My particular interest was their approach to governance and risk appetite, and there is no let-up from the obligations on insurance undertakings in this regard.
- Full qualitative and quantitative documented Risk Appetite required - argued against by some in the industry on the basis of "natuire, scale and complexity"
- Material deviation from Risk Appetite to be reported CBoI within 5 days - regardless of whether parent company or captive manager identifies it
- "Where appropriate", the board may consider a risk committee
- Internal Audit function required, but may use Group resource, or indeed outsource
I am by no means an expert in the area, but they seem like proportional, tailored solutions to retaining a presence in this market, and the Central Bank ought to be applauded for the effort, even if judging by the number of "no's" in the consultation, the industry wanted more!