The following topics should not be discussed in GRA meetings unless a separate lawful, approved, and appropriately controlled process exists outside the ordinary GRA meeting environment.
Prohibited topics include pricing, fees, premiums, commissions, spreads, margins, discounts, compensation, salaries where competition-sensitive, underwriting terms, coverage terms, reinsurance capacity, risk appetite, lending terms, credit approval, covenants, collateral, borrower files, investment terms, valuation, allocation intent, securities recommendations, capital-raising solicitations, trading strategies, deal terms, transaction documents, customer allocation, market allocation, supplier coordination, bid coordination, procurement strategy, confidential supervisory information, material non-public information, customer data, restricted public authority information, confidential claims data, internal insurer files, confidential bank files, confidential investor records, and competitor-sensitive business plans.
GRA meetings should also avoid discussion that could create an appearance of collective decision-making among competitors or regulated actors. Participants must not use GRA to coordinate market conduct, exclude competitors, influence prices, shape underwriting or lending standards for competitive purposes, divide opportunities, or pressure counterparties.
If a topic is relevant but sensitive, it should be reframed at a public-safe, aggregated, anonymized, scenario-based, or principles-based level. If it cannot be safely reframed, it should be stopped and routed outside the meeting through the correct lawful process.
