Deloitte on "How to conduct the ORSA" - facts and apocrypha

While our pals at the FSA, EIOPA, the CRO Forum, 3 of the Big 4 (here, here and here), the Little 3 (here, here and here), the IRM,  the Irish SoA, and even the guys in the stars and stripes have deemed to recommend to all and sundry what ingredients will make a good ORSA, Deloitte have chipped in this week with a 50-page whopper that tells us everyone else was wrong and they are right...

...well OK, not quite! Deloitte's release about this "important yet enigmatic" area, which seems to have a mainland Europe-flavour to it, works its way through EIOPA's reformulated opinion on L3 ORSA guidance released in July, summarising what changed between the Nov 2011 and July 2012 versions. I of course managed this feat two months ago, but I couldn't quite pad it to 50 pages! They then embellish a section-by-section analysis of the two documents with some charming apocryphal tales of what "many companies" or "the industry" are struggling with currently (i.e. their clients' problems!).

As with most things generated by the behemoths, it is a really useful piece of material despite on the face of it not adding anything new to the knowledge pool, so from an ORSA consultant's perspective, I've made the following notes;

• Emphasises that supervisory intervention will come from lax ORSA processes, as opposed to ORSA Report content (which will drive the US approach)
• Notes that, given the opportunity for the ORSA and the SCR calculations to to be conducted on different reference dates, that this may allow organisations to keep any existing strategic planning processes where they already are in the calendar, rather than unnecessarily shift them to, say, follow financial year-ends. The proviso of "no material change in the risk profile" may of course discourage that, if only due to the need to define "material"!
• Some rather controversial free text around risk appetite ("intuitively simple" as a concept) and risk appetite frameworks ("very much a work in progress" at insurers) - appreciating progress is somewhat inconsistent across industries and the inter-body squabbling on the matter, I can imagine many practitioners would argue the opposite of both points - it's complex, but we're well on the way!
• Highlights difficulties with performing obligatory entity-level ORSAs if risk appetite is expressed in regions/products/funds, which seem perfectly reasonable anchors for risk appetite statements on the face of it.
• "Most organisations" defining AMSB as parent company Boards, plus entities if applicable - no evidence provided though.
• "Many firms" struggling with the "cultural challenge" of getting Boards to drive ORSAs - this I found odd, as many ORSA processes will already be in place to a greater or lesser extent, and most would feature in their individual crystallised reporting form in a BAU board pack. They go on to suggest that getting AMSB input into stress and scenario testing is one way of evidencing ORSA "driving".
• Comment that "In general, the ORSA guidelines were seen as too prescriptive" [my emphasis] - I generally recall the clamour from the industry over the last 3 years being that there isn't enough!
• Common (unevidenced) theme identified that ORSA policies have tended to be signed off by Risk Committees, which may not satisfy the AMSB sign-off requirement
• "Some organisations" electing to split out record of the ORSA Process from the ORSA Report to trim the document size - makes perfect sense, as there's no danger of the co-ordinating function not retaining those records for repeatability purposes.

Plenty of other clutter in there on risk quantification and capital management, but nothing controversial, just nice to read. Bon appetit...