Thursday, 1 December 2011

Solvency II Forum in Dublin - Central Bank of Ireland

All manner of fun no doubt had over on the Emerald Isle today at the CBoI's Solvency II forum. Would love to have been a fly on the wall, however consultants don't get the luxury of days off! Five presentations were seemingly put on the table, and if any of you guys reading in Ireland have anything to add, I'd love to hear it!

First presentation features a nice calendar for 2012, but more importantly the results of a "preparedness for Solvency II" survey issued in September. The following seemed pertinent;
  • Around 15% didn't bother replying to and of those who did, over 10% said they were 'not preparing' at all!
  • Only 40% into the "implementation and execution" phase
  • Very high number of 'other' responses to questions on sponsorship and rollout responsibility, where the options provided were the obvious suspects (CEO, CFO, CRO, COO) - Appointed Actuary the missing link?
  • Three quarters were "quite confident" that they will be ready from end of 2012
  • Almost 90% think their boards (including NEDs) have "satisfactory" Solvency II knowledge - seems generous to say the least, however these were responses to the Central Bank, so one would be unlikely to say different!
  • Top ranked aim of Solvency II programmes was regulatory compliance - that's the spirit, no flannel about business benefits and policyholder protection, just comply!
  • 6% not very confident that the CBoI will be ready to conduct supervisory reviews "effectively and appropriately"
  • Over 20% "not very confident" that their governance structures are Solvency II compliant (odd, as the requirements of the corporate governance code mirror or indeed surpass Solvency II requirements, and they ought to be complying with those now!)
  • 50% haven't defined their ORSA Process yet!
In addition, some other CBoI preparation detail was laid down, most notably;
  • Looking to build processes in order to formally accept internal model applications from 1st June 2013 which instinctively feels very late
  • Liaising with the industry on the ORSA Supervisory Reporting requirement (which might lead to some element of prescribing content, bearing in mind the ORSA Consultation paper opens up the possibility of using one's ORSA Report to meet that requirement)
  • Details on what the CBoI expectes in the "transition year" of 2013 yet to be finalised
Interestingly, in the Internal Models presentation, they are very explicit that Validation must cover all aspects of the models inputs, processes and outputs, not just the internal model itself - this "narrow vs wide" validation scope is something which I haven't seen the FSA be this specific about.

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