Couple of very nice Q&As out today from the FSA (well spotted by Gideon on the
Solvency II Wire) which cover last week's releases from EIOPA on ORSA and Supervisory Reporting.
The ORSA Q&A gives a detailed interpretation of what the regulator thinks the processes and reporting entail. Stand-outs for me were;
- Process of recalibrating one's internal model from economic to regulatory capital purposes must be included (difficult if your EC measure is not a straightforward read off a later point on the PDF?)
- National supervisor "cannot act" if actual capital is below EC, and it "cannot be used as an intervention point" - not really sure why they need the information then!
- Sadly don't elaborate on the potential for the ORSA Report to form the basis of the supervisory report - would have been ideal comment
- IMAP does not require ORSA output - I had heard this on the grapevine, but nice to have confirmation
- Confirms the expectation that the ORSA Process must include a process for recalibrating one's internal model to the standard formula SCR
Also has a handy "what you should do now" list - would hate to think anyone has not ostensibly done any of these things by now, but reassure yourselves by having a look! Q&As on the last page may be handy to show your project managers/execs/NEDS, but they are a little light.
The piece on Pillar 3 reporting is more concise, and probably worth running by your execs - however, it is a little 'scattergun' without much opinion, and you may find the summaries from the big consultancies of more use
Finally,
The FSA's documents on the legal transposition of Solvency II into their Handbook is probably of little use to anyone outside of the UK (fascinating though it is!), so grab what you can if you're based elsewhere!
