FSA Annual Report and Business Plan - Solvency II coverage

Our friends at the Wharf have had a busy week, throwing out a multitude of paperwork with some nuggets of gold deep within - this post covers their annual report and workplan. Pretty light on Solvency II-specific material to be fair

From the FSA 2012/13 business plan, I noted the following;

• Still talking about transposition from 1st Jan 2013 (p13) - typo, or just written before Solvency 1.5?
• From p32 Insurers should expect "detailed reviews" of their risk management arrangements and internal models; with-profits business reviews from a PRA and FCA angle; underwriting and reserving controls at GI firms; and use of "external tools" in challenging senior management (citing their use of section 166 of the FSMA as an example, but not certain what else they are suggesting).
• As well as standard Solvency II work on L2 and L3 etc, they will conclude their consultations on the FSA handbook transition.
• Special levy for Solvency II will be £25.9m for the next year (and they continue to use their £100-£150m parameters for their overall Solvency II spend, which is liberal at the top end given the £110m figure they mentioned in the SOLPRU document).
• Consultation paper around Solvency II expected out at the end of this month (table on p83)

From the annual report and appendices, the following;

• Reiterates the Jan 1st 2013 date for transposition (p39) - again, I though Solvency 1.5 effectively moved that date to July 1st?
• £23m of Solvency II income booked (p137)
• In their Diversity Report, it would appear that their profile is sadly similar to many firms, being top heavy with blokes and bottom heavy with female administrators (p2). Making some headway on the ethnicity mix though (p8), and getting a little older in aggregate (p14), perhaps a by-product of all of the young bucks leaving to work on Solvency II! Also touches on sexual orientation, religion  and disability, so I highly commend this genuine look at diversity, rather than allowing gender to dominate it.

While they still haven't got to grips with the staff turnover issue, the levels of turnover that most Solvency II projects will be experiencing will be no different, so I suspect throwing more money at the issue wouldn't do much good (which the chief exec effectively said at the Treasury Select Committee in November)- the benefit of this frugality is a lower than expected industry levy, so fair play to them on that.

What is perhaps less convincing is the £150m tag to split the regulator into the PRA and the FCA - that's one expensive axe Hector...

FSA, SOLPRU and Costs

Just when you thought it had gone quiet, the FSA throw out a 200 pager covering the regulator's transposition to Solvency II!

Some important pieces in this on;

Cost

• FSA has budgeted £110m over the 5 years 2008-2013 for Solvency II implementation (which supports their statement back at a June FSA management meeting where they commented that contingency would need to be enacted (p3) if go-live date was extended past 2013). They had said in their business plan for this year that the estimated implementation cost would be £100m-£150m, so they are on the light side of that estimate. 
• Frighteningly, they are budgeting for another £178m of spend between 2014 and 2016 (on nursing internal models through assessments and  improving IT) before reverting to current equivalent levels - for those people who got a special levy refund this year, you might want to cancel the trip to Vegas!
• Estimating cost to the industry (of around 550-600 undertakings) of £1.9bn, with this estimate creeping up due to extra contractor and IT cost.

At 200 pages, some of the detail can wait, but those 2014-16 FSA costs (which will be the PRA by then I guess) are an eye opener, particularly for anyone in IMAP who will (possibly?) be coughing up a special levy for the model assessment-related element.