Organization of the Network Control Framework of an Insurance Group
Insurance group with over 15 billion in premium income
Following the entry into force of the Distribution Network Control regulation ex Reg. 40/18 IVASS, the internal structures in charge of verifying the distribution of insurance products required the support of MACFIN in order to carry out an assessment of the adequacy of the controls adopted by the Company and to formalize the rules and methodologies to be used for network control monitoring activities (i.e. information sources, KRI/KPI of reference, etc.).
Goals
Mapping the risks of non-compliance
related to regulatory requirements for the control of distribution networks
Identify areas for improvement
in relation to the existing controls on the distribution networks and prepare a Plan of action (i.e. Gap Analysis and Action Plan)
Define and formalize
in compliance with the reference regulations, the control framework of the distribution networks (i.e. roles and responsibilities, methodologies, controls, etc.) and the related internal and external reporting flows (IVASS)
Activity
Preliminary analysis
Of the organizational structure and controls implemented in relation to the activities of the distribution networks (i.e. organizational structure, procedures, etc.)
Mapping of regulatory requirements
on the control of distribution networks, the related risks of non-compliance and key controls at 1st level, through the collection and analysis of organizational documentation and existing distribution agreements
Gap Analysis and Action Plan
in relation to the overall network control framework as a function of risk mapping, taking into account the market best practices
Definition of methodologies
to be used in the activities of identification, evaluation and risks, related to an inadequate distribution of products (e.g. verification methods, information flows, KRI/KPI, etc.), and revision of management and external reporting flows (IVASS)
Results
Definition of a clear taxonomy
of the risk in terms of network control in order to orient the verification activity in a risk-based perspective
Definition of an effective control framework
intended to cover all relevant areas of insurance product distribution activities for the various sales channels
Comparability
of the verifications carried out over time and optimization of the management reporting and addressed to the Supervisory Authority in the field of network control
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