2012年-IMF国际货币组织全球_Spain_IAIS_Insurance_Core_Principles_Detailed_Assessment_of_Observance_83页_952kb

Summary of the Detailed Assessment of Observance of the Insurance Core Principles in Spain (May 2012)

Core Content

This document provides a detailed assessment of the observance of the Insurance Core Principles (ICPs) in Spain, conducted by the International Monetary Fund (IMF) in May 2012. The assessment is based on the revised ICPs issued by the IAIS in October 2011 and considers the legal and regulatory framework, market structure, and supervisory practices in place at the time of the evaluation.

Main Findings

1. Market Overview

• The Spanish insurance market is well-developed and offers a comprehensive range of products from domestic and foreign insurers.
• Life insurers account for about half of the total gross premium written in 2010 and hold approximately 80% of the industry’s assets.
• Non-life insurance is dominated by motor and property lines, with A&H (accident and health) accounting for 20%.
• The reinsurance market is relatively undeveloped, partly due to the presence of the Insurance Compensation Consortium (CCS), which provides coverage for catastrophic risks through a compulsory surcharge, reducing the need for reinsurance.

2. Market Performance

• Total written premiums increased over the past five years, except for a 6% decline in 2010.
• Insurers remained profitable, with combined ratios below 100% in the last three years and a high Return on Equity (ROE) in 2011: 15% for non-life and 13.5% for life.
• Under Solvency I, the industry showed a sound solvency margin of around 200% in the life sector and 350% in the non-life sector.

3. Regulatory Framework

• The insurance sector is supervised by the DGSFP (General Directorate of Insurance and Pension Funds), which is part of the Ministry of Economy and Competitiveness (MEC).
• The DGSFP is organically dependent on the MEC and does not have autonomy in setting its budget.
• The DGSFP has been working closely with the European Commission and EIOPA on the design of Pillar 1 of Solvency II.
• Spain has made progress in addressing several recommendations from the 2006 Financial Sector Assessment Program (FSAP), but the recommendation to strengthen the autonomy of the insurance supervisory body has not yet been implemented.

4. Supervisory Challenges

• Resource Constraints: The DGSFP faces limited resources, which may affect its ability to effectively supervise the sector, especially with the implementation of new international standards.
• Solvency II Impact: The adoption of Solvency II could lead to additional capital requirements for some insurers, requiring further calibration of the system.
• Product Disclosure: There is a need to improve product disclosure requirements for life insurance, with DGSFP working on standardizing and formalizing these requirements.
• Intermediary Regulation: There is a significant number of intermediaries, with a growing number of agents and a stable number of brokers. The DGSFP has set up an electronic register of intermediaries since 2007.

5. Market Structure

• The Spanish insurance market is characterized by a large number of small insurers and a few large ones.
• The top 5 life insurers accounted for 37.5% of the market (by assets), and the top 5 non-life insurers accounted for 50.9% (by premium).
• The market is concentrated, with five of the top 10 insurance groups being foreign, highlighting the importance of cross-border cooperation.

6. Distribution Channels

• Bankassurance is the main distribution channel for insurance products, with a 38% market share, particularly dominant in the life insurance sector.
• Agents and Brokers are the primary channels for non-life insurance, accounting for 82% of sales.
• Direct Sales (including internet) have a small market share, with only 0.01% of individual life insurance sales and 0.05% of non-life sales in 2010.

7. Insurance Assets and Investments

• Total assets held by insurers at the end of 2010 amounted to €242.3 billion, or 22.8% of GDP.
• The majority of investments are in government and corporate securities, with around 25.5% and 35.5% of life insurers’ assets respectively.
• Real estate exposure is low, and sovereign and corporate debt pose a significant credit risk.
• Intra-group and related company investments may also be a source of risk, especially for composite insurers.

Key Recommendations

• Improve the autonomy of the DGSFP in setting its budget and performing supervisory functions.
• Enhance product disclosure requirements for life insurance to ensure fair treatment of customers.
• Formalize and standardize disclosure practices at the point of sale and implement ongoing disclosures.
• Strengthen cooperation and coordination among sectoral supervisors, particularly in cross-border insurance groups.
• Continue efforts to calibrate Solvency II and address the potential capital requirements for some insurers.
• Revamp insurance contract law in collaboration with the Ministry of Justice to align with international standards.

Conclusion

The Spanish insurance sector is well-developed and has weathered the financial crisis effectively. However, challenges such as resource constraints, the need for improved product disclosure, and the potential impact of Solvency II remain. The regulatory framework is sound, but greater autonomy and coordination are needed to ensure effective supervision and resilience in the face of future risks.