Important to note the following from a UK and Ireland practitioner's perspective, on the premise that the two regulatory bodies in the UK and Ireland are setting the benchmarks in many respects;
- 'No panic' message given regarding the Omnibus II 'delays' - timetable unchanged in this regard
- No references to the Commission's draft Level 2 text as a basis for undertakings to use for internal model application activity (which the FSA went out of their way to advocate at their February IMAP event). Is there a legitimate reason for this, bearing in mind how useful the document is for applicants in ensuring their documentation addresses the final requirements, even if only 'there or there abouts'?
- Model applicants should be "well advanced with the technical aspects of their model build" - this is somewhat to the FSA's take, which was that build should be pretty much complete by now (p10)
- Some nice visceral examples of Use Test evidence requirements from undertakings, particularly around evidencing Board 'understanding' of the model - I would add that these seem onerous for NEDs, but reasonable for executives, so I would be interested to see how this is applied (could you for example see your non-industry, non-executive director justifying diversification benefits to your friendly local regulator? Is that a reasonable use of project resource/Board training time?)
- Board members will be interviewed by the CBoI individually "without the support of their technical experts" - I'll get my coat then...
- On ORSA, they "recognise that individual undertakings would like to get more details on specifics of the ORSA Reporting Process", but want undertakings to focus on the contributing processes themselves - easier said than done, particularly when even EIOPA had to relent from the mantra of 'ORSA is process, not a report' when they got to public consultation stage!