The Global Federation of Insurance Associations (GFIA) appreciates the opportunity to offer its recommendations on confidentiality of information in advance of the upcoming ComFrame Dialogue.
Strong confidentiality protections are an essential precondition to information exchange at every stage of the process contemplated by ComFrame, from the identification of internationally active insurance groups (IAIGs) to the assessment of an IAIG’s strategies and procedures in sensitive and proprietary areas such as group structure, strategy, governance, enterprise risk management, and financial condition.
Since public exposure of proprietary information may result in significant harm to insurance groups from both a regulatory and economic perspective, confidentiality protections are necessary to protect groups as well as confidence in the supervisory system. These protections must apply fully to all individuals or entities that are given access to confidential information, including but not limited to insurance supervisors (whether as part of the on-going supervisory process, supervisory review process, or peer review process); supervisors in other financial sectors; and government bodies responsible for the legislation of financial market institutions.
The ICP confidentiality guidance is generally high-level and does not discuss the reasons for confidentiality protection or specific items that need to be protected. Since the July 2 ComFrame draft includes a number of items in both Modules 2 and 3 that are likely to contain proprietary information and require protection (such as ORSA reports, the IAIG Profile, contingency and business continuity plans, group-wide risk assessment, etc.), specific protection of these items is needed in ComFrame (which of course does not exclude the need for protection of other proprietary information).
While GFIA supports the existing confidentiality protections in ComFrame, they have a number of concerns about their efficacy. Their comments highlight specific areas where GFIA believes changes to the existing text will help to strengthen these protections.
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© GFIA - Global Federation of Insurance Associations
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