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!

Insurance Banana Skins in 2015 - PwC and CSFI

PwC and the CSFI guys have teamed up for another Insurance Banana Skins publication, a particularly useful doc for the BAU Risk world, and one which I have covered on the blog in years gone by (well, 2011's and 2013's anyway).

In particular, I always found it useful as a means of digging out the kinds of awkward cross-bred expressions which would invariably end up rolling out of 75-year-old INEDs’ mouths at the next Risk Committee meeting, probably due to someone trying to sell insurance cover for it, or a business journal doing a centre spread about it. On this basis, I was delighted to see “Cyber Risk” given prominence this time around, which is the highest new entry, and apparently a “new risk” - here’s the sales forum, and here’s the HBR white paper!

Sarcasm aside, given this pulled in over 800 responses from around the globe, and across the distribution and provision side of the industry, the content is worth poring over and briefing colleagues on if this is your day job. There are also plenty of quotes from the great and good wrapped up inside as well.

I’ve only jumped on a few of the findings below;

• Regulation remains the top risk for the 3^rd survey running, and for the 4^th out of the 5 actually held. It did take a ‘world’s end’ scenario for investment returns to knock it off the top in 2009 though, which suggests that those surveyed are happy to bleat about regulatory concerns, regardless of the rest of the exogenous threats to insurance firms.

• Much of the top ten is focused on investments and returns, whether it be interest rates, investment performance or guarantees.

• Governance and management of insurance companies seen as an area of declining risk – does it therefore warrant the Banking industry-inspired whip that SIMR is about to introduce in the UK?

• Similarly, Business Practices, incorporating misselling, is falling down the list – not sure a UK-only survey would be so generous!

• Cyber Risk itself was only #6 on the list for Life Companies, while #1 for Non-Life – wonder why the guys who are selling cover rate it so highly? Of more interest, North America had it as #1 “by some margin” – this suggests the wave will be coming across the Atlantic in the next 12 months (a nice precursor of how that will emerge here)! It is written up nicely however, with cloud storage, and the richness of data held on customers, being elements which make insurers prime targets. It doesn’t dwell on the proliferation of legacy systems in insurers however, which always felt to me a good reason for criminals to ‘have a crack’.

• Europe considered the interest rate environment, regulation and guarantees to be the top 3 banana skins, which given the aggressive tailoring applied to Solvency II in the drafting stages to negate country-specific difficulties in these areas (MA/VA/Transitionals), is no surprise.

Oh, to have a day job again…

Clear Path Analysis - Solvency II "The Global Dimension"

This piece of research from the guys at Clear Path Analysis (sign up required) has been in the offing for a while, and as I covered their last impressive release on this blog (and I don't have a life :-( ), I've been looking forward to it...

There is certainly plenty in here to keep those of every persuasion entertained (with the sponsors as omnipresent as their funding permits!), but I've sectioned out highlights for my own benefit;

Foreword

• Solvency II "...clearly a step in the right direction" - oddly, not followed by a punchline...
• On the likelihood of Sol II remaining ahead of the IAIS approach to solvency regulation - "Asia no longer looks to the west for regulatory best practice", going on to cheekily recommend a cherry-picking approach

Barbara Ridpath - think tank CEO, on short-termism and regulation

• Highlights one (widely acknowledged) consequence of Solvency II being a disincentive to invest in long term and/or non-Sovereign debt instruments, which is not in the mandate of the regulations, or indeed the regulators.

Roundtable on un-level playing fields between EU and non-EU insurers - includes Standard Life Sol II lead

• Solvency II likely to weed out companies who can't handle the ongoing compliance cost from running EU operations
• Large piece on Canadian equivalence (of particular importance to Standard Life of course) and the practicalities of equivalence being neither sought nor at this point offered for a non-EEA wing of a EEA HQd insurer.
• Standard Life not happy with equivalence assessments running concurrently with IMAP, due (rightly) to the significance of a "yay" or a "nay" to the strategic thinking around non-EEA arms.
• Suggestion that Asia is looking harder at the IAIS approach as opposed to Solvency II for future direction

Data and Risk Reporting Interview - Dan Wilkinson, ERM head at Liberty Syndicates

• Increased formality around Data and Risk reporting, using both controls-focused and risk-focused approaches. Makes reference to a monthly management committee which takes reporting on data deficiency matters, which I have heard reference to on the circuit before, and certainly demonstrates that data inputs, whether for internal modelling or for strategic decision making, feature as a high priority, rather than taken as read.
• Notes that his employer is moving risk reporting away from the 1-in-200 VaR to "...more foreseeable points in the distribution", which we definitely like to hear in the ORSA world!
• Alludes to concerns around disclosing ORSA-related information to the outside world, which is an area yet to be adequately chewed over by regulators and industry quite yet, let alone ratings agencies, analysts etc
• "Sensible amount of proportionality" should be adopted when deciding what should be disclosed - is that a contradiction in terms, an oxymoron, or some other expression I can't quite lift off of Google!
• Sensibly stresses that an effective emerging risk policy should allow input and challenge at all levels of an organisation, when asked about internal models evolving with the risk profile of the business.
• "...biggest deliverable is cultural" - i.e. stripping back your long-since-gone consultancy friends' technical documentation (where required) in order to make it more accessible and free BAU staff to use the new facilities, be it a spruced up RMF or a full Internal Model - appreciate I may be doing myself a disservice by highlighting it!
• Didn't agree one bit with the comment that ORSA could "...inflate regulatory capital, based on rather speculative assumptions" - FSA have been pretty clear that ORSA has no bearing on required capital, appreciating the nuances around what they say and what actually transpires!
• Also wasn't massively sold on the comment that the ORSA "...should bring together information that is used within the business to allow analysis of medium term trends", unless of course he was cut off mid-sentence!

"Challenges of Pillar III" roundtable, focused seemingly on getting asset managers to pull their fingers out! Includes a CRO from an Italian insurer

• "Asset managers who are not willing or able to invest in appropriate data management and reporting systems will find it hard, if not impossible, to attract or retain insurance clients" - so there!
• Suggestion that "parts of the industry will have to get up to speed on" underlying assets which they are currently invested in for the look-through basis - I suspect that there are plenty of horror-stories to emerge once some CIOs and CFOs get a proper butchers at what some of their collectives are actually invested in, particularly with the advent of outsourcing investment management or just administration over the last decade or so...
• Note that ratings agency priorities over the near-term may focus more on differences between SF and IM-calculated SCRs and the impact of transitionals, rather than purely on SCR outcomes.
• Note that "Solvency II is effectively a lead in this area [transparency]", so no pre-conditions should be expected from ratings agencies
• Even bring up the old gripe that EEV/MCEV is still not understood well enough by agencies/analysts, so by implication there should be few worries about additional disclosures!

Considerations for Building a Diversified Investment Portfolio - Charles Pears from Insight Investment

Really accessible and well structured two-pager on portfolio diversification, of particular use to non-experts which covers

• Rationale for insurance companies looking for low risk returns;
• Risk drivers which make that difficult in today's environment, even if accepting minimal risk
• Why companies may look to seek excess returns, and the constraints around that
• Why decisions to accept more risk for enhanced rewards should be (but perhaps aren't always) knowledge based
• Basic options for enhancing portfolio returns without breaking the bank from a capital perspective.

Interesting is wrapped up with a comment that "...we expect insurers who adopt a Liability Driven Investment approach will secure a meaningful competitive advantage" - hard sell perhaps, but the rationale for it is well documented here.

Solvency II and asset allocation - mixed messages

There seems to have been a suite of materials on Solvency II and predicted asset allocation impacts recently, from the great and good (Gideon on the Solvency II Wire has kept on top of these, and I took a look at the Oliver Wyman/IIF document last week - much of the materials pointed towards a drive towards short term EU government debt (capital-free, and no duration penalties) ahead of where an insurer may traditionally have invested for policyholder benefit, corporate (and specifically bank) debt.

There were some left-of-centre views that I spotted, one from a representative of Markit opining that, in the current climate, government debt was now being viewed as riskier than Western European corporate debt. Another covered the potential for Insurance Linked Securities demand to increase under Solvency II, thus necessitating more issuance to be EU-based (as opposed to traditional homes Bermuda or Cayman). The third came from Union Banque Privee, with research cited in the FT that, with appropriate asset selection (cheeky derivatives used as examples), asset arbitrage will allow insurers to obtain exposure and performance without necessarily holding onerous amounts of capital as prescribed under Solvency II.

The first then indicates that the weightings may need a genuine re-examination with the Eurozone debt issues as the backdrop, while the other two suggest there are investment options to counter the new requirements. Is the IIF research therefore much ado about nothing, or perhaps is the mighty banking lobby having one last "flex of the guns" before its emasculation over the next few years?