Having reviewed the IRM's lobbying letter, it certainly has the tone of a rebuke ("recent debates have caused unnecessary confusion" being my favourite line). The presenter was a relatively big hitter at the FSA, so no reason to think this isn't the FSA party line.
What I noted from the rest of the letter was;
- Felt that the directive is being interpreted to assume a CRO must have risk and actuarial skills
- Rather harsh contention that the development of ERM-related actuarial qualifications shows that their profession does not provide "sufficiently broad training".
- "Trend in the market" for hiring business-focused CRO's. Not substantiated, but having looked at the CVs of a couple of the CRO membership it does stack up.
- Struggled to find an example where risk and actuarial have to collaborate at the moment, using Op Risk modelling as the easy case study.
- Suggests that actuarial could not perform independent oversight of reserve risk, when via chinese walls or basic separation of duties one would think they could
- "There have been suggestions that there are no suitable qualifications for risk management professionals" - this must have come verbally at the presentation, as I cannot establish this from the slides. If this was said or even insinuated it is pretty outrageous.
- Ticklist of risk function attributes under Solvency II matches up largely with the Level 2 and 3 guidance
- Strange comment that the IRM wants "further guidance" on what constitutes a fully effective risk function, presumably as the FSA and Solvency II views are perceived to have diverged.