E&Y dropped a Pillar 3 preparations survey out to a relatively small (53 respondents) but nicely spread (8 countries, and roughly split into Life/Non-Life/Composite) sample, and as one might expect, preparations were found to be slightly underdone by the majority.
They note that even for companies who have completed their gaps analysis between BAU and Solvency II demands, there remains some meaty outstanding issues such as reporting granularity; capturing synergies for other requirements (namely ORSA); policy drafting and implementation around data governance, and process redesign. Appreciating that some of these matters are still up for debate, some aspects of this gap list should be closed by now, and I suspect that the regulators will not look favourably at firms who continue to nudge this topic into the 2013 space.
Other aspects which jumped out include;
- Only a third of respondents have completed a gap analysis of QRTs against capabilities
- Less than a fifth have mocked up an SFCR/RSR, despite the prescriptive nature of Level 2 on the reports
- Interestingly, two-thirds have designated their finance functions as primarily responsible for Solvency II reporting - some have parked it with Risk which, while appreciating a three lines of defence model is not compulsory, seems very wrong regardless of the function's skillset.
- Three quarters expect to achieve reporting compliance only after "significant" or "fundamental" changes to their existing processes
- Some firms were identified as planning to speed up their existing processes to meet the proposed reporting deadlines under Solvency II, which seems an excellent idea
Good news for regulators, consumers, and anyone who is punting round Pillar 3 software solutions I guess!