Monday, 22 October 2012

FSA's Adams on Solvency II delay, IMAP and ICA - how long do you want lads?

It would appear that stabs in the dark on the Solvency II implementation date by senior insurance industry officials are like British buses - after the omerta-like silence of September, no fewer than three bigwigs have piped up in the last few days. First Sr. Bernadino decided to do his briefing via a Stateside publication, settling on 2016 as most probable, followed by Sr Montalvo who concurred (along with a great joke about his missus!).

While it didn't take a handsome Archaeology graduate to know that 2014 was ash, what the industry likes more than anything is cold, hard confirmation from their friendly national supervisor...

...which came today! Julian Adams gave a speech this morning ostensibly about the practical side of implementing the PRA's new approach after they get divorced from their FCA counterparts next year. Worth bulleting the big messages on IMAP;
  • Current timetable "completely unrealistic" after Plenary postponement confirmed last week
  • 2015 "...likely to prove very challenging"
  • FSA will agree a revised landing slot with IMAP participants (presumably just those who have yet to submit?), UP TO A MAXIMUM OF END DECEMBER 2015.
  • Will change this to match up with what comes out of Brussels if the two are divergent
  • For ICAS, "we will have to live with the current regime for longer than any of us expected"
  • The previously stated "aspiration" of potentially replacing ICA with internal model SCR will be formalised into a two step process. First, reconcile ICA with IM SCR (the easy bit!), then once the FSA are sufficiently happy, just produce IM SCR.
  • Retain discretion to apply ICG throughout the interim period
  • Benefits of this approach will therefore include much meatier pre-application evidence of use.
Hard to know where to go with this. Great news for anyone who remains on target for their original landing slots, as there is potentially some early-adopter capital benefits if they can abandon ICA. That said, the recent E&Y industry survey (which I will look at separately) suggested the Brits are mostly in a good spot for IMAP, so does extending the window negatively impact on the work already delivered? Certainly opens up a rather pricey Pandora's box around Validation activity which I'm sure many firms would have been delighted to have paid for one-time-only!

All in all, these public declarations will be welcomed by everyone who isn't writing a cheque for next year's IMAP activity...

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