So EIOPA have finally coughed with QIS5, and to help myself as a non-actuary, I tweeted the component parts most interesting to me as a Pillar 2 man. Whilst I am not at all surprised to see respondents commenting that their ORSA and system of governance preparation is lacking, to see that around 5% do not currently meet the MCR is pretty sobering.
Perhaps what is of most concern , at a time where the UK and Irish regulators cannot get heads in the door quick enough, is that the headline is that Internal Models will probably bring your capital requirements down (or at least hold them steady). With even some industry sympathy for the FSA at conducting model assessments, one has to wonder how to reconcile the desire of the industry to receive the economic benefits with the practicality of handling the volumes - partial approvals by mid-2012 anyone?
Bringing this back to my discipline, the same problem has to be in the wings for ORSA assessment - unlimited word count, and explain each and every divergence. The difficulty for both parties of course is that there is not likely to be anything like an ORSA template, so to be both concise and complete will be quite a task.