Tuesday, 12 June 2012

Elderfield speech to Insurance Day summit in Bermuda - equivalence, model approval and "hub and spoke"

Very informative speech delivered this week by Mr Elderfield from the Central Bank of Ireland to the Insurance Day summit held in his previous stomping ground of Bermuda (certainly a more welcoming climate that last month's summit in not-so-sunny London!).

He mainly covers equivalence, internal model applications and, as one might expect from the Emerald Isle, the potential for Hub and Spoke operations and the potential capital benefits of this technique (which has a sniff of Group Support about it in all but name). I noted the following;

  • Suggests Solvency II provides "...an incentive for investment in risk management, including the use of internal models" - I would substitute "incentive" for "compulsion"!
  • Singles out "small firms" as those which will "certainly" struggle to assimilate and implement Solvency II in its current guise
  • Notes that "...the current target is that member state governments will domestically implement [Solvency II] by 30th June 2013" - I have emphasised the "current target", as the very wording suggests that there is an implication it is not the "final target"!
Model applications
  • "...it is important that approval process doesn't get bogged down in detail such as endless documentation reviews" - cue some raised handbags down at Canary Wharf I suspect!
  • Highlights expert judgements around correlation and diversification (as he has done this time last year) as being much more significant around challenging the solvency requirements calculated by the models, in particular the "swing" these elements have on the final numbers. On that premise, he puts these "...at the forefront of the regulatory approval process", as well as expecting them to generate the most challenge in the boardroom.
  • Elaborates on the extent of Board challenge by commenting that "...boards should be expected to challenge vigorously the amount of diversification benefit being claimed in internal models, even if they don't know the internal plumbing of copulas or correlation matrices". Very telling comment, and clearly one to heed, bearing in mind he is on EIOPA's management board.
Hub and Spoke
  • Seeing "considerable interest" in using Ireland for the "hub" of the "hub and spoke" business model - one may have said this was for regulatory arbitrage purposes 5 years ago, but I'm guessing corporation tax, falling wages and underemployment may have kept it in play even after the recent beefing up of the CBoI
  • Comments that "...it will be interesting to see whether [the hub and spoke] model will grow as Solvency II gets closer to implementation - implies that not only does he think the existing corporate structures are not settled yet, but that Ireland is actively open for business in this regard.
  • Not sure if he was just being polite to his hosts, but he commented "...Bermuda is very well placed for [the equivalence] assessment process" - again worth heeding in the context of his position at EIOPA, as well as Bermuda coming off worst of the 3 countries which have been assessed in wave 1.
  • Suggests there should be some sort of early adopter's premium for Bermuda which makes it worth being ahead of those countries who may come in in wave 2 (no mention of one of their competitors Guernsey in this context, who continue to bang the IAIS ICP drum while stating categorically that they will not seek equivalence).
Good intelligence all in all - PS must try and swing an invite to one of these things when they go tropical!

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