The daily impact of Solvency II – Pillar II and Pillar III/media/Files/Training/2015/Solvency II presentations.pdf · PRA in the UK have consulted on this Big Four Audit Firms Other

© Simmons & Simmons LLP 2013. Simmons & Simmons is an international legal practice carried on by Simmons & Simmons LLP and its affiliated partnerships and other entities.

The daily impact of Solvency II – Pillar II and Pillar III 15 January 2015

Pollyanna Deane Partner Simmons & Simmons LLP

© Simmons & Simmons LLP 2014. Simmons & Simmons is an international legal practice carried on by Simmons & Simmons LLP and its affiliated partnerships and other entities.

1 / L_LIVE_EMEA1:24360961v2

Solvency II – The Pillars

Pillar 1: Quantitative requirements

Pillar 2: Supervisory review

Pillar 3: Disclosure

Solvency Capital Requirement (SCR):

• European Standard Formula; or

• Internal Model Sets the Minimum Capital

Requirement Own funds Assets and liabilities –

market consistent valuation

Systems and governance used to asses risks the firm faces and capital required

Own risk and solvency assessment (ORSA)

FLAOR Supervisory review

process Supervisory intervention

including capital add-on

Public Disclosure – annual solvency and financial condition report

Information to be provided for supervisory purposes, but also as part of the market

Market discipline to be imposed on the regulated firm

L_LIVE_EMEA1:24360961v1 © Simmons & Simmons LLP 2013. Simmons & Simmons is an international legal practice carried on by Simmons & Simmons LLP and its affiliated partnerships and other entities.

Pillar II – Internal Controls

Internal controls – Systems and Governance – ORSA – FLAOR

EIOPA commentary on-going

One of the most innovative changes introduced by Solvency II is the requirement that insurance companies develop their Own Risk and Solvency Assessment (ORSA) as a tool of their overall risk management system. Insurers will need to properly assess their own short and long-term risks as well as the amount of their own funds necessary to cover them to ensure on-going compliance with capital requirements. Quoting the lyrics of a song by The Velvet Underground, “I will be your mirror, reflect what you are, in case you don’t know it”. Carlos Montalvo Rebuelta, Executive Director, EIOPA (September 2014)


Pillar II – Supervisory Review

A. External controls Article 43 of the Directive

– “Insurance and reinsurance undertakings shall have in place an effective risk management system comprising strategies, processes and reporting procedures necessary to identify, measure, monitor, manage and report, on a continuous basis the risk, on an individual and aggregated level, to which they are or could be exposed and their interdependencies

– That risk management system shall be effective and well integrated into the organisation structure and in the decision-making processes of the insurance or reinsurance undertaking with proper consideration of the persons who effectively run the undertaking or have other key functions”

Supervisory controls – Review process – Intervention by the regulator – Capital



A. External controls (continued)

EIOPA’s current position

EIOPA initiatives for the next 12 months - Consumer focus

Is there a risk that EIOPA too have lost momentum re Solvency II?

Gabriel Bernadino speeches – life insurance and pensions

EIOPA consultation on proposed guidelines for product oversight and governance arrangements by insurers – responses by 23 January 2015 together with IMD2 – appropriate selling practices and simplifying information for consumers

Vision on private pensions – enhanced sustainability, strong governance and full transparency



B. External review by independent third parties? See Solvency II Wire PRA in the UK have consulted on this Big Four Audit Firms Other providers

– See also Lloyd’s Thematic Review of agents’ Pillar III preparations – completion of gap analysis; identification of data gaps and filling them – implementation of IT solutions – review current processes and procedures

– Submit a Pillar III “status” template by 30 June 2015 – Dry run – Q3 2015 – Market workshops June 2015 and October 2015


Pillar III - Disclosure and Transparency

The Level Playing Field

Uniformity across the EU – Harmonisation

Adoption of an economic risk-based approach – Incentives to properly measure and manage risks – Specific rules for valuation of Assets and Liabilities – Effective system of governance (Recitals 15 and 29)

Regular assessments of overall solvency

Qualifications and training

Outsourcing

HR Issues and Remuneration


Solvency and Transparency – Uniformity Guarantee of transparency

– Public disclosure of essential information on solvency and financial condition (Recital 38)

Stability of Financial System – Exchanges of information

– supervision – national statistical authorities

– Statutory audits Economic valuation of the whole balance sheet

– Information provided by Financial Markets – Data on insurance technical risks – Valuation standards to be compatible with international accounting

developments Standard Formula

– Internal models – prior supervisory approval – Prudent person principle – Own funds


Practical implications of Solvency II for insurers Claims

Outsourcing Data

HR: Training and Remuneration

Investment challenges Governance

Functions

Other risks


What are the risks applicable to claims?

Insurance Risk – resulting from underwriting, catastrophe or deterioration or technical provisions

Legal Risk – resulting from political and legal changes

Operational Risk – resulting from people, processes, systems or external events

Claims risk

– Uncertainty, frequency and size of large claims – Length of the claims distribution tail – Impact on reserves – Social changes resulting in increased propensity to claim or sue

Claims handling risk

– Settlements – Systems and processes inadequate – Delays – Reputational issues


What is the impact of Solvency II on claims? Introduces a new approach to establishing technical provisions for

outstanding claims and premiums

How is the approach different? – It is driven by the need to calculate liabilities on a market-consistent basis – Thus an insurer will want to know, in respect of any claim

– best estimate of costs – discounting applied (if any) – risk margin applicable to that claim


Best estimate – Claims Outstanding Valuations

Best estimate provision for claims outstanding

Solvency II requires that valuations of the best estimate provisions for claims outstanding be carried out separately from premium. They are an assessment of the position in the settlement period

Solvency II (Article 76) – “The best estimate shall be equal to the probability-weighted average of

future cash flows, taking account of the time value of money (expected present value of future cash flows) using the relevant risk-free interest rate term structure”

Calculations – Exit value – Financial market information – Generally available data – Company’s own data


Claims Outstanding Provisions

Under Solvency II best estimate outstanding claims provision will need to cover both – Future paid losses; and – Claims handling expenses at any valuation date

EIOPA General Principles published November 2014. See Guideline 69 and Annex Valuation of a best estimate provision for claims outstanding

Written reports on the provision for claims outstanding will be required, together with background methods and approaches used to determine and give estimates

Who is best placed to evaluate these risks and when in the cycle?

Who advises the insurer on the likely costs implementation and outcomes?

Impact if Outsourcing?


Outsourcing under Solvency II

Article 48(1) – Firms must remain fully responsible for their outsourced obligations. CEIOPS (now EIOPA) recommended that firms maintain in-house the competence and ability to assess whether the service provider delivers according to contract

Article 48(2) – Additional requirements in relation to the outsourcing of “critical

or important” operational functions or activities. CEIOPS (now EIOPA) believed that these include all functions within the firm that are fundamental to carrying out its core business, for example the pricing and design of insurance products and claims handling

Obligation to understand and act as owner of the process Outsourcing

– Written policy – Impact on lawyers and claims handling – Review of all third party outsourcing


Outsourcing – Article 49 SII – Article 274 DA and EIOPA Guideline 44 Requirements for insurers looking to outsource functions/activities Written outsourcing policy – impact and reporting arrangements Choosing service provider

– Detailed examination of provider – No conflict of interests – Board involvement – Data protection – Confidentiality – Written agreement

Written agreement– requirements stated Article 274.4 DA Risk management for insurers Adequate resources (financial and otherwise) of service providers


What should you do to prepare your data for Solvency II? Aviva: Don’t expect data prepared for Pillar I purposes to be useful for the other

Pillars Calculations of technical provisions

– Article 81 – “insurance and reinsurance undertakings have internal processes and procedures in place to ensure the appropriateness, completeness and accuracy of the data used in the calculation of the technical provisions”

– Article 47 – actuarial function to assess the sufficiency and quality of the data used in the calculations of technical provisions

Consultation Paper No. 43 – Standards for Data Quality Processes will come under increasing scrutiny Costs of claims handling v. results Data produced from claims handling will have a key role in the internal model as

well as reporting across the EU to assess the reserves required for operational and insurance risk

IT systems – Article 41 and Article 258(1)(h) of the Delegated Act adopted October 2014


The increasing role of Data

“In my experience, there are huge groups of people in insurance companies with the ability to gather and analyse data, but where they tend to fall down is drawing pertinent conclusions and in the communication of those conclusions. This gap will only get magnified with the exponential growth in data. The skills needed for insurers to be successful in the future are scarce.” – Jerry Albright, Partner KPMG US.


HR issues Fit for purpose - recruitment and employment of personnel with the skills,

knowledge and expertise necessary to discharge the responsibilities allocated to them properly (Article 258.1(e) DA and Article 273 DA). Assessment of fitness in accordance with Article 294 of the Delegated Acts and Guideline 13 of the EIOPA Guidelines

Proof of good repute – Article 43 SII Directive Training and competence – collectively and individually, administrative,

management and supervisory bodies need necessary qualifications, competency, skills and professional experience – Article 258(1)(c) and (d)

Need to understand procedures – so as to discharge responsibilities effectively and multi-tasking so long as doesn’t prevent discharge of duties in a sound, honest, objective manner

Clear reporting guidelines and written remuneration policy (Article 41, Article 258 DA and Article 275 DA) – must promote sound and effective risk management and not encourage risk taking outside the firm’s risk tolerance (Article 275.1(b) DA)


Governance – Chapters IX – XI of DA

Insurers required to have: – An effective system of governance – Article 40 and Article 41

– focus on Board responsibilities – capital requirements – ORSA – disclosure

Effective risk management system required

– Focus on CRO by EIOPA


Functions under Solvency II

Actuarial

Internal Audit

Risk Management

Compliance

Articles 268 – 272 DA


Impact of Pillar II on risk management activities Governance and systems and controls Insurers will have to implement a comprehensive risk management cycle for

assuring quality and control of operational procedures such as pricing, underwriting, claims settlement and claims reserving

Reinsurers and regulators are just two of the likely drivers for better data and process management

Impact on lawyers: – Reporting – in the format required, the information that is needed – Quantifying costs and values of claim and attendant legal risks

AIM: To be part of the data process Data quality, collection and processing The seeds of the next crisis….


Operational Risk

Operational risk management framework – any risk resulting from people, processes, systems or external events

Incentives for implementing operational controls Capital to be set against operational risk is to be added to the SCR –

standard model as opposed to internal model?

Article 106 - The calculation of the capital requirement for operational risk shall take account of the volume of those operations, in terms of earned premiums and technical provisions, which are held on respect of those insurance and reinsurance obligations

Your MI goes to this SCR


Investment challenges Better interaction between underwriting and investment sides of the business –

and better information flow? Article 260 DA – Risk Management Areas: Underwriting and reserving -

Liquidity risks – Investment risks

Asset-Liability management: Solvency II should lead to closer asset-liability matching: Solvency II is expected to reward firms that closely tie their investments to the underwriting risk

Functions – Investment Management function should become central for insurers as a consequence of Solvency II: crucial in ensuring the efficient allocation of risk


Solvency II and its impact for asset managers

Data is the cornerstone of Solvency II – it must be accurate, consistent and of good quality as it forms the foundation for the risk assessment and capital requirements

A greater amount of data and granularity of data will be required from (re)insurers than under the previous regime

Asset managers are the data gatekeepers – they have a fundamental role to play in helping their insurer clients in the race to achieve their Solvency II implementation goals (although the provision of all data required under Solvency II is ultimately the (re)insurers’ responsibility)

Background


What do you need to know? Servicing your insurance clients Solvency II needs

Waiting is a dangerous game – no time to do nothing

Proactive engagement with clients re the provision of Solvency II data – working together

The goalposts have changed – is this reflected in the paperwork?


• Timeline

Solvency II in 2014 and beyond: keeping up to date

Source: EIOPA

2015 2016 2014

Transposition

ITS Set 1

ITS Set 2

Application

Solv

ency

II

regi

me 31 March 2015

1 January 2016 onwards

31 October 2014: Submitted to European Commission

April – June 2014: Public Consultation

30 June 2015: Submitted to European Commission

December 2014 -March 2015: Public Consultation Im

plem

entin

g Te

chni

cal

Stan

dard

s

Guidelines Set 1

Guidelines Set 2

June – September 2014: Public Consultation

July 2015: Publication

December 2014 -March 2015: Public Consultation

Gui

delin

es February

2015: Publication

26 / Doc ID: B_LIVE_EMEA1:24360961v1 © Simmons & Simmons LLP 2013. Simmons & Simmons is an international legal practice carried on by Simmons & Simmons LLP and its affiliated partnerships and other entities.

For further information please contact: Pollyanna Deane Partner, Simmons & Simmons LLP

[email protected] / 0207 825 4303 Pollyanna Deane heads up Simmons & Simmons LLP’s non-contentious insurance team. She has over 20 years’ experience advising insurance industry participants. Unusually, she advises on both life and general insurance. In particular, Pollyanna has extensive experience in respect of professional liability and directors’ and officers’ coverage and regularly advises insurers, intermediaries and policyholders as to coverage and compliance. She sits on the Financial Services Board of the Practical Law Company, and also writes a regular column on insurance law in practice for them. She is also the General Editor of Butterworths Financial Regulation Service.

aegon.com

Solvency II: What does it mean in practice?

Arthur van den Hurk Senior legal counsel - regulatory

Amsterdam, January 15, 2015

28 28

Topics of today

Governance requirements Solvency II; Key functions; Outsourcing; Experiences/challenges Solvency II.

29

Effective system of governance: sound and prudent management of the business;

Adequate transparent organisational structure; Clear allocation of and appropriate segregation of

responsibilities; Effective system for transmission of information; Regular internal review governance structure; Written policies: risk management, internal control, internal

audit and where relevant outsourcing; ► Annual review of policies; ► Subject to prior approval of the board;

Contingency planning.

Governance requirements Solvency II

30

Emphasis on:

► Internal controls, risk management; ► Documentation; ► Responsibility of the board; ► More detailed than current rules.

Governance requirements: general features

31

Risk management Compliance Actuarial function Internal Audit (…)

Key functions Solvency II

32

Fitness and propriety Responsible persons for ‘key functions’

► Solvency II key functions; ► Others?

Entry into force as of April 1, 2015; According to the Ministry of Finance, approximately 650

persons;

Reliance on the undertaking and internal processes.

Key Functions Dutch Amendment Act Financial Supervision 2015

33

Fitness and propriety; Persons that effectively run the undertaking or have other

key functions; Notification to the supervisory authorities (DNB).

Compliance with Amendment Act 2015 should lead to

compliance with Solvency II requirements

Key functions

34

Independence

► Article 268 (1) DA: Free from influences that may compromise the function’s ability to undertake its duties in an objective, fair and independent manner

► Communication lines, authority, resources and expertise; ► Unrestricted access to information; ► Reporting lines to the management or supervisory board.

Key functions

35

Identify, measure, monitor, manage and report risks, on an individual and aggregate basis, an their interdependencies;

Underwriting and reserving; Asset-liability management; Investments in particular derivatives and similar

commitments; Liquidity and concentration risk management; Operational risk management; Reinsurance and other risk-management techniques.

Are all of these “second line” responsibilities?

Key functions: Risk management function

36

Administrative and accounting procedures; Internal control framework; Appropriate reporting requirements.

Compliance function

► Included advising the board on compliance with laws and regulations and administrative provisions adopted pursuant to Solvency II;

► Assessment of the potential impact of any changes in the legal environment on the operations of the undertaking concerned and the identification and assessment of compliance risk.

Interaction with legal function?

Key functions: Internal control system

37

Coordinate calculation of technical provisions; Ensure appropriateness of methodologies and underlying models

used as well as the assumptions made in the calculation of technical provisions;

Assess sufficiency and quality of data used in the calculation of technical provisions;

Compare best estimates against experience; Inform the board of the reliability and adequacy of the

calculation of technical provisions; Oversee calculation of technical provisions; Express an opinion on the overall underwriting policy; Express an opinion on the adequacy of reinsurance

arrangements; Contribute to the effective implementation of the risk

management system, in particular with respect to risk modelling underlying the calculation of technical provisions.

Key functions: Actuarial function

38

Evaluation of the adequacy and effectiveness of the internal control system and other elements of the system of governance;

Independence

► No responsibility for any other function; • Except in the following circumstances (proportionality): • Nature, scale and complexity of risks; • No conflicts of interest; • Disproportionate costs.

Key functions: Internal audit

39

Includes information on the system of governance (article 294 of DA) ► Description on the system of governance and its adequacy for the risk

profile of the undertaking Structure of the board, roles and responsibilities, committees, key functions;

► Material changes; ► Remuneration policy and practices regarding the boards and

employees; ► Material related party transactions; ► Fit and proper policy; ► Risk management system; ► Internal control system; ► ORSA; ► Actuarial function; ► Internal audit function; ► Outsourcing; ► Assessment of the adequacy of the governance system.

Governance: Solvency and financial condition report

40

Until 2007 ► Principes Interne Beheersing Verzekeraars; ► Nadere Regeling Prudentieel Toezicht Effectenverkeer 2002; ► Regeling Prudentieel Toezicht beleggingsinstellingen; ► Regeling Organisatie en Beheersing Kredietinstellingen (ROB).

In practice the ROB was often used as a basis,

consequently fairly rule-based.

Outsourcing: History rules in the Netherlands

41

2007- 2015 ► Art. 3:18 Dutch Financial Supervision Act; ► Article 27 – 32 Decree on Prudential Rules Wft; ► Art. 3:299 Dutch Financial Supervision Act.

► Relatively principle-based; ► Material outsourcing; ► Day-to-day policymaking cannot be outsourced; ► Light regime for intra group outsourcing.

Outsourcing: Current rules in the Netherlands

42

Article 13(28) Solvency II ► Arrangement, in any form; ► Between an insurance undertaking and service provider

(supervised or not); ► A process, a service or an activity; ► Otherwise performed by the insurance undertaking itself.

Outsourcing: Solvency II

43

Article 38 Solvency II ► Cooperation with supervisory authorities; ► Effective access of the supervisory authorities/auditors (including

on-site); ► Cooperation between supervisory authorities/role EIOPA?

Outsourcing: Cooperation supervisory authorities

44

Full responsibility for outsourced activities; Outsourcing of insurance or reinsurance activities, critical or

important operational functions must not lead to: ► Materially impairing the quality of the system of governance; ► Unduly increasing operational risk; ► Impairing the ability of supervisory authorities to monitor

compliance; ► Undermine continuous and satisfactory service to policyholders; ► Prior notification supervisory authorities outsourcing of critical or

important functions or activities; ► Material developments.

Outsourcing: general requirements (1)

45

Written policy; Due diligence; No material impact on the system of governance; No undue increase of operational risk; Ability of the supervisory authorities to supervise; Continuity an adequacy of service to policyholders; Detailed requirements outsourcing agreement.


46

No prohibition to outsource day to day policy, but… No prohibition on outsourcing functions, such as internal

audit, but… Materiality? Intra group outsourcing; Notification requirements; Detailed prescriptions with respect to policy, due diligence,

governance, content agreement, data privacy, confidentiality, audit rights.


47

Key functions; Claims handling (what about in-kind insurers?); Product management and pricing; Ongoing support key functions and accounting; Data storage; Daily maintenance (IT) systems; ORSA; Entry into insurance contracts and claims handling on behalf

of the insurer (underwriting).

Outsourcing: Critical or important operational functions

48

Current regime: ► Light regime for outsourcing within the EU ► Policies, procedures and measures (art. 29 Bpr Wft); ► Controls (Art. 30 Bpr Wft); ► In writing (Art. 31 Bpr Wft).

Solvency II: ► “Critical or important operational functions ► Additional to regular outsourcing rules ► Take account the ability to control/influence service provider.

Outsourcing: Intra group outsourcing

49

Solvency and financial condition report ► Description of the outsourcing policy; ► Outsourcing of critical and important operational functions and

activities; ► Jurisdictions of service providers.

Outsourcing: reporting

50

Market data: centralised system for asset management worldwide

Timing (interaction between the pillars) Amount of data Stability of the rules Robustness of the systems Resources (actuaries) Decision making supervisory authorities (such as on

equivalence) Transition from Basel II to III may be more gradual than

Solvency I to II…?

Experiences/challenges Solvency II in general

Thank you

Solvency II in practice

Pillar 3 – regulation and preparedness

Véronique Hijl, 15 januari 2015

Agenda

• Regulatory framework: pillar 3

• Preparation in practice

Timelines

Transposition of Directive (in NL law)

Draft delegated acts Adoption delegated acts

Implementing Technical Standards and Guidelines EIOPA (and endorsement of ITSs by EC)

Preparatory Guidelines in force

2014 2015 2016

Solvency II

Preparatory Guidelines Reporting

Solvency II Reporting requirements (1)

55

Audience Public (Solvency and Financial Condition report)

Private (Regular Supervisory Report)

Narrative Reports

Type Qualitative & Quantitative Qualitative & Quantitative

Frequency Annual • Annual summary of changes • In full every 3 years or

yearly (if requested by DNB)

Quantitative Reporting Templates

Type Quantitative Quantitative*

Frequency Annual Annual & Quarterly

National Specific Templates

Frequency N/A Annually

Other Major developments affecting relevance of SFCR will require an updated SFCR

ORSA report Ad-hoc reporting where necessary

*Additional Financial Stability reporting is required for some undertakings and groups


Quantitative reporting templates

Narrative reports

Sections covered

• Balance Sheet • Premium claims and

expenses* • Own funds • Variation analysis* • SCR and MCR • Assets • Technical provisions • Reinsurance* • Group reporting

• Business and performance • System of governance • Risk profile • Valuation for solvency

purposes • Capital management

*Not in preparatory phase


Narrative reports (not exhaustive)

SFCR RSR - details on SFCR-topics + among others:

Business, Environment & Performance

Organizational facts; Business lines and geographic spread; Underwriting and investment performance; Income and expenses.

Trends and developments; Strategy and objectives; Perceived competition position; Significant legal/regulatory issues.

Governance

Governance structure; Fit & proper requirements; Risk management system (incl. ORSA process); Remuneration policy; Outsourcing policy.

Key functions (list). Remuneration of members AMSB; Internal audits performed; Information on service providers.

Risk Profile

Risk profile for several risk categories; Off-balance sheet risks; Risk mitigation; PPP, EPIFP, Stress testing and sensitivity

Detail of risk mitigation techniques used (reinsurance, SPV, etc.); Collateral; Anticipated exposures.

Valuation

Methods and assumptions; Material differences with statutory accounts; LTG-measures.

Assumptions on future management actions and policyholder behaviour. Alternative valuation methods

Capital management

Structure, amount and quality of own funds (by tier); Ancillary own funds, SCR/MCR;IM; USP; Breaches.

Current expectations of SCR/MCR and OF over the business planning horizon.

Preparatory Guidelines – Reporting

Subset of Solvency II reporting package • Quantitative and narrative reporting • Solo and group • For supervisor only (no disclosure requirement)

• Solvency II position replaces TSC as off 1-1-2015

Timelines SII reporting in 2015

59

Jan Feb Mrt Apr May Jun Jul Aug Sep Okt Nov Dec

SI reports1

SII reports

Solo

Groups

Q4 2014, 6 weeks

Q1 20152 6 weeks

1. Only solo-reports presented. The SI financial group report is still required in 2015. 2. Only for insurers that have been requested by DNB to submit this report.

SI annual report 31 May 2015

SII annual report 2014, 3 Juni 2015

SII Annual report 2014, 15 July 2015

Q2 2015, 25 Aug 2015

Q3 2015, 25 Nov 2015

Q3 2015, 6 Jan 2016

2015 2016

Timelines SII reporting in 2016

60

Jan Feb Mrt Apr May Jun Aug Sep Okt Nov Dec

SI report1

SII reports

Solo

Groups

SII Day 1 Reporting, i 14 weeks

SII Day 1 Reporting, 20 weeks

Q1 2016 8 weeks

2016 2017

SI annual report 2015 31 May 2016

Q2 2016 8 weeks

Q3 2016 8 weeks

Q1 2016 14 weeks

Q2 2016 14 weeks

Q3 2016 14 weeks

1. . Only solo-reports presented. The SI financial group report is still required.

What do you consider to be the biggest challenge in the implementation of SII? 1. Pillar I – Capital requirements (Standard formula, IM)

2. Pillar I – Market Consistent Valuation

3. Pillar II – ORSA (Own Risk and Solvency Assessment)

4. Pillar II – Governance

5. Pillar III – Reporting

6. Pillar III – Disclosure

7. Other

What do you consider to be the nature of the main challenges?

1. Sufficient human resources (from industry, supervisors and EIOPA alike) with respective skill set

2. Approval procedures

3. Capital management in general

4. Managing capital volatility in particular

5. Risk management

6. Data and IT systems

7. Other

Which do you think is the greatest opportunity brought by SII?

1. Risk-based capital requirements

2. Improved governance and risk management

3. Greater transparency of the business

4. Better coordination of supervision of EU-based insurance groups

5. Harmonised reporting framework within the EU

Preparedness (based on self assessment) • In general, good progress have been made

• Key functions: 75% of the insurers all four key functions implemented

• Only 10% of the insurers: policy for SFCR complete

• Most insurers assessed the effects of SII in the 1st line (business) at least

partially with regards to governance and risk management

December 2014 Bram Kierkels 64

Preparedness - progress

65

Challenges • Data availability • Human resources • Regulation and guidance not finalised yet • How to apply proportionality • Complexity • Documentation requirements • IT systems • Cultural changes

66

Policy on the SFCR

67

Not or very limited Reaonable degree Yes, complete

“The secret of change is to focus all of your energy, not on fighting the old, but on building the new”

(Socrates)

Documents

The daily impact of Solvency II – Pillar II and Pillar III/media/Files/Training/2015/Solvency II presentations.pdf · PRA in the UK have consulted on this Big Four Audit Firms Other