2015 FTSE Interim Reporting and Solvency II costs - forewarned and forearmed?

Solvency II costs - impressed?

I always liked to keep an eye on the FTSE lads’ Interim and Full Year pronouncements on the Solvency II front back in the day, but given the legslative delays and sporadic cost reporting over the last couple of years, plus the internal model hokey-cokey, disclosures on the topic have been “Slim Pickens” to say the least.

For those interested, the sweep I did last year is here, and while a few of the firms featured have attempted to expand out, they have largely disclosed the same information as last year (Boiler-plate disclosures? Never!).

However, a few of the great and good have chirped up some extras about Solvency II on the home straight, none more revealing than the Canary-supporting egg-chasers at Aviva. They dished up the basics as a matter of  course;

• Solvency II costs of £46m for the half year (£39m for last half year)

• Submitted Solvency II internal model in June and expect approval in December. – must be a good one, Hannover Re-style!

• Currently operating within our expected Solvency II target range, regardless of any changes in economic capital surplus quantum and composition driven by Solvency II

The InsuranceERM lads expanded on that, having presumably dialled in to associated conference call! In a suit-and-tie version of Surprise Surprise (R.I.P Cilla), the CEO shocked listeners with the following statements;

• "[Solvency II] has taken an inordinate amount of management time and I'd really like that time back"
• "It has cost us in the region of £400m [$620m]. This figure does not impress me one little bit…” – to my shame I did do the countback on published costs, as if a CEO couldn’t count to £400m, and it does add up!

RSA, in between flirting sessions with the watchmaking fraternity, were similarly revealing, confirming;

• Solvency II costs of £14m for the half year (same as last half-year)

• “…application for Internal Model approval under Solvency II has been submitted and we target a positive outcome by year end”

• "…current Internal Model for Solvency II shows higher coverage ratios than our ECA model.”

Old Mutual does its best to treat the SAM/Solvency II imposters the same in its reporting, but in recent times has been light on our side. There was a bit more in the bag this time round though, particularly;

• "Based on the current underlying timetable and regulation of Solvency II, we estimate the total cost of completion will be up to £20 million, of which £10 million will be incurred in H2 2015, and the balance running into H1 2016".

• "The Solvency II regime will introduce a different lens through which to look at Group capital. It will use a more conservative 1 in 200 stress scenario in determining capital requirements and apply a more rules-based determination of capital fungibility and transferability"

• Given their tone on the “inherent conservatism” of Solvency II and their loving gazes at the existing FGD treatment of capital fungibility, can we read some indifference to their current treatment as a Group by the PRA, perhaps?

• "During July 2015, we completed our initial reporting to regulators under the interim arrangements of Solvency II"

I suppose the biggest surprises continue to be the (potential) absence of compulsion to internally model for entities such as Old Mutual (confirmed as “out” of IMAP on p82 here). Given the PRA’s pronouncements on Standard Formula appropriateness and capital add-ons, you might expect them to be marched down the aisle before too long.

Standard Life,perhaps betraying where their strategic priorities lie (nicely covered here), did little more than state that they will “remain strong” on the capital front – nothing on costs, nothing on implications, and nothing on modelling (though they confirm here that they are “in” apparently!). “In”, but on the naughty step perhaps, or is the topic just unworthy of comment?

L&G were happy to talk technical, rather than cry about hundreds and millions of pounds of spilt milk – their release touched on the following;

• Implementing a ‘capital-lite’ model for bulk annuity new business, by reinsuring out some of the risk (light detail here and here, more detail on p5 of the interims).

• Solvency II internal model is being reviewed by the PRA, and “…It is anticipated that our Solvency II internal model will be approved in Q4 2015, ready for use on the Solvency II go live date - 1 January 2016”

• Also have applications in for the use of transitionals, matching adjustments and using deduction and aggregation for its American business

• “We expect the final outcome of Solvency II to result in a lower Group capital surplus and solvency ratio than the Economic Capital basis. Our Economic Capital model has not been reviewed by the Prudential Regulatory Authority (PRA), nor will it be.”

• "We note recent clarification from the PRA to the effect that transitional capital will count as Tier One capital, including for assessments of dividend-paying capacity". This is particularly piquant given Sam Woods’ coverage of the “dividend” issue a few weeks ago when trying to reassure a room full of analysts that the insurance sector isn’t a busted flush from an investment perspective!

A busy reporting week for sure, with seemingly no horror stories come at the top-end of the UK Insurance Industry...Including a post-script from the Pru today.

They have revealed a miniscule spend of £17m on Solvency II costs in the year-to-date (against £28m for all of last year), as well as a few nuggets in the same vein as the competition;

• "...we submitted our Solvency II internal model applications to the Prudential Regulation Authority in June 2015"
• "We continue to seek opportunities to transfer longevity risk to reinsurers or to the capital markets and have transacted when terms are sufficiently attractive and aligned with our risk management framework."
• "We also noted at the time that certain aspects of our economic capital methodology are different to those required under Solvency II and that the outcome under Solvency II would be lower than our reported economic capital level. This remains the case." - same issue as Old Mutual, one presumes?

They even dropped a Solvency II slide into this morning's presentation pack (slide 28). Interesting that they go to the trouble of highlighting that the transitionals and risk margin "broadly offset" on the UK Life book, as well as their distinct gripes in their Asian and US businesses. 

...and another post-script from Royal London (so I have everything on one page!)

• Royal London will use the Solvency II standard formula approach initially and will consider seeking approval for its internal capital model in due course

• We expect to meet the new Capital requirements without material adverse impact on policyholders but there are significant details which remain to be clarified about the new regime. It is possible the outcome from Solvency II will require insurance companies to hold more regulatory capital than is currently required. If Royal London was required to hold significantly increased capital, then the levels of Royal London Profit Share we are able to allocate to our participating members may need to be restricted

...and two more post scripts: firstly Admiral

• "Admiral is developing an internal economic capital model which will be used to calculate regulatory capital requirements following approvals from the Group's regulators in the UK and Gibraltar. Such approval is not likely to be sought or granted before 2017."
• "The Group's regulatory capital from January 2016 will, therefore, be based on the Solvency II Standard Formula, with a capital add-on agreed by the PRA to reflect recognised limitations in the Standard Formula with regards to Admiral Group's business (predominantly in respect of profit commission arrangements in co- and reinsurance agreements and risks arising from actual and potential Periodic Payment Order (PPO) claims)."
• "The level of capital add-on and resulting Group capital requirement from January 2016 is expected to be confirmed by the PRA in the final quarter of 2015."

...and secondly Phoenix

• "...submitted its application for regulatory approval of its Internal Model in June 2015"
• "...Group capital position under Solvency II expected to be in excess [of current surplus]
• "Over 2015, clarity on Solvency II regulations has improved but uncertainties remain in relation to the Group's IMAP and other Solvency II-related applications"