보험자의 약속 이행 - Marcus Lim 싱가포르 금융통화청(MAS) 부관리이사의 기조연설, 싱가포르 생명보험협회(LIA) 연례 오찬, 2026년 3월 30일

Ms Wong Sze Keed, President of LIA Singapore Distinguished guests Ladies and gentlemen 1. Thank you for inviting me to join you today.

2. When I last had the opportunity to address you in 2023, I reached for a climbing analogy. I spoke about Alex Honnold's free-solo ascent of El Capitan, and I used it to make a point – that insurance is an enabler. It is the safety rope that allows people to take risks and reach heights they could not otherwise achieve.

3. Since then, Honnold has continued to scale new heights. In January this year, he free-soloed Taipei 101 – on live television. This time, as a 40-year old father of two – with far more at stake. Some consider him to be reckless, but we need to appreciate what goes on behind the scenes.

4. In a 2018 interview, Honnold drew a clear distinction between fear and risk. He said: “If there is a high level of risk, you should be feeling fear. It’s a warning that there is real danger. Typically, if I’m feeling a lot of fear, then I wait and prepare more, do whatever it takes to mitigate that, and then do the climb when I feel comfortable. https://www.tatlerasia.com/lifestyle/sports/alex-honnold-quotes-fear-focus-performance ”

5. Honnold does not free-solo on a whim. He free-solos after he has done the work to make the unthinkable survivable. In a way, that idea captures what insurance is ultimately about.

6. The foundational compact of insurance is one of the most elegant arrangements in commercial life. A person faces a risk he cannot bear alone. He pools that risk with others. In return for a premium, he receives, as Sze Keed mentioned, a promise: that when the worst happens, he will not face it alone.

7. That promise is the product. Not the policy document. Not the exclusion schedule. It is the promise.

8. And when I think about what it takes to keep that promise, I want to focus on three roles that matter most:

• First, being a reliable partner to customers; • Second, being a prudent risk taker; and • Third, being a discerning innovator for the future.

A RELIABLE PARTNER 9. Let me start where regulation must always begin: with the customer. Insurers need to be a reliable partner to their policyholders. Fair Dealing 10. When I look at complaints data and the feedback that MAS receives from policyholders across this country, I see an industry that in many respects serves its customers well. But I also see, in places, a drift from that original promise. There are still instances of insurers failing to provide timely updates to claimants, representatives not explaining terms and conditions clearly, and application rejection decisions that are poorly communicated. These are not abstract issues. They shape how policyholders experience insurance at the moments that matter most.

11. Take investment-linked policies for example. They are complex and can be difficult for policyholders to understand. That is why MAS consulted on a product highlights sheet to make key risks, features, and fees clearer. We will classify ILPs as complex products, signalling that advice is recommended before purchase. The response paper will be issued shortly. We also welcome the efforts by the industry to take a more holistic look at ILPs and how they serve the needs of policyholders.

12. On fair dealing, work continues to examine how well the Guidelines we issued in 2024 are being applied. We have conducted a thematic review of complaints handling processes across selected banks and insurers to get a sense of how thoroughly issues are reviewed. One clear lesson is this: complaints should not be treated in isolation. They should be discussed at the board and senior management levels for what they reveal about deeper issues – in products, processes, or people. We intend to publish an information paper later this year to share good practices observed, so that firms can better benchmark themselves. We also look forward to how the Fair Dealing Sub-Committee The Sub-Committee will be set up under the Insurance Culture and Conduct Steering Committee (ICCSC), supported by LIA and the General Insurance Association of Singapore (GIA). will bring more focus to promote and uplift fair dealing practices. Sustainable Coverage and Enhanced Customer Experience 13. A reliable partner is one that thinks ahead. In this regard, I want to thank the industry for your commitment to making coverage sustainable over the long term and for leaning forward to help your customers and their loved ones navigate critical life transitions.

14. Following MOH’s right-sizing initiative for Integrated Shield Plans, IP insurers have stepped in to enhance their communication materials to encourage customers to proactively review existing coverage with long term affordability in mind. LIA has also developed a set of guidelines to enable representatives to carry out effective right-sizing conversations. I thank LIA and all of you for the close collaboration with MAS and MOH on this important issue. These efforts matter.

15. Customers rely on insurers most during major life transitions – whether planning for later life or coping with the loss of a loved one. How the industry shows up in these moments, through clear communication, thoughtful support, and well‑designed processes, goes to the heart of building trust and delivering fair outcomes.

16. Earlier, Sze Keed touched on the infographic on death claims that LIA released last year. This is a positive step in helping the loved ones of policyholders navigate a difficult period with more clarity and less distress. We can go even further – by strengthening consumer education on statutory insurance nominations, simplifying post‑death administration through common claims forms and better asset discovery, and providing centralised, authoritative guidance. As demographic needs evolve, insurers should also reimagine how services are delivered to ensure accessibility for customers facing physical or cognitive challenges. Here we can draw on practices from other sectors, and societies that may be further along in the ageing spectrum. A PRUDENT RISK-TAKER 17. Keeping the promise requires more than good intentions. It requires the ability to deliver – and that brings me to risk management. Insurers need to be prudent risk-takers to sustainably shoulder risks over the longer term.

18. At the core of this is capital. A robust capital framework is foundational to trust. But we must strike the right balance. More is not always better. Capital must be risk‑appropriate and evidence‑based.

19. MAS recently published the revised Notice 133 on the Valuation and Capital Framework for Insurers. The revised Notice will take effect from tomorrow. Let me highlight three refinements:

First, we are implementing a new capital treatment for qualifying infrastructure investments under the enhanced risk-based capital framework for insurers (“RBC 2”). In addition, through “Project Verdi”, we are encouraging insurers to build expertise by supporting sustainable infrastructure investments even if they do not meet all the infrastructure criteria under RBC 2.

Second, we have refined the treatment of structured products, allowing insurers to recognise external credit ratings for securitised asset tranches when calculating capital charges. This brings the capital treatment in line with our approach to corporate bonds.

Third, we are introducing equity counter-cyclical adjustments. These are designed to reduce procyclical behaviours during sharp market swings. They will help insurers avoid forced asset sales during stressed market conditions, promote overall financial stability, and allow more time for thoughtful portfolio rebalancing.

20. Our objective is clear: to ensure that insurers are able to meet their obligations to policyholders. This requires a capital framework that is nimble, data-driven, and supportive of long-tailed liabilities.

21. An emerging global trend that we are tracking is the increasing allocation by insurers to private assets. This could be through direct investments in private equity or credit, or indirectly through asset-intensive reinsurance, or AIR. Reinsurance is a risk transfer mechanism and permits an insurer to optimise its balance sheet. AIR presents an opportunity for insurers to tap specialised investment capabilities – often in private markets – to support policies with significant investment risk, such as whole life and universal life.

22. While longer-dated private credit can be a natural fit for insurers’ long-term liabilities, recent market disruptions have highlighted important vulnerabilities. When liquidity dries up and valuations become opaque, stress can quickly escalate. With AIR, risk does not disappear – it changes form and shows up in collateral quality, market liquidity, and the ability to meet recapture obligations under stress. Insurers must therefore exercise strong risk management, apply robust stress testing, and ensure that the search for yield never compromises the fundamental promise of policyholder protection. MAS targets to consult on further guidance in this area later this year.

23. Beyond financial risks, insurers must also pay attention to non-financial risks and be operationally resilient. Incidents last year demonstrated that your vendors can be a weak link in your efforts to maintain trust with your policyholders. MAS is presently consulting on new Guidelines on Third Party Risk Management and Operational Risk Management. The consultation closes on 20th April and we look forward to hearing on whether the expectations set out are practical in your context. A DISCERNING INNOVATOR 24. Finally, to deliver on promises to policyholders long into the future, insurers must guard against becoming ossified. Customer expectations, technology, and risks continue to evolve. So insurers need to innovate – and to do so discerningly.

25. Artificial Intelligence (AI) is a good example. We are at an important juncture in the development of AI. Many jurisdictions, including Singapore, have articulated national strategies to harness its potential. Used well, it can make services more timely, more accessible, and more responsive. Used poorly, it can undermine trust very quickly.

26. We are currently working on a set of Guidelines in AI Risk Management. Many of you have also participated in Project MindForge, which recently published an AI Risk Management Operationalisation Handbook that seeks to complement the proposed Guidelines. I would like to thank LIA members and all participating firms for your contributions to both the consultation feedback for the Guidelines and the Handbook. Your perspectives will help us to navigate this new technology well.

27. For those who want to explore AI use cases but are not sure how, MAS is helping insurers adopt and build AI more quickly and confidently. PathFin.ai is a platform that supports firms in scaling proven AI use cases by sharing industry validated solutions and facilitating peer learning. For more AI-forward institutions, BuildFin.ai brings firms together with technology partners and research institutes to work on shared challenges faced by the industry.

28. The use of AI will also transform jobs. Here, MAS has partnered with the Institute of Banking and Finance to map how jobs will change in an AI enabled future. This will support upskilling, reskilling, and job redesign across the sector. The Singapore College of Insurance (SCI) has also launched AI capability building programmes for the insurance sector. CONCLUSION 29. Let me close by returning to Alex Honnold. In 2016, Honnold set out to free-solo El Capitan for the first time. Months of preparation. An expensive documentary crew. A climbing season that was closing. The weight of expectation on his shoulders. And 480 feet into the climb, something did not feel right. He stopped. He climbed down. The attempt was abandoned, and the climb was completed the following year.

30. This example is captured in Annie Duke's book “Quit”. In the book, she points out that this is not a story about failure, but about the quality of Honnold's decision-making. What she observed is that plenty of expert climbers have pressed on when they should have turned back. The 1996 Mount Everest disaster is one well-known example: climbers ignored predetermined turnaround times because the summit was in sight. The preparation, the money, and the built-up expectation became reasons to keep going – even after conditions had clearly changed.

31. Honnold was different. He had, in effect, set what Duke calls “kill criteria” – pre-committed signals that would override the pressure to continue. And when a key signal was triggered, he honoured it.

32. Let me ask the senior leadership teams in this room to reflect on whether your organisations have equivalent kill criteria. If a product is generating complaints at a rate you did not anticipate, what is the trigger for a fundamental review rather than a marginal adjustment? If an investment strategy is not working out, when do you decide to cut your losses? When you deploy an AI model, what are the conditions under which you will suspend its use? These are not questions about defeat. They are questions about discipline.

33. Firms that endure are not defined by perfection, but by knowing when to pivot and when to persevere. They are ultimately guided by something larger than the moment: a promise made to those who depend on them.

34. Insurance, at its core, is an expression of confidence in people and in the future. It is about enabling lives, protecting aspirations, and standing firm when times get tough. That is the promise this industry makes. When delivered with judgment, humility, and resolve, it becomes one of the quiet strengths of a resilient society. And in your hands lies the continuation of that vital promise.

35. Thank you.