EIOPA's Bernadino with keynote speech - D'ohs and Don'ts...

Solvency II implementation
- Homer called it...

The latest pit stop on the Solvency II Last Legs tour was in the picturesque, almost-an-anagram, Slovenia, where EIOPA's gaffer joined a throng of hearty souls to deliver a keynote speech last week.

Given that the outside world is seemingly becoming more sensititve to the ensuing changes (at least from a capital adequacy perspective), it has been noticeable that EIOPA's speeches have become heavier in practical tone rather than the flabbier ethereal tones of yesteryear. In particular, conduct risks, conflicts of interest and the importance of an effective second pillar to counter the aggression and self interest of distribution arms/firms have all become prominent features of what is being touted as the Solvency II benefits package. Given what it has cost, we'd better deliver it!

Back to the speech, a few basic soundbites are littered throughout, which might benefit your training packs for the home stretch;

• Solvency II is "EIOPA's top priority", 
• It is a "pretty good starting point", rather than perfect, is "...a must and a true game changer", and "brings a new risk culture"
• It is "a tool to foster a true risk culture in the organisation"
• "It is clear that Solvency II will bring more awareness and transparency on the true risk profile of certain business models"
• It will deliver "intelligent and effective regulation which does not stifle innovation"

A couple of open-ended questions emerge from the text itself;

• Does Solvency II only "encourage" firms to define their risk profiles and risk appetites, as opposed to compel it?
• Is the Solvency II take on ORSA really "best practice at international level" - seems fair, but does anyone else want a shot at the title!
• Why is "overall solvency needs" constantly accompanied by bunny ears - if these guys aren't convinced by the term, what hope does the industry have of driving it into the glossary!
• Is it just executives who need to know that ORSA is a "cultural change", as opposed to NEDs, non C-suite senior management and wider stakeholders. Institutional investors would surely benefit a 101 class, given their demonstrable views on what SCR coverage ratios mean for the plausibility of some firm's strategies, and while Sr. Bernadino comments that "...effort needs to be made" to explain SCR volatility on p8, a dawn chorus with Karel van Hulle on how "ridiculous" the outside world's expectations are doesn't even qualify as an hors d'ouevre.
• That risk culture provides "...an appropriate balance with the natural sales driven culture" - EIOPA have alluded to this before, but never quite as explicitly as this. If the Risk function's job is predominantly to counter sales activity, can it ever be seen as value adding?

And a couple of specific themes are given special treatment for everyone's benefit;

Prudent Person Principle and the investment strategy of insurers

• PPP emphasised as not giving insurers a freebie to hit the roulette tables with their asset book, and will be "...closely monitored".
• Current environment encourages aggressive monitoring, with the "search for yield" quote now ubiquitous in supervisory speeches which touch on macro matters.
• "Asset risk calibration in Solvency II should not be used to privilege or incentive any specific asset class" - not convinced on this front, given the remit of your friendly local CIO must contain an element of maximising gains within appetite, and the calibration can surely influence that.

Product availability

• "Solvency II does not intend to unduly penalise specific products" - evidently does though, hence the sprint to the door from Ergo et al in the guaranteed interest rate product space (not unduly though to be fair, given the Teutonic pleas for transitional mercy!)

ORSA and Risk Culture

• The section somewhat labours the point on coverage of all risks, assessment of all mitigation techniques, and the role of the Board in driving the associated cultural changes, but I guess given the geographical location of the speech, some of the nearby countries may benefit from the encore un foi approach - no names naturally...
• "Capital will never cover up for the lack of proper governance"
• "ORSA is based on the companies' DNA - their strategy"
• "The key role in the implementation of ORSA belongs to the top management"
• "It is up to the Boards to set, communicate and enforce a strong risk culture..."

Insurers and Supervisors in general

• Talks of Risk Functions needing the correct skills to assess risks in asset classes - is there an implication here that functions will be light on quantitative skills post-2016?
• Squares the circle of prudential and conduct risks on p7, talking of mitigating conduct risks "since inception" in one's product development, design and marketing processes.
• That Solvency II "...requires an increased degree of supervisory judgement" in order to intervene at the right time, and the new supervisory requirements represent "...an upgrade in the quality of supervision". I'm sure some countries might take that as something of a slight, given the maturity of their existing processes, but probably fair for the majority.

Plenty of fuel for your respective Board and Senior Management briefing fires, so go forth and propogate!

Standard and Poors on European ERM - momentum lost after Solvency II delays?

S&P released these pearls of wisdom regarding ERM within European insurers, specifically whether the additional breathing space offered to Solvency II may put the brakes on developments.

There's certainly no sitting on the fence with them - they start with the following as a statement of fact;

...the delayed start date of Solvency II has prompted some insurers in the region to reduce their efforts in developing ERM

Unsupported, but probably fair! They are also overwhelmingly positive on Solvency II on the whole, for example;

Solvency II remains a major driver of ERM improvements in Europe

the Directive has firmed up insurers' approaches to risk appetite, risk governance, and risk reporting

The introduction of the Own Risk and Solvency Assessment (ORSA) process...has helped to embed risk appetite in insurers' operations

Solvency II has brought risk management to the fore in insurers' strategic planning 

Easy to take any of those comments to task in the UK and Ireland, where national corporate governance code revisions, listing requirements, IAIS considerations and developments in both the actuarial and  nascent Risk professions are all taken very seriously by the respective industries, all the while cognisant of the shadow cast by Solvency II. In addition, the disciplines espoused by S&P's ERM assessments are practiced to a decent extent in existing ICA/FCR processes/reports, regardless of how 'ORSA-fied' they have become over the last couple of years.

This potential slight to the Western world is remedied on p7 however, where the research acknowledges that Western Europe effectively leads the way on ERM, and in the appendix (p8-12) where the league tables sit Germany and the UK firmly at the top of the ratings class.

They ultimately get to the real crux of their fears with this;

We would view negatively any evidence of a reduced role for economic capital in insurers' capital management arising from the delay

They are also gunning for insurers who continue to sell uneconomical products in the face of sustained low interest rates (p4), and validation standards in internal modelling (p5).

One would hope that, certainly in the UK with ICA, ICA+, and a supervisor who is continuing to staff pre-application for internal models adequately, that momentum around using economic capital in decision making will not be lost during 2014, particularly now that the PRA have as good as said that they accept EIOPA's preparatory guidance.

So give this a read if you want to know where your firm lies in the S&P ERM rating table, and if their opinion matters to your bottom line, be sure to quote this material when your Programme sponsors try to take the pace of 2014 Solvency II activity!

 

 

FTSE and European Insurers - Economic Capital and Solvency II trends - money pit filled?

Interim Results season - without question, the most exciting time of the summer for me (although to qualify that, I do live on the Isle of Man and blog in my spare time). As good an opportunity as any to peer review where the big boys are at in the UK and Europe, both on Solvency II preparations/costs and economic captial positions.

Solvency II project costs - on the wane?

As I had mentioned in an earlier post, the FTSE-listed insurers have gone noticeably quiet on both Solvency II and, in the UK's case, the havoc it was inevitably going to wreak in its 2012 form - while the 2013 silence "speaks volumes" as to the priority of the dossier, it is a smart idea to see what impact the threat of a 2014 start has had to EC positions of major insurers over the last 12 months (i.e. after last year's whingeing, did any of them actually do substantive capital-related activity!)

A few notes for each below;

Aviva

• Solvency II project costs of £44m - well down on £77m in 2012 year-to-June
• "...there is still significant uncertainty over the detailed requirements [of Solvency II]"
• Pro-forma economic capital surplus of 175%, up from 172% in December
• IGD coverage 1.8 times, up from 1.7 times in December

Axa

• Nothing on Solvency II at all or project costs
• Solvency ratio down to 218% (from 233%) since December - interest rated attributed
• Economic solvency ratio (calibrated to 1-in-200 VaR) down to 204% (from 206%) since December - dividend and market risk elements attributed

Allianz

• Nothing on project costs
• Solvency ratio (based on FCD) of 177%, down from 197% this time last year - change in accounting standards attributed
• "...Allianz continues to be exposed to two external forces that adversely affect our risk profile and would not normally be associated with our core operating activities: the European sovereign debt crisis and regulatory developments – especially the European solvency directive, Solvency II"
• No reference to economic capital or modelling

Legal and General

• "Investment projects and expenses" (which covered Solvency II last year) were £20m - £23m in 2012 year-to-June
• "...remains uncertainty both to the implementation timescales of Solvency II and the final calibrations that will be used for long term business"
• IGD surplus unchanged at £4.1bn, coverage ratio down to 226%

Old Mutual

• No mention of Solvency II project costs, same as last year
• EC coverage of "over 160%", calibrated to VaR 99.93%
• FGD surplus of 160%
• Dividend outweighed operational cash flows in the 6 month period, though this was due to the special dividend paid last year after a massive disposal

Resolution

• Solvency II project costs of £10m for the half year - well down on the £48m for 2012 comparable!
• "Proposals for Solvency II continue to be the subject of debate"
• EC Coverage of 192% - (194% in Dec - quantum increased by £200m though)
• IGCA coverage of 221% (222% in Dec) - sold a business unit, which helped cover dividend

Prudential

• £13m Solvency II project costs for the half year - £27m in 2012 year-to-June
• "...deferral until 1 January 2016 or beyond appears likely"
• "...we now know that it will not be implemented before 1 January 2016" - my emphasis
• "[potential for] optimising the Group’s domicile as a possible response to an adverse outcome on Solvency II" remains on the table, a copy/paste threat left in from last year.
• IGD coverage of 230% - quantum lower by over a billion since Dec, due to a change in requirements in their US business

Standard Life

• £36m Solvency II "and other programmes" costs for the half year - £42m in 2012 year-to-June
• Solvency II project "...continues to respond to changes in requirements"
• IGD down £500m since half year after accounting for a special dividend, and surplus generation down year-on-year (attributed to new business strain)
• IGD surplus of 185%, down from over 200% at YE2012, but up 11% from this time last year
• Not a single reference to "economic capital" in the document

Generali

• No mention of Solvency II
• Solvency I coverage at 139% - up from 130% this time last year
• Economic capital coverage of 167% - up from 159% this time last year

RSA

• Solvency II project costs down to £10m (was £16m  in 2012 year-to-June)
• "There remains continued uncertainty as delays in agreeing the rules have caused the planned implementation date of 2014 to be delayed."
• IGD covered 1.7 times - down from 1.9 times since December - dividends again cited in explaining the dip.
• Economic capital (calibrated to 1-in-200 VaR) £1.3bn, up from £1.2bn in December.

So a trend of steady Solvency I ratios, and no sign of any war chests being created by holding excess cash back - quite the opposite in some cases, with dividends (special or otherwise) on the high side. With project costs diminishing and barely a passing comment on the Omnibus II impasse, it looks very much like Solvency II is yesterday's news in the boardrooms of major insurers. 

That said, in just those insurers covered above there has been over £100m confirmed spend in the last 6 months on Solvency II preparations, during which time the implementation date has (informally) moved at least two years, IMAP has been elongated, and the LTGA panacea has turned out to be anything but. That's hardly chickenfeed, and the rest of this year can only get busier for the UK with ICAS+ and EIOPA Interim Guidelines to contend with.

I hope Finance Directors don't get too excited by the dwindling project spend though - we haven't started Pillar 3 yet, apparently!

Deloitte's 8th Global Risk Management Survey - cause for concern?

A survey from Deloitte has recently hit the news stands, namely the 8th edition of their Global Risk Management Survey - I thought I'd postpone my August holidays to pick through the bones of it (?).

The data was gleaned from an online survey they sent out to CRO/equivalents back in Sept-Dec 2012, so is a bit dusty, and there were 86 respondents, so a half-decent sample. It isn't dominated by a particular sector or continent (p7), but there are more conglomerate/bank-heavy respondents than pure insurers.

There is an infographic for those of a short attention span with a few headline numbers, but having sifted through the larger doc, I found the following elements worthy of note;

Boards, Committees and Risk Management

• 80% of Boards are reviewing and approving Risk Management Policies/ERM Frameworks and Risk Appetite Statements. Bearing in mind the types of organisation in the sample, that is disappointingly low.
• 25% don't review individual risk policies
• 23% don't review strategy against risk profile
• Almost half don't invite CRO to EXCOM meetings
• Almost two-thirds delegate risk oversight to satellite committees (and two-thirds of those delegate to a Risk Committee)
• Only half have their Risk Committee chaired by an INED.
• Use of specific management risk committees for individual risk types tends to cluster around the 40-60% bracket (for example, 60% have an ERM committee, while 44% have an Op Risk Committee). Heavily weighted by organisation size i.e. larger ones tend to have them! 
• Emerging risk reporting not supplied to 30% of Boards
• Model validation results not supplied to 70% of Boards!
• 66% (of insurance respondents) have their Boards responsible for reviewing economic capital results

CRO and Risk Management Function

• 97% of large respondents have a CRO, 81% of smaller firms 
• 88% using "3 Lines of Defence" (almost all of the larger respondents do)
• 62% have an "ERM Programme"
• 58% increasing risk management budgets (still!)
• In the list of tasks currently performed by CROs, the fact that only 63% are involved in the approval of new business lines/products is pretty telling, and not in a good way.

Other control functions

• Almost half of respondents said that Internal Audit and the ERM Framework do not use common risk categories and language.
• 33% do not have a independent model validation 'function' (remember, the banks are in these stats as well!) - most of those who have made provision park it in the Risk Management function.

Risk management techniques

• 90% using some form of stress testing in the business, with most saying the outputs are used in business planning, strategy setting and identifying risk tolerance. More than half however don't use the outputs in the allocation of capital to lines of business.
• 74% have some type of Stress Testing policy
• Over 20% either do not have a Risk Appetite Statement, or only have a quantitative one
• Almost 70% still use regulatory capital as one of their quantitative measures in their Risk Appetite Statements
• Risk limits tending to be set at enterprise level, as opposed to business or desk/subsidiary level - stats are a little murky due to the emphasis towards banking sector.
• Model risk and Liquidity risk seem to be the risk types least factored in to companies ERM programmes

Management of Key Risks

• Full list on p24, with the percentage shown representing the number of respondents who thought their management of each risk was "extremely" or "very" effective - stand outs were that perceptions of the effectiveness of the management of Operational, Model, Outsourcing and Data risks appear to be much lower than one would hope, with Lapse risk management ranked unusually high.
• Op Risk KRIs and Loss data only collected in 60% of respondents
• Just over half are modelling Op Risk in some way - varying degrees of complexity experienced
• Most are using stress testing and/or reserving to assess Insurance risk - over 40% not currently using EC, and over 50% not using VaR.

Risk and Reward

• Almost 60% of remuneration schemes have no clawback provisions
• Almost 70% of schemes do not align incentive payouts with the term exposure of the underlying risks

Solvency II-specific

• 92% (of relevant responders) will focus resource on ORSA in next 12 months
• 77% will focus resource on Data Quality in next 12 months
• 69% will focus resource on Documentation and Reporting in next 12 months
• Less than 25% rate their processes and systems for Data Governance extremely/very effective.
• Declining trend of insurers who will be modelling economic capital (p19)
• Only 80% actually calculate Economic Capital
• Some very grim stats on p21 covering which risk types are modelled for EC purposes (underwriting risks seemingly very low on the list)

There are a number of areas touched on here which fall short of pending (or indeed actual) national/international regulations and codes, never mind "best practice". Perhaps we can account for the innate conservatism of CROs in their responses, and assume things aren't quite as bad as they have self-assessed here?

Towers Watson on US ORSA, Economic Capital and modelling trends

Towers have released a few decent bits of material of use to risk practitioners over the last couple of weeks which are worthy of comment. One on Economic Capital for Life Insurers is effectively a sales aid for their RiskAgility modelling software, but actually captures the drivers behind the UK's efforts to improve their ICA models to meet Solvency II requirements.

In particular the references to how firms ought to be making their model output 'useful' where they currently fall short (capital by business/risk/product, daily runs without running ALM models and ability to produce "what if" analysis) should be featuring highly on the agendas of both embedded use practitioners and AMSBs during 2013. Of course the sad part for any users of the software comes with the statement that RiskAgility is built "...specifically to deliver monte carlo simulation of 1 year VaR economic capital" - love to hear how the lack of multi-year is being dealt with in firm's ORSAs!

A second publication on ORSA preparedness in North America is also worth a read, even if only for us EU-based practitioners to have an opportunity to live vicariously through a country which will actually get it implemented! It is a relatively small quantum of respondents (mostly CFOs), and around half think they will be exempt on size grounds, but the perceptions which emerge are still valid, and one should be prepared to encounter this either side of the Atlantic;

• 21% see it as a compliance exercise, while 60% think it will improve ERM and capital/strategic planning
• Only 22% see their prevailing ERM frameworks tightly liked to strategic and capital planning
• Only 40% are ready to implement an ORSA in the next 6-12 months
• Concerns remain around resource requirements for educating "key personnel" and directors/C-suite - 45% and 66% respectively felt they have work to do in this area without necessarily having enough staff to do so.
• 13% of respondents didn't see their risk management departments contributing to the ORSA process (I'll get my coat then...)
• 3 year projection of capital requirements is the most common planning period envisaged

The same North American slant is then given to a financial modelling survey, which gives us another chance to peek over the fence. They found the following;

• Reasonable amount of dissatisfaction around run-times
• Around half planning to change their model governance processes in the near future

Looks like the NAIC/EIOPA covergence work should be a walk in the park then, at least on these topic...

Society of Actuaries in Ireland on ORSA - a rock in a sea of turmoil

In these days of certainty around the Solvency II implementation timetable (i.e. certainly not 2014!), it’s nice to cling on to the consultant's comfort blanket of ORSA which, thanks to the IAIS and NAIC, isn’t disappearing in a hurry for global insurers. This item flagged on the SAI's newsletter last month, but dating back to April, would benefit anyone working in the ORSA space, being a "practical considerations" guide which is very accessible for non-actuaries, particularly for assessing or challenging options for the required ORSA processes.

 

The document takes care to reference the at-the-time EIOPA guidelines in each chapter (which would have been superseded by June's release of course, but didn't change seismically), and does an excellent job of focusing on required processes as opposed to ORSA Reporting, which these types of papers often do. Worth reading all but noting the following;

Overview

·     Proportionality - remember justification of approach is as important as executing the selected approach itself.

·     Documentation - "...Traditionally, this is not an area of strength for actuaries" - I'll drink to that!

ORSA Contributors

·     "It is likely" that Risk will co-ordinate the process. This logic follows on from the IRM’s survey findings (p2) which saw Risk as predominantly leading early process development, and there is nothing to suggest the other candidate functions are likely to be sufficiently staffed in the BAU world to both actively participate and co-ordinate.

·     Board as "owners” of the ORSA – this is an important point which, for practitioners, is awkwardly inferred by the Directive text, rather than spelled out. Indeed this document later goes on to say the Risk function "will likely be the owner of the overall ORSA process".

This gruesome melange of who owns what in the ORSA space (and indeed what 'ownership' confers), remains a little too common in thought papers like this, so be certain to define these elements in your ORSA Policy.

·     Capital Management function - "ORSA is the process where risk and capital management get together" - get a room you guys!

Policy and Process

·     Generally a very clean and useful section, particularly around "dynamic" and "static" processes and their outputs. Section on ORSA Report content is less useful, being based on the 2008 issues paper, and there are plenty of papers covering that topic (sift through yourself!).

·     Projection process - No suggestion of whether recommendations from balance sheet projection activity should be balled up in the ORSA Report or reported separately as part of conventional committee/Board reporting. I always found this element a nuisance to pin down, as one wouldn’t necessarily want to present material of such significance in a 20-200 page ORSA Report if it meant it didn’t get the appropriate table time at strategy days etc.

Economic Capital 

·     Practical obstacles - all seem to revolve around there being a shortage of actuarial time/resource. Well get off my land and go do some counting then!

EC and Risk Management

·     Document is a little unclear around risk appetite framework/risk management framework/risk management system terminology, which is a little unhelpful

·     Interesting comment regarding non-quantification of risk that "risks cannot be quantified" rather than "risks cannot be quantified easily" – this is an actuarial paper, you guys can quantify anything, surely!

·     Define reverse stress testing as "testing to destruction" - the UK definition is more discrete than this, and certainly more useful for stimulating debate in Board exercises

ORSA Projections

·     More industry consensus on what 'business planning period' constitutes, being 3-5 years. Barely seen anything to suggest firms venturing outside this window for projection purposes.

·     Nice simple explanation of the component parts of the economic balance sheet which should be projected as well as recommendations for projecting risk appetite metrics and the P&L.

·     Suggestion that, unless already stochastically projecting, firms will project deterministically, "unless the company is planning significant changes to its future business mix". Judging by the jostling for position around Long Term Guarantees right now, is that not likely to be quite a few!

·     Acknowledge that the approaches already used for Financial Condition Reporting should be leaned on for smaller or less complex entities.

Scenarios

·     Reverse stress testing has grown into a different beast from that reference earlier in the piece, incorporating "back-solving" (new one on me!), and looks for events that reduce own funds to zero - not sure I've heard RST defined like that before, and certainly not convinced that own funds of zero necessarily constitutes "destruction"

·     Good recommendation for selecting scenarios from emerging risk assessments as well as a firm’s existing quantum – best not to take the path of least resistance in this area of ORSA.

KMPG - Economic Capital Modelling in the Insurance Industry survey

Just when you think things will be quiet while the normal world goes to the beach for a month, KPMG chip in with a survey on EC modelling, polling 43 of the world's largest global insurers, with a nice spread of continents and insurer-types represented. Over 90% of respondents were Chief Actuary/CCO/CRO etc level.

With this subject being a hotter potato right now than a Jersey Royal locked in a sauna, in a tank top, in Bangkok, I've had a trawl through and found the following highlights:

• Most reasonable business uses of EC metrics appear to be applied or planned by respondents (pricing/underwriting decisions being the straggler)
• 40% of respondents said management understanding of EC is still limited - schematic on p9 showing the differences between 'sophisticated' Europe and 'savage' RoW hints at some kind of Solvency II dividend, though the results are not flattering across the board.
• Interesting schematic on implementation difficulties (p12), broken down by continent - data quality seems to have topped the list of implementation problems, which is no surprise I guess, but they neatly connect it with potential for over-reliance on expert judgement, simplifications and approximations to fill the gaps (all of which are to the detriment of a pure EC approach, at least in theory).
• Curve fitting is the majority-used approach (58%) to deliver model outputs quicker (i.e. 'lite' modelling), with replicating portfolios and LSMC less favoured
• Understanding around fungibility and dependency higlighted as areas for improvement
• Two-thirds still not allowing for sovereign debt risk in their EC calcs - I admire the persistency!
• Very interesting bit towards the back on effectively projecting EC, the holy grail for anyone in the ORSA space right now. While they loosely refer to the business planning horizon as "typically 3 years" (I've seen longer than that before breakfast, lads!), the point made is perfectly valid, namely that methodologies for this kind of projection are in their infancy.
• Finally, a nugget on Operational Risk Modelling (which I only touched on yesterday!), by some distance the least effective part of respondent's EC frameworks. They do note that 60% of EU respondents have moved to stochastic-based Op risk models with all bar one using expert judgement to calibrate them! They also bemoan the lack of credible data and subjectivity around cause/effect/latency of op risk events.

I guess the most surprising element of the document is how cagily it is written, as if EC modelling of risk profiles still has something to prove against, say, arbitrary and aimlessly prudent margins - the authors acknowledge that, if done badly, EC modelling is an accident waiting to happen, which supports the "rigour" being applied by the FSA when pre-assessing the UK insurance industry's model applications.

Also surprised that more reference to ratings agency demands wasn't made, particularly with that element seemingly influencing EC calibration points in the EU right now (hands up if you're at 1-in-2,000!)

FTSE Insurers and Solvency II at interim-time - 'Oops I spent it again'

While the politicians and eurocrats are having a well earned soak in the August sun before they pick up their Omnibus II cudgels again, the rest of the Solvency II world has to continue with the more mundane tasks of counting beans and predicting the future.

On that basis, the great and good of UK Insurance plc have been comparing abs this week on both cost and go-live date, with the following revelations;

Legal and General

• "...expect implementation [of Solvency II] could be later than 2014"
• On track to submit IMAP by end 2012 - guessing this means a large amount of tedious rolling forward of balance sheets, SCR etc for the guys in 2013 in order to meet FSA application requirements
• £23m spent on "Investment Projects" for the half year, predominantly related to Solvency II - pro-rated, this is down slightly on 2011's total spend of £56m.

Old Mutual

• Bermuda's new capital regime (fishing for equivalence of course) has obliged the Group to send capital to Bermuda itself, reducing their FGD surplus.
• Seem confident that the overhanging Omnibus arguments (equivalence, discount rate methodology, contract boundaries) will affect its SCR surplus
• "...increasing risk of delay in the Solvency II timetable beyond January 2014"
• "...currently on track to deliver all requirements for Solvency II compliance"
• No word on project costs as such

Aviva

• Costs associated with preparing the businesses for Solvency II for the half year of (eeeekk!) £72m (as opposed to just under £100m for all of 2011)
• Note that a draft of the Level 2 implementing measures were "published in 2011" - I wouldn't call unofficial circulation via national trade organisations "publication" as such!
• Implementation date "...continues to be discussed"

RSA

• Content that go-live is still scheduled for 2014
• Interesting, calibrating their EC model to 1-in-1,250, which doesn't copy the vogue of 1-in-2,000 which appears to have landed with larger firms, I guess to save the ratings agencies having to work a bit harder!
• £16m of Solvency II costs for the half year 

Prudential

• "...currently anticipated to be implemented from 1 January 2014"
• "...continue to evaluate actions, including continuing consideration of the group's domicile"
• Total of £27m spent on Solvency II implementation costs in the half year

Resolution

• £48m at half year - their bigger news on exiting IMAP until 2015 is covered on this blog post.

Standard Life

• £42m at half year for Solvency II and RDR "restructuring programmes" - RDR is a beast in itself, so may be difficult to attribute a portion of that cost, though the guys were in the £50m+ bracket for all of 2011.
• Little in the way of additional Solvency II comment

Royal London

• £9m in "corporate costs", which includes Solvency II, but doesn't cover all by any stretch
• No additional comment

Some big money getting laid down right now, which was no doubt budgeted as tapering-off by now in previous budgets, alongside (no doubt well briefed) messages of uncertainty on go-live date - let's hope we get it right kids!

InsuranceERM's Roundtable on Solvency II - extracting value and meeting challenges

InsuranceERM have kindly taken their pay barrier off the outputs of the Roundtable they hosted with Deloitte, bringing some of the talking heads we know and love and discussing the challenges of Solvency II, as well as the struggle to extract value from the project.

I thought the following was worthy of comment (too much effort to attibute to each commentator, so read the article if something tickles your fancy!);

From the value section;

• Suggestion that small/medium sized insurers required "education" on risk management to attain the awareness and levels of larger firms (patronising but fair?)
• Comment tha "documentation probably isn't as good as it should be" - the FSA would certain concur, based on their speech last month, and indeed the deal they cut with Lloyds last week.
• All references to ORSA centre on the ORSA Report/"Record of the ORSA Process", rather than the process itself. This is very natural (I fight it on a daily basis), but if it is a continuous assessment process, then we must redouble our efforts to talk of it as such, and not as a reporting process.
• Strange comment that non-executive directors feel they are being asked to do too much ("act like executive directors"). Appreciating this is a once-in a career suite of legislative activity, it's not that bad for a few days work, get on with it!
• Big statement made about Boards having internal model knowledge "before Solvency II came in" - I suspect the depth and breadth of what the Board needs to know about their models will be one of the hardest knowledge gaps to bridge for the 70-odd model applicants, so surprised to hear someone so dismissive.
• On Risk Appetite, a comment that ORSA is "forcing boards to actually reflect and achieve concensus around risk appetite" (which I would be mortified if Boards didn't already do), followed by a mention of monitoring "unused risk-bearing capacity" in one's risk profile, which I really like.
• One guy notes that UK capital requirements are not driven by regulatory capital, but rather ratings agency capital (or economic capital/overall solvency needs by another name) - while its a big statement, it is probably fair, bearing in mind where the big boys have calibrated their EC measures (all at or around AA - coincidence?).
• Quite a disappointing section on diversification benefits, which pretty much touched on M&A, and not much else

From the challenges section;

• Beautifully timetabled comment regarding the FSA and Lloyds "not delaying their timetables" - obviously didn't get the inside track on that one!
• One personal concern tabled that "given the level of resources in the FSA, the tier-one approval process may well drag out longer" - obviously DID get the inside track!
• "Many UK firms are targeting IMAP in the fourth quarter of this year" - so now we know?
• Guarded comment about regulators needing to be open and honest "about the basis and whether reliefs and concessions are going to be extended" regarding IMAP.
• Good comment regarding contingency plans for failed model applications - "capital loadings will come into play, rather than having to revert back to a standard formula", which is easy to forget when constructing said plans
• Another less well trodden discussion regardin the FSA compelling an organisation without resource to use an internal model - not certain of likelihood, but always good to be reminded of the Standard Formula not being a safety blanket in that respect.
• Nice piece on difficulties for groups, with "parents and subsidiaries running at different speeds depending on where they are located", followed on by regulatory arbitrage comment - is the FSA effective enough to coax the less well armed regulators to work at their speed?
• One commentator with a US presence noted he is participating lobbying the NAIC on ORSA and its value (it would certainly help the equivalence argument no end if they could get that one to stick, and it's already going well).
• Ends with one of my pet peeves, the CRO/Actuary debate - one commentator nails it with the CROs needing to be "broad-based business leaders with a high level of financial literacy", as opposed to an actuary, while another commends the "wave" of actuarial CROs, but is generous enough to say he can see it "broadening out a little bit" - thanks pal!

FTSE Insurers, Solvency II and Capital Adequacy - Resolution

There's enough disclosure in Resolution's releases today to choke a donkey, with preliminaries and slides full of the usual treats - this is probably the last of the major moheicans, so I'll probably do a round up post for my own benefit, though you can click through on the links on this post to get to the earlier ones.

On the Solvency II front they disclose £55m of project spend avec finance transformational costs, which is the same ball park as most competitors (L&G, Standard Life and Pru all within a couple of million). Their comment on p7 that "The current legislative draft looks less favourable for the UK industry with the treatment of matching premium and contract boundaries, in particular, being more onerous than the last quantitative impact study (QIS5) undertaken by the industry", feels like it pre-dates the ECON vote from last week, and they have comment scattered throughout on impact of Solvency II on capital management strategy, with-profits distribution and annuities. Some more substantial comment on project progress is on p63.

On the capital front, their disclosures are a little muddier than in their excellent analyst day presentation from last year which helps identify something approaching their "economic capital" measure (although this is not your conventional insurance business of course, and like Zurich, has an interesting major outsourcing angle). On p24 of that slideshow they look at Solvency II aggressively in the context of potential for cash returns, but no sign of that aggression today.

They also disclose in today's slides that they have already generated substantial capital savings through an optimisation programme (dividend-inspired rather that Solvency II-driven I dare say!)

Listed Insurers and capital adequacy - Generali

Onto the home straight with these now, as most of the UK Tier 1's and the larger mainland European have already presented their preliminaries for 2011, but Generali kindly pushed their disclosures out yesterday, which made for interesting reading on the capital adequacy/transition to Solvency II front. I had blogged last summer that these guys may be stretching it on the capital front on the basis of some numbers touted by the FT, so I have been looking forward to these!

In the main report, they draw out the following;

• Solvency I coverage down to 117% at 2011 year end (from 132% at end 2010) - similar to Aviva, they throw together a pro-forma estimate for end-February to show that the year-end number was something of an "exceptional volatility" fluke, and suggest it is back around 130% again (p76).

In their analyst presentation, they are a lot more forthcoming on both regulatory and economic capital, and cover the following;

• "Restoring capital adequacy" slide on p5 shows the need for the pro-forma capital recovery mentioned above.
• Same slide shows economic capital was as low as 124% before the post-year end recovery (not disastrous bearing in mind they are calibrated to 1 year VaR at 99.95%, the same as Aviva and Zurich, and the same ballpark as Old Mutual).
• Analysis of change in the Solvency 1 Margin (p33) shows how both the ratio and the amount have been decimated y-o-y - relatily small dividend element, so that should be safe I guess.
• Economic Capital ratio change (p35) sees them also reference a more generous area of the PDF in order to give context to the level of coverage (only 124% covered at year end using AA rating as the calibration, but 159% covered using BBB rating). I'm guessing things look rosier at 99.5% for everyone else as well though fellas!
• A slide covering the Solvency I change between 2010 year end and the improved pro-forma number at the end of February 2012. They gain €1.1bn from "Italian anti-crisis legislation", which I'm guessing is bond-related, and amplifies why the economic issues in that area of the Eurozone have to be catered for.
• Some stress tests on the Solvency I ratio on p74 - useful for consideration

You might also get some use out of their EEV report if you are knee deep in sensitivity/scenario testing, and they go to the trouble of defining some of the terminologies we know and love in their methodology section (particularly nice effort on internal capital on p30)

FTSE results and spare capital - Legal and General

We must be entering the final straight in terms of UK disclosures (I think I've got most of them already) - L&G entered the fray today with their preliminaries, and had the following Solvency II-relevant items to disclose:

• IGD coverage of 220% - touch down on last year, but up in absolute terms from £3.7bn to £3.8bn - interesting that they declare it post dividend, unlike Prudential yesterday (the focus on how cash generative the L&G model is in their report might explain this relative flashiness!)
• Spend on Solvency II  (and other investment projects) up to £56m from £39m in the previous year
• "Countercyclical dampeners" highlighted as a key area in which L&G are engaged in the debate at EU level 

I may try and round these disclosures up into a nice table once the last few put their heads above the parapet.

FTSE (and other) results and spare capital - Prudential, Munich Re, Standard Life

...and the result keep raining in! Hot on the heels of Old Mutual, Aviva, and a bunch of others all bundled together, a few more preliminaries of those we know and love slipped out today. Highlights below;

Standard Life

“significantly de-risked our business…well placed to operate in the currently proposed Solvency II environment”

• P63 - £59m spent on Solvency II (£64m last year)
• P32 - Solvency cover down from 206% to 173%, mostly due to subordinated debt shenanighans last year

Prudential

• P34 - £55m spent on Solvency II (£45m last year)
• P63 - "Our capital position remains strong. We have continued to place emphasis on maintaining the Group’s financial strength through optimising the balance between writing profitable new business, conserving capital and generating cash. We estimate that our IGD capital surplus is £4.0 billion at 31 December 2011 (before taking into account the 2011 final dividend), with available capital covering our capital requirements 2.75 times. This compares to a capital surplus of £4.3 billion at the end of 2010 (before taking into account the 2010 final dividend)." Note - not sure of the necessity to qualify "pre-dividend", but normally means something cheeky!
• "Therefore, in parallel to continuing our preparation for eventually implementing the Solvency II rules, we also evaluate actions to mitigate the possible negative effects. We regularly review the range of options available to us to maximise the strategic flexibility of the Group. Among these options is consideration of optimising the Group’s domicile, including as a possible response to an adverse outcome on Solvency II."
• Tracts of explanatory text on p63-64 on Solvency II status, most pertinent being "...the Solvency II rules relating to the determination of the liability discount rate and to the treatment of US business remain unclear and Prudential's capital position is sensitive to these outcomes"

Munich Re

• "The economic solvency ratio thus totals 111% (136%), a year-on-year decline of 25 percentage points that is largely ascribable to the very low interest rates and high volatility on the capital markets. Nevertheless, the figure still clearly reflects Munich Re's capital strength – Munich Re's economic risk capital, which produces the solvency ratio described above, corresponds to 1.75 times the capital that is likely to be necessary under Solvency II based on the Group's internal risk model. Munich Re's available financial resources therefore add up to 194% of the required risk capital under Solvency II. "

• "As part of its active capital management, Munich Re intends to buy back an outstanding subordinated bond and to issue a new subordinated bond. Owing to restrictions resulting from US legislation, offers will only be made to investors resident outside the USA. It is not possible to provide further written information at present, also for legal reasons. This new bond is designed to be compliant with the existing (Solvency I) and anticipated future (Solvency II) supervisory regime, and to meet current rating agency requirements." (i.e. More subordinated bond activity having substantial impact on balance sheets, as found at Aviva and Old Mutual)

• P140 "Though the economic solvency ratio of 111% (136%) is 25 percentage points lower than for the previous year, it reflects Munich Re’s capital strength. Munich Re’s economic risk capital, which produces the solvency ratio described above, corresponds to 1.75 times the capital that is likely to be necessary under Solvency II according to our internal risk model. Were we not to apply the safety cushion of 75% to the value at risk with a confidence level of 99.5% and merely to comply with the Solvency II standard, the economic solvency ratio would be 195% (238%)."

• 
  

  P154 "Our long-term target of a 15% return on our risk-adjusted capital (RORAC ) after tax across the capital-market and insurance cycle applies unchanged, but it will be difficult to achieve given the current low-interest-rate environment. As soon as the requirements of Solvency II and the new IFRS s for insurance contracts and financial instruments have been finalised, we will gear our target performance measures to the key indicators from this new framework with its strong economic focus."

Geneva Association Paper on Capital Allocation - More Capital = More Stability?

Very nice and very concise paper from our chums at the Geneva Association, using Solvency II/Swiss Solvency Test backdrop to challenge the appropriateness/perversity of increasing capital requirements in order to instill/achieve improved confidence, and the exponential costs of looking for incremental improvements in confidence, covering some normal and fat tail distribution angles, and the ultimate overall cost to society in seeking 100% confidence - well worth a read.

FTSE results and spare capital - Old Mutual

UK results season - my favourite time of year (note to self: get out more). Old Mutual have put their goodies in the window today, and while not disclosing how much Solvency II project spend they have laid out in the last year, they have been very bullish on project preparations to date, for example;

• "The Group comfortably met the recent stress tests required under the EU-wide Solvency II project"
• "In tests there was no scenario when the Group's capital reduced below the SCR level. "
• "We were the first major UK retail group to submit Group QIS5 results and the Self Assessment Questionnaire on the internal model to the FSA" - not such a boast now the FSA have ripped the template up!

They also indicate the most material uncertainties left in the EC/EIOPA/Parliament squabbling,which is very refreshing - latter seems most perturbing on their front;

·         "Discussions on the treatment of EPIFP (Expected Profits In Future Premiums) have moved in a positive direction and we believe they are likely to be eligible as Tier 1 capital under Solvency II".

·         "Bermuda was included in the first of three groups of non-EEA jurisdiction equivalence assessments. EIOPA‟s findings from this assessment were inconclusive and will be revisited this year. The equivalence of South Africa will be reviewed in 2012 as part of the second group of assessments".

·         "The latest draft regulations have suggested that a short contract boundary may be applied to some of the Group‟s long-term unit-linked insurance business. We believe this proposal is not aligned with an economic balance sheet valuation of this business and we have raised concerns about this definition with the FSA and other bodies".

The bits on capital are just as lively as those released to date (captured here and here), with some shenanighans regarding what is in and what is out for FGD surplus purposes on bond capital where they have followed Aviva's "but if we show it like this it's better..." philosophy!

Their FGD requirement actually came down y-o-y unlike Aviva's, though this was by virtue of "required capital" falling by more than the "available capital" fell by (if that makes sense!). Most bizarrely, the UK-specific regulatory capital coverage went from 2.8x to 5.1x to 2.0x between Dec-10/Jun-10/Dec-11 - no idea what to think about that!

Interesting post-script in light of the multiple moves on Boardroom diversity (or "gender diversity" as it might as well be called) is that they have ticked off a couple of boxes with a new NED hire. As I recall they have committed to a gender-specific target by 2014-15, and this obviously gets them going. I'm certain the 30% club might like to see more executive directors however... 

Late Post-script - Annual Report and Accounts and Annual Review and Summary Financial Statements published at the end of March contains all the ORSA-related disclosure materials one could want (p74-88)

FTSE results and spare capital - Aviva

Just when you thought, after first AEGON and then the Pru, the EU exodus was about to start at the thought of Solvency II compliance costs, up front the lads at Aviva with their results today, accompanied by their UK CEO stating they were committed to being part of UK plc 'hook line and sinker'.

Regardless of whether such an EU-centric company has anywhere else to go is another matter, but it is refreshing that such regulatory arbitrage is not near the top of everyone's agenda (at least not publicly!).

The view also seems somewhat perverse when you look at the numbers - IGD surplus is down seismically y-o-y (although the sneaky pro-forma IGD estimate for end of Feb highlights how much of that was due to grumpy markets), but of more interest from an overall solvency needs perspective, their economic capital coverage is also well down, sitting at around 125% at year end. Again, they have thrown a quick-and-dirty pro-forma in to show the number at 145-150% at end of February.

As they are calibrated to AA rated (p8), this is ample for SCR coverage I guess, but the cynic in me suspects that capital efficiency must be putting HQ moves on everyone's agenda, particlarly when you look at the £96m bill for their Solvency II preparations last year (p 31)!

Axa results and economic capital measures - indication of things to come?

So results season kicked off today with Axa putting the basic full year out (got to love European efficiency on these matters!). This was followed by the EEV Report and Analyst Presentation.

Of particular interest is of course the Solvency I vs Economic Capital measures which most insurers are now kind enough to table up, and the figures were pretty stark. On the Solvency I measure they were a touch up year-on-year, while their Economic Capital measure was massively down (numbers on first page, rationale on third).

Detail on their Economic Capital (and indeed their entire Capital Management Strategy) was fired out in 2010 as part of an investor day. They appear to be using the 1-in-200 stress as their EC measure, which would suggest that (model approval notwithstanding) they have received a 'beasting' on their SCR coverage over 2011.

I blogged in August last year about an FT article which opined on how companies may approach economic capital targets under Solvency II (125-150% of SCR in UK, and perhaps 170% in mainland Europe was their conclusion, for what its worth). While that would have put Generali fractionally out at the time, most of the other big boys were comfortably covered using that yardstick...until now!

The rationale for the drop presented goes to adverse experience on interest rates and spreads "net of changes to the liquidity premium". A smarter man that me will probably be able to read between the lines on that one to find where they are exposed in a way that leads to such a swing in EC, but if one of the major lobbyists is experiencing this volatility, what chance the rest of us?

NB - Generali punted this round today in order to contextualise the recent downgrading activity of insurers by the ratings agencies - surprising to see a company lump all of their competitors onto a press release from their own offices, but I guess there is safety in numbers! Few comments on Solvency on it, but mostly seems to be about negative outlooks on Eurozone default possibilities, new business and economic conditions etc