- "What [any further delay off the back of March's ECON vote] might do instead is merely compress the period between transposition and implementation"
- "...for the time being we remain of the view that we must plan for a 2014 implementation"
- "...it is vitally important that you stick to the submission slots we have already agreed with you"
- "By sticking to your submission slot you will also be considered alongside a peer group of firms" - this is the first I have heard of submission slots being allocated to groups of 'peer' companies, assuming this was not a figure of speech
- "...we are basing our approach to the next phase [of IMAP] on the stable draft text of the Level 2 material which was circulated by the Commission in November" - which is nice if everyone else had access to it [leaks notwithstanding!]
- "[we] will be publishing later today an updated version of the self assessment template based on this" - you may be able to sers toi at this location (ZIP file)
- "We appreciate that this change will require some additional work for firms" - nicely played down!
- "...the materials we are launching today do not take any account of the Level three text", but promises to do more once the L3's stabilise
- On technical provisions - "Our view is that we would not be able to approve a model under Solvency II without having reasonable assurance as to the accuracy of the underlying balance sheet, and we will therefore be undertaking a review of the technical provisions of IMAP firms as part of our existing activity with the firm before and after its submission slot"
- "...it is unlikely that we will review the calculation of technical provisions until a point in 2013", while the approach used will be assessed earlier, but "which may include the use of external review"
- "It will be necessary for us to gain assurance that all [300+ criteria in the Directive text] of these requirements have been met before we can decide to grant approval for a model’s use
Monday, 27 February 2012
FSA and Solvency II - speech from Julian Adams today for IMAP firms
Hot off the press, Julian Adams spoke to the great and good today (i.e. I wasn't there!) regarding those who are in IMAP, and dropped the following hot chat: