PRA's Pillar 3 Industry Working Group - the horsetrading begins...

The PRA have at last released the materials from their pre-Christmas Pillar 3 industry working group, which should provide a little cheer to anyone working in that space, and indeed the vendors who are manfully trying to supply software solutions to address it.

The materials include;

• A "record of the discussions" (definitely not 'minutes'!) 
• A Pillar 3-specific Q&A
• Some feedback on the industry data collection exercise held in May 2013 (details here)

As I mentioned in a previous post, these materials were due for publication 12 working days after the meeting, and the lag had me a little bit concerned that the debate had taken a terrible turn! It wouldn't appear so on review, but I thought the following issues were worth flagging;

From Q&A

• National-specific template consultations will start "at earliest" in July 2014
• Suggest that dialogue between firms and the PRA will aid the appropriate application of proportionality up to 2016
• Suggest that firms "regularly check" EIOPA's website for relevant material, as well as stating that they will update the Q&A doc. Both of these things lead to a "pull" of information by individual firms rather than a co-ordinated "push" by supervisors and rulemakers, which I find displeasing.
• EIOPA will be expected to provide definitions of any ambiguous terms
• PRA will not publish a reporting timetable in the preparatory period
• Smaller firms will not be allowed to submit material in a format other than XBRL

From "record of the discussion"

• Myriad issues tabled regarding interactions with external parties (ratings agencies, data vendors, asset managers)
• Range of assumptions, simplifications and materiality calls already being made in the absence of definitive guidance or supervisory college "party line"
• Publicly disclosed QRTs listed as an area where "more information is needed" - the PRA expect the Implementing Technical Standards to cover these in more detail. 
• XBRL - Final templates for preparatory phase are due in May 2014. The final ones for Solvency II itself are due in December 2014.
• The industry flagged their issues regarding XBRL solution vendors and the poorly taxonomised templates as they stand. The PRA therefore asked for specific examples of what might be compromising lead times and budgets.
• There are some open ended questions at the back of this document which are for the PRA to answer at a later date.

From Data Collection exercise

• PRA confirm that in most cases, the information submitted is being used "to inform ongoing supervisory work" as a minimum.
• Some general insurers submissions were incomplete, while some life insurer submissions either did not segregate their with-profit and non-profit funds. This is seemingly less than helpful while the PRA struggle to calibrate their Early Warning Indicators (more on that here and here).
• A clear supervisory focus on the standardised risk information submitted around the tails of the distributions and diversification benefits - you've been warned about taking liberties already UK and Ireland!