The Joint Committee for the SIPMP convened two meetings on November 22, 2017, with the ECCU Regulators and the Insurance and Pensions Industry Representatives, respectively.
The meeting outlined the progress of the SIPMP Work Program over the past 9 months, looking at the major components of the 2017 Work Program.. An outline is summarized below:
1.0 Project Organization and Reactivation: The Project Management Office has been established in St Vincent and the Grenadines and a Work Program and Budget was adopted by the Joint Committee in May 2017. Three Working Groups/Sub-Committees comprised of Regulators and Industry representatives are functional and detailed Terms of Reference for the Core Committee, Joint Committee and the Sub-Committees have been adopted. In addition, a comprehensive Terms of Reference for the technical assistance required for the project has been compiled. The project has benefited through CARTAC, from the technical expertise of Morneau Shepell, a Canadian based consulting and regulatory firm as well as a St Lucian based company, Legislative Drafting Consultants LLC.
2.0 Establishment of the Legislative Framework: Progress with the ECCU Uniform Insurance and Pension Bill and the ancillary legislation, the Eastern Caribbean Financial Services Commission (ECFSC)Agreement and the ECFSC Bill is as follows:
- ECCU Uniform Insurance and Pension Bill: Review of Part 14- Association of Underwriters, Part 19- Pension Plans and Part 8- Statutory Funds and Pledged Assets is in process. This is coordinated through the Working Groups with direct interface with the technical experts. Final agreed drafting instructions in respect of Parts 14 and 19 are targeted for December 2017, with Part 8 recommendations to be finalized by February 2018. Work on the remaining technical aspect of the law- Solvency Guidelines and Fines and Penalties will commence in 2018.
- ECFSC Agreement/Agreement Bill: The Agreement and Agreement Bill has had two rounds of circulation to the ECCU Attorneys General. A final version of the legislation was circulated in November2017 and will be on the Agenda of the next Monetary Council meeting during the first quarter of 2018. Ratification of the Agreement is also targeted for the first quarter of 2018.
3.0 Establishment of the Single Regulator, ECFSC: In August this year, a Request For Proposal(RFP) was submitted to each ECCU jurisdiction. This was an invitation for submission of bids by participating Governments for the location of the ECFSC Headquarters. Copy of the RFP is available on the Publication Page. Bids received are under evaluation and will be submitted for decision of the Monetary Council during the first quarter of 2018.
The Levy Impact Sub-Committee has also commenced work on the funding options for the ECFSC. Statistical information on existing fees, taxes and levies has already been collected through survey from the Regulatory Authorities and the Ministry of Finance in each jurisdiction. Various existing funding models of regional based organizations will also inform the work of the Sub-Committee.
4.0 Establishment of an External Disputes Resolution Mechanism:- This is an important aspect of the SIPMP and seeks to address an existing gap regarding consumer protection and recourse in relation to financial services in the ECCU. This is targeted for 2018 and technical assistance requests are being made for this aspect of the work program.
5.0 Public Awareness and Stakeholder Engagement: Keeping stakeholders informed and providing avenues for communication and feedback to the project remain a priority. This has been primarily accomplished through regular reports at each meeting of the Monetary Council and by launch of the SIMPM website. The Project Manager has also engaged Regional Regulators in presentations on the SIPMP, made at the Caribbean Association of Insurance Regulators and Caribbean Association of Pension Supervisors Annual Meetings held in Jamaica in July, 2017. The Project Management Office has also accepted, and remains open to industry invitation to participate in events in which project updates and trends in insurance and financial services regulation have been the subject of discussions.
The forum held on November 22, 2017 was the second such event for the year, the earlier meetings having taken place in February and April of 2017.
6.0 Reporting and Risk Management: The Joint Committee provides direct oversight of the Project and reporting is achieved at three levels on a monthly and quarterly basis- the Monetary Council, the ECCU Technical Core Committee on Insurance and the Joint Committee. In addition, a detailed Risk Register which documents and rates identified risks to successful project implementation, complete with triggers and contingency plans, is maintained, updated on a quarterly basis and reviewed by the Core and Joint Committees.
The major challenge experienced to date was the passage of Hurricanes Irma and Maria which impacted timelines and quite understandably, shifted focus of the participating governments. One of the significant risks also identified , is the availability of technical assistance for specific areas of the work program. Efforts to secure appropriate expertise are on-going, with the assistance of the ECCB.
7.0 Planned Event: A two- day Change Management Seminar is planned for May/June 2018 and will seek to bring together Regulators and Industry Representatives to discuss the impact and changes resulting from the SIPMP. The seminar will address coping with change and the role of Stakeholders in effecting successful change. NOTE: This event is contingent on available funding and further details will be circulated upon finalization of funding and other arrangements.