Solvency Assessment and Management: Steering Committee Position Paper 9 1 (v 3) The Communications strategy

Transcription

1 Solvency Assessment and Management: Steering Committee Position Paper 9 1 (v 3) The Communications strategy 1. INTRODUCTION The Financial Services Board is developing a new risk-based solvency regime for South African long-term and short-term insurers, to be known as the Solvency Assessment and Management (SAM) regime. A variety of stakeholders within the insurance industry will need to be kept abreast of the changes necessitated by the introduction of the SAM regime and how these changes will affect them. The decision was taken to include an instructive component in the development of the SAM regime to address the matter of communicating with South Africans on this subject; and the SAM Communication Task Group ( CTG ) was thus established. 2. PURPOSE This document sets out the communications strategy proposed by the CTG and the reasons for adopting a communications strategy. 3. REASONS FOR THE DEVELOPMENT OF A COMMUNICATIONS STRATEGY The mandate of the CTG as reflected in the Terms of reference is: To develop an education programme to communicate information to the category analysts/ fund managers/ industry professionals/ industry practitioners/ company directors / media / general public. To propose a strategy for delivery of such a programme. 1 Discussion Document 9 was adopted by the SAM Steering Committee 0n 26 November 2010.

2 The CTG grappled with the appropriateness of its mandate in relation to the objectives of the SAM structure and the mandate and function of the FSB. The CTG, being a structure created by the FSB through the implementation of the SAM regime, would need to ensure that its efforts are within the authority and powers of the FSB. Section 3 of the Financial Services Board Act No 97 of 1990 does not afford the FSB or, for that matter, the CTG, the powers to develop education programs. The FSB is, however, authorised to promote programmes and initiatives of financial institutions in relation to consumer education. The CTG has conducted a preliminary assessment of the needs of the identified target groups and has established that, inasmuch as a need for education may exist within the identified target groups, given the powers and functions of the FSB, the CTG is better placed to formulate a communications strategy. The proposal regarding a formulation of a communications strategy as opposed to an education programme has been tabled with senior officials of the FSB and was received favourably. The formulation of a communications strategy is however not in line with the terms of reference and consequently it is proposed that the terms of reference be amended accordingly. Given the delay that such an amendment may have on the finalisation and approval of the communications strategy, it has been decided that the request for the amendment to the terms which has been tacitly supported, run concurrently with the finalization and approval of the communications strategy. 4. THE COMMUNICATIONS STRATEGY 4.1 Introduction The CTG s communications strategy will be aligned with the following preliminary FSB and industry associations communication initiatives that have been identified. The CTG will undertake to ensure that the communications strategy is constantly monitored to keep it in line with any further initiatives by the FSB and industry associations: Information letters; The SAM Roadmap; Insurance Regulatory Workshops; 2

3 Workshops on the published draft of primary legislation; Circulars and articles by industry associations; and Presentations at forums. The CTG will ensure that communication initiatives are updated on a regular basis. It should be noted that the CTG will develop a framework for a communication programme but will not be involved in actively educating the identified target groups. It should also be noted that training in the specifics of the SAM regime and the details of what is required by the industry, is the responsibility of the industry and will not be addressed in this proposal. 4.2 Objectives of the strategy To communicate the processes, updates and outcomes of the SAM project to the identified target groups in a structured and timely manner, thereby enabling: A better understanding of the purpose and objectives of SAM, and More effective and timely compliance. 4.3 Mission of the strategy To provide a framework for the dissemination of high-level information to the identified target groups on the proposed SAM regime and its impact on the insurance sector, using various communication channels appropriate to the target audience. 4.4 Deliverables of the strategy To design and establish mechanisms, in the form of a communications strategy for the regular provision of information to target groups. 4.5 Target groups The heterogeneous nature of the audiences as listed in the mandate requires commensurately targeted information. For this reason the Task Group has agreed on creating three separate target groups, namely the Insurance Industry Group, the Media Group and the General Public Group. 3

4 i. Insurance Industry Group This group will be dealing directly with the subject matter and will require a complete understanding of SAM. The individuals who would be targeted in this segment would be: Board Members Executives and Senior Managers Actuaries and Actuarial Assistants Risk Managers and Risk Specialists Compliance Officers and Compliance Analysts Finance Departments Internal Auditors Industry Professionals ii. The Media Group This group include financial and insurance publication houses that will most likely include SAM within their publications and TV/Radio time slots. iii. The General Public Group The general public includes all policyholders, potential policyholders, prospective policyholders and beneficiaries. 4.6 International examples of Solvency II communication initiatives The CTG considered communication initiatives adopted by international regulators in relation to Solvency II as well as other forms of communication tools adopted within international insurance sectors, when designing the communication proposal. The following examples of communications strategies with respect to Solvency II were identified: i. United Kingdom The United Kingdom has utilised the following methods to communicate with industry: 4

5 Insurance Sector Newsletters published by the Financial Services Authority ( FSA ), which can be located at: o Delivering Solvency II which summarizes key policy developments and implementation activities and is published by the FSA. Issue 1 can be located at: o The FSA Forums where firms, trade associations and other stakeholders are invited to discuss key developments and issues in the policy negotiations. ii. Malaysia Malaysia has utilised the following methods of communication with the industry: Newsletters A Prudential Regulation and Supervisory Framework that summarises the key principles behind the new solvency regime, which can be located at: o iii. Ireland Ireland has utilised the following methods of communication with the industry: Newsletters and forums, which can be located at: The Irish Insurance Federation issued a Solvency II Roadmap, similar to the document issued by the FSB, which can be located at: o 5

6 4.7 Strategy deliverables The strategy deliverables encompass the Communication Task Group s proposals as well as FSB and industry associations initiatives. A work plan will be developed for each communication method adopted below, which will detail the timing, the channels used and the content of the communication. Please note that the strategy deliverables section of this document is a working document to be revised as and when required. Strategy deliverables: No Communication Methods How Target Group Who Content What Time frame When Institution Responsible 1 Solvency Assessment and Management (SAM) Roadmap SAM principles & project processes and timelines November 2010 FSB N/A 2 Media Release on the SAM Roadmap Media General Public About the Roadmap November 2010 FSB N/A 3 Newsletters Quarterly electronic FSB newsletters Latest feedback on the SAM project November 2010 and then after every SAM Steering Committee meeting FSB Industry N/A 4 Articles in publications Quarterly FSB Bulletin Frequent newsletters by Industry Media General Public Articles from the industry e.g.: Reality and impact of SAM Quarterly Ongoing and as required FSB Industry N/A 5 Websites Industry to create a SAM sub-page Media General Public All publications on SAM including booklets, newsletters, pamphlets, Ongoing Industry N/A 6

7 Strategy deliverables: No Communication Methods How Target Group Who Content What Time frame When Institution Responsible Radio/TV interviews, etc 6 Industry Annual Conferences The FSB to be invited to discuss SAM at annual conferences Media SAM As and when Industry N/A 7 Internal Model Approval Process The FSB to issue the IMAP Information on the internal model approval process Quarter 1 of 2011 FSB N/A Information Seminars: Interim measures SAM: All interim measures October November 2011 FSB R Presented by experts on the interim measures To be presented at venues in Cape Town, Pretoria and Durban A General Key aspect booklets: Interim measures SAM: All interim measures October November 2011 FSB N/A A summary of the interim measures, with its objectives and how it forms part of the 2014 measures The objectives of the interim measures 9 In an A5 format To be introduced at Information Seminars: Interim Measures Frequently Asked Questions Only available electronically on the FSB s website 7

8 Strategy deliverables: No Communication Methods How Target Group Who Content What Time frame When Institution Responsible 10 FSB workshops: Draft primary legislation Discussions and debates to be held on draft primary legislation Quarter 3 and 4 of 2011 FSB N/A 11 Articles in commercial financial publications Websites and magazines Media General Public Introduction to SAM Objectives of SAM Benefits of SAM October 2011 January 2012 March 2012 October December 2012 FSB Industry R January 2013 March TV and Radio TV: SABC 1, Summit TV and CNBC Africa Radio: 702 & Cape Talk, Radio 2000 and SA FM. Media General Public Introduction to SAM Objectives of SAM Benefits of SAM Introduction sessions to SAM to commence in 2011 More information from January 2013 June FSB Industry R Government Publication The draft of primary legislation published for public comment Quarter 1 of 2013 FSB N/A 14 Media Release on the primary legislation Includes Industry with media release to ensure consistent and factually correct communication Media General Public About the draft primary legislation Quarter 1 of 2013 FSB Industry N/A 8

9 Strategy deliverables: No Communication Methods How Target Group Who Content What Time frame When Institution Responsible 15 Information Seminars: Final Presented by experts on the final To be presented at venues in Cape Town, Pretoria and Durban Primarily legislation Secondary legislation / rules Once the primary legislation has been approved by Parliament April 2013 June 2013 FSB R Key aspect booklet: Quantitative Requirements A summary of the Quantitative In an A5 format Only available electronically on the FSB s website on the FSB s website Summary of the final quantitative The objectives of Frequently Asked Questions Once the primary legislation has been approved by Parliament April 2013 June 2013 FSB N/A 17 Key aspect booklet: Risk Management and Governance A summary of the Risk Management and Governance In an A5 format Only available electronically on the FSB s website Summary of the final risk management and governance The objectives of Frequently Asked Questions Once the primary legislation has been approved by Parliament April 2013 June 2013 FSB N/A 18 Key aspect booklet: Reporting and Disclosures A summary of the Reporting and Disclosure In an A5 format Only available electronically on the Summary of the final reporting and disclosure Information on annual and quarterly returns Once the primary legislation has been approved by Parliament April 2013 June 2013 FSB N/A 9

10 Strategy deliverables: No Communication Methods How Target Group Who Content What Time frame When Institution Responsible FSB s website The objectives of Frequently Asked Questions 19 Pamphlet Electronic Z-fold double sided information brochure To be made available on all insurers websites Media General Public Introduction to SAM Objectives of SAM Benefits of SAM Once the primary legislation has been approved by Parliament April 2013 June 2013 FSB Industry Insurers N/A 10

11 4.8 Resources i. Skills and Expertise The CTG has noted that the FSB has specific skills and resources in the form of the communications and consumer education departments, which have well-developed relationships with the media. However until such time as the communications strategy has been approved and a work plan developed for each communication method, the extent to which these resources can be utilised is not known nor the impact of possible capacity restraints. ii. The strategy deliverables contains a rough estimate of the projected costs of each communication method proposed. A request for tender without commitment can be obtained on request, which would provide a more accurate estimation of costs. It is envisaged that once the proposal, including the cost estimates contained in the budget for this strategy, is approved, funds will be provided for within the FSB s budgetary process for the 2011/2012 financial year. s for the new financial year are normally submitted in February. 4.9 Monitoring and evaluation Survey questionnaires will be developed as well as other mechanisms to evaluate the various interventions contained in the communications strategy, in order to establish whether the impact and influence of the communications as achieved, whether budget was met and the right tools were used. 11