Showing posts with label GCAE. Show all posts
Showing posts with label GCAE. Show all posts

Monday, 24 June 2013

EIOPA's Long Term Guarantees Assessment and the early fallout - Plenary delay pending?

EIOPA's Long Term Guarantees Assessment rocked up last week while I was enjoying my new arrival, perhaps the most eagerly anticipated document out of Frankfurt since the days of Goethe...

Wielded fiercely all year by all stakeholders in need of an excuse for the delays in Solvency II's legislative passage (and hence the need for more budget), it appears to have variously pleased everyone and no-one at the same time. The key findings/recommendations are nicely summarised here.

Major players have since piped up with the following over the last week, none of which suggests the report's conclusions will be ole'd through the trilogue and parliamentary vote. 

EU Institutions

- "We are confident that the results of the LTGA, combined with the EIOPA advice will provide the EU political institutions with a reliable basis for an informed decision on the long-term guarantee measures and a conclusion on the Omnibus II negotiations"
- "The Commission trusts that the Council and Parliament will use this very good report and its findings as a basis for an urgent agreement on Omnibus II and show pragmatism and willingness to compromise"
- "Speaking for the European Parliament, we are very confident that Eiopa's work and the subsequent analysis will provide for a successful restart of the negotiations, and as rapporteur, I am ready to start as quickly as possible, even before the summer break, to pre-launch trilogue negotiations. It is our firm intention to conclude the long-term package before the end of this year, so we can adopt Omnibus II in early spring 2014"

Industry representative and lobbying bodies 

- Insurance Europe - "Insurance Europe’s preliminary review of EIOPA’s proposed improvements to the Solvency II regulatory regime shows that adaptations are needed to avoid unnecessarily damaging insurers’ ability to provide long-term guarantees and invest long-term"
- GCAE - "With the publication of the report, the EU is one step closer in the process to finalising the Solvency II dossier"
- UK's ABI - "The EIOPA report is a small step in the right direction. But there is still a long way to go before British pensioners can be confident of a reasonable deal on their annuities"
- Institute and Faculty of Actuaries - "Today’s proposals outlined by EIPOA (sic) would seem to address many of the important issues. However, the detail needs to be worked through and the effect in a variety of scenarios assessed, before the full implications of the proposals for companies and their customers can be understood"

Ratings agencies
- Fitch - EIOPA’s proposals “offer no prospect of an end to the long-running dispute between regulators and insurers over suitable capital levels for products with long-term investment guarantees"
Print Media
- Commercial Risk Europe - "...unlikely to resolve key issues stalling the implementation of Solvency II and may lead to yet further delays to the Directive"

Consultancies
- PWC - "many insurers may find the proposals onerous and will not welcome the continued uncertainty over the final rules. We anticipate there may be concerns about the capital required for certain types of assets backing annuities in particular; and the effectiveness of measures designed to address short-term asset volatility"
- KPMG - "...it is likely that certain European countries will look very unfavourably at the EIOPA proposals."

I have emboldened the quote from Burkhard Balz above which suggests that the Omnibus II vote is going to move again. The rationale for that is two-fold; the prospective Plenary date (which was down as October 2013) appears to have suspiciously disappeared from the EU Parliament's Omnibus II procedure file altogether, while Mr. Balz clearly states early 2014 is targeted 'adoption date' while 'speaking on behalf of the Parliament'!

Thursday, 29 September 2011

GCAE Minutes - "effective co-operation between European institutions"

I had almost forgotten to post the link to the Groupe Consultatif's minutes for September - concise and clear as ever. Some interesting plans on a potential position paper on ORSA, and some IFRS/Solvency II convergence work.

Nice of them to plant a seed of uncertainty with the headline "Planned implementation of Solvency II on 1 January 2014 depends on effective co‐operation between European institutions and on action by member states". This has the air of fighting talk from EIOPA, who they met with in the month.

Thursday, 11 August 2011

Groupe Consultatif and dates for revised pre-consultation docs for Pillar 2

Nice and simple this one - Groupe Consultatif Actuarial Europeen minutes for the last month's lobbying activity. Note the quote that "It is expected that pre‐consultation on ORSA and governance will be re‐published in the autumn." Might want to put that into your diaries...

Wednesday, 27 July 2011

Committee on Economic and Monetary Affairs - proposed text changes to Omnibus II

The GCAE published this on their site today - while I am not an expert on the legislative process, this looks like the proposed text for Omnibus II, hard-coding in deadlines for EIOPA to present draft Implementing Technical Standards and/or Regulatory Technical Standards for the articles which are subject to transitional measures. Justifications for the proposed change are generally provided.

Not sure if these deadlines are new news though (drafts to be provided to the Commission by EIOPA in most parts between March and July 2012).

Thursday, 21 July 2011

GCAE Minutes - "disappointing" delay

The Groupe Consultatif Solvency II working group pushed out their minutes for June (post-Omnibus II announcement). Interesting to see that they are disappointed with the "very probable" delay, as well as a conspicuously larger-text paragraph on how a lobbying point on calculating Life Technical Provisions has yet to be resolved to their satisfaction (and indeed looks like they will lose out on it).

Not sure who the victor is (EIOPA at a guess), as it is not completely clear who they are lobbying against on the "principle of market consistency"

Tuesday, 28 June 2011

Groupe Consultatif - Actuarial Function research (Solvency II slant)

I really liked this doc, released last week by Groupe Consultatif Actuariel Europeen (GCAE), which ostensibly is used to confirm that there is sufficient actuarial resource in the union to address the future requirements under Article 48 of Solvency II. Covers 20 countries and 18,000+ actuaries - of particular note;
  • Most work on setting, validating and certifying technical provisions (all sub categories were 80-90+%)
  • 46% of Life actuaries have a role in risk management
  • 48% of Life actuaries have a role in Internal Modelling
  • 54% of Life actuaries are involved in Internal Model validation (high, bearing in mind this at least nominally moves to Risk under Solvency II)  
  • 8 countries will only have qualified actuaries running the function (Life only) - 12 will be run by "mostly qualified actuaries"
  • The Groupe "will ensure that education is enhanced to capture the changed environment, especially in relation to risk management"
  • Highlight "concerns that the use of actuaries may be diminished in some way by the apparent change in role from the current position".
I struggled to work out the missing parts. From what I could see;
  • Only 20 actuarial associations covered by the research, against 27 EU members - the following countries are not covered; Bulgaria, Cyprus, Latvia, Malta, Romania, Slovakia, Slovenia. Would love to know if that is because they don't have associations worth talking about, or the function itself it not afforded the same gravitas as in other jurisdictions
  • Two countries have no qualification requirements!

Wednesday, 8 June 2011

Groupe Consultatif Solvency II workgroup - meeting with Karel van Hulle

I suspect the GCAE's Solvency II workgroup is more prolific than their minutes suggest, however I noticed a couple of areas of note in their progress report for June;
  • They met with Karel van Hulle, who noted his intention to "publish hopefully" (!) final Level 2 text in October, and that binding technical standards work is underway with EIOPA
  • They discussed transitionals only insofar as "agreement on the need for these"
  • They separately note that they are working with EIOPA on future premiums, but are "reserving their position on any conclusions"...