to inform the ipsa review include recommendations from two external reviews of insurance regulation and supervision. these were an imf financial sector assessment programme6 ( ‘ fsap ’ ) in 2017 that assessed new zealand compliance against international standards for prudential supervision of insurers, followed by an independent review of reserve bank supervision of cbl in 20197. other developments that 5 significant factors that indicate an overseas entity is carrying on insurance business in new zealand include ( but is not limited to ) having a physical place of business, staff or infrastructure in new zealand or actively and directly advertising or soliciting business within new zealand. 6 https : / / www. rbnz. govt. nz / news / 2017 / 07 / bulletin - article - reviews - outcomes - of - imfs - financial - sector - assessmentprogramme 7 https : / / www. rbnz. govt. nz / - / media / reservebank / files / regulation - and - supervision / insurers / cbl - rbnz - finalreport. pdf provide material for consideration in the ipsa review include the fma / rbnz thematic review of life insurer conduct and culture, the thematic review of the appointed actuary regime, and the amendments in train to the conduct legislation. as it stands, our plan is to resume the ipsa review from october with : the release of an initial overview paper ; commencement of a consultation on the solvency standards at the same time ; subsequent consultation papers on various components of the review during 2021 to 2023. we welcome feedback through the formal processes associated with the consultation papers as well as being open to engagement and discussions on a continuous basis throughout the review ’ s duration. details will be covered in october ’ s paper. we envisage a staggered implementation of changes, ranging from operational changes that might be relatively easy to implement, through to legislative changes that require decisions from parliament. this impacts on timeframe and our estimated completion date is 2024. the solvency standard is an example. it will need to be revised for ifrs 17 by end - 2021, and is expected to be further revised to align with the ipsa changes by 2024. the ongoing impacts of covid - 19 on the sector as we reported in our may financial stability report, there is considerable uncertainty as to how covid - 19 and the associated economic downturn will affect new zealand insurers. whilst death and disability claims do not currently pose a threat to the solvency

of life insurers, covid - 19 could play out in a number of ways, including the possibility of further waves of infection. the initial economic responses to the pandemic created major disruptions to economic activity - particularly travel - and that has been reflected in travel insurance claims. other key areas of impact or potential impact include credit insurance in relation to unemployment and impacts on investment portfolios. overseas, there are also some questions about the scope of business interruption insurance and liability in relation to covid - 19 related claims and many will be watching closely to see if outcomes from ongoing court cases have implications for local insurers. low interest rates have impacted some insurers adversely and this factor will continue to materialise in the next few years. insurers adapted quickly to working under the lockdown environment and we sensed an almost routine response by insurers to the recent return to level 3 in auckland and level 2 elsewhere. we ’ ve also noted the various ways in which insurers have sought to provide customer - focused responses to hardships arising from covid - 19. our stance in relation to prudential risks to insurers from covid - 19 is that there are many unknowns still to play out in terms of flow - on impacts from what we have already experienced, as well as the potential for new outbreaks. this caution is also reflected in our stance on capital retention and dividend payments, which we regard as being imprudent under these conditions. we will update insurers on our stance on this at or before publication of the next financial stability report in november. appointed actuary review appointed actuaries have a critical legislated role to measure and report on material risks and the role also entails providing impartial advice to an insurer ’ s board and senior management to assist with decision - making. insurance is about known and unknown risks and strong, independently minded actuarial advice is crucial to managing risks. this was the backdrop to our recent appointed actuary review8, so that we could better understand how the appointed actuary role works in practice for insurers, actuaries and the reserve bank, and to identify potential areas of improvement to make the role and regime more effective. we selected 15 insurers and their appointed actuaries for the review and published our findings and recommendations in june. the input and participation from industry stakeholders in this review was incredibly helpful, and we look forward to similar constructive engagement in the ip