Contributions to the Supervisors on Supervision Stocktake
Should culture, and the conduct proclivities it may promote or discourage among employees, factor into supervisory engagements?
“Culture is crucial for insurance supervisors because it underpins the decisions, behaviours, and practices that influence an insurer’s financial soundness, customer treatment, and overall integrity.
Supervisory focus on culture helps identify vulnerabilities, mitigate misconduct risks, and promote public trust in the insurance sector.
There is strong recognition of the need to ensure a robust supervisory framework for the insurance sector — one that promotes the financial soundness of individual insurers and the stability of the sector, as well as a culture of fair treatment of customers.”
“An insurer’s culture is a key determinant of how effectively it manages both prudential and conduct risks.
[The IAIS] 2021 Issues Paper on Insurer Culture explored the role of insurer culture as a point of intersection for managing prudential and conduct risks and mitigating misconduct.”
“The Global Financial Crisis highlighted the importance of supervisors not only focusing on microprudential supervision of the financial soundness of individual insurers, but also the potential build-up of systemic risk arising from sector-wide activities through macroprudential supervision.”
How does the lack of a common supervisory approach to culture and conduct risk across jurisdictions pose a concern?
“Global challenges require global solutions, grounded in cross-border supervisory coordination and cooperation, and robust stakeholder engagement. Closing protection gaps will require an intensified global collaborative effort amongst policymakers, supervisors, and the insurance sector.”
How does a lack of effective tools and frameworks for culture risk supervision impact perceptions of supervisory legitimacy?
“Supervisors are striving to be forward-looking to prevent, or at least mitigate, consumer harm instead of only learning of misconduct after the fact but at the same time supervisors face resource constraints and competing priorities.”
What frameworks have supervisory bodies considered as an effective means by which to assess culture risk governance among firms?
“The IAIS developed a significant resource for members on the use of conduct indicators providing guidance and examples… of how to draw informative, actionable and well-targeted indicators from data collections.”