Tuesday, 15 May 2012

Barnett Waddingham Solvency II Survey - IMAP, ORSA and Pillar 3 progress

Bit late blogging on this (released last week), but Barnett Waddingham's short but perfectly formed survey on a sample of 38 insurers' progress on Solvence II programmes is worth a read (link to the PDF is at the bottom of the landing page). Not clear whether all respondents are IMAP candidates, but it appears to be a given.

It is a pretty diverse sample, weighted more towards small/medium life companies, but the results seem to be as the FSA suggests is par for the course right now, namely that Validation work is way behind where it ought to be (almost half of respondents are behind schedule on validation or indeed haven't started!). This despite the fact that three quarters of respondents flag validation as one of the most challenging aspects of IMAP, which one would hope would ensure it is given sufficient resource and management time. Only 7% are using external resource to validate for IMAP, which is surprising bearing in mind the size of the companies polled.

In addition, documentation is also flagged by a majority of respondents as a challenging IMAP issue, which surprises me to some extent, as the FSA have been particularly critical of this aspect.

Despite these issues, three quarters are confident/very confident that their applications will be approved - I'm guessing this may have lowered after the robust speech delivered by Julian Adams a couple of weeks back!

On the ORSA front, there was a bit of a mixed bag with regards to respondents opinion of the suitability of EIOPA's level 3 guidance (I personally thought it was pretty good, but not everyone agrees, particularly around documentation and group elements). With regards to where respondents were up to with the mechanics of the ORSA Process, every element appears to be underdone at this point, most worryingly around elements requiring model interaction such as S&ST, risk profile assessment and deviations between SF SCR and assumptions underlying the organisation's risk profile. As this would only be supporting evidence for model applications, you can perhaps cut a little slack here, but this is a big ticket item for Use Test, and to have so much work in progress at this stage does not lend itself to demonstrating embedded use!

Not entirely convinced by the most challenging aspect of ORSA being the daily monitoring of SCR - this is not a requirement by my reading, but even if it is (and accounting for all the proxies and assumptions that one would have to carry on the liability side of the balance sheet in particular), it shouldn't be a problem for model users unless you don't have someone to push the button.

On the Pillar 3 front, nothing especially new - difficulty in populating various aspects of the required templates/submissions are being experienced, most notably the 30% stating that they still have problems with quarterly balance sheet reporting, and an almost 50-50 split of respondents feeling they do not have the required data available to satisfy the requirements.

Worth a benchmark against your own progress at the very least, particularly if you are one of the little guys still hanging on in IMAP.

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