I have touched on the movement of the US towards production of ORSAs in earlier blog posts, including recently on the preparedness of firms to meet ORSA reporting requirements,
From another earlier post, I can see the 15 volunteer company pilot which was mooted at the start of the year ultimately became 13 companies by the conclusion of the pilot (no word on who started, but couldn't be bothered finishing!). According to the Clearwater information, only 8 participants ORSA Reports were considered "complete", this despite the NAIC providing an ORSA Manual from which to work from.
Is this ratio of incompleteness indicative of what the 27 EU national regulators are likely to encounter in 2014, or is the lack of prescriptive guidance at Level 1 and Level 2 handy in this regard (i.e. ORSA Supervisory Reports will be "passed" regardless of quality, and regulatory arbitrage is back on the agenda).
Either way, Clearwater also note that 2015 is looking like the most likely time for imposition of ORSA reporting, so the guys will still have time to borrow from our experiences, as we can from theirs - suggested improvements from the NAIC's sub-group to the participants (none of which would hurt anyone in the ORSA space over here!) include;
- Include a summary of “significant changes” from prior year
- Provide additional detail regarding risk managers and compensation
- Include additional stress testing, specifically for liquidity