## _cr0682

## Source details

**Canonical URL:** [_cr0682](https://www.imf.org/-/media/websites/imf/imported-full-text-pdf/external/pubs/ft/scr/2006/_cr0682.pdf)

## Other formats

- [Markdown version](/-/media/websites/imf/imported-full-text-pdf/external/pubs/ft/scr/2006/_cr0682.pdf.md)
- [Structured JSON version](/-/media/websites/imf/imported-full-text-pdf/external/pubs/ft/scr/2006/_cr0682.pdf.json)

---

### Introduction and Methodology
- Assessment scope: observance of the International Association of Insurance Supervisors (IAIS) Insurance Core Principles (ICP) in Italy.
- Supervisory authority assessed: Istituto per la Vigilanza sulle Assicurazioni Private e di Interesse Collettivo – ISVAP (prudential and market conduct supervision of insurance companies and intermediaries).
- Context: conducted under the IMF and World Bank Financial Sector Assessment Program (FSAP); mission dates: July 5 – July 20, 2005; assessment based on circumstances and practices "at that time."
- Assessor: Michael Hafeman, consultant formerly with the Office of the Superintendent of Financial Institutions Canada.
- ICP basis: Insurance core principles (ICP) of the IAIS dated October 2003.
- Sources used: ISVAP questionnaire responses and self-assessment; ISVAP annual report; translations of ISVAP circulars; industry and ratings publications; extensive meetings with ISVAP, industry associations, ratings agencies, insurers and other supervisors.

### Institutional and Market Structure — Key statistics and features
- Premium growth: "premium increases of about 12% in both 2003 and 2004."
- Market penetration: "gross domestic premium income accounted for 7.5 percent of GDP in 2004 (EU average close to 9 percent)."
- Life share of premiums: "about 65 percent (EU average about 70 percent)."
- Total assets of insurance companies: "34.6 percent of GDP in 2004 (27.3 percent life and 7.3 percent non-life)."
- Employment and intermediaries: "insurers employ approximately 40,200 people; over 200,000 people work as intermediaries, loss adjusters and in other industry-related functions."
- Licensed entities at year-end 2004:
  - "76 life insurance companies."
  - "81 non-life insurance companies."
  - "19 composite companies (licensed for both life and non-life)."
  - "3 reinsurers."
  - "67 branches of foreign companies (primarily non-life sector)."
- Market concentration (2004):
  - "Largest five life companies accounted for 47 percent of sector’s total insurance premiums."
  - "Largest ten life companies accounted for 65 percent of sector’s total insurance premiums."
  - "Largest five non-life companies wrote 41 percent of premiums."
  - "Largest ten non-life companies wrote 61 percent of premiums."
- Group concentration (2003): "five largest groups accounted for 53 percent of life premiums and 67 percent of non-life premiums."
- Asset mix:
  - "12 percent of assets in equities."
  - "30 percent in unit trusts."
  - "57 percent in fixed-income products."
  - "1 percent in real estate."
- Distribution channels (2004):
  - "Banks and post offices accounted for 59 percent of life insurance sales."
  - "Agency distribution accounted for about 30 percent of life insurance sales and 88 percent of non-life insurance sales."
- Life product features and performance:
  - Predominantly savings-oriented; traditional and unit-linked policies; some guaranteed rates.
  - Life premium growth: "slowed to 3.6 percent in 2004 (from 18.8 percent in 2002 and 13.8 percent in 2003)."
  - Life return on equity: "10.5 percent in 2004."
- Non-life product features and performance:
  - Motor insurance dominant ("almost 60 percent of non-life premiums"); motor claims costs increasing.
  - Non-life premium growth: "slowed to 3.4 percent in 2004 (from 14.8 percent in 2002 and 10.6 percent in 2003)."
  - Combined ratio declined from "109 percent in 1999 to 96 percent in 2004."
  - Non-life return on equity: "13.4 percent in 2004."
- Supervisor characteristics: "ISVAP is an independent supervisory authority with a Board of Directors, funded by a levy on premiums."

### Principle-by-Principle — Summary findings and deficiencies
- Overall observance levels:
  - "More than two-thirds of the principles assessed as being observed or largely observed."
  - Remaining principles assessed as "partly observed."
- Noted shortcomings and areas for improvement:
  - Legal protection for ISVAP staff and third-party reporters: "no legal protection exists."
  - Governance and disclosure: requirements for insurers not subject to listed-company rules should be strengthened; ISVAP could publish entity-specific financial information.
  - Risk assessment and on-site inspections: increase frequency and scope of on-site inspections of insurers and intermediaries.
  - Information sharing: greater sharing with other supervisors, particularly those outside the EU/EEA.
  - Intermediaries supervision: many distribution channels and only some individuals under ISVAP’s direct supervision; full observance requires legal changes, collaboration with other authorities, and industry discussions.
- Observance counts (Table 2):
  - Observed "7" — CP 6, 11, 12, 14, 16, 20, 22
  - Largely observed "13" — CP 1, 2, 4, 7, 8, 10, 15, 17, 19, 23, 25, 27, 28
  - Partly observed "8" — CP 3, 5, 9, 13, 18, 21, 24, 26
  - Not observed "0"
  - Not applicable "0"

### Supervisory powers, processes and capacity (selected findings)
- ISVAP powers: can issue and enforce rules, legally-binding orders and circulars; decisions appealable to administrative courts.
- Governance and independence: Board of Directors with seven members; President appointed for "five year term, reappointment once."
- Funding and staff: "340 staff, including 328 regular employees and 12 persons hired under employment contracts." Hiring specialists (actuaries, lawyers, IT) is difficult; employment contract hires limited by law to "20."
- Reporting and monitoring:
  - ISVAP empowered to require quantitative and qualitative information and set accounting standards.
  - Annual audited financial statements and extensive supervisory returns (solo and consolidated) submitted annually and quarterly.
  - On-site inspections (2004): "105 inspections were performed, covering 122 risk areas. 42 of these inspections were performed at insurers’ head offices, 9 at claims settlement divisions, and 54 at intermediaries."
- Enforcement toolkit: moral suasion; solvency restoration plans; administrative orders; fines; activity restrictions; appointing administrator; license withdrawal through MoPA decree. Fines currently administered by MoPA on ISVAP recommendation; pending code will "significantly increase" fines.

### Governance, internal control, risk management and actuarial issues (selected findings)
- Licensing (CP 6): governed by "174/1995" and "175/1995"; licensing criteria and processes described; refusal must be communicated "not later than six months from the date that complete documentation of the application is received." Assessment: Observed.
- Suitability (CP 7): ministerial decree "186/1997" requires fit and proper for significant owners, board members and chief executive; external auditors/auditing actuaries not explicitly covered. Assessment: Largely observed.
- Corporate governance (CP 9): largely set by Civil Code; independence not required for directors; ISVAP authority to set rules and draft circular on internal control expected in 2005. Assessment: Partly observed.
- Internal control (CP 10): Circular "366/1999" requires internal control systems; draft circular to require annual self-assessment and reporting to ISVAP. Assessment: Largely observed.
- Technical provisions and valuations (CP 20): rules in "174/1995", "175/1995" and "173/1997"; appointed and auditing actuaries review provisions; valuation rules described; insurers not required to have board-approved investment policy. Assessment: Principle 20 Observed; Principle 21 Partly observed.
- Reinsurance limits when calculating solvency margin: "limited to 85 percent of the technical provisions for life insurance and 50 percent of the technical provisions for non-life insurance, or to 50 percent of the capital at risk."

### Intermediaries, consumer protection, AML/CFT and fraud (selected findings)
- Intermediaries (CP 24): laws "48/1979", "792/1984", "166/1992"; EU Directive on Insurance Intermediation being implemented in new insurance code; many intermediaries (sub-agents, financial promoters, bank/post employees) not required to register with ISVAP. Assessment: Partly observed.
- Consumer protection (CP 25): Circulars "533/D/2004", "551/D/2005", "518/2003"; ISVAP assists consumers with complaints but cannot force resolution. Assessment: Largely observed.
- Information/disclosure (CP 26): audited annual accounts filed with Chamber of Commerce; from 2005 consolidated accounts under IFRS; ISVAP does not publish entity-specific supervisory return data. Assessment: Partly observed.
- Fraud (CP 27): rules on internal controls and ethics; motor claims data collection ("137/2000" and "505/2003"); no explicit requirement insurers allocate resources to fraud controls. Assessment: Largely observed.
- AML/CFT (CP 28): Laws "197/1991" and "431/2001"; UIC central AML authority; ISVAP has memorandum with UIC since 1994; conducts "approximately ten focused AML/CFT inspections annually." Assessment: Largely observed.

### Selected exact numeric and dated points retained
- ISVAP staff: "340 staff, including 328 regular employees and 12 persons hired under employment contracts."
- Actuaries: "approximately 800 registered actuaries."
- Auditors registered with Ministry of Justice: "approximately 100,000 individuals registered."
- On-site inspections in 2004: "105 inspections were performed, covering 122 risk areas. 42 of these inspections were performed at insurers’ head offices, 9 at claims settlement divisions, and 54 at intermediaries."
- Draft consolidated insurance code: "Final adoption of the new insurance code is expected in September 2005, with effect from January 2006."
- Reporting transitions: "Since 2003, auditing standards have been harmonized with International Standards on Auditing (ISAs). Insurers will in 2005 begin reporting consolidated accounts to shareholders under International Financial Reporting Standards (IFRS)."
- Supervisory returns deadlines: "The annual financial statements and supervisory returns must be submitted to ISVAP within one month after their approval, but not later than the end of May, while quarterly filings are due within 45 days."
- Definition: "A qualifying holding is defined as a direct or indirect holding of at least ten percent of the capital or of the voting rights of an insurance company, or a holding which makes it possible to exercise a significant influence over the management."

### Priority recommendations (by supervisory area / ICP)
- Conditions for effective supervision (CP 1)
  - Define responsibilities for supervision of pension products sold by life insurers to support ISVAP’s prudential role and avoid duplication.
  - Harmonize Italian GAAP supervisory reporting with IFRS as far as possible.
  - Establish a specialized alternative dispute resolution mechanism (e.g., independent ombudsman).
  - Improve timeliness and consistency of legal processes, including winding-up procedures.
- Supervisory objectives and authority (CPs 2–3)
  - Explicitly communicate principal supervisory objectives and link plans/activities to objectives.
  - Provide legal protection or indemnification/liability insurance for ISVAP board and staff for good-faith actions; adopt a code of conduct prohibiting dealing in shares and investing in supervised companies.
  - Reform funding: subject assessment formula to board approval rather than MoF decree; publish audited financial statements and explain main expenditure items annually when meeting industry.
- Supervisory process and cooperation (CPs 4–5, 12–15)
  - Develop criteria for insurer overall risk assessment and define supervisory actions per risk level; inform insurers of their risk ratings when ready.
  - Consider a specialized independent tribunal as first-level appeal.
  - Increase number and scope of on-site inspections; provide advance notice except when specific compliance concerns; focus inspections on effectiveness of risk identification and management.
  - Shorten deadline for submission of annual supervisory returns.
  - Amend legislation to enable ISVAP to restrict/suspend dividends/payments that jeopardize solvency and to ensure breaches of fitness/propriety are not automatically disregarded after three years.
- Governance, internal control, risk management (CPs 6–11, 16–21)
  - Contact home supervisor of non-EU/EEA insurers applying for license and as part of fit and proper assessments.
  - Amend legislation to require all senior management meet fit and proper requirements.
  - Finalize and prioritize draft circular on internal control and risk management; strengthen off-site assessment and confidential meetings with internal audit, appointed actuary and auditors.
  - Require insurers to have a board-approved strategic investment policy reviewed annually; provide guidance on investment policy elements.
  - Consider adopting international actuarial standards when available; extend appointed actuary requirement to all non-life classes.
  - Regularly review stress testing results for liabilities, assets and solvency once required.
- Reinsurance, intermediaries, consumer protection, disclosure, fraud, AML/CFT (CPs 19, 24–28)
  - Finalize circular on reinsurance and increase reinsurance assessments (off-site and on-site).
  - Adopt the new insurance code and implement intermediaries provisions with high priority: require registration and direct supervision of all intermediaries (including sub-agents, financial promoters, bank/post employees); require examination-based demonstration of expertise; require claims adjusters to register.
  - Require insurers/intermediaries to obtain appropriate consumer information before advice/contract conclusion and to disclose conflicts of interest for all classes.
  - Amend law to clarify ISVAP’s power to require insurer disclosure; require all insurers to make audited financial statements easily available; ISVAP to publish entity-specific supervisory return information (balance sheet, income statement and solvency margin; year-end and interim data; accessible over the Internet as soon as possible after reporting period).
  - Require insurers and intermediaries to implement procedures and controls against fraud and assess effectiveness periodically.
  - Increase frequency of AML/CFT on-site inspections; provide guidance for foreign branches/subsidiaries; amend legislation to make ISVAP a member of the FSC.

*Assessment and recommendations summarized from the Detailed Assessment of Observance of the IAIS Insurance Core Principles for Italy (mission conducted July 5 – July 20, 2005).*

### 1. Detailed Assessment of Observance of the IAIS Insurance Core Principles.........................6

### 1. Detailed Assessment of Observance of the IAIS Insurance Core Principles

### Introduction — General
- Assessment scope: observance of the International Association of Insurance Supervisors (IAIS) Insurance Core Principles (ICP) in Italy.
- Supervisory authority assessed: Supervisory Authority for Private Insurance Undertakings and Insurance Undertakings of Public Interest (Istituto per la Vigilanza sulle Assicurazioni Private e di Interesse Collettivo – ISVAP).
- Responsibilities of ISVAP: prudential and market conduct supervision of insurance companies and intermediaries.
- Context: conducted under the IMF and World Bank Financial Sector Assessment Program (FSAP).
- Mission dates: July 5 – July 20, 2005; assessment based on circumstances and practices "at that time."
- Assessor: Michael Hafeman, consultant formerly with the Office of the Superintendent of Financial Institutions Canada.

### Information and Methodology Used for Assessment
- ICP basis: Insurance core principles (ICP) of the IAIS dated October 2003.
- Coverage: comments on both essential and advanced criteria given the developed nature of the Italian market; overall level of observance assessed using essential criteria per Annex 2 of the ICP.
- Sources:
  - ISVAP’s answers to IMF questionnaire.
  - ISVAP comprehensive self assessment.
  - ISVAP annual report.
  - Translations of ISVAP circulars.
  - Publications of industry associations and ratings agencies.
  - Extensive meetings with ISVAP management and staff.
  - Meetings with: Associazione Nazionale fra le Imprese Assicuratrici (ANIA); Ordine Nazionale Degli Attuari (Ordine); National Council of Actuaries; Associazione Italiana Revisori Contabili (Assirevi); Federperiti; Unione Europea Assicuratori (UEA); Associazione Italiana Brokers di Assicurazioni e Riassicurazioni (AIBA); Borsa Italiana; three ratings agencies; senior executives of several insurance companies and fund management companies.

### Institutional and Macroprudential Setting — Overview (Key statistics and market structure)
- Recent growth: premium increases of about 12% in both 2003 and 2004.
- Market penetration: gross domestic premium income accounted for 7.5 percent of GDP in 2004 (EU average close to 9 percent).
- Life insurance share of premiums: about 65 percent (EU average about 70 percent).
- Total assets of insurance companies: 34.6 percent of GDP in 2004 (27.3 percent life and 7.3 percent non-life).
- Employment: insurers employ approximately 40,200 people; over 200,000 people work as intermediaries, loss adjusters and in other industry-related functions.
- Licensed entities at year-end 2004:
  - 76 life insurance companies.
  - 81 non-life insurance companies.
  - 19 composite companies (licensed for both life and non-life).
  - 3 reinsurers.
  - 67 branches of foreign companies (primarily non-life sector).
- Market concentration (2004):
  - Largest five life companies accounted for 47 percent of sector’s total insurance premiums.
  - Largest ten life companies accounted for 65 percent of sector’s total insurance premiums.
  - Largest five non-life companies wrote 41 percent of premiums.
  - Largest ten non-life companies wrote 61 percent of premiums.
- Group concentration (2003): five largest groups accounted for 53 percent of life premiums and 67 percent of non-life premiums.
- Asset mix:
  - 12 percent of assets in equities.
  - 30 percent in unit trusts.
  - 57 percent in fixed-income products.
  - 1 percent in real estate.
- Distribution channels (2004):
  - Banks and post offices accounted for 59 percent of life insurance sales.
  - Agency distribution accounted for about 30 percent of life insurance sales and 88 percent of non-life insurance sales.
  - Financial advisors accounted for most of remaining life insurance sales.
  - Brokers handled the balance of non-life sales, focusing on medium to large commercial risks.
- Life insurance product features and performance:
  - Predominantly savings-oriented; include traditional and unit-linked policies.
  - Products sometimes incorporate guaranteed rates of return; insurer exposure to such guarantees does not appear excessive.
  - Legislation under consideration expected to expand opportunities to sell life insurance to fund supplemental individual pensions.
  - Life insurance premium growth slowed to 3.6 percent in 2004 (from 18.8 percent in 2002 and 13.8 percent in 2003).
  - Overall return on equity in life insurance: 10.5 percent in 2004.
- Non-life insurance product features and performance:
  - Motor insurance predominant, accounting for almost 60 percent of non-life premiums.
  - Motor insurance claims costs increasing rapidly; premiums have kept pace.
  - Non-life premium growth slowed to 3.4 percent in 2004 (from 14.8 percent in 2002 and 10.6 percent in 2003).
  - Overall combined ratio declined from 109 percent in 1999 to 96 percent in 2004.
  - Return on equity: 13.4 percent in 2004.
- Supervisor characteristics: ISVAP is an independent supervisory authority with a Board of Directors, funded by a levy on premiums.

### Principle-by-Principle Assessment — Summary Findings
- Overall approach: insurance supervision in Italy operates within a legal framework incorporating relevant EU Directives.
- Supervisory evolution: ISVAP has moved toward a more forward-looking approach, working toward full implementation of a risk-based supervisory methodology and promoting better risk management practices by insurers.
- Solvency II: implementation ahead; ISVAP actively involved in development.
- Observance levels:
  - More than two-thirds of the principles assessed as being observed or largely observed.
  - Remaining principles assessed as partly observed.
- Areas identified with shortcomings or needing improvement:
  - Legal protection: no legal protection exists for those involved in the supervisory process, including ISVAP staff and third parties charged with reporting concerns to ISVAP.
  - Governance and disclosure: governance requirements and disclosure requirements for insurers not subject to listed-company rules should be strengthened.
    - Possible mitigation: ISVAP could publish entity-specific financial information on its website.
  - Risk assessment and on-site inspections: ISVAP’s ability to assess sector risks could be improved by increasing frequency and scope of on-site inspections of insurers and intermediaries.
  - Information sharing: greater sharing with other supervisors, particularly those responsible for other parts of the Italian financial sector and insurance supervisors outside the European Union, would enhance ISVAP’s understanding.
  - Intermediaries supervision: wide variety of distribution systems exist and only some individuals are under ISVAP’s direct supervision.
    - Achieving full observance on intermediaries would require legal changes (currently under consideration), collaboration with other supervisory authorities, and discussions with industry.
- Capacity to improve observance:
  - Several legislative and supervisory initiatives underway that could materially improve observance.
  - Some improvements (e.g., inspections, information sharing, publication of entity-specific information) can be achieved through allocation of staff resources by ISVAP.
- Assessment methodology notes:
  - Observed: all essential criteria observed, or all observed except some not applicable.
  - Not applicable: essential criteria do not apply given jurisdictional structure.
  - Largely observed: only minor shortcomings that do not raise concerns about authority’s ability to achieve full observance.
  - Partly observed: shortcomings sufficient to raise doubts about authority’s ability to achieve observance.
  - Not observed: no substantive progress toward observance achieved.
  - For a criterion to be considered observed, legal authority and satisfactory exercise of that authority are generally required; mere existence of a power in law is insufficient except where criterion is specifically limited.

*Source: Detailed assessment of observance of the IAIS Insurance Core Principles for Italy (mission conducted July 5 – July 20, 2005).*

### 21.      While it is generally expected that full observance of a principle is achieved through

### _cr0682 - 21.      While it is generally expected that full observance of a principle is achieved through

### Conditions for effective insurance supervision (Principle 1 and context)
- Findings:
  - Responsibilities for supervision delegated to four independent authorities: ISVAP (insurance), Bank of Italy (banking), CONSOB (securities, with Bank of Italy collaboration), and COVIP (pension funds).
  - Italy’s legal system: civil law, domestic and EU legislation; EU law overrides domestic law under the Treaty of Rome; EU directives must usually be implemented into national law by member states.
  - A draft consolidated insurance code expected: final adoption expected in September 2005, with effect from January 2006.
  - Judicial delays noted: winding-up of an insurance company often takes more than ten years.
  - Accounting/auditing: auditing standards harmonized with ISAs since 2003; from 2005 insurers will begin reporting consolidated accounts to shareholders under IFRS; reporting to the insurance supervisor on consolidated accounts will be based on IFRS; reporting at the individual entity level will continue to be based on Italian GAAP.
  - Auditors: approximately 100,000 individuals registered with the Ministry of Justice; 25 audit firms registered with CONSOB perform most audits of insurers.
  - Actuaries: actuarial profession regulated since 1942; registration requirements include university degree in statistics and actuarial science, exams, continuing education; approximately 800 registered actuaries.
  - Data availability: extensive socio-economic data from ISTAT, Bank of Italy, Eurostat, IMF, OECD.
- Assessment: Largely observed.
- Key recommendations:
  - Clearly define responsibilities for supervision of pension products sold by life insurers to support ISVAP’s prudential supervision while avoiding duplication or conflict.
  - Harmonize accounting and supervisory reporting requirements under Italian GAAP with IFRS as far as possible.
  - Establish a specialized alternative dispute resolution mechanism (e.g., independent ombudsman) for insurance consumers.
  - Improve timeliness and consistency of legal processes to aid consumer resolution and winding-up efficiency.

### Supervisory objectives, authority and process (Principles 2–5, 12–15)
- Findings:
  - Supervisory objectives: promote sound and prudent management, disclosure and fair behavior, stability and efficiency, solvency, consumer information, protection of policyholders and beneficiaries. ISVAP communicates plans (annual report) but does not explicitly describe objectives or linkage to activities.
  - ISVAP powers: can issue and enforce rules, legally-binding orders and circulars; decisions appealable to administrative courts.
  - Governance and independence: ISVAP is independent, reports to Parliament, works through Minister of Production Activities (MoPA) on legislative initiatives and license revocation; board of directors with seven members; President appointed for five year term, reappointment once.
  - Funding and staff: ISVAP financed by assessments on industry; budget set annually via ministerial decree (MoF), though MoF has never varied assessment; ISVAP has flexibility to reallocate resources within total. Staff: 340 total (328 regular employees, 12 persons hired under employment contracts). Employment contract hires limited by law to 20. Difficulties in hiring specialists (actuaries, lawyers, IT).
  - Legal protection and conduct: ISVAP is liable for damages if court overrules decision; individual employees lack legal protection against lawsuits; liability insurance secured by ISVAP’s President and board members at personal expense. No general ISVAP code of conduct or specific prohibitions on investing in supervised companies.
  - Supervisory process: documented internal procedures, internal audit function, publishing of official supervisory actions in national gazette, annual report and website communications. ISVAP does not rate overall risk of each insurer; about five full-time staff equivalent involved in appeals.
  - Reporting/off-site monitoring: legislation empowers ISVAP to require quantitative and qualitative information and set accounting standards; audited financial statements annually; extensive supervisory returns annually and quarterly; returns provided solo and consolidated; ISVAP performs extensive analyses and follow-up.
  - On-site inspections (2004): 105 inspections covering 122 risk areas; 42 at insurers’ head offices, 9 at claims settlement divisions, 54 at intermediaries.
  - Preventive/corrective measures and sanctions: ISVAP has range of measures (moral suasion; solvency restoration plan; administrative orders; fines; activity restrictions; appointing administrator; license withdrawal through MoPA decree). Fines imposed by MoPA on recommendation of ISVAP; amounts to be significantly increased with pending new insurance code.
- Assessments:
  - Principle 2: Largely observed.
  - Principle 3: Partly observed.
  - Principle 4: Largely observed.
  - Principle 5: Partly observed.
  - Principle 12: Observed.
  - Principle 13: Partly observed.
  - Principle 14: Observed.
  - Principle 15: Largely observed.
- Key recommendations:
  - ISVAP should explicitly communicate principal objectives of insurance supervision and explain how activities support these objectives.
  - Provide legal protection or indemnification/liability insurance for board and staff for good-faith actions; adopt a code of conduct including prohibition on dealing in shares and investing in supervised companies.
  - Reform funding arrangements: subject assessment formula to board approval rather than MoF decree; publish audited financial statements in ISVAP’s annual report; include annual explanation of main expenditure items when meeting industry on priorities/budget.
  - Develop criteria for assessing the overall risk of an insurer and define supervisory actions per risk level; inform insurers of their risk ratings once ISVAP is confident.
  - Consider establishing a specialized independent tribunal as first-level appeal to improve speed and consistency of appeals.
  - Significantly increase number and scope of on-site inspections; provide advance notice of inspections except when specific compliance concerns; shift inspections to assess effectiveness of risk identification and management, not only compliance.
  - Shorten deadline for submission of annual supervisory returns (current: annual statements submitted within one month after approval, but not later than end of May; quarterly filings due within 45 days).

### Governance, internal control, risk management, and corporate practices (Principles 6–11, 16–21)
- Findings:
  - Licensing (Principle 6): licensing governed by decrees 174/1995 and 175/1995; licenses issued per class of insurance; licensing criteria include suitability of owners/directors/senior managers, auditor/actuary registration, capital vs minimum, organization and controls, three-year business plan, product conditions, audited accounts. Refusal must be communicated not later than six months from receipt of complete documentation. Assessment: Observed.
  - Suitability of persons (Principle 7): Ministerial decree 186/1997 requires fit and proper for significant owners, board members, board of statutory auditors and chief executive; legislation does not explicitly require external auditor/auditing actuary/appointed actuary to meet fit and proper though ISVAP can report concerns. Assessment: Largely observed.
  - Changes in control and portfolio transfers (Principle 8): ISVAP approval required for acquiring qualifying holding (direct/indirect ≥ ten percent or significant influence); notification of 5 percent or more changes required; ISVAP must be notified and assesses transfers considering interests of policyholders and solvency; assessment: Largely observed.
  - Corporate governance (Principle 9): corporate governance largely set by Civil Code; boards of directors and statutory auditors; independence not required by Civil Code for directors; external auditing firm appointed for three-year term; ISVAP power to set rules on administrative organization and internal controls; draft circular on internal control and risk management expected 2005. Assessment: Partly observed.
  - Internal control (Principle 10): Circular 366/1999 requires internal control systems; draft circular expected 2005 will require annual self-assessment and reporting to ISVAP; internal audit function required appropriate to size and nature; no mandatory compliance function; appointed actuaries required for life and motor insurance. Assessment: Largely observed.
  - Market analysis (Principle 11): ISVAP regularly assesses market circumstances and issues statistical surveys; no formal program of monitoring; participates in EU, OECD, IAIS and CEIOPS activities. Assessment: Observed.
  - Winding-up and exit (Principle 16): voluntary and involuntary winding-up supervised by ISVAP under legislative decree 93/2003; formal insolvency by court based on ISVAP opinion; assets to cover technical provisions have first priority to insureds/policyholders/beneficiaries/claimants; guarantee fund protects motor insurance policyholders and uninsured motorist liability claims. Assessment: Observed.
  - Investments and liabilities (Principles 20–21): technical provisions rules in legislative decrees 174/1995, 175/1995 and 173/1997; appointed and auditing actuaries review technical provisions; ISVAP can require increases in technical provisions; valuation rules prescribed by ISVAP (most investments valued at lower of purchase cost and market price; unit-linked/index-linked at market price). Insurers not required to have board-approved investment policy. Assessment: Principle 20 Observed; Principle 21 Partly observed.
- Key recommendations:
  - For licensing and fitness: contact home supervisor of any non-EU/EEA insurer applying for license and as regular part of fit and proper assessments.
  - Amend legislation to require all senior management (not only chief executive) meet fit and proper requirements.
  - Document and publish specific criteria for assessing proposed changes in control and portfolio transfers; consider requiring independent actuary report on risks of proposed transfers.
  - Consider requiring all insurers to conform to corporate governance requirements applicable to listed companies.
  - Provide legal protection from liability for parties required to report concerns to ISVAP.
  - Finalize and prioritize implementation of draft circular on internal control and risk management; strengthen off-site assessment of internal controls and meet confidentially and regularly with heads of internal audit, appointed actuary, external auditor, auditing actuary and board of statutory auditors (legislation may need amendment to permit confidential meetings).
  - Require insurers to have an overall strategic investment policy approved and reviewed annually by the board; provide guidance on elements of investment policy.
  - Consider adopting international actuarial standards when available; extend requirement for appointed actuary to all non-life classes of business.
  - ISVAP to regularly review results of stress testing of liabilities, assets and solvency once required by circular.

### Specific technical supervision areas: underwriting, reinsurance, intermediaries, consumer protection, disclosure, fraud, AML/CFT (Principles 19, 24–28)
- Findings:
  - Underwriting/pricing and reinsurance (Principle 19): insurers free to set premiums; life premiums required to be adequate; motor premiums must be consistent with underlying risk; appointed actuaries required for life and motor classes; draft circular on reinsurance issued; ISVAP hired additional reinsurance expertise. Assessment: Largely observed.
  - Intermediaries (Principle 24): agents, brokers and motor claims adjusters governed by laws 48/1979, 792/1984, 166/1992; EU Directive on Insurance Intermediation being implemented in new insurance code; agents/brokers/register; many intermediaries (sub-agents, financial promoters, bank/post employees) not required to register with ISVAP; brokers must have liability insurance and participate in guarantee fund. Assessment: Partly observed.
  - Consumer protection (Principle 25): Circular 533/D/2004 (advertising, ethics, training), Circular 551/D/2005 (life disclosure), Circular 518/2003 (complaints management), Law 675/1996 (privacy). ISVAP assists consumers with complaints but cannot force resolution. Assessment: Largely observed.
  - Information, disclosure & transparency (Principle 26): audited annual accounts required and filed with Chamber of Commerce register; from 2005 consolidated accounts and listed companies must report under IFRS; ISVAP currently does not publish entity-specific supervisory return data. Assessment: Partly observed.
  - Fraud (Principle 27): ISVAP has rules on internal controls and ethics; collects detailed motor vehicle claims data (law 137/2000 and circular 505/2003); prosecution of insurance fraud under Criminal Code; no explicit requirement that insurers allocate resources to fraud controls. Assessment: Largely observed.
  - AML/CFT (Principle 28): Laws 197/1991 and 431/2001; UIC is central AML authority; Financial Security Committee (FSC) lead on terrorist financing (ISVAP not represented); ISVAP provides supplementary guidance since 1992 and has memorandum of understanding with UIC since 1994; ISVAP conducts approximately ten focused AML/CFT inspections annually. Assessment: Largely observed.
- Key recommendations:
  - Finalize and implement draft circular on reinsurance with high priority; increase depth and breadth of off-site and on-site reinsurance assessments.
  - Adopt new insurance code and implement provisions on intermediaries with high priority; require registration and direct supervision for all insurance intermediaries operating in Italy, including sub-agents, financial promoters, and bank/post office employees; require examination-based demonstration of insurance expertise for registration; require claims adjusters for any class to register with ISVAP.
  - Require insurers and intermediaries to seek appropriate information from consumers for all classes before advice or contract conclusion; require disclosure of possible conflicts of interest for all classes.
  - Amend legislation to clarify ISVAP’s power to require insurer disclosure on financial situation and risks; require all insurers to make audited financial statements easily available to stakeholders; ISVAP to publish entity-specific supervisory return information (balance sheet, income statement and solvency margin; year-end and interim data; as soon as possible after the end of each reporting period; accessible over the Internet).
  - Explicitly require insurers and intermediaries to implement procedures and controls against fraud and assess effectiveness periodically.
  - Increase frequency of AML/CFT on-site inspections; provide guidance for foreign branches and subsidiaries to observe AML/CFT measures consistent with Italy; amend legislation to make ISVAP a member of the FSC.

### Observance summary (Table 2)
- Observance counts:
  - Observed: 7 — CP 6, 11, 12, 14, 16, 20, 22
  - Largely observed: 13 — CP 1, 2, 4, 7, 8, 10, 15, 17, 19, 23, 25, 27, 28
  - Partly observed: 8 — CP 3, 5, 9, 13, 18, 21, 24, 26
  - Not observed: 0
  - Not applicable: 0

### Selected numeric and dated points retained exactly as in the source
- ISVAP staff: "340 staff, including 328 regular employees and 12 persons hired under employment contracts."
- Actuaries: "approximately 800 registered actuaries."
- Auditors registered with Ministry of Justice: "approximately 100,000 individuals registered."
- On-site inspections in 2004: "105 inspections were performed, covering 122 risk areas. 42 of these inspections were performed at insurers’ head offices, 9 at claims settlement divisions, and 54 at intermediaries."
- Draft consolidated insurance code: "Final adoption of the new insurance code is expected in September 2005, with effect from January 2006."
- Reporting transitions: "Since 2003, auditing standards have been harmonized with International Standards on Auditing (ISAs). Insurers will in 2005 begin reporting consolidated accounts to shareholders under International Financial Reporting Standards (IFRS)."
- Licensing refusal communication deadline: "not later than six months from the date that complete documentation of the application is received."
- Supervisory returns deadlines: "The annual financial statements and supervisory returns must be submitted to ISVAP within one month after their approval, but not later than the end of May, while quarterly filings are due within 45 days."
- Definitions: "A qualifying holding is defined as a direct or indirect holding of at least ten percent of the capital or of the voting rights of an insurance company, or a holding which makes it possible to exercise a significant influence over the management."
- Reinsurance reduction limits when calculating solvency margin: "limited to 85 percent of the technical provisions for life insurance and 50 percent of the technical provisions for non-life insurance, or to 50 percent of the capital at risk."
- Legislation references cited verbatim where used: legislative decrees "174/1995", "175/1995", "173/1997", law "576/1982", ministerial decree "186/1997", legislative decree "93/2003", circulars "366/1999", "533/2004", "518/2003", "551/D/2005", "364/1999", orders "147/1996", "148/1996", "1801/2001", "297/1996", "981/1998", and laws "48/1979", "792/1984", "166/1992", "137/2000", "505/2003", "197/1991", "431/2001", "675/1996".
- Table 2 counts: Observed "7", Largely observed "13", Partly observed "8", Not observed "0", Not applicable "0".

*Assessment and recommendations summarized from the Detailed Assessment of Observance of the IAIS Insurance Core Principles (Italy).*

### 22.      The recommendations of actions that will improve observance of IAIS Insurance

### 22.      The recommendations of actions that will improve observance of IAIS Insurance Core Principles

### Conditions for effective insurance supervision (i.e., CP 1)
- It is recommended that the responsibilities for the supervision of pension products be clearly defined in a manner that supports the ability of ISVAP to conduct prudential supervision of insurers selling such products, while avoiding the duplication or conflict of supervisory requirements applicable to the insurers.
- It is recommended that the accounting and supervisory reporting requirements applicable to insurers under Italian GAAP be harmonized with IFRS as far as possible. This will provide both ISVAP and other stakeholders with a consistent basis for the evaluation of insurers and minimize the reporting burden.
- It is recommended that a specialized alternative dispute resolution mechanism, such as an independent ombudsman, be established to deal with complaints of insurance consumers (or all financial sector consumers). This could hasten the resolution of some problems and lessen the burden on the courts and on ISVAP.
- It is recommended that steps be taken to improve the timeliness and consistency of the legal process. This will assist consumers both directly, in the resolution of insurance claims and disputes, and indirectly, by aiding in the efficient winding-up of failed insurers.

### Supervisory objectives (i.e., CP 2)
- It is recommended that ISVAP explicitly communicate the principal objectives of insurance supervision and explain how its plans and activities support these objectives.

### Supervisory authority (i.e., CP 3)
- It is essential that a supervisory authority be able to take good-faith actions without fear of lawsuits. Therefore, it is recommended that both the board of directors and staff of ISVAP be protected against lawsuits for actions taken in good faith while discharging their duties, if not through formal protection under the law then at least through liability insurance or a written promise of indemnification for costs.
- It is also essential that those working for a supervisory authority be able to be completely objective in the exercise of their duties. It is recommended that ISVAP establish and enforce a code of conduct that includes a prohibition on dealing in shares and investing in companies subject to ISVAP’s supervision, and that it impose the same requirements on external specialists that it retains.
- ISVAP’s independence from government, assurance of access to funding and accountability could be enhanced by making changes to the cost assessment and financial reporting processes. It is recommended that ISVAP’s budget and assessment formula be subject to the approval only of its board of directors, rather than requiring a decree by the MoF, and that its audited financial statements be published in its annual report.
- It is also recommended that ISVAP’s meetings with industry representatives to discuss its priorities and their budgetary impact include an annual explanation of the main items of expenditure for the most recent year and the budget for the coming year.

### Supervisory process (i.e., CP 4)
- It is recommended that ISVAP develop criteria for assessing the overall risk of an insurer and define the nature of supervisory action corresponding to various levels of risk, and communicate this information to the industry.
- It is recommended that once ISVAP is confident of its ability to perform overall risk assessments, it inform each insurer of its particular risk rating.
- It is recommended that consideration be given to establishing a specialized independent tribunal as the first level of appeal against decisions of ISVAP. This could improve both the speed with which appeals are resolved and the consistency of decisions, while reducing the workload of both ISVAP and the courts.

### Supervisory cooperation and information sharing (i.e., CP 5)
- It is recommended that ISVAP take steps to exchange information with relevant supervisors outside of the EU/EEA.
- It is also recommended that legislation be amended to remove the requirement of reciprocity as a condition of such exchanges. These actions will help to ensure that ISVAP is adequately informed of developments that may affect all supervised entities.

### Licensing (i.e., CP 6)
- It is recommended that ISVAP contact the home supervisor of any non-EU/EEA insurer applying for a license, as a regular part of the assessment process.

### Suitability of persons (i.e., CP 7)
- It is recommended that the legislation be amended to require that all senior management of an insurer, not just the chief executive, meet fit and proper requirements.
- It is recommended that the fit and proper requirements be defined and applied broadly enough to consider an individual’s competence and soundness of judgment for fulfilling the responsibilities of the particular position, the diligence with which the person is fulfilling or is likely to fulfill those responsibilities and whether the interests of policyholders or potential policyholders of the insurer are, or are likely to be, in any way threatened by the person holding that position. This will enable the supervisory authority to take action to address serious problems in the direction or management of an insurer.
- It is recommended that ISVAP contact the home supervisor of any non-EU/EEA insurer, as a regular part of the process of assessing the fitness and propriety of its key functionaries.

### Changes in control and portfolio transfers (i.e., CP 8)
- It is recommended that ISVAP document and publish the specific criteria that it will apply in assessing proposed changes in control and portfolio transfers.
- It is recommended that consideration be given to including a requirement, either in the legislation or among the assessment criteria, that a report be prepared by an independent actuary regarding the risks that a proposed change in control or portfolio transfer may pose to the interests of the policyholders of both the transferee and transferor.

### Corporate governance (i.e., CP 9)
- It is recommended that consideration be given to requiring that all insurers conform to all of the corporate governance requirements applicable to listed companies. This would help to strengthen the governance of all insurers and the protection of their policyholders.
- It is recommended that legislation provide for legal protection from liability for those parties required to report concerns to ISVAP, in respect of their fulfillment of this requirement. This would reinforce their ability to communicate freely with ISVAP.
- It is recommended that ISVAP strengthen its off-site and on-site assessment of both compliance with corporate governance requirements and the effectiveness of insurers’ corporate governance practices. Such assessments could include regular reviews of minutes of the board of directors and board of statutory auditors, materials provided to these boards and business plans.
- Regular, ongoing contact between supervisory staff and the senior management of insurers, along with periodic meetings with their boards and auditors, would also contribute greatly to the ability to make such evaluations.

### Internal control (i.e., CP 10)
- It is recommended that the draft circular on internal control and risk management be finalized and implemented with high priority.
- It is recommended that ISVAP strengthen its off-site assessment of internal controls by routinely reviewing internal audit plans and reports, as well as reports of the board of statutory auditors.
- It is recommended that ISVAP meet regularly with the head of the internal audit function, the appointed actuary, the external auditor, the auditing actuary and the board of statutory auditors to obtain information from them regarding the effectiveness of internal controls. Such meetings should take place on a confidential basis, without management present, and it is recommended that the persons involved have legal protection from liability for providing information to ISVAP.
- It is recommended that legislation be amended, as necessary, to facilitate these changes.

### Market analysis (i.e., CP 11)
- It is recommended that the market analysis process include regular meetings and cooperation in quantitative analyses with the other Italian financial sector supervisors.
- It is also recommended that the information gathering include regular meetings with various industry and professional associations, the agendas of which would include discussion of market developments.
- It is also recommended that ISVAP ensure that the results of its market analysis are communicated widely within the organization. This will contribute to the ability of staff to assess risks in the insurance sector and to establish supervisory priorities.

### Reporting to supervisors and off-site monitoring (i.e., CP 12)
- It is recommended that the deadline for the submission of annual supervisory returns be shortened. This recognizes both the need for timely analysis in light of potentially rapid changes in the financial markets and the growing capabilities of insurers to prepare financial information more quickly.

### On-site inspection (i.e., CP 13)
- It is recommended that ISVAP significantly increase both the number and scope of its on-site inspections.
- It is recommended that ISVAP provide advance notice of its inspections, except in cases of specific compliance concerns. Advance notice would enable an insurer to make the relevant staff available for discussions with the inspectors, would be less disruptive to the insurer’s operations, and promote a more cooperative relationship that should increase the flow of information to ISVAP.
- It is recommended that ISVAP’s on-site inspections seek to assess not only compliance with requirements but the effectiveness of an insurer in identifying and managing its risks.

### Preventive and corrective measures (i.e., CP 14)
- See ICP 4 for a related recommendation on risk-ratings.

### Enforcement or sanctions (i.e., CP 15)
- It is recommended that legislation be amended to explicitly enable ISVAP to restrict or suspend dividends or other payments to shareholders, when such payments would jeopardize the insurer’s solvency.
- It is recommended that legislation be amended to provide that no breach of fitness or propriety requirements will be automatically disregarded after three years have passed, but that certain breaches may be disregarded by ISVAP after such period. This will help to protect insurers and their policyholders from individuals who have committed serious or recurrent adverse actions.

### Winding-up and exit from the market (i.e., CP 16)
- (No specific recommended actions listed in the provided text for CP 16.)

### Group-wide supervision (i.e., CP 17)
- It is recommended that ISVAP systematically exchange quantitative and qualitative information with its Italian counterparts responsible for supervision of the banking, securities and pension sectors, where a supervised insurer is a member of a group that includes companies operating in the other sectors. This will assist ISVAP and the other supervisors in assessing the overall risk profile of a group, as well as possible implications to the individual supervised entities.
- It is recommended that ISVAP contact the home supervisor of any non-EU/EEA insurer operating in Italy, as a regular part of the process of assessing the potential impact of group activities on such insurer.

### Risk assessment and management (i.e., CP 18)
- As noted above (see ICP 10), it is recommended that the draft circular on internal control and risk management be finalized and implemented with high priority.
- Full implementation of these proposals by insurers, along with regular assessment of the overall effectiveness of insurers’ risk management by ISVAP, should significantly increase the level of observance of this principle.

### Insurance activity (i.e., CP 19)
- It is recommended that the draft circular on reinsurance be finalized and implemented with high priority.
- It is also recommended that ISVAP implement its plans to increase the depth and breadth of its off-site and on-site assessments of reinsurance. Taken together, these recommendations should help to ensure that insurers have appropriate reinsurance programs in place, commensurate with the levels of risk determined by their boards of directors and acceptable to ISVAP.

### Liabilities (i.e., CP 20)
- International standards for the valuation of insurance contracts are currently under development by both the International Actuarial Association and the International Accounting Standards Board, in connection with the development of IFRS. It is recommended that consideration be given to adopting international actuarial standards when they become available.
- It is also recommended that legislation be amended to extend the requirement for an appointed actuary to all non-life classes of business. This will strengthen the ability of ISVAP to rely on the adequacy of the reported technical provisions for these classes of business.
- It is recommended that ISVAP regularly review the results of the stress testing of liabilities, for those insurers that already undertake such testing and for others, once such testing is required in accordance with the circular on internal control and risk management.

### Investments (i.e., CP 21)
- The investment requirements are focused on ensuring the quality of assets supporting the technical provisions. It is important that the board of directors take overall responsibility for both the quality and suitability of all of an insurer’s assets. Therefore, it is recommended that ISVAP require each insurer to have an overall strategic investment policy and that such policy be approved and reviewed annually by the board of directors.
- It is also recommended that ISVAP provide guidance regarding the main elements to be addressed by an insurer’s investment policy.
- It is recommended that ISVAP regularly review the results of the stress testing of assets, for those insurers that already undertake such testing and for others, once such testing is required in accordance with the circular on internal control and risk management.
- ISVAP should also review the contingency plans that will developed by insurers in accordance with that circular.

### Derivatives and similar commitments (i.e., CP 22)
- (No specific recommended actions listed in the provided text for CP 22.)

### Capital adequacy and solvency (i.e., CP 23)
- Although reinsurers are supervised by ISVAP, they are not subject to the solvency margin requirements. Since the ICPs apply to the supervision of both insurers and reinsurers, it is recommended that Italy take action to extend relevant prudential requirements to reinsurers. This might be accomplished through implementation of the EU Directive on reinsurance.
- Under the current solvency margin approach, some EU insurance supervisors have provided guidance to insurers that a higher level of capital adequacy is expected of them. It is recommended that ISVAP establish and communicate a solvency control level in excess of the minimum solvency margin.
- It is recommended that ISVAP regularly review the results of the stress testing of solvency, once such testing is required in accordance with the circular on internal control and risk management.

### Intermediaries (i.e., CP 24)
- The implementation of the EU Directive on Insurance Intermediation, through the new insurance code, will strengthen the legal framework with respect to those intermediaries who are required to register with ISVAP. It is recommended that the new insurance code be adopted and that its provisions on insurance intermediation be implemented with high priority.
- The new insurance code is expected to include provisions that would address the significant number of individuals dealing with the public in the sale of insurance that are currently outside the scope of registration, i.e., sub-agents, financial promoters, and bank and post office employees. It is recommended that legislation be adopted to require that all insurance intermediaries operating in Italy be subject to registration and direct supervision, and that the conditions of registration include demonstration, through examination, of adequate insurance expertise.
- It is recommended that ISVAP cooperate with CONSOB and the Bank of Italy, as appropriate, to ensure that all insurance intermediation activities are subject to periodic on-site inspection.
- It is recommended that claims adjusters dealing with any class of insurance be required to register with ISVAP.
- These recommendations should help to ensure that consumers are being adequately served and advised in their insurance dealings.

### Consumer protection (i.e., CP 25)
- It is recommended that insurers and intermediaries be required to seek information from consumers that is appropriate in order to assess their insurance needs, with respect to all classes of insurance, before giving advice or concluding a contract.
- It is also recommended that insurers and intermediaries be required to disclose possible conflicts of interest to existing or potential policyholders, with respect to all classes of insurance.
- Several industry participants commented on the use of multi-year non-life insurance contracts in Italy, expressing concern regarding their suitability for consumers. It is recommended that ISVAP perform an analysis of the use of multi-year non-life insurance contracts and take action in response to deal with any potential abuses posed by the use such contracts.

### Information, disclosure & transparency towards the market (i.e., CP 26)
- The implementation of IFRS should considerably improve the extent and comparability of information disclosed by listed insurers and other insurers required to apply IFRS. It is recommended that legislation be amended to clarify ISVAP’s power to require insurers to disclose information on their financial situation and the risks to which they are subject.
- It is also recommended that ISVAP establish disclosure which, to the extent practical, is consistent with the disclosures required of listed companies.
- It is recommended that legislation require all insurers operating in Italy to make their annual audited financial statements easily available to stakeholders.
- It is recommended that ISVAP publish, on an entity-specific basis, some of the information provided to it by insurers in the supervisory returns. It is recommended that the information: include the balance sheet, income statement and solvency margin; include both year-end and interim data; be made available as soon as possible after the end of each reporting period; and be accessible over the Internet.
- It is recommended that legislation be amended, as necessary, to facilitate such publication.
- These recommendations should contribute significantly to the ability of consumers to easily obtain consistent and reliable information about the insurers with which they are dealing.

### Fraud (i.e., CP 27)
- It is recommended that ISVAP explicitly require that insurers and intermediaries implement procedures and controls against fraud and that it assess their effectiveness periodically.

### Anti-money laundering (i.e., CP 28)
- It is recommended that ISVAP significantly increase the frequency of its on-site inspections of both insurers and intermediaries regarding AML/CFT. ISVAP’s inspections have often identified weaknesses in AML/CFT controls, which highlights the need for more significant coverage of the insurance sector in the inspection process.
- It is recommended that additional guidance be provided to emphasize the need for foreign branches and subsidiaries of Italian insurers to observe AML/CFT measures consistent with the requirements in Italy.
- It is recommended that legislation be amended to make ISVAP a member of the FSC. This should help to strengthen ISVAP’s ability to meet its responsibilities – and to ensure that insurers and intermediaries meet theirs – in combating the financing of terrorism.

*Source: _cr0682 - 22.      The recommendations of actions that will improve observance of IAIS Insurance*

---


_Source: https://www.imf.org/-/media/websites/imf/imported-full-text-pdf/external/pubs/ft/scr/2006/_cr0682.pdf_