As with the last post, the Omnibus II draft has clearly hit the consultancy and lobbying firms, hence the burst of new media at the turn of the month.
The CEA of course had their own views on the timetable shifts in the context of transitionals. Strangely, they seemed to be more concerned with legislative draft quality than this persistent dithering between the main policy protagonists. They are still insistent on receiving transitional benefits for areas far away from Sr Bernadino's agenda at EIOPA (3yrs for governance and supervisory reporting for example). The divergence in requirements at national supervisory level is also a key concern, as arbitrage opportunities could open up in the unlikely event that transitionals are applied, but done so at national level (as I posted earlier, Italy or Poland could be a good place to be headquartered!).
The additional request for a temporary internal model transitional seems fair, especially since the FSA have made it clear they are not staffed for model approval - one for the UK to keep an eye on!
Maths isn't my strong point, but quite a forceful point is made about allowing EIOPA to lay claim to setting risk-free rates ("impossible for capital planning and ALM strategies") - the political arguments only supplement this vigour.
The gap in perspectives between EIOPA and the CEA is beginning to look canyon-esque, that's for sure...
An online repository for Solvency II, ERM and Corporate Governance material and comment from the Principal of Governance Matters, an independent Risk Consultancy firm based on the Isle of Man.
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