IAIS Sets Out Recommendations for Benchmark Transition for Insurers

The key findings and recommendations identified from the survey responses are largely consistent with those of the FSB-BCBS report on supervisory issues associated with benchmark transition, albeit with a few points specific to the insurance sector. The issues that are specific to the insurance sector arise because insurers are exposed to transition risks on both sides of the balance sheet. The survey results highlight that, overall, insurer exposures to LIBOR are limited, but might be more concentrated in certain insurers, depending on their geographical location, balance sheet structure, business model, products, and size. Approximately half of the responding jurisdictions indicated that there is no material exposure to LIBOR in their insurance markets and hence did not report to have a transition strategy in place. Other jurisdictions are still in the process of executing a work plan to analyze the LIBOR exposures.

From a micro-prudential perspective, similar to the findings from the FSB-BCBS survey, transition risks may arise from the operational, legal, prudential, conduct, hedging, and accounting perspectives. Similar to non-insurance supervisors, most insurance supervisors have not set targets and deadlines for insurers to transition from LIBOR to alternative reference rates. Authorities in LIBOR currency jurisdictions are relatively more advanced in taking initiatives to facilitate and monitor benchmark transition. Similar to the FSB-BCBS survey, based on the responses received, IAIS has identified a number of recommendations adopted by authorities to address LIBOR transition challenges. Some of these recommendations have been already adopted by authorities that have progressed more toward LIBOR transition. A wider implementation of these recommendations by jurisdictions could facilitate a more effective and coordinated transition globally. The report includes three sets of recommendations:

• Identification of LIBOR exposures and transition challenges—Insurance supervisors are recommended to closely monitor LIBOR transition and actively reach out to the sector based on a risk-based approach. Insurance supervisors should issue public statements to promote awareness of LIBOR cessation and associated risks. Supervisory authorities should evaluate the need and then undertake regular surveys to monitor financial institutions’ (including insurers) exposure to LIBOR and to identify possible areas of risk concentration. Insurance supervisors are recommended to request, as part of the insurer risk management and reporting, a board-level summary of key risks and action plans related to LIBOR transition, steps already taken, and designated senior management responsible for transition. 
• Transition facilitation—Insurance supervisors should maintain regular dialog with insurers to discuss the transition plans, the progress against set timelines or milestones, and the readiness of internal and external systems. Insurance supervisors should provide further regulatory clarifications or supervisory guidance to facilitate the transition.
• Supervisory cooperation and coordination—Insurance supervisors are recommended to promote financial sector-wide coordination, maintain dialog on the adoption of fallback language, consider working with relevant financial sector supervisors to identify legislative solutions where necessary, and exchange information on best practices and challenges as well as on progress across jurisdictions. International bodies, standard-setting bodies, and supervisory authorities encourage financial institutions, including insurers, to maintain a good understanding of wider market developments.

IAIS and its members are committed to supporting the next steps proposed by BCBS and FSB in further assessing transition progress and monitoring the evolving impact of the COVID-19 pandemic on benchmark transition.

Keywords: International, Insurance, Securities, Interest Rate Benchmark, LIBOR, Risk-Free Rates, IBOR Transition, OTC Derivatives, BCBS, FSB, IAIS