Key Challenges Reflections from the FSA

Similar documents
Update from the FSA. Current Issues in General Insurance Conference, May 2010 James Orr and Vishal Desai

Overview of Results of ERM 1 Assessment based on ORSA 2 Reports and ERM Hearings

A (personal) view. Philip Whittingham, European Chief Enterprise Risk Officer. 22 March 2010

Solvency II Detailed guidance notes for dry run process. March 2010

The road to Solvency II: The Regulatory View

INTERNAL CAPITAL ADEQUACY ASSESSMENT PROCESS GUIDELINE. Nepal Rastra Bank Bank Supervision Department. August 2012 (updated July 2013)

IAIS: Enterprise Risk Management for Capital Adequacy & Solvency Purposes. George Brady. IAIS Deputy Secretary General

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

4. This letter sets out our key regulatory priorities for 2017 for insurance companies and covers the following areas:

Insurance Stress Testing

Statement of Guidance for Licensees seeking approval to use an Internal Capital Model ( ICM ) to calculate the Prescribed Capital Requirement ( PCR )

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

Solvency II Insights for North American Insurers. CAS Centennial Meeting Damon Paisley Bill VonSeggern November 10, 2014

The Society of Actuaries in Ireland

FSC Newsletter. Liquidity Risk Management. Number 3 Year Background

Own Risk and Solvency Assessment (ORSA)

INSURANCE CORE PRINCIPLES, STANDARDS, GUIDANCE AND ASSESSMENT METHODOLOGY

32 / RISK MANAGEMENT

Solvency II overview

Bermuda s Insurance Solvency Framework The Roadmap to Regulatory Equivalence. September

Increased Corporate Governance Requirements for Insurers

Webinar. The Gibraltar Financial Services Commission. Solvency II Implications for Non-Executive Directors (NEDs) 28 th May 2015

Regulation and risk The strategic response to insurance regulatory developments Alex Thomson, May 2013

ERM and ORSA Assuring a Necessary Level of Risk Control

SAIA SAM PSO. Issue 3 / ORSA: meeting the challenge and seeking the value

Basel II Briefing: Pillar 2 Preparations. Considerations on Pillar 2 for Subsidiary Banks

LIQUIDITY RISK MANAGEMENT: GETTING THERE

Solvency Control Levels

Guidance Note: Stress Testing Credit Unions with Assets Greater than $500 million. May Ce document est également disponible en français.

International Trends in Regulatory Capital & Target Surplus. Caroline Bennet - Trowbridge Deloitte Jennifer Lang - CBA

Lessons from the ICAS regime for UK insurers

An Introduction to Solvency II

Consultation on Domestic Actuarial Regime and Related Governance Requirements under Solvency II. Consultation Paper CP92

Guidance Note System of Governance - Insurance Transition to Governance Requirements established under the Solvency II Directive

Christina Urias SMI Task Force Chair Director, Arizona Department of Insurance

Insurance Supervisory Approach January February 2018

Does the ORSA add value? Challenges and initial achievements. Lukas Ziewer Risk Management Perspectives, 18/11/2014

Solvency Assessment and Management: Stress Testing Task Group Discussion Document 96 (v 3) General Stress Testing Guidance for Insurance Companies

Embedding Stress Testing as Part of an Integrated Risk Management Framework

GUIDELINE ON ENTERPRISE RISK MANAGEMENT

Critical Reflection of Two State-of-the-Art Risk Management Frameworks (SRM004)

Guidelines. No. 2/2010. Guidelines for Sound Liquidity Risk Management and Supervision

OIC & ORSA. Thanita Anusonadisai Director of Capital and Solvency Standard Department Office of Insurance Commission, Thailand

Approach to Insurance Regulation

Solvency Monitoring and

RESERVE BANK OF MALAWI

STRESS TESTING GUIDELINE

GUIDANCE NOTE ON LICENSED INSURERS OWN SOLVENCY ASSESSMENT

Solvency II. Insurance and Pensions Unit, European Commission

The future of life insurance, Solvency II and investment strategies

ORSA An International Development

Karel VAN HULLE. Head of Unit, Insurance and Pensions, DG Markt, European Commission

ERM Implementation and the Own Risk and Solvency Assessment (ORSA)

Aviva Life & Pensions UK Limited

ORSA An international requirement

Solvency II is a huge step forward for policyholder protection and the implementation of a true single market for insurers and reinsurers in the EU.

Prudential Standard GOI 3 Risk Management and Internal Controls for Insurers

Cover Note Authorisation and supervision of branches of thirdcountry insurance undertakings by the Central Bank of Ireland

IAA Fund Seminar in Chinese Taipei

Keeping Pace With Solvency II

A. General comments. October 27, 2012

Friends Life Limited Solvency and Financial Condition Report

Practical Uses of Local Reporting in Taiwan. Kitty Ching 金肖雲 VP, Actuarial Risk Management

GUIDANCE NOTE ASSET MANAGEMENT BY AUTHORIZED INSURERS

SOLVENCY ASSESSMENT AND MANAGEMENT (SAM) FRAMEWORK

Finalised guidance. Individual Liquidity Systems Assessment (ILSA) Simplified ILAS BIPRU Firms (ILSA) Simplified ILAS BIPRU Firms.

Own Risk Solvency Assessment (ORSA) Linking Risk Management, Capital Management and Strategic Planning

EIOPA-CP-13/ March Cover note for the Consultation on Guidelines on preparing for Solvency II

Internal Capital Target (PD-11)

January CNB opinion on Commission consultation document on Solvency II implementing measures

Professional Indemnity Forum 2009 An Actuary's Analysis of the PI Market 7 July 2009

Stress Testing Beyond DCAT

Solvency II: Implementation Challenges & Experiences Learned

BERMUDA MONETARY AUTHORITY GUIDELINES ON STRESS TESTING FOR THE BERMUDA BANKING SECTOR

GL ON COMMON PROCEDURES AND METHODOLOGIES FOR SREP EBA/CP/2014/14. 7 July Consultation Paper

BaFin Solvency II Conference The Current UK Perspective on the Insurance Industry including Solvency II Implementation

2017 Seminar for Senior Bank Supervisors from Emerging Economies. Implementation of Basel III Liquidity Requirements in Emerging Markets

Title of the presentational;;l

CAPTIVE BEST PRACTICE GUIDELINES

INSURANCE REGULATION OMNIBUS CONSULTATION A CONSULTATION PAPER ON REVISION OF THE RULES AND GUIDANCE FOR LICENSED INSURERS

Vice President and Chief Actuary CLHIA

Link between Pillar 1 and Pillar 2

NAIC OWN RISK AND SOLVENCY ASSESSMENT (ORSA) GUIDANCE MANUAL

Basel Committee on Banking Supervision. Consultative Document. Pillar 2 (Supervisory Review Process)

Country: Bermuda. Solvency Modernization Initiative Country Comparison Analysis November 2009 (Note: Portions excerpted directly from BMA materials.

Consultation Paper CP20/16 Solvency II: consolidation of Directors letters

MAS consults on Enterprise Risk Management ( ERM )

Lloyd s Minimum Standards MS6 Exposure Management

Current status of Solvency II and challenges down the line. Matthew Edwards 11 October 2011

ERM and Reserve Risk

EIOPA: recent developments in insurance and pensions. EVCA Investors' Forum Geneva, 14 March 2012

Solvency II developments in selected European countries Brian Morrissey, KPMG 2004 Life Convention 7-9 November. EICC Edinburgh Scotland

Solvency II: Orientation debate Design of a future prudential supervisory system in the EU

BERMUDA MONETARY AUTHORITY

Taylor Fry Newsletter 3 on the APRA Capital Update February Time for action on APRA changes

Subject SP2 Life Insurance Specialist Principles Syllabus

LLOYD S MINIMUM STANDARDS

lloyd s Chain of security 2009 three layers of financial back-up

Market Value Management

Solvency II Where do we stand? Consumer Protection Where do we go?

Transcription:

Momentum Conference, December 2010 Daniel Draper and Yen Ni Tan Key Challenges Reflections from the FSA 2010 The Actuarial Profession www.actuaries.org.uk

Agenda Update from GIAT Issues on the regulatory agenda Managing practical aspects of the ICAS process in the lead up to Solvency II Update on Solvency II Solvency II aims and benefits Internal models pre-application 2010 The Actuarial Profession www.actuaries.org.uk 1

Issues on the Regulatory Agenda Economic Issues General State of the Market Retail Wholesale / Commercial Reinsurance Reserving Adequacy Stress and Scenario Testing Solvency II 2

Economic Issues (1) Economic environment now more benign Central scenario is one of steady recovery Macroeconomic changes affected non-life and life insurers in different ways In the life sector capital levels came under pressure In the non-life sector reserve releases supported results, cushioning the impact of investment and underwriting losses Now we are recovering the economic crisis has left challenges for the non-life industry 3

Economic Issues (2) Financial crisis on the non-life sector was less immediate Prolonged recession and the slow and uncertain recovery have increased the prudential risks in this sector Altered characteristics of the risks insured Increased propensity to claim Reserving adequacy Exchange rate volatility 4

General State of the Market (1) Retail Underwriting performance under pressure Deterioration in loss ratios and low investment yields Customer appetite shifted towards the self-service model 2010 at a glance: Robust balance sheets Pressurised investment returns Profit margin erosion Reserve releases appear unsustainable Key risk areas: Rate increases Data validation Conduct Risk 5

General State of the Market (2) Wholesale and Commercial Extended soft market raises questions over pricing and reserving adequacy 2010 at a glance: Low interest rates and conservative investment strategies H1 one of the costliest on record General trends in the wider environment Outlook of low returns Delayed claims FX volatility Crime and insurance fraud Legal and regulatory change Key risk areas: Reserve strength / releases Underwriting management Risk management 6

General State of the Market (3) Reinsurance Abundant capacity as confidence and capital levels recover Reinsurers have managed to generate profits Contraction in demand, further augmenting current over-supply Impact of Deepwater Horizon BP oil spill to date on rates is restricted to energy risks Reduced demand, higher net retention by primary insurers and limited growth opportunities Key risk areas: Price adequacy and reserving assumptions Structural challenges Understanding of very low frequency cat exposures 7

Reserving Adequacy (1) Reserving Adequacy Project To put reserving at the centre of our consideration of firms financial positions and to keep it there Greater focus and support to supervisors complementary to ICAS Quantitative reserve statistics Qualitative oversight and controls focus on policy 8

Reserving Adequacy (2) Market Level View The Reserving Cycle 15.0% 10.0% 5.0% 0.0% 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009-5.0% -10.0% -15.0% -20.0% -25.0% UW Result Current Year Underwriting Result Prior Year Reserve Movement -30.0% 9

Reserving Adequacy (3) Focus on reserve releases over time against market against peers Resource provided to supervisors prompt for discussion basis for challenge Expect direct and pressing questions from the FSA 10

Reserving Adequacy (4) What we d like to see Firms that understand and manage their risks Consistent approaches to risk and key processes Clearly articulated policies around case estimation and claims management actuarial reserves (IBNR / IBNER) reserve margins controlled by management Transparent and verifiable decision-making 11

Stress and Scenario Testing 12

Solvency II Solvency II Maximum harmonisation Resilience Capital ICAS Risk Management ARROW Realistic balance Sheets Implementation UK Enhancements Solvency I Minimum harmonisation 2010 The Actuarial Profession www.actuaries.org.uk 13

It s not all about the calculation kernel Solvency II aims to deliver Good quality capital Market consistent balance sheets Strong requirements on forward looking risk identification and management Strong emphasis on enhanced transparency of firms financial positions and risk management approaches It s no good having a great capital model if the framework around it is weak 14

Managing practical aspects of the ICAS process in the lead up to Solvency II (1) As we move towards implementing the Solvency II regime we are changing our approach to reviewing firms scheduled ICAS FAQ s in the FSA Insurance Sector Newsletter, July 2010 Do I still need to calculate my ICA? Do I still need to notify the FSA of material changes in my business Will ARROW reviews continue? How will I know if you decide not to proceed with a scheduled ICA submission? What happens if the Solvency II implementation date is changed? If I feel my ICG no longer matches my business may I still request an ICG review? Information available at www.fsa.gov.uk 15

Managing practical aspects of the ICAS process in the lead up to Solvency II (2) ICAS was designed to anticipate Solvency II Good practice aligned to Solvency II Data quality, documentation and justification much stricter Data quality - design, capture and policy Case Reserving - focus and standards Governance Framework Reporting and management information feeds Main point is that Solvency II will soon be BAU so the BAU issues will soon be Solvency II issues - think about the implications of the current risk environment and BAU issues; many of which will be relevant under Solvency II 16

Solvency II Transfers of business Firms considering Part VII transfers as part of their Solvency II planning Practical implications for us Contact us as soon as possible Adequacy of actuarial resources in the market 17

Pre-application Process 9. A Milestone in the firms plan is reached Once all milestones have been completed Firm FSA 2.Scoping & Planning Meeting 1.Internal Preparation 3.Prepare Pre-application pack for firm 4. Organise Meeting with firm to discuss requirements This could be several meetings 5.Meet firm and discuss requirements 6.Firm completes Self assessment and submits to FSA 7.Agree Work Plan 8. Monthly (Written report) & Quarterly Progress meeting (Face to Face) 10.. ASSESSMENT Onsite Assessment by FSA Once a milestone is reached, the FSA will perform an assessment. This assessment will take the form of a desk-based review, an onsite assessment or a combination of the two. 11.Firm submits Formal Application Internal Desktop Review 2010 The Actuarial Profession www.actuaries.org.uk 18

Some of the benefits we are already seeing Pre-application proving a positive and informative experience PAQC useful at identifying better prepared firms Promoting efficient direction of limited resource Working with other supervisory authorities laying way for group supervision Providing early sight of potential areas of concern and where to focus review Allowing us to compare and contrast firms, informing view of acceptability not just for our firms but also for us as the regulator 2010 The Actuarial Profession www.actuaries.org.uk 19

Getting ready for internal model pre-application (1) Sound planning has already been completed Robust, credible Solvency II implementation plan in place Adequate budget and fully mobilised resource Clear link between project plan activity to Directive and Level 2 requirements Whole business engaged in the development of governance, risk and capital management framework. Implications of Solvency II on group structure considered 20

Getting ready for internal model pre-application (2) and implementation is well under way Engaging in dialogue with all relevant regulatory authorities; preapplication underway Developing a strong governance and risk management framework Defining its internal model scope and underway with capital model build Making progress with wider aspects ORSA, technical provisions, reporting Completing QIS5 Drafting detailed documentation vision with significant material 21

Embedding Solvency II into the organisation For us as regulator Solvency II is about embedding the Directive Ultimately, firms must embed Solvency II into their business and can demonstrate that they: - understand the risks they face; - manage risks effectively and appropriately; and - have greater senior management accountability at day 1 of the new regime and ongoing. With the aim of increasing policyholder protection, reducing the possibility of consumer loss or market disruption in insurance. 22

Questions or comments? Expressions of individual views by members of The Actuarial Profession and its staff are encouraged. The views expressed in this presentation are those of the presenter. 23