SUSEP’s public consultation on regulatory proposals changing the scope of SRO ends on August 02, 2024

An opportunity to suggest simplifications and reduce SRO requirements by the insurance market

On July 02, 2024, the Superintendence of Private Insurance (“SUSEP”) published, in the Federal Official Gazette of Brazil, Public Consultation Notice No. 08/2024, aiming to increase transparency in its regulatory process. The notice addresses the drafts of SUSEP’s Circulars, defining the data that supervised entities must register in the Operations Registration System (“SRO”).

The SRO is an initiative to update the submission of information to SUSEP, carried out by the regulated sector through authorized entities that register transactions involving insurance, open private pension, capitalization, and reinsurance.

The normative proposal is based on the definitions of the Working Group created by SUSEP Ordinance No. 8,242, dated November 23, 2023. This group reviewed the scope of information to be registered in the SRO informative circulars, aiming to reduce the frequency and volume of data submitted, as well as to streamline the information received.

The group must identify the essential information for the supervision and regulation of all insurance branches covered by the SRO, both mandatory and non-mandatory. However, the SRO will not replace the statistical tables of the Periodic Information Form.

The premises to be followed by the group include:

• The obligation to register is limited to the minimum necessary for ongoing or planned supervision activities, which can include the development of new supervision techniques, provided they are justified.
• By way of exception, information not provided for in the circulars published can be requested, upon justification.
• The review of the scope of mandatory information must include all SUSEP’s circulars on the subject, even those already published.
• The layouts defined after identifying the information to be registered are mandatory for all registrars, who must maintain and publish them.

The intent stated at the “Preamble” section to the public consultation is to simplify the requirements and reduce regulatory costs to the market, in line with Decree No. 10,411/2020, which governs the analysis of regulatory impact to regulated markets by the Brazilian Federal Government.

Interested parties can send comments or suggestions on the text by August 02, 2024, through the Public Consultation System.

Access the circular draft in full.

Demarest’s Insurance, Reinsurance, Private Pension, and Supplementary Health team is monitoring the development of this public consultation until the final text is published and remains available to provide any additional clarifications needed.