I noted the following when going through it;
- Requirements "still developing" - unlikely with this new impasse at parliamentary level, and they are actually perfectly visible between the L3 and the Issues Paper (as there was no L2)
- Approach to ORSA "deliberatley non-prescriptive" - I suspect becasue the regulators couldn't staff a prescriptive review.
- ORSA to exert "increasing influence over key operational activities" - I would substitute 'increasing' for 'almost complete'.
- Dependent on "nature scale and complexity of the risks inherent in the business" - as if clients wouldn't have read this already
- Useful list of ORSA requirements in various guises between EU/US/IAIS/Bermuda as well as early incarnations
- Not keen on the principle of risk culture per se (little too much like nest feathering as a consultant) but the ticklist of positive attributes is admirable on p4
- Don't agree at all that Risk Appetite represents "overall philosophy to risk taking" - I have never considered it to be anything other than granular personally.
- Recommends a "slimline" ORSA to "engage the executive" - certainly in the UK where Boards will be familiar with ICAs, this may be tempting, but seems very presumptuous when there is so much prescriptive material in the L3 and CEIOPS Issues Paper.