding Companies 

Significantly Engaged in Insurance Activities, 84 Fed. 

Reg. 57,240 (October 24, 2019). 
December 2020 9 

steering on the further improvement of the ICS and 

oversight of the comparability assessment, which 

will determine whether the AM can be recognized as 

an alternative implementation of the ICS. Team 

USA members also participate in the Policy Development Committee, which is responsible for 

standard-setting activities as well as the subcommittees involved in ICS development, monitoring, and 

the data collection exercises. FIO and the Federal 

Reserve will continue to work collaboratively as part 

of Team USA in the engagement with the IAIS during the ICS monitoring period.49 

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

a common methodology through which the ICS 

achieves comparable—i.e., substantially the same— 

outcomes across jurisdictions. Toward that end, the 

IAIS will implement the ICS in two phases: (1) a 

five-year monitoring period from 2020–24 during 

which the ICS will continue to be refined through 

data analysis and feedback from supervisors on its 

performance and practicality, and (2) a subsequent 

phase starting in 2025 when the ICS will be implemented as a prescribed capital requirement. Based 

on the compromise reached in the November 2019 

IAIS meetings, the IAIS has requested that annual 

confidential reporting during the monitoring period 

be strongly encouraged by supervisors, although it is 

not mandatory. Confidential reporting involves the 

reporting of a reference ICS.50 Additional reporting 

of the ICS will be allowed at the option of the 

groupwide supervisor.51 

In addition, the IAIS will make certain key decisions 

during the monitoring period on whether other 

approaches will be part of the final framework 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. To that end, the IAIS plans to issue a public 

consultation in the latter part of the monitoring 

period, requesting feedback on the design of the ICS 

as a prescribed capital requirement as well as on 

GAAP Plus and criteria for evaluating other methods of calculating the ICS capital requirement. 

Ongoing engagement with industry participants continues to aid members of Team USA in advocating 

for an ICS that can meet the needs of the U.S. insurance marketplace. 

In 2019, the IAIS reached an agreement to move forward on the definition of comparable outcomes and 

the overarching approach for the development of 

comparability criteria. Further work will be necessary to develop a comparability assessment. This 

includes (1) establishing high-level principles that will 

feed into the criteria for evaluating the AM relative 

to the ICS, (2) drafting and issuing a public consultation on the definition of comparable outcomes and 

the high-level principles, and (3) developing appropriate comparability criteria based on the high-level 

principles that include feedback from the public consultation. The AM better reflects the U.S. insurance 

regulatory framework than does the reference ICS 

because the AM leverages the Group Capital Calculation, which is being developed by U.S. state regulators, and the Building Block Approach developed by 

the Federal Reserve.52 FIO and the Federal Reserve 

will be engaged actively in these ongoing discussions 

on comparability. 

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.53 In the interim, the Federal 

Reserve and Treasury continue to advocate for an 

ICS that is appropriate for the U.S. insurance sector 

and for the IAIS to continue its efforts to develop the 

criteria and processes such that the AM can be 

deemed a comparable implementation of the ICS. 

Treasury and the Federal Reserve consider that, 

in order for any form of an ICS to be implement49 Treasury, “Readout on the International Association of Insurance Supervisors Annual Meeting,” press release, November 14, 

2019, https://home.treasury.gov/news/press-releases/sm830. 50 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 stan- 5

dards 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. 51 Optional reporting for the ICS can include ICS results based on 

an alternative valuation methodology (generally accepted 

accounting principles with adjustments or GAAP Plus) and 

other methods of calculating the ICS capital requirement 

including with the use of internal models and dynamic hedging. 

2 The Building Block Approach is a capital requirement proposed by the Federal Reserve under which depository institution holding companies significantly engaged in insurance 

activities would be required to aggregate their state-based capital requirements into a consolidated requirement. Federal 

Reserve, Regulatory Capital Rules: Risk-Based Capital 

Requirements for Depository Institution Holding Companies 

Significantly Engaged in Insurance Activities, 84 Fed. 

Reg. 57,240 (October 24, 2019). 53 Act § 211(c)(3)(A), 31 U.S.C. § 313 note. 
10 Global Insurance Regulatory or Supervisory Forums in 2019 

able globally, it must be suitable for the U.S. insurance market. tices.60 The IAIS will also develop and finalize application papers on macroprudential supervision and 

liquidity metrics. These activities will be accompanied by reporting to the FSB and to the public. 

Treasury and the Federal Reserve supported the 

development, adoption, and implementation of the 

Holistic Framework. Although the Holistic Framework has been adopted by the IAIS, significant work 

remains at the IAIS to implement it. Treasury and 

the Federal Reserve will remain actively engaged in 

this ongoing work, advocating for U.S. interests. 

IAIS Strategic Plan 

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

and the Federal Reserve is critical and will remain so 

in the future. To that end, FIO participated in the 

IAIS Strategic Plan and Financial Outlook Task 

Force, which developed the 2020–24 strategic plan 

adopted by the IAIS in 2019.61 

The IAIS’s 2020–24 strategic plan recognizes that the 

IAIS will be moving toward different priorities in the 

next five years, having largely completed the package 

of reforms related to the 2008 financial crisis.62 The 

strategic plan articulates high level goals and strategies to respond to trends and developments that, 

according to the IAIS, have “the potential to reshape 

the business of insurance in the coming years.”63 In 

2019, the IAIS condensed and reframed its prior 

high level goals so that the IAIS core functions can 

evolve to respond to these trends and developments.64 

Holistic Framework 

In November 2019, with approval by the FSB, the 

IAIS finalized the Holistic Framework for implementation. In light of the finalized Holistic Framework, the FSB, in consultation with the IAIS and 

national authorities, suspended identification of 

G-SIIs as of the beginning of 2020.54 Based on the 

initial years of implementation of the Holistic 

Framework, the FSB planned to review the need to 

either discontinue or re-establish an annual identification of G-SIIs by the FSB in 2022.55 

Concurrently with the adoption of the Holistic 

Framework, the IAIS published three related documents—the Holistic Framework,56 an Explanatory 

Note,57 and the Global Monitoring Exercise58—in 

addition to updated ICPs, ComFrame, and guidance.59 As outlined in these published documents, 

the Holistic Framework is comprised of three key 

elements: supervisory material, a global monitoring 

exercise (GME), and an implementation assessment 

of related supervisory material. The IAIS implementation assessment of the Holistic Framework supervisory material will focus on globally consistent and 

effective implementation, building on existing IAIS 

assessment methodologies. It will proceed in phases: 

following the initial baseline assessment the implementation assessment will move towards more intensive jurisdictional assessments, which will include 

targeted, in-depth verification of supervisory prac54 FSB, “FSB welcomes insurance holistic framework,” press 

release, November 14, 2019, https://www.fsb.org/2019/11/fsbwelcomes-insurance-holistic-framework/. 55 The review was initially planned for November 2022, but the 

impact of the COVID-19 global pandemic on the timing of this 

review is still to be determined. 56 IAIS, Holistic Framework for Systemic Risk in the Insurance 

Sector (November 2019), https://www.iaisweb.org/page/news/ 

press-releases-prior-to-2014/file/87109/holistic-framework-forsystemic-risk. 57 IAIS, Explanatory Note on Holistic Framework for the Assessment and Mitigation of Systemic Risk in the Insurance Sector 

(November 2019), https://www.iaisweb.org/page/news/pressreleases-prior-to-2014/file/87113/explanatory-note-on-holisticframework-for-systemic-risk. 58 IAIS, Holistic Framework for Systemic Risk in the Insurance 

Sector: Global Monitoring Exercise (November 2019), https://

www.iaisweb.org/page/news/press-releases-prior-to-2014/file/ 

87206/global-monitoring-exercise. 59 See also the discussion above in the section “ICPs and 

ComFrame.” 

60 IAIS, Explanatory Note on Holistic Framework for the Assessment and Mitigation of Systemic Risk in the Insurance Sector, 3, 

press release, November 2019, https://www.iaisweb.org/page/ 

news/press-releases-prior-to-2014/file/87113/explanatory-noteon-holistic-framework-for-systemic-risk. 61 IAIS, The IAIS Strategic Plan 2020-2024 (June 2019), 3, https:// 

www.iaisweb.org/page/about-the-iais/strategic-plan/file/82533/ 

2020-2024-strategic-plan. 62 IAIS, Strategic Plan, 3. 63 IAIS, Strategic Plan, 3, 5. 64 IAIS, IAIS Mission and 2015-2019 Strategic Goals, https://ww

.iaisweb.org/file/62748/iais-mission-and-2015-19-strategicgoals-amended-12-november-2015

w 

(identifying seven high level 

goals: (1) assessing and responding to insurance sector vulnerabilities; (2) the IAIS as the global standard setter for insurance; (3) contributing to financial stability in the insurance sector; (4) enhancing effective supervision; (5) enhancing implementation and observance of ICPs; (6) effective stakeholder 

outreach and external interaction; and (7) effective and efficient 

organisation and operations). 
December 2020 11 

The 2020–24 strategic plan sets out five new high 

level goals: 

• Assessing and responding to market developments: 

“The IAIS assesses global market trends and developments in, or relevant to, the insurance sector 

and responds to issues that present opportunities, 

challenges, and risks relevant to our Mission.” 

• Standards: “The IAIS sets and maintains globally 

recognized standards for insurance supervision 

that are effective and proportionate.” 

• Supporting supervisory practices: “The IAIS supports its Members by sharing good supervisory 

practices and facilitating understanding of supervisory issues.” 

• Supporting observance of standards: “The IAIS 

assesses and promotes observance of its supervisory material.” 

• Effective operations and transparency: “The IAIS 

operates effectively, efficiently and transparently in 

delivering its Mission and in communicating with 

stakeholders.”65 

The strategic plan also notes that it “does not set out 

a significant increase in the scale of IAIS activities 

but rather a shift in focus in line with the revised 

[high level goals] and new strategic themes.”66 It also 

explains that the governance structure changes to the 

IAIS’s committee structure and composition (discussed in the section “IAIS Overview”) “were introduced in anticipation of the strategic direction” in 

the strategic plan, and in support of the high level 

goals.67 

The IAIS further emphasized that an “important 

component” of the strategic plan is “the additional 

attention it gives to proactive stakeholder engagement.”68 To that end, the IAIS ExCo discussed targeted enhancement to its Stakeholder Engagement 

Plan, which emphasizes the importance of transparency and meaningful dialogue with stakeholders. 

(The IAIS’s stakeholder engagement is discussed 

later in the section “Transparency Efforts at the IAIS 

and the FSB.”) 

Treasury and the Federal Reserve will continue to 

engage with the IAIS and advocate for U.S. interests 

as the IAIS implements the strategic plan. 

Other IAIS Work 

Implementation and Assessment Committee 

In 2020, the IAIS will begin to pivot from the development of standards to supporting the implementation and assessment of standards. Team USA continues to advocate for effective and appropriate practices at the 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 “responsible for issues related to 

assessments and assistance in the implementation of 

IAIS principles, standards and guidance.”69 To 

achieve its mandate, the IAC may support supervisory discussion and sharing of best practices as well 

as discussions intended to address implementation 

challenges and respond to emerging issues. 

In 2019, the IAIS completed its first assessment 

under the new Peer Review Process (PRP) with a 

PRP on ICP 1 (Objectives, Powers, and Responsibilities of the Supervisor) and ICP 2 (Supervisor).70 It 

also completed its first Member Assessment Process 

of Guernsey71 and undertook a PRP on ICPs 4, 5, 7, 

and 8 as well as a PRP on ICP 19.72 

Treasury and the Federal Reserve are both members 

of the IAC and multiple, related subcommittees and 

will continue to advocate for U.S. interests at these 

groups. 

IAIS Work Product 

Treasury and the Federal Reserve continue to 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 

65 IAIS, Strategic Plan, 6, 9-16. 66 IAIS, Strategic Plan, 18. 67 IAIS, Strategic Plan, 18. 68 IAIS, IAIS “Newsletter” (February 2019): 1, https://www 

.iaisweb.org/page/news/newsletter-archive/file/80574/iaisnewsletter-february-2019. 

69 IAIS 2018 Annual Report, 7. 70 IAIS, “Newsletter” (October 2019): 2, https://www.iaisweb.org/ 

page/news/newsletter-archive/file/86774/iais-newsletteroctober-2019. 71 See, e.g., IAIS, “Newsletter” (June 2019): 11, https://www 

.iaisweb.org/page/news/newsletter-archive/file/82778/iaisnewsletter-june-2019 72 See, e.g., IAIS, “Newsletter” (December 2019–January 2020): 9, 

https://www.iaisweb.org/page/news/newsletter/file/88456/iaisnewsletter-december-2019-january-2020. 
12 Global Insurance Regulatory or Supervisory Forums in 2019 

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.73 In July 2019, 

the IAIS released its sixth edition of the GIMAR, 

the 2018 GIMAR.74 

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.75 The IAIS did not publish any issues papers 

in 2019 but did have consultations on a draft “Issues 

Paper on the Implementation of the Recommendations of the Task Force on Climate-related Financial 

Disclosures” and a “Draft Issues Paper on Use of 

Big Data Analytics in Insurance.”76 

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.”77 As 

with supervisory materials, supporting material 

undergoes a public consultation process. The IAIS 

consulted on a “Draft Application Paper on Liquidity Risk Management” and published two application papers in 2019: “Application Paper on Proactive 

Supervision of Corporate Governance” (issued in 

February) and “Application Paper on Recovery 

Planning” (issued in November). 

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. The IAIS formed the Resolution Working 

Group (ReWG) in late 2013 to develop and maintain 

supervisory guidance on the resolution of all insurers, and to contribute to the resolution-related content of ComFrame and related ICPs. FIO currently 

chairs, and the Federal Reserve is a member of, the 

ReWG. The ReWG also represents the IAIS at relevant FSB bodies, such as the Resolution Steering 

Group (ReSG) and its subcommittee, the CrossBorder Crisis Management Group for Insurers 

(iCBCM). 

Over 2018–19, in furtherance of its supervisory guidance mission, the ReWG prepared an “Application 

Paper on Recovery Planning” that was adopted at 

the IAIS Annual General Meeting in November 2019.78 Following the adoption of the “Application Paper on Recovery Planning,” the ReWG began 

drafting another application paper addressing resolution powers and planning based in part on issues 

raised during the consultation on ICP 12 and related 

ComFrame material. Work on this application paper 

is ongoing. 

FSB Cross-Border Resolution 

Planning Activities 

The FSB oversees some insurance resolution planning work through the iCBCM.79 The FSB’s iCBCM 

assists and supports regulatory authorities in the 

development and implementation of resolutionrelated policy measures for G-SIIs. Specifically, the 

iCBCM works under the direction of the FSB’s 

ReSG and in coordination with the IAIS’s ReWG to 

develop guidance for resolution powers and tools 

regarding G-SIIs as well as addressing issues relating 

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

www.iaisweb.org/page/supervisory-material/financial-stability/ 

global-insurance-market-report-gimar. 74 IAIS, 2018 GIMAR (July 2019), https://www.iaisweb.org/page/ 

supervisory-material/financial-stability/global-insurancemarket-report-gimar/file/82889/iais-global-insurance-marketreport-2018v2. See also IAIS, “Newsletter” (Summer 2019): 3, 

https://www.iaisweb.org/page/news/newsletter-archive/file/ 

83788/iais-newsletter-summer-2019. 75 IAIS, “Issues Papers,” https://www.iaisweb.org/page/ 

supervisory-material/issues-papers. 76 IAIS, “Closed Consultations: 2019,” https://www.iaisweb.org/ 

page/consultations/closed-consultations/2019. 77 IAIS, “Application Papers,” https://www.iaisweb.org/page/ 

supervisory-material/application-papers. 

78 IAIS, “Application Paper on Recovery Planning,” (November 2019), https://www.iaisweb.org/page/supervisory-material/ 

application-papers//file/87519/application-paper-on-recoveryplanning. 79 See 2018 Fed-FIO Annual Report. 
December 2020 13 

to their application.80 Both FIO and the Federal 

Reserve are members of the iCBCM. 

In 2014, the FSB released its Key Attributes for 

Effective Resolution Regimes for Financial Institutions (Key Attributes), which covers financial institutions overall, and includes separate annexes for various sectors, including insurance.81 During 2019, the 

iCBCM continued work on the Key Attributes 

Assessment Methodology for the Insurance Sector 

(KAAM), which is a proposed approach for assessing implementation of the Key Attributes in the 

insurance sector.82 The FSB addressed comments 

received from a consultation in March 2018 and 

tested the revised draft in an International Monetary 

Fund Financial Sector Assessment Program (FSAP) 

pilot assessment in 2019. The draft KAAM was further revised in the context of lessons learned during 

the FSAP exercise. 

In November 2019, the FSB issued its eighth 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.83 

2018), http://www.fsb.org/2018/03/public-responses-to-theconsultation-on-key-attributes-assessment-methodology-forthe-insurance-sector/; http://www.fsb.org/wp-content/uploads/ 

P211217.pdf

80 FSB, FSB 2019 Resolution Report: Mind the Gap, (Basel: FSB, 

November 2019), 16, https://www.fsb.org/wp-content/uploads/ 

P141119-3.pdf. 81 FSB, Key Attributes of Effective Resolution Regimes for Financial Institutions (October 15, 2014), http://www.fsb.org/wpcontent/uploads/r_141015.pdf. 82 See FSB, Public responses to the consultation on Key Attributes 

Assessment Methodology for the Insurance Sector (March 5, 

; FSB, Key Attributes Assessment Methodology for 

the Insurance Sector: Consultative Document (December 2017), 

http://www.fsb.org/2017/12/key-attributes-assessmentmethodology-for-the-insurance-sector-consultative-document/. 83 FSB, FSB 2019 Resolution Report, 16. 

15 

Transparency Efforts at the IAIS and the FSB 

Team USA promotes efforts to increase transparency 

at the IAIS and the FSB. It also promotes transparency with stakeholders through the FACI, which 

provides non-binding advice and recommendations 

to FIO, and the IPAC, which serves a similar role for 

the Federal Reserve. 

IAIS Transparency Efforts 

To improve transparency throughout 2019, the IAIS 

continued to build on previously noted steps,84 

including 

• enshrining in IAIS by-laws the requirement to

“operate in an open and transparent manner”;85 

• committing, in its 2017 Stakeholder Engagement

Plan, to enhanced engagement opportunities;86 

• holding an annual conference, open to all stakeholders and the general public;87 and

• expanding reliance on its newsletter and website to

publish key materials and publicize engagement

opportunities.

88 

In 2019, the IAIS secretary general further asserted 

that the IAIS has “a fresh commitment to further 

strengthen these stakeholder engagement efforts.” He 

stated that future plans include extending the length 

of public consultation periods wherever possible; 

expanding the participation of new stakeholders 

(such as FinTech practitioners) in milestone events; 

organizing additional subject matter-specific workshops on emerging or emerged risks; expanding 

external representation in organizations relevant to 

the IAIS’s new strategic themes; extending efforts to 

actively seek input from consumer groups; reaching 

out to academics for global dialogues; and holding 

roundtable discussions with chief risk officers, investors, and rating agencies on sector developments and 

regulatory reforms.”89 

The IAIS also discussed the appropriate level of 

transparency on the identification of IAIGs.90 The 

IAIS will publish a list of IAIGs that have been publicly identified by their groupwide supervisor.91 Neither the Federal Reserve nor FIO currently acts as a 

groupwide supervisor for an IAIG. 

Finalization and adoption of standards (ICPs and 

ComFrame) and guidance (issues papers and application papers) are always preceded by publication in 

draft, solicitation of comments, and a summary of 

how stakeholder comments were addressed or 

resolved.92 Moreover, individual IAIS committees 

and subcommittees from time to time also organize 

stakeholder outreach sessions to discuss ongoing 

work and matters of interest for the mutual exchange 

of ideas, suggestions, insights, and concerns.93 In 

addition, the major policy initiatives of the IAIS in 

recent years—ICS, the Holistic Framework, and 

ComFrame—have been undertaken in an increas84 See 2018 Transparency Report, 2018 Fed-FIO Annual Report. 

See “IAIS By-Laws,” Art. 2(3). 86 See 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. 

85 

See also IAIS, 2017 Annual Report, 10 

(referencing the “commitments contained in the IAIS Stakeholder Engagement Plan”). 87 See, e.g., IAIS, “International Association of Insurance Supervisors 25th Annual Conference,” https://annualconference 

.iaisweb.org/2018/welcome.html; IAIS, Stakeholder Engagement 

Plan, section I(J). 88 See, e.g., IAIS, “Newsletter,” https://www.iaisweb.org/page/ 

news/newsletter; IAIS, Stakeholder Engagement Plan, 

section I(K). 

89 IAIS, “Newsletter” (Summer 2019): 1, https://www.iaisweb.org/ 

page/news/newsletter-archive/file/83788/iais-newslettersummer-2019. 90 IAIS, “Newsletter” (June 2019): 6, https://www.iaisweb.org/page/ 

news/newsletter-archive/file/82778/iais-newsletter-june-2019. 91 IAIS, “Frequently Asked Questions: IAIS Common Framework for the Supervision of Internationally Active Insurance 

Groups (ComFrame),” 4, https://www.iaisweb.org/page/ 

supervisory-material/insurance-core-principles-and-comframe/ 

file/87287/comframe-frequently-asked-questions. 92 All current and closed consultations are compiled and published on the IAIS website. See IAIS, “Consultations,” https:// 

www.iaisweb.org/page/consultations. 93 For example, note in table 2 the multiple sessions held in 2019 

by the Accounting and Auditing Working Group. 
16 Global Insurance Regulatory or Supervisory Forums in 2019 

ingly transparent manner, through multiple consultations and public background sessions worldwide.94 

Treasury and the Federal Reserve support such 

transparency efforts through their engagement with 

one another, and with the state members of Team 

USA, in preparation for IAIS stakeholder sessions 

and in responding to stakeholder comments. Further, 

to enhance stakeholder outreach, Team USA works 

together to host meetings and active working sessions with U.S. insurance industry stakeholders for 

open dialogue regarding policy matters currently 

before the IAIS. On May 1, 2019, FIO hosted a 

stakeholder session on IAIS work at Treasury with 

representatives from the members of Team USA: 

FIO, the Federal Reserve, the NAIC, and the state 

insurance regulators. The topics addressed included 

the development of the ICS and the development of 

the IAIS’s Holistic Framework. Throughout 2019, 

FIO continued to coordinate efforts on international 

insurance matters to ensure that U.S. stakeholders 

have regular opportunities to meet and work with 

Team USA. 

The compilation of the various stakeholder consultations conducted by the IAIS in 2019 appears in 

table 2. Team USA members have been active participants in each of the sessions, including by chairing some of them. In the view of Treasury and the 

Federal Reserve, this expansive list demonstrates 

that the IAIS is taking seriously the need for transparency, for which Team USA will continue to 

advocate. 

The IAIS also published a 2019 “public roadmap” to 

inform stakeholders of the IAIS’s key activities and 

to facilitate greater awareness and engagement in 

these activities.95 The roadmap categorized the 

IAIS’s key activities for 2019 thematically as (1) stanTable 2. IAIS stakeholder consultations and meetings, 2019 

Date Consultations and meetings 

January 15, 2019 Stakeholder consultation event (Miami, Florida) on proposed Holistic Framework for the Assessment and Mitigation of Systemic Risk in the 

Insurance Sector. 

February 1, 2019 Stakeholder consultation event (Basel, Switzerland) on ICS Version 2.0 consultation document. 

February 28, 2019 Interested stakeholder call-in session with IAIS Accounting and Auditing Working Group to provide updates on its activities and gather feedback 

on key matters of interest. 

March 7, 2019 Public discussion session (teleconference) on comments received during the 2018 public consultation on the “Application Paper on Proactive 

Supervision of Corporate Governance.” 

April 10, 2019 Stakeholder consultation event (Orlando, Florida) to provide a forum for constructive feedback on ICS Version 2.0. 

May 22, 2019 Interested stakeholder call-in session with IAIS Accounting and Auditing Working Group to provide updates on its activities and gather feedback 

on key matters of interest. 

June 28, 2019 Public background session (teleconference) on the following materials: Draft revised IAIS Glossary, Draft ComFrame Assessment Methodology, 

Draft ComFrame Assessment Methodology, Revisions to the Introduction to ICPs and ICP 7 (Corporate Governance) related to ComFrame 

development, and Draft revised ICP 22 (Anti-Money-Laundering and Combating the Financing of Terrorism). 

Public discussion session on the outcome of the 2018 public consultation on overall ComFrame. 

July 2, 2019 Public background session (teleconference) on the following draft revisions related to the holistic framework: ICP 9 (Supervisory Review and 

Reporting) and ComFrame in ICP 9, ICP 10 (Preventive Measures, Corrective Measures and Sanctions), ICP 16 (Enterprise Risk Management for 

Solvency Purposes) and ComFrame in ICP 16, ICP 20 (Public Disclosure), and ICP 24 (Macroprudential Supervision). 

August 2, 2019 Interested stakeholder call-in session with IAIS Accounting and Auditing Working Group to gather feedback on IASB Exposure Draft 

Amendments to IFRS 17. 

September 4, 2019 Stakeholder session (teleconference) on the ICS Version 2.0 public field testing package that was released on June 25, 2019. 

September 9, 2019 Public background session (teleconference) on the draft issues paper on “The Use of Big Data Analytics in Insurance” that was released on 

September 2, 2019. 

September 23, 2019 Interested stakeholder call-in session with IAIS Accounting and Auditing Working Group to provide updates on its activities and gather feedback 

on key matters of interest. 

November 26, 2019 Public discussion session (teleconference) on the outcome of the 2019 public consultation on the following items: Draft revised IAIS Glossary, 

Draft ComFrame Assessment Methodology, Revisions to the Introduction to ICPs and ICP 7 (Corporate Governance) related to ComFrame 

development, Draft revised ICP 22 (Anti-Money-Laundering and Combating the Financing of Terrorism), and Application Paper on Recovery 

Planning. 

December 10, 2019 Public background and discussion session (teleconference) related to the Holistic Framework for Systemic Risk in the Insurance Sector, 

addressing key elements of the framework. 

Public consultation on an “Application Paper on Liquidity Risk Management.” 

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

94 See, e.g., ICS “stakeholder consultation event” listed in table 2. 

Note that all consultations are commenced both by publication 

of the relevant materials and at least a telephonic background 

session open to the public. 

95 IAIS, IAIS Key Projects – Public Roadmap for 2019, https:// 

www.iaisweb.org/page/about-the-iais/public-roadmap/file/ 

82771/key-iais-projects-for-2019-public-roadmap. 
December 2020 17 

dard setting, (2) financial stability, (3) implementation and assessment, and (4) assessing and responding to emerging and emerged risks and opportunities. The roadmap lists and describes IAIS projects and provides key milestones. 

FSB Transparency Efforts 

Treasury and Federal Reserve have also worked to 

increase transparency at the FSB, including through 

the Federal Reserve’s leadership role. Since December 2, 2018, Federal Reserve Vice Chair for Supervision, Randal K. Quarles, has served as FSB chair. He 

has made increasing FSB transparency and stakeholder engagement a key part of the group’s agenda. 

In 2019, for the first time in the FSB’s history, the 

FSB publicly disseminated its comprehensive work 

program. Vice Chair Quarles and the FSB continue 

to look for ways to further increase stakeholder 

engagement. Also in 2019, the FSB conducted a 

study of its regional consultative groups to improve 

the efficacy of outreach and feedback mechanisms. 

The FSB has also increased its direct engagement 

with insurers, including on the ICS. In 2019, the FSB 

and IAIS held a joint stakeholder engagement event 

with representatives of the large internationally 

active insurance groups. In the recovery planning 

and resolution area, the iCBCM has held several 

stakeholder sessions. These sessions have focused on 

invited stakeholders, seeking their input to the 

iCBCM on specific topics. 

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 nongovernment persons having an interest in FIO’s 

duties and authorities, including state insurance 

regulators, industry experts, and consumer advocates. FACI has three subcommittees, which prepare 

draft recommendations for FACI’s consideration. 

The Subcommittee on FIO’s International Work presented draft recommendations to FACI at the September 2019 and December 2019 meetings, which 

FACI adopted and formally presented to FIO.96 

At the September 2019 meeting, FACI presented 

ICS-related recommendations urging FIO to 

focus on 

• “The importance of continued strong collaboration across the members of Team USA in its negotiations at the IAIS.” 

• “Establishing a viable pathway to international 

acceptance of Aggregation. This effort should be 

the key priority for Team USA and should encompass: outreach and education on the NAIC’s development of its Aggregation construct, wellspecified IAIS public communications about the 

way forward, detailed work-plans and timelines, 

and realistic and achievable criteria for assessing 

Comparability.” 

• “Developing a coherent design and candid framing 

of the so-called ‘Monitoring Period’—which, in 

addition to concrete work-plans on Comparability, 

should also specify mechanisms for further work, 

messaging on the inappropriateness of use of ICS 

results by third parties (such as rating agencies), 

and impact testing of the potential negative externalities of the ICS on product availability and 

procyclicality.” 

The written recommendations elaborated on each of 

the three key points above. 

FACI also recommended a continued focus on the 

Holistic Framework around a set of five substantive 

themes: (1) promoting a true cross-sectoral, 

activities-based approach; (2) ensuring that macroprudential surveillance does not become a monolithic, over-engineered data mining exercise; 

(3) ensuring that the IAIS approach does not overtly 

single out or discriminate against U.S. insurance 

products; (4) deferring to local supervisors as the primary and accountable authorities for systemic risk 

oversight; and (5) implementing the ABA based on a 

principle of proportionality relative to an insurer’s 

exposure to potential systemically risky activities.97 

At the December 2019 meeting, FACI stated that 

Team USA had delivered an IAIS outcome consistent with its recommendations, particularly with 

respect to “well-specified IAIS public communications about the way forward, detailed work-plans 

and timelines, and realistic and achievable criteria for 

96 FACI, Minutes – 23 September 2019, 14, https://home.treasury 

.gov/system/files/311/September2019FACI_Minutes.pdf;

97 See “Recommendations re. FIO’s International Work,” FACI 

Subcommittee on FIO’s International Work, September 23, 

2019, 

 FACI, 

Minutes – December 5, 2019, 5-7, https://home.treasury.gov/ 

system/files/311/December2019FACI_Minutes.pdf. 

https://home.treasury.gov/system/files/311/ 

September2019FACI_Intl_Sub_Presentation.pdf. 
18 Global Insurance Regulatory or Supervisory Forums in 2019 

assessing Comparability” as well as providing 

“coherent design and candid framing of the Monitoring Period.” FACI then noted, “The outcome 

from [the November 2019 IAIS meetings] demonstrably enhances the stature of Aggregation within 

the ICS process, while laying a solid foundation for 

further substantive work to demonstrate Comparability with ICS.” FACI recommended that FIO, in 

“forging ahead on the next critical steps,” 

• “Help to drive forward the work needed to ensure 

timely execution on the milestones laid out in [the 

November 2019 IAIS meetings in] Abu Dhabi”; 

• “Continue its successful engagement model,” 

including both “active and coordinated collaboration across Team USA” and “frequent and transparent stakeholder engagement”; and 

• “Execute substantively on the outcome from Abu 

Dhabi,” including “the integration of Aggregation 

into all relevant aspects of the ICS work plan during the Monitoring Period”; “a methodical, objective, and evidence-based clarification of the potential ambiguities inherent in the published IAIS 

Comparability definition and principles”; “continued technical enhancements to the ICS, particularly with a view to aligning the ICS design more 

closely with US business models and capital management practices”; and “reinforcement of the 

IAIS messaging that ICS ratio reporting (i) is nonmandatory and provisional in nature, (ii) must 

remain strictly confidential and should not be disclosed by individual insurers (even on a voluntary 

basis), and (iii) should not be used by third parties 

for assessing insurer financial strength during the 

Monitoring Period.”98 

These recommendations were taken into consideration by FIO and helped inform Treasury’s position 

on the ICS and the Holistic Framework. 

Insurance Policy Advisory 

Committee 

During 2019, the Federal Reserve implemented the 

requirement to form the IPAC, which was established 

by Congress through the Act.99 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.”100 During 2019, the Federal Reserve adopted a 

charter for the group, established a new record 

system to facilitate receiving public applications for 

membership on the IPAC,101 solicited applications 

for the IPAC,102 and appointed the inaugural 21 

members of the IPAC.103 The inaugural IPAC members include persons with expertise in life insurance, 

property and casualty insurance, and reinsurance. 

Members have professional backgrounds in insurance accounting, actuarial science, academia, insurance regulation, policyholder advocacy, capital markets, and other areas. 

The Federal Reserve hosted the first meeting of 

the IPAC on November 4, 2019. This meeting 

occurred before the IAIS Annual General Meeting to 

allow the IPAC to advise the Federal Reserve in matters related to the ICS negotiations. During the meeting, the IPAC also advised the Federal Reserve on its 

proposed Building Block Approach and other 

matters. 

98 See “Recommendations re. FIO’s International Work,” FACI 

Subcommittee on FIO’s International Work, December 5, 2019, 

https://home.treasury.gov/system/files/311/ 

December2019FACI_InternationalProposedRecs_0.pdf. 

99 See Act § 211(b), 31 U.S.C. § 313 note (establishing the Insurance Policy Advisory Committee). 100Act § 211(b)(2). 101Privacy 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. 102 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. 103 Federal Reserve, Federal Reserve Board announces inaugural 

21 members of the Insurance Policy Advisory Committee, press 

release, October 16, 2019, https://www.federalreserve.gov/ 

newsevents/pressreleases/other20191016a.htm. 
19 

Conclusion 

In 2019, 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 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 

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