EIOPA's Long Term Guarantees assessment - long time coming

So EIOPA have finally released the specifications for the Long Term Guarantees assessment (press release here), the second most eagerly awaited release this year behind Kate and Will's baby. Relatively straightforward timetable of events expected by EIOPA it would appear;

• End of March - completed templates submitted to national regulator
• April and May - national regulator and EIOPA will analyse and synthesise results
• Second half of June - technical results to be provided by EIOPA to the trilogue parties
• Mid-July - report provided by the Commission to the co-legislators

I am stressing the second half due to the current procedure file for the Omnibus II Parliamentary Plenary session pointing at a 10th June date, which is of course too early to consider that report in making a decision on Omnibus II. That leaves one more Plenary window in July before the summer recess, so we can probably bank on a postponement to September at the very least, particularly as the report is bound to contain more contentious bones than a frozen beefburger...

A few things of note in the suite of materials published by EIOPA today, of which the presentation slides are perhaps most useful;

• Objectives of the assessment include "possible competition distortions" and "impact on long-term investment", which have surely topped the list of differences between trilogue parties and indeed individual countries to date.
• Predominantly based on YE 2011 balance sheet, but will test pre and post financial crisis positions as well (2004 and 2009)
• Can optionally use internal models for capital and risk margin calculation, provided the entity is in a national IMAP.
• At least 50% of Life non-linked TPs and 20% of Non-Life TPs in each country must be covered (hence the industry has been quite vocal about doing this at financial year-end!)
• 13 scenarios included in the assessment, of which one does not include any of the proposed measures - not sure if that reduced quantum addresses the concerns of the FSA's Insurance Standing Group back in September, when the number sat at 18.

The main meat in today's releases are of course for the digestion of your friendly local actuaries and accountants - best of luck!

EIOPA, Parliament, IRSG and LTGs - momentum sustained?

I guess I should start with a Blein Vie Noa to one and all - after a relaxing few weeks in France I am now back on the beautiful Isle of Man sizing up opportunities for 2013 and beyond.

I didn't expect I would be missing much over the festive period and, other than the FSA sacking-off their proposed January IMAP industry briefing in favour of a (yet to be delivered) letter, things did go quiet. Freshfields kindly filled some airtime by pulling together another of their "where are we now" summaries that remain excellent (and free) materials that I would recommend punting on to your non-executive directors.

Luckily the noisemakers got back in the game as soon as school restarted, focused largely on the content of EIOPA's Insurance and Reinsurance Stakeholder Group's minutes. This meeting was held in October, so in terms of new news, it is right up there with "Earth is not flat". That said, we don't all have access to the inside track before publication of such materials, so it was interesting to pick through the doc for steers. I noted the following;

• Continuing problems with terms of reference for the LTG assessment (indeed the LTG sub-group note on p7 that there isn't even a EU-consistent definition for LTG!) - still looking like it will impact on the designated Plenary session for Omnibus II due to a combination of last minute delivery of the technical specifications to the industry itself as well as the output report to the Parliament, who themselves were reported today as being less than impressed with the final TORs. The potential number of scenarios in the assessment also clearly remains a sore point.
• Acknowledgement that "Autumn 2013" is now "best case scenario" for Omnibus II adoption, though, according to van Hulle at the last EIOPC meeting, the Commission and Parliament remain almost diametrically opposed on what should materialise at Level 1 and Level 2 (full minutes from EIOPC here)
• Confirms the ex-ante approach is favoured by Parliament and Commission (significance covered by Gideon here), and that Parliament have no wish to commit to an implementation timescale.
• The Council members are being "heavily lobbied", fostering implementation uncertainty.
• Attending stakeholders supported a definitive 2016 date.
• The IRSG's Governance sub-group flag up consistency issues around Fit and Proper regs as well as the "AMSB" term that I'm sure we have all had practical issues with over the last 2 years!
• Proportionality remains a "main concern" for mutuals, as well as smaller insurers - despite having a designated sub-group, any substantive guidance on applying the proportionality principle looks a distant prospect at best.
• Astonishingly, minutes from May 2012 could not be approved due to EIOPA's "workload" - small instance of an institutional tardiness problem?

Whether or not the industry is losing it's appetite for the Solvency II banquet, when you check out EIOPA's workplans for the next couple of years, at least one body will be filling its face!

Another interesting piece came out in the last week, when InsuranceERM pushed out the findings of a Solvency II roundtable (no sub required), bringing in a few UK-based CROs and the like, ostensibly to chew over the loss of momentum in the project. A few noteworthy bits jumped out;

• Solvency II balance sheet appears to be off the agenda for ICA+, for both regulator and industry
• Perception that, with the transition of regulatory "ownership" to the Bank of England, there is a decreased likelihood that the industry will be able to use Solvency II as a capital release mechanism
• A suggestion that the FSA was more minded towards EIOPA's opinions than the industry's during IMAP 1.0, something which has seemingly reversed with the advent of ICA+

One certainly hopes that the UK industry and regulator can make a decent fist of this indeterminate transition period without having to break the bank...