CMF pone en consulta norma que precisa la constitución de reservas de siniestros para seguros de caución o garantía a primer requerimiento

The proposal would require insurers to reserve the full amount claimed, capped at the insured sum, removing ambiguity in current practice. For compliance teams at insurers writing these products, the key action is to assess whether existing reserving methodologies align with this criterion, model the balance-sheet and capital impact, and consider whether to submit comments before the 23 October 2026 deadline. Banks and corporates that rely on these guarantees should note that insurer reserving practices may affect pricing, capacity, and counterparty risk.

While the consultation is at an early stage, the direction of travel points to more conservative and transparent reserving, which could increase reported liabilities and reduce earnings volatility if applied consistently. Firms should engage now to shape the final rule, update reserving policies, and ensure data systems can calculate reserves at the individual claim level. RegCanary will monitor the final text for implementation timelines.