Solvency II, Omnibus II and Trilogue - two steps forward, two steps back?

Headline results from an Economist Intelligence Unit survey have been published this week, apparently suggesting that most global insurers continue to see Solvency II as their biggest regulatory challenge. Despite its prominence in the agendas of insurers' committees, boards and control functions, the legislation appeared to have taken a back seat in the decision-making fora of the European Union since the publication of EIOPA's LTGA in June.

So while the EU Parliamentarians go off for their hard earned 5 weeks in the sun (and by association Omnibus II/Solvency II will temporarily sit untouched like a pair of pink booties in Buckingham Palace), we can try and work out what the crack is with the dossier!

Trilogue
So with the Trilogue process itself necessarily one of closed doors, secret handshakes and unpublished shady deals, at least we formally know that they reconvened before the summer holidays thanks to Sharon Bowles' diary handler! Other than InsuranceERM's piece on a "muted start" to the negotiations (subscription only), the well is pretty dry on comment, suggesting that they got off to an inauspicious (re)start.

Parliament
As far as the latest ITER listings go (p1), ECON will not be considering the dossier again until 18th November 2013. From what I can read of the Parliamentary calendar, that is too close to supply the November Plenary with anything to vote on, and the December one is scheduled early in the month. Fair to say that, as indicated by Burkhard Balz last month, the Parliament won't vote on Omnibus II before 2014?

Council

Bed made - but covers stolen...

So the Lithuanian presidency is in town, and apparently sees the Omnibus II dossier as having "high importance" (p3) within their recently published work programme. ECOFIN have a state of play meeting provisionally scheduled for 15th October 2013.

That said, when pressed for comment when attending ECON before the summer holidays, they seems to have learned from the Paula Abdul school of making progress: for the two steps forward indicated by the Lithuanian Finance Minister's comment that the Presidency is committed to resolving, amongst other dossiers, Omnibus II (p12), he immediately takes two steps back by noting one of the key tactics will be "...focusing on uncontroversial technical issues to facilitate progress" (p13) - might be OK for some of the multitude of delayed dossiers, but not this one!

EIOPA
EIOPA naturally consider their work largely done for Omnibus II, and consider the report a "reliable basis" for making decisions on LTGs, and ultimately Omnibus II itself. Sr. Bernadino did however admit at the ABI conference a week back that, for 2016 to remain a viable "Go Live" date, political agreement on Omnibus II would be needed by the end of this year. Judging by Parliament's position above, I guess 2016 is out then!

European Commission
While Commissioner Barnier had lavished praise on EIOPA's, errr, "very good [LTGA] report", the Commission has lost its Solvency II specialist to retirement during this year, which might lead some observers to believe the Commission will be less effective as a negotiator while the new boy learns the ropes. However, Gideon managed to get some words from Karel van Hulle's replacement a couple of weeks back, and his modus operandi doesn't sound like one which will lead to a swift decision at the expense of one or two angry outliers in any case.

Specifically his comment that "We need to find a solution that works for almost all Member States. That is our ambition. So we don’t like to get the project through, just about ", suggests that anyone at the table with a gripe will get some airtime. With the LTGA outcome causing more gripe than at a constipated nursery, I suspect that the delays caused by the current 5 week vacance soleil will be a mere drop in the ocean...

PRA's take on EIOPA Guidance - no truck with dual reporting?

One of the Barnett Waddingham crew was kind enough to make a few notes about the PRA's current position, presented in an industry briefing back in early June (slides seemingly unavailable). While it didn't touch on pre-application for internal models, it did publicly tease out a few more details on ORSA and System of Governance from those already available, for example;

• The concept of a "Glide Path" towards ultimate Solvency II compliance, which is being agreed between firms and the PRA, to make up for the lack of certainty around both EIOPA's requirements from 2014 and of course the ultimate 'Go Live' date itself - gives both parties plenty of wriggle room in their preparations
• PRA are currently doing an "EIOPA vs PRA" comparison, but are not looking to change the PRA Handbook (which would neccesitate a consultation period, and therefore wouldn't be ready for 2014)
• That the PRA are not especially enamoured with their reporting requirements up to EIOPA!
• That the PRA believe that the trilogue discussions will be concluded before EIOPA's guidelines come into force. That seems less likely with every passing day
• That the PRA do not have the resources to feedback on any of the firms' efforts in the Solvency II reporting space

I guess the slightly odd thing is that the PRA have just announced a radically reduced Special Purpose Fee for Solvency II preparation (only £3.1m for IMAP, and a rebate for non-IMAP due to underspend last year - compare that to previous years!). Could they perhaps have just hung on to a bit more cash to provide a more substantial service in the next 18 months, or have they also given up the ghost on anything of substance happening in the foreseeable future?

ABI and PRA on 'Meeting the Challenges of a Changing World' - Solvency II in particular...

Low Yield issue - not just for insurers

While I disposed of my son for the summer last week for an extensive potty training course in Bordeaux (PS you might want to avoid the 2013 whites!), the ABI gathered the great and good for their biennial conference, themed Meeting the Challenges of a Changing World.

A corresponding publication from the ABI which the event hung its hat off to a certain extent is particularly useful for anyone in the emerging risk/ORSA/reverse stress testing space, touching on 7 specific 'challenge' themes, which are themself further broken into sub-categories. With the ABI providing a mouthpiece for the interests of the UK insurance industry (and being currently Chaired by an avid opponent of Solvency II), it was worth picking up on this document's take on Solvency II, specifically;

• That it could be a future constraint on the nascent equity release market
• Its well documented "...potential effects on infrastructure financing"
• That British insurers should "...[continue] being proactive and engaged in trying to shape vital regulation such as Solvency II rather than simply criticising it from the sidelines". Not sure if the implication is that the UK is drifting from the box-seat in this regard, but certainly in the context of the next decade, a slated in/out referendum on EU membership may make proactivity on Solvency II a moot point!

The regulatory meat in this lobbyist event sandwich came from a keynote speech by the PRA's Andrew Bailey which, in the process of publicly revealing a few nuggets of truth, still left me safe in the knowledge that insurance is still the banking industry's boring cousin - that he needed to "...make clear at outset that insurance supervision matters as much as banking supervision" and stress that "...insurance supervision is a skill on its own" while supporting most prevailing regulatory techniques with the prefix 'what we learned from Banking is...' tells its own story.

That aside, the following comments are worthy of highlighting;

• The PRA's current trend of using "business model analysis" in their supervisory work - surprised that this was not already par for the course frankly (what else other than the types of analyses referenced at the bottom of p4 would you be doing?), but one would expect that the advent of ORSA will enhance everyone's activity in this field soon.
• Taking that into account, it is "...logical for us to make early adjustments to our existing regime to incorporate the ORSA under ICAS+"
• The suggestion that management "...take responsibility for understanding and mitigating the risks in their business" - 'managing', rather than 'mitigating' surely, we'll tolerate anything within appetite!
• That the truly woeful "Solvency II/Crossrail" costing analogy used by Mr Bailey to a parliamentary select committee was the PRA "...making a point on behalf of firms".
• That "PRA have not withdrawn from involvement in Solvency II, far from it", though recognises that the result around the classic matching adjustment is not what UK plc would wish for - goes on to comment that we "...still have a good way to go to make the Solvency II regime manageable in its use and implementation"
• That, as far as Sol II's legislative progress is concerned, negotiations "...continue over summer, with a conclusion expected in the autumn", and that the official implementation date discussed recently on this blog is "clearly unrealistic".

In a week where a wall of silence has descended upon the co-legislators and the Commission, it is reassuring to see at least one NSA body with a solid-ish implementation plan, regardless of the immediate lack of things to implement - however judging by the words captured by Gideon of Dr. Wiedner, the lightly briefed (and from what I could read, lightly fed) replacement of Karel van Hulle, I suspect that Solvency II on the whole remains "Klaus but no cigar"...

Chartered Institute of Internal Auditors - final guidance on Effective Internal Audit for financial services

The Chartered Institute of Internal Auditors have followed up on their consultation earlier this year on Effective Internal Audit in the Financial Sector with this final set of recommendations.

Doesn't appear to have been any seismic changes as a result of the consultation, though the "need for proportionality" has been recognised, and clarification has been added that the content itself has not been mandated by the profession as best practice.

Interestingly, huge emphasis has been put on clarifying the primary role of Internal Audit as being the "protection" of a firms's assets, reputation and sustainability - does the profession feel well resourced and equipped to handle reputational defence? - while a few other elements sprung out at me;

• A focus remains on IA challenging the "tone at the top", as if the expression now carries so much weight and definition that professional guidance can be hung from it.
• "Risk Appetite" is again not defined, however IA are on the hook for assessing that it has been established and reviewed by senior management
• Emphatically declares that "...the assurance map cannot be carved up between the Risk, Compliance and Internal Audit functions", stressing that IA will be expected to include the challenge of the work of other control functions in their audit plans
• Built in some leeway around their earlier suggestion of compulsory attendance of IA function heads at Executive Committee meetings (ostensibly in order to understand strategy) - for insurers, one could anticipate that the advent of ORSA may take care of that knowledge gap 

Certainly the PRA/FCA have been fast to come out with support for the final version, so I guess all control functions had better make their peace with the content and prepare appropriately.

EU Commission and Quick Fix 2 - Silence is golden (delicious)...

We are a good week down the line since Solvency II technically became a rolling ball, at least from a 'transcription into national law' perspective, and the party has barely stopped around the EU...

Man from Del Monte
- he says 'Non-Compliant'

Joking aside, the wonderfully obscure lobbying miscreants at ICODA released findings (expanded on here) of a straw poll they had issued to all member states around their preparedness to implement both Solvency II and EIOPA's interim measures. Not even half of those polled responded, and only 6 responded in full, so the sample isn't ideal. That said, there are enough seeds of doubt sown by the responses to grow a Del Monte-style orchard of non-compliance by next year.

As one would have anticipated off the back of the last-ditch attempt to secure a second 'quick fix' Directive, there would appear to be major concerns around NSAs meeting the requirements as at 1st Jan 2014, for example;

• All respondees are in favour of 'Quick Fix 2'
• 40% don't feel adequately prepared for ORSA obligations
• Half are not prepared for internal model pre-application obligations
• A quarter are not prepared for submission of information obligations

Is 'Quick Fix 2' simply being seen by some of the straggling NSAs as an opportunity to postpone the inevitable rather than to actually prepare for it, thus avoiding the decadent yet ultimately unnecessary project spend of the early adopters? Indeed, is 'Quick Fix 2' even legally possible now that the date for transcription into national law has passed?

I took the opportunity on Monday 1st July to contact representatives of note to ask where the legislation currently stands, specifically around the potential for retrospective 'Quick FIx 2', and received the following cavalcade of replies in the last 7 days;

• EU Commission - nothing
• An EU Parliamentarian heavily involved in Solvency II - nothing
• EIOPA - a holding e-mail thanking me for my question

I hope that world exclusive information helps you all with your preparations!

Late post-script - I didn't bother checking in with the Council, but they have surprisingly made public comment today due to the changeover in presidencies to the Lithuanian delegation. Knowing the guys in Vilnius are big fans of the whole Solvency II shooting match (?), it was interesting to see they only have "...continued negotiations on the Omnibus II insurance dossier" scheduled over the next 6 months, as opposed to something more positive. We'll certainly be seeing Santa before the Parliamentary Plenary vote then, big question is will we also see the 2014 Easter Bunny?

Actuarial profession and the Risk Function - from 'land grab' to 'colonisation'?

Back in the early days of this Blog I used to post frequently on the Solvency II-sponsored creep towards Risk functions in insurers being 'Chiefed' by members of the actuarial profession as a matter of course rather than choice (here, here and here for a start). It was even a thread in a presentation I delivered to ILAG in late 2012 around areas of control function crossover, in particular that the actuarial profession was acknowledging that there were professional deficiencies in their ability to address the basics of an actuarial function under Solvency II, yet preferred the ambition of conquering a newer (less arduous?) space ahead of remedying them.

Whilst a quant is no doubt a decent fit for such a task, it was an evident snub to the nascent Risk Management 'profession', who took umbridge at the implication of such compulsion from the UK regulator in April 2011, though with seemingly little impact. However, limits to the amount of time and money bodies such as the IRM and FERMA can throw at developing a one-size-fits-all Risk Management qualification package that can appeal to quants and non-quants alike, plus some furious inter-squabbling in the ISO 31000 world, are certainly not lending any credence to "Risk Management" as a profession in its own right as we stand.

Risk and Actuarial professions - 'Poles' apart?

Over in Ireland, the opportunity for the Actuarial profession to secure an additional control function has been pursued so rabidly that the SAI incoming and outgoing presidents were recently able to congratulate themselves on having busted into "the new frontier" of Risk, and are now moving on into "colonisation mode" (p2)! In the UK, the Institute and Faculty of Actuaries already seem to consider that area of influence secured judging by the new president's remarks recently, indicating a desire to influence more mainstream debates than those around risk management systems and corporate governance.

The UK and Ireland don't appear to be the only ones afflicted by the perception of compulsory quants in Risk functions. Munich Re's excellent Knowledge Series delivers a Germanic take that there is "no doubt" that professional mathematicians will be needed for tomorrow's Risk functions.

When considering the history of the Actuarial profession (beautifully summarised here), there should be no reason why Risk Management cannot achieve a similar position given time, regardless of the disparity in existing approaches from representative bodies. A modular qualification which can prepare a 'risk professional' for their favoured activity (insurance buying/continuity management/financial risk/op risk/ERM) is surely an ambition which those bodies can harbour in concert? My concern would naturally be that I probably don't have another 50-100 years to wait for the that convergence to happen and enhance my own career prospects!

Or maybe I do - does anyone know an expert in longevity?

Solvency II delays - the unanswered questions...

There's a couple of unanswered questions loitering around in the Solvency II space which I'm sure a more plugged-in switched-on kind of girl could answer, but which I'm struggling to pin down. Looking forward to hearing from anyone on the following;

"Quick Fix 2" - as far as the paperwork from the first "quick fix" is concerned, the Solvency II 'clock' starts ticking on 30th June 2013, and despite the brave attempts of a cabal of Parliamentarians to obtain a second "quick fix", it seems like they failed. Is the clock really ticking for transposition into national law as of Monday?

Omnibus II - putting quick fixes to one side, the anticipation of EIOPA's LTGA report feeding into a positive EU Parliamentary Plenary vote in October 2013 was one of the anchors of what one might call a timely implementation calendar (i.e. 2016). In a typically unannounced manner, the indicative Plenary date, which had already been kicked down the road at least seven times, has this week been inauspiciously removed from the Procedure File entirely (confirmed here on the 'History' tab on 20/06/13).

With EU Parliamentary elections scheduled for May 2014, and Parliament begging for the Solvency II inertia to be broken beforehand, do we reasonably have another window to get Omnibus II through a Plenary vote before that political upheaval, or is the removal of an indicative date acceptance that the LTGA has generated more problems than it has solved?

(Level 2) Implementing measures - the European Commission had these timetabled in their 2013 "expected adoption dates" list, chalked down specifically for Q4 2013. In the last two months this has been removed from the list in its entirety (well spotted Norton Rose). Is this direct acknowledgement that, as indicated by Burkhard Balz last week, that there is no chance of Omnibus II clearing the Plenary hurdle this year?

Someone must know something - don't be shy!

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

EIOPA 

- "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"

EU Commission

- "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"

EU Parliament (via Burkhard Balz)

- "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'!

Institute of Risk Management's latest on ORSA - presentations and surveys

I haven't kept too much of an eye on the IRM's Solvency II Special Interest Group activity, which during 2011/12 was prolific, but with the disappearance of the finishing line, I suspected there may have been some fall off. There has certainly been a Partidge-esque rebadging of it (now called 'ERM in Insurance'), which I suspect helps most attendees justify to their bosses, in the face of interminable Solvency II delays, taking half a day off to attend these shindigs!

Rebadged - IRM's Solvency II SIG

A recent one on the incorporation of ORSA into the business planning process is worth highlighting, being focused (at least on the face of it) on the more visceral elements of the ORSA process rather than the theory. While the Kiln CRO seemingly had more to say than was put on his slides, the Allianz UK Head of Op Risk noted a few things which those working in the field would benefit from benchmarking against;

• Risk department seemingly responsible for ORSA report production
• 'Record of ORSA Process' documentation - shooting for around 60 pages, which feels light to me as a "record" (about par for a "report" perhaps?)
• ORSA Board report - summarised from the 60 pages referenced above, so again light
• Lists some 'example' ORSA triggers, which are good for peer comparison
• Seemingly will be validating their ORSA process, despite it not being a regulatory requirement.

The IRM's related survey also produced some notable material, particularly around participation levels - only 14 participants, compared to 22 back in 2011 and 33 this time last year, showing perhaps the extent of the fatigue on the matter. With the tiny sample also heavy in GI firms, one might take any revelations with a pinch of salt, however, I spotted;

• Frequency - A quarter are planning to run the ORSA process quarterly, most going annually
• Preparedness - Areas such as data quality, ORSA validation, ORSA record keeping and the forward-looking assessment are all lagging
• Projection length - 80% going for 3 years, though the GI heaviness of the sample will have skewed this for sure
• Projection technique - around half doing future years in isolation, and half doing multi-year (dependent) projections
• Forward looking assessment - All respondents are factoring in expected risk profile changes into their FLAs
• Stress & Scenario Testing - All respondents using scenarios with interdependencies, while two are not using reverse stress testing at all.

More from EIOPA and PRA on internal models - anything you can do...

Certainly looks like there is a bit more mileage in this back-and-forth around internal models and the assessing of their appropriateness. As I posted recently, the UK's PRA have come out fighting on the subject of 'Early Warning Indicators' (EWIs) to highlight where a company's internal model, for fair reasons or foul, may be measuring the Solvency Capital Requirement in a way which does not meet the required calibration standard of the 1-year VaR at 99.5th percentile.

Early Warnings - time well spent?

EIOPA, through the words of their Chairman, have already made a pitch for assessing internal models on behalf of our overworked national supervisors, at least at some point in the medium-term future. It would now appear they have also piggy-backed the PRA's work around developing and monitoring EWIs as well!

That article is on Risk.net, so for non-subscribers, EIOPAs work is specifically looking at (in the author's words, not EIOPA's) "...threats to a firms solvency that are not picked up by the company's internal model". These will include qualitative and quantitative measures, and are due to be discussed (by their internal models committee) in the Autumn -  you know, that relatively quiet point in the Solvency II implementation calendar...

The EWI article was published at the same time as an interview with Sr. Bernadino and Insurance Risk magazine was released, where the tone of the interview is particularly aggressive around EIOPA's inability to compel national supervisors to "comply" with their recently-issued preparatory guidance. Whilst it is hard not to admire his optimism ("we are moving closer to the date of implementation"), he is quite fixated with "some countries" who, without EIOPA's guiding hand, he feels would end up divergent from the rest of the market.

I certainly am not familiar enough with continental Europe's positions as it stands, but it certainly reads like a not-too-subtle finger point at Royaume-Uni at the very least. He also goes on to mention that, while 'full Board support' was received at EIOPA to issue the preparatory guidance, not all participants were 'completely happy'. One would certainly feel aggrieved at the smaller end of insurance supervisors to comply-or-explain on preparations for a new regime which doesn't have a kick-off date, while still having to administrate the existing one!

An interesting side-issue around potential discord amongst the states is this recent request (which I have procured through the magic of Google!) from most of the Member States for a second "quick-fix" Directive, based on the fact that some of the implementation countdown dates that feature in the first one are next month (good spot Gideon)! According to the letter, the Commission already appear to have singularly ruled out the need for another quick-fix,

Four countries didn't make it onto the list of senders (Ireland, Netherlands, Malta and Lithuania) - not concerned, or not consulted?

Also worth highlighting the recent spectacularly ill-timed London press strafing of the internal modelling world - an strange development, particularly at the same time that the UK Independence Party has been lifting up its dress for London's financial sector to have a gander underneath. With some of the UK's bigger beasts such as L&G and Pru already openly hostile to Solvency II (and Resolution being an early faller in the IMAP stakes), is there potential for the rinsed-out UK insurance sector to throw its weight behind a political force such as UKIP, who would happily make an EU Directive bonfire, using Solvency II for kindling?

EIOPA and PRA - model appropriateness, expanding remits and early warnings

Another short flurry of activity recently on the Solvency II front ahead of the day (well, 'month') of reckoning for the Long Term Guarantees assessment. The industry media is certainly very chipper around the prospects of a deal being done off the back of the LTGA (here and here), highlighting that some German products may be the beneficiaries of this new found camaraderie (here).

German products - carved out from 

LTG requirements?

EIOPA themselves have been vocal on power extension this week, with Sr Bernadino making a few waves in his submission to a public hearing on Financial Supervision in the EU. Apart from his Partridge-esque diatribe about 'evolution, not revolution', he also highlighted what he considers enhancements to the existing supervisory structure in the EU, namely:

1. Strengthening EIOPA's operational independence - effectively through a change in its funding arrangements, going as far a potentially levying the industry direct, and also by having more money in any case (referred to cheekily as 'budgetary flexibility'!).
2. Reinforcing its existing 'independent challenge' role - by securing access to national supervisors' QRT data and allowing EIOPA to conduct EU-wide investigations of conduct-related issues (effectively an FCA for Europe!)
3. Enhancing both its mandate and powers - perhaps most controversially, fishing for centralised oversight of internal models, as well as powers to ban or restrict activities in member states.

One might say to EIOPA 'don't walk before you can toddle', but I guess if we are serious about operating a single market, the UK's consumers shouldn't need to rely on generally being in the vanguard on these matters (both producing nefarious financial products, then banning them and recouping the profits for compensation!)

Back to the UK's national regulator, the PRA dropped a few pearls of administrative agony for the insurance industry this week, with a couple of 'dear CEO' letters which were part-briefing and part-data request, ultimately driven by the UK's aggressive take on assessing internal model adequacy (i.e the same activity which EIOPA wishes to expropriate from national hands!). 

The purpose of the letters is nicely summarised by Chris Finney here, so I only need to highlight a couple of elements for my own interest;

Solvency II update letter

• "Unlikely to be any certainty" on timetable before autumn
• "Just under half" of IMAP candidates have applied to participate in ICAS+
• They are hoping to share learnings from ICAS+, "particularly developments used by firms in their modelling techniques" - danger here of the early birds determining what's hot and what's not in the world of assumptions/calibration/expert judgement/documentation for those not participating in ICAS+?
• Highlight pension risk as one area where the standard formula is potentially not suitable
• Next industry briefing forecast for late November (post-Omnibus II ratification?) - that's what I call 'scaling back' on costs!

Early Warning Indicators letter - remember here that the PRA's plans are potentially at odds with EIOPA's, to the extent that the PRA are already braced for some kind of legal challenge

• EWI's aim to test calibrations of internal models as well as "monitor any downward drift in capital" - presumably just quantity for the latter?
• Ratios being monitored are of pre-corridor MCRs (as illustrated in firm's LTGA submissions earlier this year) against current Individual Capital Guidance - once we go live, this is likely to be replaced by modelled SCR
• Special treatment for With-profits business to account for the fineries of that sector (cost of guarantees, level of free assets and the proportion of non-profits written in the book)
• Ratios are deliberately set so that 10% of affected firms will fall below
• Information required to conduct this work is covered by the data collection exercise below

Data collection exercise letter

• Fishing for data from all internal model applicants using YE2012 balance sheets (unless you can excuse using earlier data) which covers standard formula SCR, Internal Model SCR and ICAS by end of July.
• Also asking Life firms for key percentiles from distributions for 'risk variables' - one assumes this means each one of the risk drivers in one's SCR calculation.
• Conducting what seems to be peer review work around credit stresses and stochastic simulation files (for anyone using them).

With EIOPA and the PRA both seemingly interested in being top dog in the world of assessing model appropriateness, it looks like we might need a walk-off...

Judging model appropriateness - EIOPA or PRA?

Risk Appetite white paper from Oliver Wyman - hold the onions...

A white paper on Risk Appetite from Oliver Wyman caught my eye recently whilst fishing for supporting materials for my own take on the matter. I have covered on this blog a range of opinion

Risk Appetite - need to 'ketchup' with
latest benchmarks?

pieces on Risk Appetite from the professional institutes to the consultancies to the regulators perspectives, and so far they never seem to be on the same page at the same time.

From the Solvency II perspective, we know that (as it stands) Risk Appetite only exists in written word in Level 3 System of Governance and ORSA guidance, namely;

• That the AMSB is "ultimately responsible" for setting it (Sys Gov G15)
• That EIOPA did not wish to distinguish between "risk appetite" and "risk tolerance", rather let national regulators and the industry scrap out any divergence in term usage themselves (Sys Gov p30-38!)
• On that basis, "Risk Appetite" doesn't even feature in the L3 ORSA Guidance, though "risk tolerance limits" do (ORSA G7 and G11), perhaps indicating what terminology EIOPA prefer.

From the national regulatory perspective, the PRA have ingrained its importance as the "foundation of [an insurer's] risk management framework" in its new approach paper (section 110), whilst the Central Bank of Ireland have not only built Risk Appetite into the supervisory structure, but even had time remonstrate with the industry for its lack of progress around Risk Appetite statements!

The ratings agencies expectations on Risk Appetite also come into play, with S&P expecting its "clear communication" and "linking to risk limits" as part of its ERM assessment programme (p5, and more extensively, p9). They do however have the courage to define their terms with respect to appetite, tolerance and preference in the appendix. 

Appreciating therefore the Oliver Wyman paper is catering outside of the financial services sector, it still contains a host of rather inane platitudes such as;

Risk Appetite Framework

"...bringing discipline to major strategy decisions" - as opposed to the Chief Exec and Chair? 

"...essential for firms considering an ambitious growth strategy" - as opposed to all firms?

"...developing a robust risk appetite framework does not take an inordinate amount of time and effort" - might want to tell that to the rest of the invoice-generating consultancy world!

Risk Appetite Statement

"...more than just a set of benchmarks" - at what point has a RAS ever been that?

"...setting the 'tone at the top' about the relationship between risk and return" - "tone" as opposed to "rules"? 

It also contains a number of apocryphal tales and irritants, such as

• Senior management "often" fail to take risk appetite into account - probably true even in the financial services world pre-2007 (indeed it was a major feature of the Lehman's autopsy!), but one would think less so now.
• "Few" companies able to unlock benefits of a risk appetite framework - that feels a bit light, though I don't doubt some firms may struggle depending on their corporate structure and industry.
• Frequently interchanging between "Framework" and "Statement" throughout, in the same way as many ORSA-related materials do so for "Process" and "Report".

It ultimately recommends that a Risk Appetite Framework should contain the following characteristics;

1. Qualitative and Quantitative Risk Appetite Statement
2. Ensure the statement content is "useful" for all internal stakeholders (Board, Senior Management, Financial analysis teams and business unit leaders"
3. Connect the statement to the planning, review and decision making processes and forums

There are also a number of positive elements within the document, which I would certainly advocate, such as;

• Size Limit - they recommend no more than 4 pages for a Risk Appetite Statement, and one could probably get away with less
• Concepts of Ability (what one can technically afford) and Willingness (to tolerate uncertainty)...
• ...applied as appropriate to a set of qualitative and quantitative themes which are pretty much ready off the shelf (p3)
• Ensuring the metrics used for monitoring are company-specific - very easy to replicate what one has seen in previous firms, but these will inevitably not make the cut in decision making processes, thus defeating the point.

I'll be doing more on this topic in the near future, but for now this material may at least be of use to you for benchmarking purposes.

Lloyds of London on Validation - testing and reporting enhancement ideas

Lloyds of London delivered a presentation around model validation last week to its 80-odd syndicates which anyone in the world of IMAP would benefit from picking through the bones of, bearing in mind the rather unique position of the Lloyds application (i.e. in the door of the PRA, and seemingly well received!).

They had noted in that presentation linked to above that they had found some weaknesses in 5 areas in particular, so this presentation is a deep-dive examining the strengths and weaknesses of validation - one may expect the other 4 'weak' areas flagged may receive similar treatment in coming weeks.

While their 2013 programme aims only to close the gap between full compliance with Solvency II tests and standards and today's position, it's worth flagging some fundamentals;

• Only half of syndicates felt to meet tests and standards in full - a third are 'pending' positive assessment, the rest have not passed.
• 'Fails' seem to be centred around following up on test failures and documenting findings in the summary report, rather than anything broader.

Around the production of Validation Reports, they noted negative findings around;

• Uncertainty about how to progress when something 'unacceptable' is found during validation testing
• Content of validation reports being statistic-heavy (i.e. indigestible to any non-quants who need to make decisions off the back of the findings)
• A lack of sophistication in the testing of material risks in some instances.

The last one is particularly interesting, as the central team at Lloyds has devised a schematic (slide 11) to show the kind of testing they expect to see on the more material risks (RST, P&L attribution) versus less material (going as far as qualitative tests).

It is also worth highlighting for any benchmarkers out there that Lloyds appear to advocate around 5 pages of Validation Report per risk factor, leaving their overall expectation of reports to be 30-40 pages, with 5-10 pages of appendices (p16). Bearing in mind these reports will I suspect be some of the first to go through the PRA's hands, the frame of reference may help encourage you to bulk up or slim down your own versions!

A large amount of this presentation (from p19 onwards) is devoted to fairly granular examples of how a validation test may be 'failed', and what action would be performed in order to gain a 'pass', so for those in the test design/conduct game, you may find something to support your approaches in that detail, regardless of the risks shown in the example (premium and reserve).

Solvency II "Where are we now" - summaries from Milliman and PwC

Some useful "where are we now" materials have emerged over the last couple of weeks which you may find helpful, if only to validate your own interpretations of the current state of play:

PwC Ireland preparing for solvency II

Predominantly covers summaries of EIOPA's preparatory guidance, with some nice touches around;

• Differences between Irish Corporate Governance code and L3 system of governance demands (p15)
• Insisting that "an automated solution is required" for the reporting to NCAs, no doubt in the hope of drumming up some work out of such projects now that Pillar 2 work is largely done (p27)
• Comprehensive Use Test schematic (p39)
• General problems encountered meeting data requirements (p47)

In addition, PwC appear to be facilitating the set-up of a CRO Network over in Ireland, which will allow "all the different professional skills that feed into risk management" a place to swap Solvency II risk function-related war stories. First meeting at the end of the summer, can't wait to hear the outcomes.

Milliman - Solvency II Where are we now?

This very detailed slide package was released last week, and like the item above, covers all of the timeline-related activity around EIOPAs L3 work. It goes into updating readers on the latest position on;

• Economic Balance Sheet - noting similarities and differences in IFRS Phase II/Solvency II approaches to valuation, and a large amount of detail around technical provisions
• Data Management - retreads some of the FSA's findings from last year
• SCR - Covers latest standard formula position, as well as partial internal models and generic IMAP issues (again, retreading FSA letter content from last year). Particularly nice IM schematic on slide 21
• System of Governance - Basics on general requirements, function requirements and risk categories (which they have as 'risk management areas'). ORSA piece is fairly generic, but the schematic on Risk Appetite Frameworks (p35) is quite handy.
• Supervisory review - covers circumstances around capital add-ons and how they see the PRA identifying and assessing such instances.
• Supervisory disclosure - SFCR, RSR and QRT content and timetables for submission. Particularly useful to have this summarised, bearing in mind EIOPA's expectations for the interim period are for a subset of the full QRT suite previously published
• Insurance Groups and Equivalence are also covered at the end

Plenty of substance between the two (around 100 slides), so if you have an hour to kill, sers toi tout seul!

NAIC's ORSA Manual for US Insurers - a helping hand?

"Tired and Emotional" - European
Insurance industry in 2013 

After the self-inflicted Solvency II transformational pressures of 2011 and 2012 resulted in more wobbly legs than a teenage disco at midnight, the relative calm of 2013 (to date) will have come as a blessed relief for European regulators and industry alike. Not so over in the States though, as they crack on with their take on the Own Risk and Solvency Assessment, releasing their industry guidance manual a few weeks back, in preparation for a proper crack at implementation in 2015, the driver of course being IAIS ICP obeisance rather than Solvency II equivalence.

They have kindly summarised the changes made since their 2011 version of the same manual on p9, which focus on accounting basis, scope (for groups) and ensuring certain year-on-year changes are appropriately flagged. 

Generic ORSA content - what
regulators "really really want"?

Unlike in the UK where there has been a marked reluctance to offer anything in the way of meaningful assistance to smaller insurers, such as a report template or checklist of suitable content/processes, the NAIC, just like the Spice Girls before them, are happy to "tell ya what I want", regardless of the potential for genericism.

That said, a recent Towers Watson survey suggested that there is still plenty of work to be done and staff to be hired in order to get with their ORSA programme.

The NAIC clarify that the US ORSAs are expected to be conducted no less than annually, with insurers documenting the process and results. After that, a high level "ORSA Summary Report" is to be submitted to the lead/state regulator once a year, which "should contain";

1. Description of the Risk Management Framework
2. Assessment of Risk Exposure (we would read as "risk profile" from what I can see)
3. Assessment of Risk Capital and prospective solvency

The Manual states that "[it] is intended to provide guidance for completing each section of the ORSA Summary Report", which should therefore make the job a doodle!

Some interesting bits jump out, not necessarily in contrast to reported/observable differences from the EU approach, more the fact that they are specified in the manual rather than taken as given;

GENERAL

• Chief Risk Officer/executive head of ERM Framework must sign the ORSA Summary Report
• Timing of supervisory reporting may move to match up to strategic planning cycle of an insurer
• Internal documentation expectations seemingly not as exhaustive as EU "repeatable by independent knowledgeable third party", simply to allow a more in-depth look at a given are at supervisor's request

DESCRIPTION OF RISK MANAGEMENT FRAMEWORK

• Specifies in principle what an "effective ERM Framework" comprises of (p18) - includes our old friends 'risk appetite', 'risk tolerance' and 'risk limits' in this, though they are isolated and defined in a passable manner on p25!
• Asks for various descriptive texts around processes
• Specifies that weaknesses/omissions found in the report here may change the supervisor's approach to the insurer!

ASSESSMENT OF RISK EXPOSURE

• Quantitative and/or qualitative assessments of risk exposure, in normal and stressed environments, for each "material" risk. Noticeably don't list Strategic/Frictional risks in the examples of "material" risk, though do mention Reputational risk as one for which "quantitative methods may not be well established"
• "Simple stress tests or more complex stochastic analyses" may be used in assessing the stressed environment
• Potential for supervisory intervention in the levels of stress assessed (in deterministic scenarios) or  even parameters in the ESG (for firms with stochastic capability)
• On risk correlation, "History may provide some empirical evidence of relationships, but the future is not always best estimated by historical data" - not sure where that leaves everyone!

ASSESSMENT OF RISK CAPITAL AND PROSPECTIVE SOLVENCY

• Provide a non-exhaustive list of considerations that an insurer/group will need to cover when assessing the adequacy of capital over its business planning period, which touches on many of the areas prominent in the EU's work (time horizon of assessment, valuation basis, definitions of "Solvency")
• Defines that this part of the assessment should identify "...the capital needed within a holding company system to achieve its business objectives"

Is this the type of demi-prescription that the smaller EU insurers are looking for? Is it too much to ask for national regulators (Ireland a notable exception) to take a similar stab at communicating what they want to see?

Internal Model Validation - the "desire for certainty"

Some useful snippets on the links here for anyone in the model validation space, whether if be the practical applications of Monte-Carlo simulation outside of the insurance industry, actuarial perspectives on model risks themselves such as parameter uncertainty and goodness of fit testing where "the problem is more often too many candidate distributions" as opposed to restrictions in choice.

This fantastic blog post from one of Willis's finest is about as blunt a critique of actuarial modelling activity and its potential for subsequent misuse as I have read, and I would strongly recommend it on to non-expert risk practitioners who may one day find themselves in the model validation/use test firing line. A few of the pearls of wisdom offered (focused on reinsurance industry, but relevant to all) include;

• How the human "want to believe" and "desire for certainty" can lead to models making rather than guiding decisions
• Reliance of models on "large numbers of heroic assumptions"
• "Data is always limited and flawed"
• That "models take combinations of assumptions and torture them to come to conclusions"
• The revisiting of assumptions only when the answers don't fit expectations ("euphemistically called 'calibration'", hilarious!)
• That using models for setting regulatory capital, rather than just informing decision making, has led to "extremely onerous" IMAP activity i.e. the limitations noted above are so well established that the regulators cannot ignore them at a granular level.

Then there this piece from Deloitte US on model validation, or more specifically, research into the quality of existing actuarial modelling controls, is an eye-opener for anyone working in the validation space. With RMORSA and associated capital modelling firmly on the agenda Stateside, it is interesting to watch how aggressively they approach validation, bearing in mind this work was commissioned by the Society of Actuaries, whose members may ultimately be charged with applying some of these recommendations!

This research in particular assesses current state versus best practice controls over the assumptions, inputs and outputs of actuarial models, and though the sample of respondents to the survey is relatively small (representing "30 unique companies"), the absence of suitable supporting documentation around model governance so evident in the UK's IMAP process appears to be a depressingly constant theme. This report at least includes recommendations as to how the US actuarial profession may bridge some of the gaps Deloitte identify.

In the NAIC's ORSA Manual, they ask that "ORSA Summary Report should provide a general description of the insurer’s process for model validation, including factors considered and model calibration" (p7), which I guess is what one expects to see in the EU (i.e. validation being a sub-process of the ORSA, which can be summarised in the ORSA reports). That said, the breadth of validation work performed over there will surely be driven by S&P expectations communicated in ERM Level III reviews, rather than profession-sponsored consultancy recommendations!


Finally (and slightly off track), an odd piece from Towers Watson on validating ORSAs, pitched to a room full of Internal Auditors. Would be unfair to say there aren't some salient points throughout, but given that there is "no clear requirement" to validate ORSAs (there was something on the matter in the original CEIOPS ORSA pre-consultation, but it was dropped in the public consultation and the final advice), then you would think it could be covered in less than 30+ slides!

As it happens, the TW slide pack for internal model validation appears to have been raided and had the acronym 'ORSA' jemmied into the text for much of the second half of it.

Munich Re on Strategic Risk - ORSA food for thought

A thought-provoker from Munich Re for anyone in the business of Emerging Risk/'Top Down' risk review activity with this release called "Strategic Risk to Risk Strategy", which leans on the findings of the World Economic Forum's 2012 Risk Report to observe how the risks highlighted may compromise existing insurer strategies, as well as materialise into the thoughts of underwriters once sufficient data exists.

With coverage of "strategic risk" featuring in everyone's ORSA thoughts, as well as obligations around scenario analysis and reverse stress testing, there are some benchmarks in here that are worthy of consideration for practitioners. In particular;

Strategic Risk definition
Risk of making wrong business decisions, implementing decisions poorly, or being unable to adapt to changes in the operating environment


Subcategories of Strategic Risk

• Ineffective M&A
• Incorrect interpretation of external activity in a given market
• Decision making based on poor pricing/profitability assumptions
• Legal misinterpretation

Specific points

• In their opinion an insurer's risk strategy "goes beyond covering the risk capital requirement for a portfolio for the forthcoming financial year on the basis of valid models" to actually questioning and enhancing a company's business. I think most practitioners would agree that any documented risk strategy would look further forward than one-year! 
• That shortcomings around the evaluation of Strategic Risk "...are not so much of a question of the [informational] resources available", which are plentiful, nor are they especially time-pressured.
• They also include a definition of Reverse Stress Testing as scenarios which "endanger a company's business model as a whole" - interesting purely in the absence of an EU-driven definition to-date, as it tallies along with UK equivalent definitions.

An edited list of Strategic Risk scenarios is included (p3) which you may want to line up against your own activity in this field, and follow on by exploring which of these are within and outside of an insurer's sphere of influence. You might also benefit from the diagram on p6 on the main stakeholders in an insurance company which may influence your selection of strategic risk scenarios depending on your structure and business model. 

The aim of Solvency II is...

As Solvency II implementation stubbornly drags its heels like a legislative bull in the Plaza del Toros of European bureaucracy, I noticed a few mutterings about the 'aim', 'purpose' and 'objective' of the Directive and its companion texts as the main protagonists play for time.

Aim of Solvency II - could be better

This is particularly frustrating as a practitioner, where consistency and brevity of message is vital when one generally has limited time with AMSB members (most notably Non-Executives), and therefore may find the messages being offered to the press differ from those previously communicated to clients.

In addition, EIOPA's status as "super-regulator" (Omnibus II pending!) now allows for further demarcation of message between those who currently determine the adequacy of senior management/director fitness, propriety and Solvency II knowledge, and those who will be co-ordinating the revised approach from 2014.

Finally from the bottom up, the stealthy creep of Solvency II into the general public/intermediaries worlds surely makes it imperative that the overriding purpose of the Directive (as well as the expense and delays!) can be explained in unequivocal lay terms - though maybe not as haplessly as the PRA's top man the other week when he tried to price Solvency II in terms of unfinished tunnel projects...


Regulators and industry tend to be focusing on policyholder protection when justifying the Solvency II approach to supervision, though in a rather long-winded manner in the CBoI's case!

Regulators

Bernadino to Croatian press, March 2013

Purpose of Solvency II is "...a harmonized prudential framework in the EU"

Bernadino to German press, April 2013

"The purpose [of Solvency II] was to increase policyholder protection and incentivise better risk management"

The Prudential Regulatory Authority

"[Solvency II's] main objective is the adequate protection of policyholders and beneficiaries"

Central Bank of Ireland

"Solvency II is a risk based approach that aims to provide the basis for a more ‘root and branch’ review of the overall financial position of an insurance undertaking. It represents a new system of supervision that assesses the overall financial position of an insurance undertaking or group. The new supervisory system is concerned with, amongst other areas, highlighting the importance of holistic risk management and prudential standards. Solvency II also aims to reduce the possibility of both insurance undertaking failure and, in a wider sense, of disruption to the efficient operation of the insurance market"

Industry

Lloyds (whose CEO has been a touch vocal on the threat of Solvency II early implementation recently) have the objectives bullet-pointed on their site as;

• Improved consumer protection
• Modernised supervision
• Deepened EU market integration
• Increased international competitiveness of EU insurers 

Others tend to get "protection" somewhere in the mix;

"[Solvency II] should bring consistency to the way in which EU insurers manage capital and risk with the aim of enhancing protection for consumers" - Standard Life AR&A 2012 p6

"[Solvency II's] objectives are to establish a solvency system that is better aligned to the true risks of insurers, and aims to enable supervisors to protect policyholder interests as effectively as possible" - Aviva AR&A 2012 p129

"The purpose of Solvency II is to unify a single EU insurance market and to enhance policyholder protection" - IPB 360 AR&A 2012 p69

"The aim of Solvency II is to introduce EU-wide regulations that match capital requirements as closely as possible to the risks incurred." - Munich Re

Expert lobbyists

"The overriding aim of Solvency II is to bring a common, risk-based approach to capital setting, supervision and disclosure to the whole of Europe" - ABI's Tim Breedon, 2010 (original speech text unavailable from ABI site)

"The primary purpose of Solvency II is consumer protection" - FERMA executive board member 

Naturally, the consultant/vested interest world generally prefers to keep it fluffier to justify the invoices (Thomson Reuters a notable exception);

Consultancies

"Solvency II represents an opportunity to not only improve insurers' operations, but also develop significant competitive advantage in a challenging market" - KPMG's Phil Smart

"[Solvency II] is expected to provide a catalyst to transform the way insurance companies run their business" - E&Y

"[The Solvency II] project aims to create a more harmonised, risk-oriented solvency regime resulting in capital requirements that are more reflective of the risks facing insurers" - Towers Watson

Vendors/vested interests

"The aim of Solvency II is to gather all risk together in a holistic way" - FINCAD

 "[Solvency II] will ensure that insurers are protected against financial collapse, which is rife in today's unstable financial environment" - Xactium, clearly not big readers of the SIFI materials currently doing the rounds!

"The primary aim of Solvency II is the creation of an effective single market in insurance services across all 27 countries, creating the conditions for an adequate level of consumer protection." - Thomson Reuters

"[Solvency II's] aim is to ensure the financial soundness of insurance companies to not only protect policyholders’ interest, but also increase competition in the EU insurance market" - SAS 

Saddening really to see how a decade of malaise and false starts can even start to erode the fundamentals...

Elderfield at the European Insurance Forum - one for the road...

So the European Insurance Forum is in full swing over in Dublin, which from what I have seen to date in the tweetosphere (thanks DIMA and Mike!), sounds more like Alan Partridge's sales conference for Ireland plc.

That aside, Matthew Elderfield, the outgoing Head of Financial Regulation at the Central Bank of Ireland, gave a rousing speech touching on risk-based supervision and the 'prospects' for Solvency II. As a member of EIOPA's management board and head of the second largest internal model assessment body in the EU, his words are very much worth heeding.

Given that he has already addressed this forum a couple of years ago on such matters, as well as being relatively outspoken  recently on the quality of components parts of Irish risk management systems, one might expect a few home truths on his way out of the door to an equally precarious task as Head of Compliance at Lloyds Banking Group.

EIF 2013 - More to Ireland 'dan dis'?

The headline acts for me was his revelation that diversification in internal models remains a bugbear, to the extent that he supports the kind of 'floor' arrangement being given airtime at the PRA. Given he had already made his distaste at the extent of the diversification benefits being sought clear in a speech last year, it is not surprise to see it on his agenda, more that it implies that the expert judgements of those involved in the calculation process may be overridden (due to regulatory prudence?), regardless of how well they are documented or supported. 

In addition, his angle on bridging the LTG issue makes interesting reading for anyone who doesn't receive briefings on EIOPA's inner workings.

Noteworthy points (my emphasis if emboldened) therefore included;

On Solvency II

• Drawn out process has "naturally resulted in a combination of fatigue and exasperation", with the "...high costs of preparation compounding concerns"
• Regardless, "it is unacceptable that the common regulatory framework for insurance in Europe in the 21st century is not risk-based"
• "Urgently need" the framework to reflect asset risks, riskiness of different lines of business, encourage better governance and risk management, and provide better disclosure.
• "Solvency II does indeed have its imperfections", but "...the benefits of moving ahead with Solvency II outweigh the costs..."
• Notes his "long-standing concern" around over-optimism in the calibration of internal models
• "...complexity has clearly gone too far in some areas - and makes implementation very difficult for smaller companies"

On Omnibus II and EIOPA's LTGA

• Omnibus II delay "...is a course of considerable concern to regulators and industry alike", and the "...entire framework is essentially stuck on one issue" which "...will require a political compromise"
• Personally supports a more generous approach to matched premium adjustments on certain lines of business, provided they are (a) only applied to the back-book, (b) companies provide Pillar 3 disclosures both with and without those adjustments, and (c) supervisors can apply capital charges if they are not happy.
• "With European elections looming next year, it is important that this process concludes in the autumn at the latest"

EIOPA - filling gaps
since 2013

On EIOPA's Interim Guidelines

• As justification for supporting them, "Much of the Solvency II framework is already clear", and emphasises that "we will adopt a proportionate approach"
• EIOPA is "helping 'fill the gap' created by the hiatus in the political negotiation"
• "The EIOPA initiative should be strongly welcomed by regulators and industry alike"
• Hopes the system of governance and ORSA interim guidance provide "manageable and useful transitional steps towards full Solvency II adoption"
• For Pillar 3, expecting "best efforts" especially from High Impact insurers, with the use of statutory powers held in reserve "as a last resort.
• For IMAP, can neither sanction an "early conclusion" nor a "hard stop", so will ultimately elongate the administrative burden, hopefully leaving less to do towards the end.

On Diversification benefits

• "...in common with a number of other [unnamed] supervisors", CBoI is concerned to ensure "prudent recognition of diversification effects"
• "Fundamentally, what is needed is a broad agreement on the outer bounds of acceptable levels of diversification in the model approval process", citing one jurisdiction (UK?) looking at hard SCR floors based on proportion of MCR.
• "...the Central Bank's message to Irish firms is to take a conservative approach to the recognition of diversification..."
• Points to the failure to add formal constraints on diversification benefits in the Directive text
• "Supervisory quants are at risk of being outgunned by industry quants in the minutiae of a correlation debate"
• Also has a stab at "overly generous approval" in other member states in the context of regulatory arbitrage - is it that hard to say "no" just because the home regulator says "yes"?

Of less consequence for those outside of Ireland, he goes on to cover the CBoI's bespoke work around VA-specific risks (in light of prolonged low interest rate environment), the failure of Quinn Insurance, and the bedding in of their PRISM risk-based supervisory framework, the latter eliciting the comment that "we are still some way from fully embedding our new approach".

From this, one might reasonably think that, should Mr Elderfield's successor continue in the same vein, that the correlation matrices of Ireland's 30-something IMAP candidates are likely to get a severe working over in the next couple of years. Let's hope the industry gets their documentation in order!