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

Efforts to Increase Transparency at 

Meetings of the International Association 

of Insurance Supervisors 

November 2018 

Steven T. Mnuchin 

Secretary of the Treasury 

Randal K. Quarles 

Vice Chairman for Supervision 

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

www.federalreserve.gov/publications/default.htm. 

To order copies of Federal Reserve Board publications offered in print, 

see the Board’s Publication Order Form ( ) 

or contact: 

Printing and Fulfillment 

Mail Stop K1-120 

Board of Governors of the Federal Reserve System 

Washington, DC 20551 

(ph) 202-452-3245 

(fax) 202-728-5886 

(email) Publications-BOG@frb.gov 

www.federalreserve.gov/files/orderform.pdf
iii 

Contents 

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

The International Association of Insurance Supervisors ........................................... 3 

IAIS Structure and Decisionmaking .............................................................................................. 3 

IAIS Mission ............................................................................................................................... 3 

Stakeholder Engagement and Transparency at the IAIS ............................................ 7 

Efforts to Increase Transparency and Stakeholder Engagement ............................. 9 

Team USA Involvement in the IAIS ............................................................................................... 9 

Treasury and Federal Reserve Efforts to Promote Transparency ..................................................... 9 

Conclusion ............................................................................................................................... 11 
1 

Introduction 

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

into law the Economic Growth, Regulatory Relief, 

and Consumer Protection Act, Pub. L. 115-174, 132 

Stat. 1296 (2018). This report is submitted pursuant 

to section 211(c)(4) of this 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 designees, to report to Congress on the 

efforts of Treasury and the Federal Reserve “to 

increase transparency at meetings of the International Association of Insurance Supervisors” (IAIS). 

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 a late stage in the policydevelopment process. Although the IAIS has taken 

initial steps to improve stakeholder transparency, 

Treasury and the Federal Reserve support the objective of further increasing transparency and stakeholder input into IAIS decisionmaking. As detailed 

in this report, Treasury and the Federal Reserve are 

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

and the Federal Reserve work collaboratively with 

the 56 U.S. state and territory insurance regulators 

and the National Association of Insurance Commissioners (NAIC) to coordinate efforts and harmonize 

their policy positions at the IAIS. The U.S. members 

of the IAIS are the Treasury’s Federal Insurance 

Office (FIO), the Federal Reserve, state and territory 

insurance regulators who represent the individual 

sovereign jurisdictions within the United States, and 

the NAIC. The U.S. members of the IAIS—who are 

informally known, collectively, as “Team USA”—develop their positions with input from U.S. stakeholders, and advocate for international standards that are 

in the best interests of the United States. Treasury 

and the Federal Reserve support and will continue to 

expand opportunities for robust engagement with 

U.S. stakeholders to inform international policy 

priorities. 

Involvement and leadership of Team USA at the 

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

consumers. It is important to recognize, however, 

that the IAIS does not have regulatory power or legal 

authority. In the United States, this means that any 

standards agreed upon at the IAIS are not binding 

and must be adopted voluntarily by each member 

jurisdiction in accordance with applicable domestic 

laws. Any international standards are not operational 

in the United States unless implemented through the 

relevant state or federal legislative or administrative 

process, as appropriate.1 

This report begins with an overview of the IAIS, 

including its structure and mission, in order to provide context for the report’s main discussion. The 

report then outlines current IAIS processes and initiatives for , including efforts 

to improve transparency. Finally, the report describes 

additional efforts of Treasury and the Federal 

Reserve to increase transparency and stakeholder 

engagement concerning the activities of the IAIS. 

stakeholder engagement

1 See Treasury, A Financial System That Creates Economic 

Opportunities: Asset Management and Insurance (2017) (EO 

Report on Insurance), at 130–131, https://www.treasury.gov/ 

press-center/press-releases/Documents/A-Financial-SystemThat-Creates-Economic-Opportunities-Asset_ManagementInsurance.pdf. The EO Report on Insurance includes an overview of the IAIS and information on the membership of U.S. 

federal agencies in various international bodies.
3 

The International Association of 

Insurance Supervisors 

IAIS Structure and Decisionmaking 

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.2 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 in more than 140 countries.3 

The IAIS operates through five key mechanisms: 

(1) the General Meeting; (2) the Executive Committee (ExCo); (3) the Policy Development Committee 

(PDC); (4) the Macroprudential Committee (MPC); 

and (5) the Implementation and Assessment Committee (IAC).4 The IAIS’s General Meeting ultimately oversees matters before the IAIS, with the 

authority “to adopt principles, standards, and guidance developed by the [IAIS] or other persons or 

entities not already adopted by the” ExCo.5 The 

ExCo serves as the principal decisionmaking body of 

the IAIS and is tasked with taking “all decisions necessary to achieve the mission of the [IAIS] in accordance with the directions given by the General Meeting.”6 

2 See IAIS, 2016 IAIS Annual Report (November 2017), at 6, 

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

70097/annual-report. See also Federal Insurance Office (FIO), 

Annual Report on the Insurance Industry (2018), at 36–37, 

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

Documents/2018_FIO_Annual_Report.pdf. 3 2016 IAIS Annual Report, at 6–7. 4 See, e.g., IAIS, IAIS Committee and Subcommittee Membership 

List Updated June 2018, https://www.iaisweb.org/page/aboutthe-iais/organisational-structure//file/75208/iais-committeesand-members-public. 5 See IAIS By-Laws, Art. 11(1)(c), https://www.iaisweb.org/page/ 

about-the-iais/by-laws/file/74644/2017-by-laws. 6 See IAIS By-Laws, Art. 14(2). 

ciples, standards, and guidance. Multiple working 

groups and task forces, focused on a range of prudential regulation and supervision topics, report to 

these committees.

The PDC is responsible for standard-setting 

activities, the MPC for overseeing the work on issues 

related to financial stability, and the IAC for assessments and assistance in implementing IAIS prin7 All of the committees and subcommittees (the collective term for IAIS working 

groups and task forces) are composed of IAIS members, supported by a Secretariat. Figure 1 illustrates 

the IAIS organizational structure. 

IAIS Mission 

The mission of the IAIS is to “promote effective and 

globally consistent supervision of the insurance 

industry in order to develop and maintain fair, safe 

and stable insurance markets for the benefit and protection of policyholders, and to contribute to global 

financial stability.”8 In support of its mission, the 

IAIS developed the Insurance Core Principles 

(ICPs), a set of standards and supporting guidance 

intended to be a supervisory framework for insurers. 

The ICPs “seek to encourage the maintenance of 

consistently high supervisory standards in IAIS 

member jurisdictions.”9 

The ICPs are intended to be suitable for application 

to all insurers, but under the IAIS supervisory framework, certain insurers are subject to additional 

supervisory standards known as the Common 

Framework for the Supervision of Internationally 

Active Insurance Groups (ComFrame).10 Under the 

7 See, e.g., FIO 2018 Annual Report, at 36–37. See also IAIS, 

IAIS Organisational Structure Updated January 2018, https:// 

www.iaisweb.org/page/about-the-iais/organisational-structure. 8 2016 IAIS Annual Report, at 8. 9 IAIS, Draft Revised ICP Introduction and Assessment 

Methodology (November 8, 2017), at 2 (paragraph 2), https:// 

www.iaisweb.org/page/supervisory-material/insurance-coreprinciples/file/69883/draft-revised-introduction-andassessment-methodology. 10 IAIS, Draft Overall ComFrame for Public Consultation (clean 

version) (July 31, 2018), at 9–10 (paragraph 18 et seq.), https:// 

www.iaisweb.org/page/supervisory-material/commonframework/file/76143/draft-overall-comframe-for-publicconsultation. See also FIO, 2018 Annual Report, at 39. 
Figure 1. IAIS organizational structure 

General Meeting 

Executive 

Committee 

Budget 

Committee 

Policy Development 

Committee 

Accounting 

and Auditing 

Working Group 

Capital, Solvency, 

and Field Testing 

Working Group 

Governance 

Working Group 

Insurance Groups 

Working Group 

Market Conduct 

Working Group 

Resolution 

Working Group 

Supervisory Material 

Review Task Force 

Financial Crime 

Task Force 

Macroprudential 

Committee 

G-SII Analysts 

Working Group 

Macroprudential Policy 

and Surveillance 

Working Group 

Coordination 

Group 

Audit and Risk 

Committee 

 Implementation 

and Assessment 

Committee 

Financial lnclusion 

Working Group 

Signatories 

Working Group 

Standards Assessment 

Working Group 

Supervisory Forum 

Core Curriculum 

Task Force 

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

4 Efforts to Increase Transparency at Meetings of the International Association of Insurance Supervisors 
November 2018 5 

IAIS’s supervisory framework, 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 IAIS11

11 “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% 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 (September 2014), at 2, 

. 

https://www.iaisweb.org/page/supervisory-material/commonframework//file/58726/revised-comframe-draft-2014

“ComFrame seeks to assist supervisors in: addressing group-wide activities and risks; identifying and 

avoiding supervisory gaps; [and] coordinating super-

—and visory activities efficiently and effectively between 

consists of an enhanced set of supervisory standards, the group-wide and other involved supervisors.”

encompassing both entity-level and group-wide 

supervisory standards. As stated by the IAIS, 

Since 2016, the IAIS has been directly integrating 

ComFrame material alongside the relevant ICPs to 

clarify the presentation of the two sets of 

standards.13 

12 

12 Draft Overall ComFrame, at 9 (paragraph 19). 

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

13 
7 

Stakeholder Engagement and Transparency 

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.”14 The IAIS as a body 

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.15 

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.16 

Recently, the IAIS has expanded steps to make its 

newsletter more user-friendly for stakeholders by 

highlighting stakeholder engagement opportunities 

and providing more hyperlinks to referenced materials.17 

14 IAIS By-Laws, Art. 2(3). 15 See IAIS, Stakeholder Engagement Plan (March 20, 2017), 

https://www.iaisweb.org/page/about-the-iais/policies-andprocedures//file/65579/iais-stakeholder-engagement-plan-2017. 16 See, e.g., IAIS, “International Association of Insurance Supervisors 25th Annual Conference,” https://annualconference 

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

Plan, at section I(J). 17 See, e.g., IAIS, “Newsletter,” https://www.iaisweb.org/page/ 

news/newsletter; IAIS, Stakeholder Engagement Plan, at 

section I(K). 

ComFrame material, issue papers, or application 

papers, 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.

Before finalizing and issuing any revised ICPs, 

18 To enhance public consultation on major 

policy documents (e.g., Insurance Capital Standard 

(ICS) Version 2.0 and overall ComFrame revisions), 

the IAIS holds dedicated public background sessions.19 Finally, the IAIS organizes other stakeholder 

workshops for projects such as the ICS and public 

consultations through which Team USA has additional opportunities to solicit stakeholder comments 

and feedback. 

18 IAIS, “Consultations,” https://www.iaisweb.org/page/ 

consultations. See also FIO, 2018 Annual Report, at 40 (providing table listing, by ICP, all public consultations related to ICP 

and ComFrame revisions in 2017 and 2018, as of September 2018). 19 See, 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. 
9 

Efforts to Increase Transparency and 

Stakeholder Engagement 

Team USA Involvement in the IAIS 

Staff from Team USA members serve on nearly 

every IAIS committee and subcommittee20 and 

Team USA members hold a number of important 

leadership positions within the IAIS, including seats 

on the ExCo, PDC Chair, MPC Vice-Chair, and 

Chair or Vice-Chair of numerous task forces and 

working groups. Both Treasury and the Federal 

Reserve support representation and committee leadership—in particular, committee and subcommittee 

chair positions—that are geographically balanced 

among IAIS members. Treasury further believes that 

U.S. interests will be best served by the FIO having a 

permanent and voting membership on the ExCo.21 

Throughout their IAIS work, Treasury and the Federal Reserve staff prioritize coordination and collaboration with the other members of Team USA. 

Team USA members consult on IAIS work frequently through telephone, email, and in-person 

meetings. Through their collective and collaborative 

engagement in technical and substantive IAIS decisionmaking, Team USA members continue to advocate for the development of international insurance 

standards that are appropriate for the United 

States.22 Where Team USA holds key leadership 

roles within the IAIS structure, its members are in a 

position to exercise greater influence and can more 

effectively advocate for increased transparency and 

stakeholder engagement—including more in-person 

and telephonic stakeholder consultation sessions—as 

well as U.S. interests more broadly. 

20 See, e.g., IAIS Committee and Subcommittee Membership List; 

FIO, 2018 Annual Report, at 38–39. As of June 2018, the sole 

task force without a U.S. member was the Core Curriculum 

Task Force. 21 See, e.g., Treasury, EO Report on Insurance, at 136; FIO, 2018 

Annual Report, at 38. 22 See e.g., FIO, 2018 Annual Report, at 38–39. 

Treasury and Federal Reserve Efforts 

to Promote Transparency 

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 

updates on its IAIS work at open meetings of the 

Federal Advisory Committee on Insurance.23 FIO 

also details IAIS developments in its Annual Reports 

to Congress, which are publicly available on Treasury’s website.24 The Federal Reserve meets with 

interested parties, and will engage with the Federal 

Reserve’s Insurance Policy Advisory Committee on 

International Capital Standards and Other Insurance 

Issues, to maintain a robust appreciation for stakeholder views regarding matters before the IAIS and 

other international insurance issues. 

Development of the Insurance Capital Standard 

(ICS), a key ongoing IAIS project, provides an 

important illustration of Team USA collaborating to 

increase transparency, engage with stakeholders, and 

promote U.S. policy positions. The ICS—which aims 

to be the first, group-wide, risk-based capital standard broadly applicable to IAIGs—is part of the 

international ComFrame under development at the 

IAIS.25 The IAIS began work on the ICS in 2013, 

issued an initial consultative proposal in late 2014, 

and then published a subsequent consultative pro23 Treasury, “Federal Advisory Committee on Insurance (FACI),” 

https://www.treasury.gov/initiatives/fio/Pages/faci.aspx. 24 See, e.g., FIO, 2018 Annual Report, at 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); 39–40 (outlining recent public consultations 

on ICP and ComFrame revisions). 25 See Draft Overall ComFrame, at 9 (paragraph 20). 
10 Efforts to Increase Transparency at Meetings of the International Association of Insurance Supervisors 

posal in July 2016 in progression toward ICS Version 

1.0.26 The IAIS decided in late 2017 to implement 

the ICS in two phases: a five-year monitoring phase 

beginning in 2020, followed by an implementation 

phase.27 At the same time and in response to Team 

USA’s advocacy, the IAIS also 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 standard.28 By performing an 

aggregation across all of the individual legal entities 

of an insurance group, the aggregation method 

would, as with the ICS, provide a consolidated capital standard for an insurance group. The IAIS 

released a public document on ICS Version 2.0 on 

July 31, 2018.29 Team USA continues to hold regular 

teleconferences to provide updates and collect feedback from U.S. stakeholders and U.S. volunteers on 

the ICS, which assists in Team USA’s continued 

advocacy for an implementable ICS that is appropriate for the United States. 

26 IAIS, Risk-Based Global Insurance Capital Standard Version 

2.0: Public Consultation Document (July 31, 2018), at 12 (section 2.1), https://www.iaisweb.org/page/supervisory-material/ 

insurance-capital-standard/file/76133/ics-version-20-publicconsultation-document. See also IAIS, Risk-Based Global 

Insurance Capital Standard Version 1.0 for Extended Field Testing (July 21, 2017), https://www.iaisweb.org/page/supervisorymaterial/insurance-capital-standard/file/67651/ics-version-10-

for-extended-field-testing. 27 Insurance Capital Standard Version 2.0, at 16 (section 2.5). 28 Insurance Capital Standard Version 2.0, at 17 (section 2.5, paragraph 34). 29 Insurance Capital Standard Version 2.0. This document notes 

that the IAIS “remains committed to developing/defining criteria so that it is in the position, by the end of the monitoring 

period, to assess comparable, i.e., substantially the same (in the 

sense of the ultimate goal), outcomes to the ICS.” Id. at 17 (section 2.5, paragraph 35). The field testing and monitoring may 

further enable Team USA to advocate that an aggregation 

method provides comparable outcomes to the reference method 

ICS. See also FIO, 2018 Annual Report, at 20–22 (detailing ICS 

background and current status). 

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

Treasury and Federal Reserve staff, 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, and other opportunities that 

Team USA or stakeholders may propose. Further, 

Treasury and Federal Reserve staff will continue 

advocating for greater transparency and stakeholder 

engagement at the IAIS itself. 

Treasury and the Federal Reserve continue to believe 

that the IAIS, its members, and stakeholders can 

Some stakeholders have commented that the 

standard-setting process at the IAIS is not sufficiently transparent because stakeholders are generally able to participate only late in the process, when 

stakeholder engagement takes the form of consultation, rather than during early stages of IAIS work on 

policy development. Within the United States, Team 

USA has been working to address these concerns 

through the stakeholder calls and meetings referenced above. At the IAIS, Treasury and the Federal 

Reserve support enhancing transparency and taking 

further steps to improve access and stakeholder 

engagement. Treasury and the Federal Reserve support having the IAIS seek public comment on draft 

documents with proposed approaches and frameworks for the supervision of insurers, including 

IAIGs. For example, Treasury and the Federal 

Reserve advocated for the IAIS to release an interim 

consultation paper on the activities-based approach 

to systemic risk in December 2017, followed by a second consultation paper in late 2018.30 This two-stage 

consultation process by the IAIS provided increased 

engagement opportunities for stakeholders during 

the early stages of policy development. 

30 IAIS, Activities-Based Approach to Systemic Risk (December 8, 

2017), https://www.iaisweb.org/page/consultations/closedconsultations/2018/activities-based-approach-to-systemic-risk// 

file/70440/interim-aba-cp-final-for-launch. 
11 

Conclusion 

Treasury and the Federal Reserve will continue their this goal. In addition, Treasury and the Federal 

efforts to improve transparency and increase stake- Reserve, along with the other members of Team 

holder engagement at the IAIS, in coordination with USA, will continue to actively engage with U.S. 

state insurance regulators and the NAIC. Placing insurance stakeholders on issues being considered by 

Team USA members in key IAIS leadership posi- the IAIS and continue to report to Congress on their 

tions should provide further pathways to accomplish efforts. 
home.treasury.gov 

www.federalreserve.gov 

1118