QuestionsQuestions (IC Circular Letter No. 2015-41-A)
Investments made under an IMA account require prior approval of the Insurance Commission (IC).
The request must be accompanied by: (1) a Board Resolution authorizing the placements under IMA; (2) a pro-forma copy of the IMA; and (3) three (3)-year audited financial statements of the investment/fund manager.
The investment/fund manager must be a duly licensed and authorized bank by the Bangko Sentral ng Pilipinas (BSP).
All investments under the agreement must be subject to the provisions and limitations prescribed under the New Insurance Code and all applicable circulars and regulations issued by the Insurance Commission.
The IMA must incorporate: (1) all investments under the agreement shall be registered in the name of the company; (2) all investments shall comply with the New Insurance Code and applicable IC circulars/regulations; and (3) investment risk exposures must be clearly defined and measured according to the Risk-Based Capital (RBC) framework.
It ensures that the insurer (company) is the registered owner of the investments, aligning with regulatory control and compliance requirements stated in the circular.
Investment risk exposures should be clearly defined and measured using the Risk-Based Capital (RBC) framework.
The Insurance Commission must be furnished with quarterly reports on the investments held under the IMA account.
The circular explicitly requires prior approval; failure to obtain it would be non-compliance with the IC guideline, exposing the insurer to regulatory enforcement risk (e.g., possible sanctions or directives to regularize).
It authorizes the placements under the IMA, serving as proof that the insurer’s board approved the transactions subject to IC approval.
It allows the IC to review the proposed IMA terms before approval of the investments/placements under the agreement.
To provide IC with evidence of the financial condition and credibility of the investment/fund manager over a multi-year period.
The Insurance Commission must give prior approval for the investments. Separately, the BSP licenses and authorizes the investment/fund manager (as a bank).
No. The circular requires that the investment/fund manager be duly licensed and authorized bank by the BSP.
The New Insurance Code and applicable Insurance Commission circulars and regulations.
It requires that the IMA include specific provisions (registration in the company’s name, compliance with insurance laws/circulars, and RBC-aligned risk measurement), meaning the contract must be drafted to meet regulatory requirements.
IC approval must be obtained prior to the investment/placements under the IMA account, and quarterly reporting follows after investments are held.