Monday, 30 September 2013

EIOPA's FINAL preparatory guidance for national supervisors - it's on at last!

Sporting less change than a busker's flatcap, EIOPA have published their final version of the preparatory guidance for the EU's National Competent Authorities (NCAs) to get themselves ready for Solvency II ahead of the anticipated implementation date of 2016. You can catch my post on EIOPA's consultation papers here if you want to dig out their position prior to the consultation, which saw over 4,000 comments offered.

EIOPA - Thanks for the feedback,
here's your change...
Over the last week, while I have been recuperating from yet another rugby injury, there is plenty of chatter recently about the kick-off date, Omnibus II's progression through trilogues (and hopefully parliament before the May 2014 elections), etc elsewhere, so I've just had a run through the final guidance to see what got lobbied out, and whether that is a win for all stakeholders, or just the industry. As the PRA have already made it clear that should the go-live date move, their expectations on supervisory reporting will also move (p3), whether it is 2016, 2017, etc. is kind of a moot point.

The mainstream press has trumpeted the big wins as being in the reporting space which, judging by the IRSG's scathing take on that topic, should be no surprise to anyone. However, it would appear that EIOPA have refused to bend for much else, adopting a relatively sniffy tone in response to stakeholders concerns/complaints.

Below are links to separate blog posts covering the more contentious highlights for each of EIOPA's 4 hot topics, while Mike Claffey and the Milliman crew have quickly summarised the changes here;

System of Governance - Final Guidance (EIOPA Doc)

ORSA/Forward Looking Risk Assessment - Final Guidance (EIOPA Doc)

Reporting/Submission of information to NCAs - Final Guidance (EIOPA Doc)

Pre-application for Internal Models - Final Guidance (EIOPA Doc)

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