Lloyds of London on Solvency II - Annual Report content

Hot on the heels of their delay in submitting their IMAP pack to the FSA, Lloyds of London pushed out their annual report today - as ever, a riveting read in general (and emphasises the scale of Nat Cat activity last year), but I concentrated more on the Solvency II side. They noted;

• "… we have made excellent progress to ensure that, whatever its final implementation date, the Lloyd’s market will be operating to the standards required of Solvency II by January 2013" (p8) - no mention of the IMAP delay, although this could of course work in their favour when looking to achieve this target.
• "Lloyd’s preparations for Solvency II advanced well in 2011, both within the Corporation and the market, and the entire programme across all relevant parts of the business is on track" (p22) - again, odd when IMAP activity has been postponed 3 months!
• "...Solvency II may have a positive impact on the reinsurance sector by increasing demand for reinsurance products" (p49) - same message put out by Swiss Re.

They also note good progress on the ORSA process and reporting front;

• "Lloyd’s has also further developed its approach to the Own Risk and Solvency Assessment (ORSA) – which aligns all of the activities Lloyd’s uses to manage risks and ensure the right level and type of capital. This alignment improves the quality of management information and the resulting decisions. In 2011, we produced a series of pilot reports to enable senior management to review the ORSA’s proposed structure and content. A live report was finalised and approved by the Franchise Board during the first quarter of 2012. In future, the report will be produced at least annually." (p30)

And finally a nice piece of disclosure on economic capital;

• "The capital provided by every member is assessed according to the Lloyd’s Individual Capital Assessment (ICA) capital setting framework. When agreed, each ICA is then ‘uplifted’ (by 35% for 2011) to provide an extra buffer to support Lloyd’s rating and financial strength. This uplifted ICA, which is the Economic Capital Assessment (ECA), is used to determine members’ capital requirements subject to prescribed minimum levels. The FSA oversees the annual review of syndicate ICAs by the Corporation, which reviews the historical performance, business plans and risk appetite of that syndicate in assessing the adequacy of the capital level proposed." (p69).

Whether all of this is good enough to allow them to achieve their objective of avoiding parallel running ICA and the internal model in 2013 is anyone's guess, but let's wish them good luck.