Submission to AMF re: Consultation on Third Party Risk Guideline

The CLHIA submits its comments to the Autorité des marchés financiers (AMF) regarding its draft guidelines on third-party risk management.

The CLHIA welcomes the overall objective of the proposed framework and the information sessions held by the AMF, particularly the focus on harmonization with other standards. However, it emphasizes that the guideline will be new to insurers and that a implementation period will be necessary to adapt existing frameworks.

The submission makes four key recommendations:

• Exclude insurance distribution arrangements
• Review the expectations for subcontractors
• Reconsider the expectations around systemic concentration risk
• Remove the expectation that the register be “centralized”

According to the CLHIA, these adjustments would improve clarity, reduce unnecessary burdens, and promote more consistent and proportionate application of the guideline.