C-OSFI Revised Reinsurance Guidance


On Feb. 11, C-OSFI issued final B-2 and B-3 practices, procedures.


  • C-OSFI issued revised reinsurance guidelines following review for effect Jan. 1, 2025.
  • For federally regulated insurers (FRI) re sound reinsurance practices and procedures.
  • Also, property and casualty large insurance exposures and investment concentration.
  • Guideline B-2
  • Entitled Property and casualty large insurance exposures and investment concentration
  • Requires property and casualty FRIs cover max losses re single insurance exposure.
  • To account for largest unregistered reinsurer with applicability to FRI-issued policies.
  • Establish gross underwriting limit policy (GUWP) to define single insurance exposure.
  • Gross insurance risk limits and senior management oversight for policy annual review.
  • Consideration criteria of single insurance exposure: property, credit, surety, and title.
  • Addresses exposure limits from affiliated firms that are direct writers of business and caps the total capital available and caps 100% net assets available of foreign branches.
  • Sets investment concentration: 5% firm's assets; 5% of foreign branch assets in CAN.
  • Guideline B-3
  • Authority guidance B-3 is entitled, Sound reinsurance practices and procedures.
  • Sets expectations for FRIs to best identify, manage reinsurance and counterparty risk.
  • Establishes elements for reinsurance risk management policy (RRMP) to manage risk.
  • Goal for firms meet capital criteria under Life insurance capital adequacy test (LICAT).
  • In addition, Minimum capital test (MCT), by sound reinsurance risk management.
  • Notes RRMP should set ceding limits for book of business, line of business if needed.
  • Advises counterparty concentration limits re individual or group of affiliated entities.
  • Onus rests with senior management to ensure RRMP compliance and monitoring.
  • Guide includes FRI responsibility to stress test on reinsurance program performance.
  • Cites complement guidance re reinsurance security, outsourcing, LICAT, governance.
  • Effectiveness
  • FRIs to remain compliant with current regulations and transition prior to Jan. 1, 2025.
  • Dec. 2024 C-OSFI Title Implementation Delay
  • On Dec. 11, 2024, C-OSFI published letter on decision to defer application of Section II of Guideline B-2 for the title insurance writers to Jan. 1, 2027 to allow additional time.
  • Time to further examine approach applied to large exposures in other jurisdictions.
  • Also, to engage in additional consultation with industry on implementation approach.
  • Accordingly, small modification to S. 2 Large Insurance Exposures portion for clarity.

Regulators C-OSFI
Entity Types Bank; BHC; Ins
Reference Lt, 12/11/2024; PR, Gd, Lt, 2/11/2022;
Functions Compliance; C-Suite; Financial; Legal; Operations; Reinsurance; Reporting; Risk; Treasury; Underwriting
Countries Canada; Cross-Border
Category
State
Products Banking; Corporate; Deposits; Insurance; Insurance-Casualty; Insurance-Property; Loan; Title Insurance
Regions Am
Rule Type Final
Rule Date 2/11/2022
Effective Date 1/1/2025
Rule Id 129294
Linked to N/A
Reg. Last Update 12/11/2024
Report Section International

Last substantive update on 12/16/2024