Financial Sector Assessment Financial Sector Assessment ProgrammeProgramme

Indian Insurance Sector- Indian Insurance Sector- Compliance with ICPsCompliance with ICPs

Dr. Mamta SuriDr. Mamta SuriJoint Director-F & AJoint Director-F & A

Insurance Regulatory And Development AuthorityInsurance Regulatory And Development AuthorityHyderabad, IndiaHyderabad, India

FSAP – FrameworkFSAP – Framework Macro-Prudential Analysis – Stress Testing – Macro-Prudential Analysis – Stress Testing –

Scenario Analysis – Financial Soundness Scenario Analysis – Financial Soundness Indicators – Macro-Financial Linkage.Indicators – Macro-Financial Linkage.

Financial Sector Structure e.g. efficiency, Financial Sector Structure e.g. efficiency, competitiveness, concentration, liquidity, competitiveness, concentration, liquidity, access etc.access etc.

Assessment of the observance of best Assessment of the observance of best international standards, codes and practices.international standards, codes and practices.

Country Specific Stability Issues.Country Specific Stability Issues.

Three Pillars of AssessmentThree Pillars of Assessment

Pillar I => Macro prudential Pillar I => Macro prudential Surveillance and Financial Stability Surveillance and Financial Stability AnalysisAnalysis

Pillar II => Legal and Institutional Pillar II => Legal and Institutional Infrastructure and Development IssuesInfrastructure and Development Issues

Pillar III => Assessment and Status of Pillar III => Assessment and Status of Implementation of International Implementation of International Financial Standards and CodesFinancial Standards and Codes

Pillar IPillar ISteps in Stability AssessmentSteps in Stability Assessment

Compilation of a set of key indicators ofCompilation of a set of key indicators of- Financial Structure- Financial Structure- Financial Soundness (Sector-Wise, - Financial Soundness (Sector-Wise, Market-based, Performance-based)Market-based, Performance-based)- State of Development- State of Development

CoverageCoverageBanks, Insurance, Capital Markets and Non-Banks, Insurance, Capital Markets and Non-Financial SectorFinancial Sector

Pillar IIPillar IIInstitutional infrastructureInstitutional infrastructure

Regulatory GovernanceRegulatory Governance(Objectives of regulation, independence and resources, (Objectives of regulation, independence and resources, enforcement powers, and transparency of regulatory process)enforcement powers, and transparency of regulatory process)

Prudential frameworkPrudential framework(Risk management, risk concentration, capital requirements, (Risk management, risk concentration, capital requirements, corporate governance, and internal controls)corporate governance, and internal controls)

Regulatory PracticesRegulatory Practices(Group-wide supervision, off-site monitoring and on-site inspection, (Group-wide supervision, off-site monitoring and on-site inspection, reporting to supervisors, enforcement, and licensing & ownership)reporting to supervisors, enforcement, and licensing & ownership)

Financial Integrity and safety netFinancial Integrity and safety net(markets (integrity and financial crime), customer protection, (markets (integrity and financial crime), customer protection, information, disclosure, and transparency)information, disclosure, and transparency)

OthersOthers(Licensing, Capital requirements, accountability requirements, and (Licensing, Capital requirements, accountability requirements, and Risk management practices)Risk management practices)

Pillar IIIPillar IIIInternational Financial Standards International Financial Standards

and Codesand Codes

Standards are widely accepted good Standards are widely accepted good principles, practices or guidelines in a principles, practices or guidelines in a specified areaspecified area

Called codes to reflect that they have a legal Called codes to reflect that they have a legal status or are accepted, signed or ratified by status or are accepted, signed or ratified by members of concerned multilateral agencies.members of concerned multilateral agencies.

To be implemented, either in their entirety or To be implemented, either in their entirety or in phases, considering the country-specific in phases, considering the country-specific circumstances. circumstances.

Flexibility an essential ingredient for the Flexibility an essential ingredient for the success of the initiative.success of the initiative.

IAIS – Insurance Sector IAIS – Insurance Sector Core PrinciplesCore Principles

Core Principles - Developed in year Core Principles - Developed in year 20002000

Key Global standards for Prudential Key Global standards for Prudential Regulation & SupervisionRegulation & Supervision

Act as diagnostic tools to assist in Act as diagnostic tools to assist in improving supervision globally.improving supervision globally.

Can act as roadmap for reform agenda.Can act as roadmap for reform agenda.

Need for convergenceNeed for convergenceGlobal Nature of insurance MarketsGlobal Nature of insurance MarketsPresence of conglomeratesPresence of conglomeratesExpansion of cross border transactionsExpansion of cross border transactionsGlobal Nature of Reinsurance MarketsGlobal Nature of Reinsurance MarketsPresence of active off shore centresPresence of active off shore centresThus, need for convergence of regulatory Thus, need for convergence of regulatory practices and norms. practices and norms. To ensure effectiveness of regulations and To ensure effectiveness of regulations and level playing field.level playing field.Financial crisis highlights need for Financial crisis highlights need for convergenceconvergence

ICP Assessment MethodologyICP Assessment Methodology Based on set of essential & advanced Based on set of essential & advanced

criteriacriteria Intended at making a comprehensive Intended at making a comprehensive

precise and objective assessment.precise and objective assessment. Essential Criteria – components intrinsic to Essential Criteria – components intrinsic to

implementation of core principlesimplementation of core principles Advanced criteria – improve essential Advanced criteria – improve essential

criteria and enhance supervisory regimecriteria and enhance supervisory regime

Observance StatusObservance Status

1.1. Observed When stipulations exists and practiced by the insurers

2.2. Largely Observed

Gaps have been identified and steps are being taken to fill in the gaps

3.3. Partly Observed

Compliance observed in case of few of the requirements of the criteria and absence of compliance in case of certain requirements

4.4. Not Observed No stipulations exists, no initiation of process of filling the gaps on date

5.5. Not Applicable Stipulations prohibit the requirements indicated in the criteria ab initio

6.6. Observance Not Tested

Stipulations exists but there were no instances to observe compliance

7.7. Observance in alternative manner

Though not stipulated by the legislation/Supervisor, criteria is complied with in an alternative manner

Core Principles – 28 principlesCore Principles – 28 principles

Grouped into 7 categories:Grouped into 7 categories:II Conditions for Effective Insurance Conditions for Effective Insurance SupervisionSupervisionIIII The Supervisory SystemThe Supervisory SystemIIIIII The Supervised Entity The Supervised Entity IVIV On-going SupervisionOn-going SupervisionVV Prudential RequirementsPrudential RequirementsVIVI Markets and ConsumersMarkets and ConsumersVIIVII Anti-money Laundering, Combating Financing of Anti-money Laundering, Combating Financing of Terrorism (AML/CFT)Terrorism (AML/CFT)

I I Conditions for Effective Insurance SupervisionConditions for Effective Insurance Supervision(Elements of environment where supervision can be most effective)(Elements of environment where supervision can be most effective)

ICP 1 Condition for Effective Insurance ICP 1 Condition for Effective Insurance SupervisionSupervision

- - Broad requirements in the financial Broad requirements in the financial policy and financial markets policy and financial markets infrastructure to support effective infrastructure to support effective supervision.supervision.

II The Supervisory SystemII The Supervisory System(Mandates and responsibilities of the Supervisor)(Mandates and responsibilities of the Supervisor)

ICP 2 Supervisory Objectives – Clarity in LawICP 2 Supervisory Objectives – Clarity in Law ICP 3 Supervisory Authority – Adequate ICP 3 Supervisory Authority – Adequate

powers, resources and legal protectionpowers, resources and legal protection ICP 4 Supervisory Process – Transparency and ICP 4 Supervisory Process – Transparency and

accountabilityaccountability ICP 5 Supervisory Cooperation and Information ICP 5 Supervisory Cooperation and Information

Sharing – Within the insurance sector and Sharing – Within the insurance sector and across financial services (domestic and across financial services (domestic and international)international)

III.III. The Supervisory EntityThe Supervisory Entity(Form and governance of insurers)(Form and governance of insurers)

ICP 6 Licensing – requirements for licensing be ICP 6 Licensing – requirements for licensing be clear, objective and publicclear, objective and public

ICP 7 Suitability of Persons – Ongoing ICP 7 Suitability of Persons – Ongoing assessment of fitness and proprietary assessment of fitness and proprietary

ICP 8 Changes in Control and Portfolio Transfer ICP 8 Changes in Control and Portfolio Transfer – Supervisory approval for changes, in mergers – Supervisory approval for changes, in mergers and in portfolio transfersand in portfolio transfers

ICP 9 Corporate Governance – Management of ICP 9 Corporate Governance – Management of business on basis of standards, & role of board business on basis of standards, & role of board and senior managementand senior management

ICP 10 Internal Control – Systems, audit & ICP 10 Internal Control – Systems, audit & reporting reporting

IV. On-going SupervisionIV. On-going Supervision(Actual practice of the supervisor)(Actual practice of the supervisor)

ICP 11 Market Analysis – Macro prudential surveillanceICP 11 Market Analysis – Macro prudential surveillance ICP 12 Reporting to Supervisor and Off site monitoring – ICP 12 Reporting to Supervisor and Off site monitoring –

Comprehensive monitoring (solo & group) on an on-going basisComprehensive monitoring (solo & group) on an on-going basis ICP 13 On site inspection – Powers for the insurers & ICP 13 On site inspection – Powers for the insurers &

outsourced companies, clarity of scopeoutsourced companies, clarity of scope ICP 14 Preventive & corrective measures – Adequate, timely, ICP 14 Preventive & corrective measures – Adequate, timely,

graduated spectrum of remedial measuresgraduated spectrum of remedial measures ICP 15 Enforcement – based on clear objective criteriaICP 15 Enforcement – based on clear objective criteria ICP 16 Winding up – Procedures for insolvency & priority with ICP 16 Winding up – Procedures for insolvency & priority with

respect to policyholdersrespect to policyholders ICP 17 – Group wide supervision – Insurance group or ICP 17 – Group wide supervision – Insurance group or

conglomerate conglomerate

V.V. Prudential RequirementsPrudential Requirements(Financial and risk management processes)(Financial and risk management processes)

ICP 18 Risk Assessment & Management –Systems ICP 18 Risk Assessment & Management –Systems and their reviewing by supervisorand their reviewing by supervisor

ICP 19 Insurance Activity – Evaluation of risksICP 19 Insurance Activity – Evaluation of risks ICP 20 Liabilities – adequacy of provisioning ICP 20 Liabilities – adequacy of provisioning ICP 21 Investments – Standards on investment ICP 21 Investments – Standards on investment

policy, Asset mix, valuation, risk management and policy, Asset mix, valuation, risk management and ALMALM

ICP 22 Derivatives & other similar commitments – ICP 22 Derivatives & other similar commitments – restriction on use and disclosures restriction on use and disclosures

ICP 23 Capital adequacy & Solvency – To cover ICP 23 Capital adequacy & Solvency – To cover claims, expenses and unexpected losses claims, expenses and unexpected losses

VI.VI. Markets and ConsumersMarkets and Consumers(Distribution, consumer protection, Disclosure (Distribution, consumer protection, Disclosure and fraudand fraud

ICP 24 Intermediaries – Licensing and business ICP 24 Intermediaries – Licensing and business requirements requirements

ICP 25 Consumer Protection – providing ICP 25 Consumer Protection – providing information before and during a contract information before and during a contract

ICP 26 Information, Disclosure and Transparency ICP 26 Information, Disclosure and Transparency toward the Market – adequacy of disclosuretoward the Market – adequacy of disclosure

ICP 27 Fraud – measures to prevent, detect and ICP 27 Fraud – measures to prevent, detect and remedyremedy

VII.VII. Anti-money Laundering, Combating the Anti-money Laundering, Combating the financing of Terrorismfinancing of Terrorism

ICP 28 Anti-money Laundering and ICP 28 Anti-money Laundering and Combating the Financing of Terrorism Combating the Financing of Terrorism (AML/CFT) – Measures to deter, detect (AML/CFT) – Measures to deter, detect and report in line with FATF standardsand report in line with FATF standards

GroupGroup No. of No. of PrinciplPrincipl

eses

ObserveObservedd

Largely Largely ObservObserv

eded

Partly Partly ObservObserv

eded

I Conditions for Effective Insurance I Conditions for Effective Insurance SupervisionSupervision

11 11

II The Supervisory SystemII The Supervisory System 44 00 44

III The Supervised EntityIII The Supervised Entity 55 11 22 22IV On-going SupervisionIV On-going Supervision 77 33 44

V Prudential RequirementsV Prudential Requirements 66 22 11 33VI Markets and ConsumersVI Markets and Consumers 44 22 11 11VII AML, Combating and Financing VII AML, Combating and Financing

of Terrorismof Terrorism11 11

TotalTotal 2828 55 1313 1010

Position of observance - Insurance Core Principles

ICP 1: Largely observedICP 1: Largely observedConditions for effective insurance supervision: Conditions for effective insurance supervision: (Elements of environment where supervision can be most effective)(Elements of environment where supervision can be most effective)Insurance supervision relies upon Insurance supervision relies upon a policy, institutional and legal framework for financial sector supervision a policy, institutional and legal framework for financial sector supervision a well developed and effective financial market infrastructure a well developed and effective financial market infrastructure efficient financial markets. efficient financial markets. Status: Status: Strong legislative, regulatory and institutional framework Strong legislative, regulatory and institutional framework Well developed and effective constitutional &legal framework, including Well developed and effective constitutional &legal framework, including financial Professional bodies facilitates oversight of the financial sector - financial Professional bodies facilitates oversight of the financial sector - Accounting, Auditing and Actuarial – Although gaps identified in terms of Accounting, Auditing and Actuarial – Although gaps identified in terms of adequacy of Actuarial professionalsadequacy of Actuarial professionalsGaps: Gaps: Move towards global standards in accounting and audit issues – Move towards global standards in accounting and audit issues –

timeframe for adoption of IFRS laid down. These are being addressedtimeframe for adoption of IFRS laid down. These are being addressed Amendments required to legislative framework - Proposals for Amendments required to legislative framework - Proposals for

amendments to the Insurance Act, 1938 and the LIC Act, 1956 forwarded amendments to the Insurance Act, 1938 and the LIC Act, 1956 forwarded to Central Governmentto Central Government

ICP -1 ICP -1 Crit. Contentsa The government establishes and publicly discloses a policy statement

aimed at financial stability, effective financial sector supervision b Publicly disclosed, institutional and legal framework exists for financial

sector issuesFinancial Market infrastructurec There is a reliable, effective, efficient and fair legal and court system d Accounting, actuarial and auditing standards are comprehensive,

documented, transparent and consistent with international standards. e These experts are competent and experienced, comply with technical

and ethical standards f Professional bodies set and enforce technical and ethical standards g Basic economic, financial and social statistics are available to the

supervisor, the industry and the public. Advanced criteriah Laws and regulations are updated, as necessary, to reflect current best

practices and industry conditions. Efficient Financial Marketsi Well-functioning money and securities markets exist to support the

availability of both long term and short term investment opportunities.

II The Supervisory SystemII The Supervisory System(Mandates and responsibilities of the Supervisor)(Mandates and responsibilities of the Supervisor)

ICPs involved: 2- 5ICPs involved: 2- 5

ICP 2: Largely observedICP 2: Largely observed

Supervisory objectives:Supervisory objectives:The principal objectives of insurance The principal objectives of insurance supervision are clearly defined supervision are clearly defined Status: Status: Objective of supervision clearly laid down Objective of supervision clearly laid down Dual role of Development and RegulationDual role of Development and RegulationSupervisor vested with the powers to discharge supervisory Supervisor vested with the powers to discharge supervisory responsibilitiesresponsibilitiesGaps: Gaps: Dual role has come in for some comment Dual role has come in for some comment Some of the powers still rest with the Government of India. Some of the powers still rest with the Government of India. The regulatory position with respect to the exempted insurers is The regulatory position with respect to the exempted insurers is

not clear. not clear. State-owned insurers continue to be governed by certain State-owned insurers continue to be governed by certain

provisions of the specific legislationsprovisions of the specific legislations

ICP 2ICP 2Crit. Contents Compliance

a. Legislation or regulation clearly defines the objectives of insurance supervision.

Insurance Regulatory and Development Authority Act, 1999. The Insurance Act, 1938 and the Regulations framed there under lay down the regulatory framework for supervision

b. Key objectives of supervision promote the maintenance of efficient, fair, safe and stable insurance markets for the benefit and protection of policyholders.

Key objective is enshrined in the mission statement which isTo protect policyholders interestTo regulate, promote and ensure the orderly growth of insurance and reinsurance business.

c. Where there are multiple objectives, Supervisor discloses and explains how each objective will be applied

Objective of the supervisor are cohesive and not mutually exclusive.

d. Supervisor gives reasons for and explains any deviations from its objectives.

There are no instances of deviations from the stated objectives.

e. Correction in law/Regulation initiated where objectives are contradictory

There are no contradictions in the objectives of the supervisor

ICP 3: Largely observedICP 3: Largely observedThe supervisory authority:The supervisory authority:has adequate powers, legal protection and financial resources to has adequate powers, legal protection and financial resources to exercise its functions and powers;exercise its functions and powers;is operationally independent and accountable in the exercise of its is operationally independent and accountable in the exercise of its functions and powers;functions and powers;hires, trains and maintains sufficient staff with high professional hires, trains and maintains sufficient staff with high professional standards; and standards; and treats confidential information appropriately. (19 ECs and 2 ACs)treats confidential information appropriately. (19 ECs and 2 ACs)Status: Status: Supervisor independent agency reporting to Parliament through Supervisor independent agency reporting to Parliament through the Union Ministry of Finance.the Union Ministry of Finance.Powers vest with Authority to discharge its role Powers vest with Authority to discharge its role Free from political interferenceFree from political interferenceThe funds requirements met from fees levied. The funds requirements met from fees levied. Process of consultation with stakeholders in framing Process of consultation with stakeholders in framing policies/regulations policies/regulations Transparent processes.Transparent processes.Disclosure of performance Disclosure of performance Gaps: Gaps: Adequacy of powers to be addressed through legislative Adequacy of powers to be addressed through legislative

amendmentsamendments Certain powers rest with the Government.Certain powers rest with the Government.

ICP 3 Contd…ICP 3 Contd…

Crit. Contents Compliance

a Legislation identifies the authority responsible for supervision

Duties, powers and functions of IRDA are laid down in the IRDA Act, 1999.

b Legislation gives power to issue and enforce rules by administrative means

Section 14(2) of the IRDA Act, and Sections 34 and 114A of the Insurance Act deal with the powers vested in the Authority.

c Legislation grants powers for effective discharge of responsibilities.

Supervisor vested with powers to enforce observance of the law and the regulations framed there under.

Independence and Accountability

d Governance structure of supervisor defined

Internal governance procedures in place

Structure of IRDA clearly defined in the IRDA Act, 1999

e Explicit procedures on appointment and dismissal of the governing body in place

Procedures on appointment of the governing body are in place

f Institutional relationships between the supervisor, executive and the judiciary- clearly defined

The institutional relationship between IRDA, the Central Government and the Judiciary are clearly defined.

Circumstances when the Central Government would have overriding powers - laid down in the Act.

ICP 3 Contd…ICP 3 Contd…Crit

.Contents Compliance

g Supervisor and its staff - free from undue political, governmental and industry interference

IRDA and its staff are free from political, government or industry interference. They are public servants and are protected under law for acts in good faith

h Supervisor financed in a way that there is no undermining its independence

No reliance on the government grants for funding

Requirements met from “Fees” received from the insurers/ intermediaries.

i Supervisor has discretion to allocate its resources

IRDA adopts its annual budget depending on requirements.

j Supervisor has transparent processes and procedures for making decisions.

Consultation process adopted in framing various policies/ regulations.

k All material changes to the legislation and supervisory practices are normally subject to prior consultations with market participants.

Every proposal for change in regulation/ new regulation is preceded by consultation process.

ICP 3 Contd…ICP 3 Contd…Crit. Contents ComplianceAdvanced criterial Representatives of the Supervisor

publicly explain policy objectives, and report on their performance

Operations of Supervisor detailed in annual report available in public domain

m Subject to confidentiality considerations, information is provided publicly about problem or failed insurers, action taken

Violations/non-compliances, problems faced by insurers, action taken thereon Published on IRDA’s website

Powers:n Supervisor has powers to take

immediate action where necessary.

Adequate powers implied in legislation to take quick actions where necessary.

Financial Resourceso Supervisor

has own budget to conduct effective supervision. able to attract and retain highly skilled staff, hire outside experts as necessary

No constraints on financial resources Supervisor offers attractive pay package

at par with the other regulators in the financial sector to attract and retain qualified staff.

p Supervisor publishes audited financial statements on a regular basis.

Annual Report of IRDA, with details of its operations is placed in public domain

ICP 3 Contd…ICP 3 Contd…Crit.

Contents Compliance

Human Resource and Legal Protectionq The supervisory authority and its staff

-observe the highest professional standards-have the appropriate levels of skills and experience have the necessary legal protection to protect them against law suits for actions taken in good faith

Conditions of service for officers and staff laid in Regulatory framework

Employees in supervisor’s office governed by requirements of confidentiality.

Staff of the Supervisor given the status of Public Servants and are protected from being sued for actions done in good faith

r Supervisor has the authority to hire, contract or retain the services of external specialists

Authority to hire external specialists is implicit in its general operational powers.

s Where functions are outsourced, Supervisor assess their competence, monitor their performance, and ensure their independence

There is no proposal at present to outsource any of the supervisory functions.

The function of licensing of agents delegated to specified officers of insurers with appropriate safeguards in place

Confidentialityt Supervisor maintains appropriate

safeguards for the protection of confidential information in its possession.

Information specific to an insurer are treated/kept confidential

u External specialists hired by Supervisor are subject to the same confidentiality and code of conduct requirements as the staff of the Supervisory.

External specialists hired by Supervisor are bound by proper agreements/contracts containing adequate safeguards on this aspect.

ICP 4: Largely observedICP 4: Largely observedSupervisory process Supervisory process The supervisory authority conducts its functions in a The supervisory authority conducts its functions in a transparent and accountable manner.transparent and accountable manner. Status: Status: Regulations in consultation with industryRegulations in consultation with industryTransparent & consistent Transparent & consistent Decisions subject to judicial review Decisions subject to judicial review Publicly available - hosted on website Publicly available - hosted on website Quick decisions in emergent situationsQuick decisions in emergent situationsGaps: Gaps: Due to legacy issues relaxations/additional time Due to legacy issues relaxations/additional time

given to public sector insurersgiven to public sector insurers Presence of Consultative Committee can lead to Presence of Consultative Committee can lead to

delaysdelays

ICP 4 Contd…ICP 4 Contd…Crit.

Contents Compliance

a. Supervisor adopts clear, transparent and consistent regulatory and supervisory processes.

Guidelines issued in consultative process

Rules, regulations, guidelines etc are available in the public domain

b. Supervisor applies all regulations and administrative procedures consistently and equitably based on risk profiles of insurers.

Properly recorded decisions enable consistency and equitable treatment

c. Administrative decisions of the supervisor can be subject to substantive judicial review.

Currently, Legislation does not provide for the same

d.

Supervisor makes information on its role publicly available.

Role of the supervisor is prescribed in legislation is in public domain

ICP 4 Contd…ICP 4 Contd…Crit

.Contents Compliance

e. Structure of decision-making lines enable immediate action in case of an emergency situation

Decisions on major policy issues taken by the Board of the Authority. Board can meet at short notice

Also Chairman is authorized to take emergent decisions

f Process of appeal on supervisory decisions -specified and balanced to preserve independence and effectiveness

No mechanism for appeal on the penalties imposed by IRDA currently

g. Supervisor publishes a regular report – at least annually on its policy, objectives

Supervisor publishes the annual report on an annual basis.

 h. Supervisor publishes information about financial situation and major developments in the insurance industry.

Supervisor publishes the ‘Annual Report’ with various details

ICP 5: Largely observedICP 5: Largely observedSupervisory cooperation and information sharing:Supervisory cooperation and information sharing:The supervisory authority cooperates and shares The supervisory authority cooperates and shares information with other relevant supervisors subject to information with other relevant supervisors subject to confidentiality requirements. confidentiality requirements.

Status: Status: Sharing of information with counterparts – both domestic Sharing of information with counterparts – both domestic and foreign and foreign Interacts with other supervisors to draw upon their Interacts with other supervisors to draw upon their experiences experiences Cooperation amongst regulators within the country Cooperation amongst regulators within the country Home supervisor not required to take specific supervisory Home supervisor not required to take specific supervisory action against foreign establishments action against foreign establishments Gaps: Gaps: Absence of framework for sharing of information – hindrance to Absence of framework for sharing of information – hindrance to

supervision. supervision. Addressed through: Guidelines for sharing of information Addressed through: Guidelines for sharing of information - Confidentiality and reciprocity- Confidentiality and reciprocity - Application for MoU with the IAIS- Application for MoU with the IAIS