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Solvency II
    Update

Dublin – 6 July 2010
Solvency II update – Agenda




 Current position and the key milestones over the next couple of years?

 Quantitive Impact Studies (QISs) past and present

 Internal Models and Model Validation

 Documentation

 Captives

 The Actuarial Function

 Own Risk and Solvency Analysis (ORSA)

                                     2
Solvency II Update – Current
 Position & Key Milestones




             3
Solvency II update - Scope and Structure of Solvency 2

►   Unified prudential regulation of
    insurers and reinsurers
►   Beyond quantitative measures
►   Overall risk management
►   Overhaul of European supervisory
    structure
►   Transparency and market discipline
►   Increase policyholder protection
    and minimise regulatory burden
►   Non-zero failure regime
►   Three pillar structure, based on
    Basel II and CRD
►   Link to IASB work on insurance
    contracts?
►   Employs Lamfalussy arrangements
Solvency II update – Three Pillars


                                     Solvency II
                        Three Pillars of Corporate Governance
            Pillar 1                      Pillar 2              Pillar 3
        Adequate Financial                                   Reporting
                                     Systems Governance
           Resources                                        Requirements
          Quantitative                  Qualitative
                                                              Disclosure
         Requirements                  Requirements

           Balance Sheet             Corporate Governance     Disclosure
            Evaluation                                       Requirements
                                       Risk Management
             Reserves                                       Transparency on
                                       Documentation,         Risk Appetite
         Minimum Capital             Systems and Controls    & Risk Strategy
        Requirements (MCR)
                                        Stress Testing
         Solvency Capital
        Requirements (SCR)                  ORSA

                                      Supervisory Review
                                           Process
Solvency II update - Timeline



                                                                                                                                 Solvency II
                                                                                                  Level 2
           Draft Framework                        Framework                                       implementation                 in force –
           Directive published –                  Directive approved                              approved –                     Oct 2012
           Jul 2007                               –                  CEIOPS                       H2 2011
                               CEIOPS reports     Apr/May2009        provides final
                               on Groups and
                                                                     advice on
                               Proportionality
                                                                     implementation
                                                                                                                Level of
                               – May 2008
                                                                     – Jan 2010                                  effort
                    QIS 3 report –      QIS 4 report –                                                                  CEIOPS
                    Nov 2007            Nov 2008                                                                        finalises
                                                                                                                        Level 3
                                                                                                                        guidance –
                                                                                                                        H2 2011
MILESTONES



    2007                   2008                  2009                    2010                 2011                 2012

TIMELINES
                               QIS 4 –                                              QIS 5
                                                 Sol II project
                               Apr to Jul                                           Aug to
                                                 lead – Mar
                               2008                                                 Nov
                                                 2009
                                                                  Firms to notify   2010 Dry runs of   Submission to              Model
                                                                  of intention to         models for   for approval –            approval
                                                                  seek internal           approval –   Oct 2011                  effective
                                                                  model approval          Jun to Nov
                                                                  – Jun 2009              2010
Solvency II Update –
Quantitative Impact Studies




            7
Solvency II update - Quantitative Impact Studies




       QIS 1                         QIS 2                        CP 20                        QIS 3                      QIS 4                 Draft QIS 5



     Focused on               First calibration formula   Analysis and comments on     Second calibration formula   Simplification of the   Fourth calibration
  technical reserves           and approach for the        QIS 2 and preparation for                                approach, option to     formula
                                  SCR calculation                   QIS 3                                            use entity-specific
                                                                                                                        parameters
                                                                                                                      Third calibration
 3 levels of prudence to       SCR per risk and total                                                                     formula
be calculated : 60th, 75th,   SCR obtained by taking                                        Focus on group
     90th percentiles             into account risk                                         reporting issues
                                   correlation and
                               diversification effects

    Autumn 2005                    Summer 2006                  Winter 2006                   Spring 2007              Spring 2008          15th April 2010




         Next step: Final technical specifications for QIS 5 was due to be published on
         1 July 2010 with study being run between August and November 2010




                                                                                  8
Solvency II update - Quantitative Impact Studies


QIS are a good opportunity for entities to kick off their Solvency 2 project:

 ►   At an organisational level
       • Launch of a «Solvency 2» project, setting up of a solvency committee
       • Implementation of a global and consistent approach.
       • Early identification of areas where internal processes, procedures and infrastructure need
         improvement


 ►   At a technical level
       •   Quantification of levels of prudence in reserves
       •   Risk study and mapping
       •   Improved risk measurement tools
       •   Optimisation of capital, asset allocation


 ►   At a financial level
       • Further perspective on risk management tools: reinsurance, ALM, derivatives,…
       • Sources of capital: securitisation, super-subordinated securities




                                                     9
Solvency II update - Overview of the Economic Balance Sheet


              ASSETS           LIABILITIES
                                                   Excess
Available                                                      Solvency
                                                   capital
  for                                                          Capital
                Market
SCR/MCR                                            MCR         Requirement
                value
                                                               (SCR)
                of total                           MVM
                assets                                         Market-
                (MVA)                                          consistent
                                                   Expected
                                                               value of
                                                   future cash
                                                               liabilities
                                                   flows       (MVL)


                                                     Valuation of MVL
Solvency II update - Solvency II Balance Sheet

                      Solvency I        Solvency II
Unrealised gains, …
                                                                  Surplus


                        Surplus                                                       The SCR should deliver a level of capital that enables an insurer to
                                       SCR – MCR                                      absorb significant unforeseen losses and gives reasonable
                                                                                      assurance to policyholders that payments will be made as they fall
                        Margin                                                        due.

                                                                                      The MCR reflects an absolute minimum level of required capital
                        Level of                                      MCR             below which supervisory action will automatically be triggered.
                       prudence


                                                                          Risk
    Eligible                                                             margin
                                        Market-consistent valuation
                                                                                      The « Best Estimate » equals the expected present value of future
    assets                                                                            cash flows, using the relevant risk free yield curve, based upon
                                                                                      current and credible information and realistic assumptions.

                       Technical                                          Best
                                                                       Estimate of    The risk margin covers the risk of variability in future cash flows
                       Reserves                                                       relating to insurance liabilities.
                                                                        technical
                                                                        reserves
                                                                                      It is equivalent to the cost of providing an amount of capital equal to
                                                                                      the SCR necessary to support the insurance liabilities over the life
                                                                                      time thereof.


                                                                         Non-
                                   Hedgeable
                                                                       hedgeable


                                                                                     11
Solvency II update – Two Capital Requirement Levels


     Two capital requirement levels

                                    Add-On                              Surplus                                   Level of margin expected
                                                                                                                  by the supervisor
             Adjusted                                     SCR
              SCR                                   Standard formula
                                                                                                                  Graduated and
                                                                                                                  normalised regulatory
                                                                                            Constituted           intervention
                                   SCR                                                        margin
                                                                  SCR
                                                             Internal Model

          MCR                                                                                                     Authorisation
                                                                                                                  withdrawn



MCR : Minimum Capital Requirement            SCR : Solvency Capital Requirement                Adjusted SCR
   More    complex       formula   than        Standard        formula        (European          Add-on: the supervisory authorities
   Solvency 1                                  coefficients), or                                 can, following review of the insurer’s
   Between two percentages of the              Internal models, or                               own risk assessment, require the firm
   SCR                                         Partial   models    plus     elements   of        to hold additional capital
   Ultimate regulatory sanction to be          standard formula                                  Some actions can be taken to reduce
   applied if breached                         Graduated regulatory measures                     the level of Add-Ons

                                                                   12
Solvency II update – QIS4 Framework




                                      13
Solvency II update – Draft QIS 5 Framework
Solvency II update - SCR General formula


SCR = Overall Standard Capital
Requirement = BSCR + SCRop



                        BSCR =           ∑   ij
                                                  Corr i,j ×SCR i ×SCR j + SCRintangibles
                    CorrSCR=      SCR mkt         SCR def   SCR life   SCR health   SCR nl
                      SCR mkt        1            0.25      0.25         0.25       0.25
                      SCR def      0.25             1       0.25         0.25        0.5
                      SCR life     0.25            0.25       1          0.25        0
                     SCR health    0.25            0.25      0.25          1          0
                      SCR nl       0.25             0.5          0         0          1




     SCRop = Capital charge for operational risk

     SCRintangibles = Capital charge for intangible assets = factorIA * fair_value_intangible assets,

     where factorIA = 80%


                                                            15
Solvency II update – Causes of Insolvencies


  An AM Best survey has summarised the main causes of insolvencies in the United States
  between 1969 and 1998:
                                                        Nuber o f
              Main causes of insolvency                 Compnies    in %
                                                        impacted


      Insufficient reserves / Inadequate pricing            143     22.4%
                                                                            Underwriting risks
                   Too rapid growth                          86     13.5%
                                                                                 41.5%
                  Catastrophic losses                        36      5.6%


                   Overstated assets                         40     6.3%        Asset risks
             Failure of reinsurance cover                    22     3.4%           9.7%


        Subsidiaries and other related entities              26      4.1%
         Significant change in core busisness                28      4.4%
                    Alleged Fraud                            44      6.9%
                    Miscellaneous                            44      6.9%
                  Unidentified causes                       169     26.5%


                        Total                               638     100%
    Illustration : Example of risks leading to insolvency


Source : AM Best


                                                        16
W
 or
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         r   's
                  co                                     Millions €
                       m
                        pe
                          ns




                                         0
                                             1
                                                 2
                                                     3
                                                           4
                                                                      5
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           as                 ri
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          te            rE
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                          te
                 E q ri s k
                                                                                  Solvency II update – SCR Components Example




                        ui
                           t
               Sp y ris
                     re              k
                        ad
               C               ris
      D           lu                k
        E* ste
              S C r ri
                                  s
        D Rm k
           E*                ar
                ba              ke
        O            si              t
           pe            c
                             SC
                ra                 R
                    t in
                         g
                             SC
                                    R
                             SC
                                    R
Calculation of the SCR – Concentration Risk


The definition of market risk concentrations is restricted to the risk regarding the accumulation of
exposures with the same counterparty. It does not include other types of concentrations (e.g.
geographical area, industry sector etc.)

To determine the loading needed to cover the concentration risk, calculate the surplus exposure
of each security risk (e.g. shares, bonds).

                                                                                    Ratingi           CT
                            Ei                                                    AA-AAA           3.00%
                XSi = max0;        − CT 
                          Assetsxl                                                  A              3.00%
                                                                                     BBB             1.50%
                                                                                 BB or lower         1.50%


                                                                                    Credit Quality
                                                                       Ratingi                         gi
                                                                                        Step
                   Conci = Assetsxl • XSi • gi
                                                                        AAA
                                                                                          1           0.12
                                                                         AA
                                                                         A                2           0.21
                                                                        BBB               3           0.27
                                                                     BB or lower,
                                                                                       4 – 6, -       0.73
       Mktconc =        ∑    (Conci2   +   ∑0.25 * Conc * Conc )
                                           j
                                                       i      j
                                                                      unrated

                         i
                                                  18
Solvency II update - Elements of the Solvency Margin


 The principles of eligibility and of                                    Nature
 classification of capital – “own funds” are                                        Basic capital    Ancillary capital
                                                                   Quality
 defined in the Directive.
                                                                         High          Tier 1              Tier 2

 Each element has a different capacity to                              Medium          Tier 2              Tier 3
 absorb losses.
                                                                         Low           Tier 3                 -
 These elements of capital are classified in
 three levels or « tiers » based on some
 qualitative  considerations    (nature   of
 elements and capacity to absorb losses).


           Tier 3                       Tier 2                           Tier 1



                                                                                                    Quality of capital


   Other contractual         Unpaid called up capital            Capital
    arrangements             40% Supplementary premiums          Reserves
60% Supplementary premiums   Perpetual subordinated notes        Unrealised gains
                             Letters of credit

                                                            19
Solvency II update – Elements of the Solvency Margin


  The following elements constitute basic capital:
    ►   The surplus of assets over liabilities, as evaluated in conformity with the Directive (at “market value“);
    ►   Subordinated liabilities;
    ►   Reduced by the amount of any investment in own shares.

  Ancillary capital is composed of other elements that can be used to cover losses. This includes the following
  elements, as far as they are not part of basic capital:
    ►   Unpaid called up capital;
    ►   Letters of credit or guarantees;
    ►   Any other legally binding commitments e.g. calls for supplementary contributions (mutual or mutual-type
        associations)

When an item of ancillary capital is paid up, it stops being ancillary capital and becomes part of basic capital.

The amount of the ancillary capital to be taken into consideration is subject to prior supervisory approval.

  Authorities will base their approval on an assessment of the following:
    ►   The status of the relevant counterparty, with regard to its ability and willingness to pay;
    ►   The recoverability of the funds, taking into account the legal form of the item in question and any
        conditions which might prevent the funds being successfully paid up;
    ►   Any relevant information on the outcome of similar calls for ancillary capital in the past.
Solvency II update - Elements of the Solvency Margin


 The use of some tiers of capital is restricted for solvency purposes:


                     At most 1/3
                        Tier 3
                                                       Remaining share
                                                         only Tier 2
                   Remaining share
         SCR
                       Tier 2                  MCR
                                                         At least 50%
                     At least 1/3
                                                             Tier 1
                        Tier 1




 No tier 3 items can be used to cover the MCR
 Hybrid instruments may be tier 1 capital but they should not account for more
 than 20% of tier 1 capital




                                        21
Solvency II update - Example


 French non-life company



                    SolvencyI I
                     Solvabilité                                             Solvency -II – 4
                                                                              Solvabilité II QIS QIS 4
 18 000
                                      16 165             1 6 00 0                                        1 4 95 5
 16 000
                                                         1 4 00 0
 14 000
                                                         1 2 00 0
 12 000
                                                         1 0 00 0
 10 000                                                                               8 41 4
                                                          8 00 0
  8 000
                                                          6 00 0
  6 000
                4 361
  4 000                                                   4 00 0
                                                                    2 32 3
  2 000                                                   2 00 0

    -                                                        -
          Exigence minimale de      Fonds propres                    MC R             SC R         Fon ds p elements
                                                                                                   Eligible ropres
          S1 minimum requirement      Own funds
          marge de solvabilité

                                                                                               x 178%
                           x 370%

                                                                                    x 645%



                                                    22
Solvency II Update – Internal
    Models and MIMAP




             23
Solvency II update – Internal Models


                                                                                     Asset / Liability
       ORSA
                                                                                      Management
                                         Assumptions
      Reward
                                                                                       Investment
      Strategy             Data Systems (Internal and External)                         Decisions

                                       Economic
     Business                                       Reserving           Risk
                          Cat Model    Scenario
     Strategy                                        Models            Register
                                       Generator


                                                                                     Management of
                                                                                       Business
                                 Calculation Kernel
                                                                                        Product
                                                                                      Development
   Risk Mitigation                                  Economic
                            Risk      Management                      Regulatory
                                                     Capital
                         Management   Information                      Capital
                                                    Allocation
                                                                                      Underwriting
                                                                                       & Pricing
Exposure Management


                      Outward Reinsurance                        Financial Plans /      Business
                           Purchase                                 Statements          Planning


                                               24
Internal Models – Validation


    Market         Credit                            P&C    Operational
     Risk                         Life Risk
                    Risk                             Risk      Risk




                                     Use Test

                          Statistical Quality Standards


                               Calibration Standards

                                 P & L Attribution

                               Validation Standards

                            Documentation Standards
                                        25
Model Validation – Specific Tests


 Gaining approval to use internal model to calculate SCR not a trivial process
   ►   undertakings should develop models that inform significant risk management and business decisions


 Six Tests:
   ►   Use test
   ►   Statistical quality
   ►   Calibration
   ►   P&L attribution
   ►   Validation
   ►   Documentation



 Validation of all quantitative and qualitative processes of internal model

 Validation is a set of tools and processes

       Must document how validation will take place and why it is an appropriate
       approach

                                                   26
Mazars Independent Model Approval Process - MIMAP


      A bespoke approach that complements the ‘Dry Run’ process

                 MIMAP
                                         Benefits of our process:

                                         • A proven process
                             Q           • Uses skills and experience of the
                             I             Technical Governance Panel (TGP)
                                         • Meets clients’ specific requirements
                             S           • Supported by technical models
                             5           • Based on practical experience




                                    27
MIMAP - Planning




                   • Kick Off workshops
                   • Current status
                   • Detailed scoping
                   • Training
                   • Integration of TGP
                   • Stage 1 results and feedback




                          28
                                                    28
MIMAP – Technical Validation




                               • Calibration
                               • Validation tools
                               • Stress / reverse stress testing
                               • P&L attribution
                               • Back testing
                               • Standard SCR comparison
                               • Stage 2 results and feedback




                                    29
                                                                   29
MIMAP – Governance & Use




                           • Risk coverage
                           • Model governance
                           • Statistical quality
                           • Data policy
                           • Use test
                           • Model change




                               30
                                                   30
MIMAP – Validation Policy




                            • Define purpose & scope
                            • Monitoring & performance
                            • Testing & tools
                            • Documentation
                            • Future developments




                                 31
                                                         31
Model Validation – Process & Controls



                               Validation
                                Scope


                               Materiality



                               Validation
                                 Tools



                               Frequency           Model Change Policy


                              Roles and
                            Responsibilities          Independent
                                                       Validation

                          Escalation / Reporting

                                        32
Model Validation - Validation Policy


 Purpose and Scope – Extent to which firms gain comfort and how achieve it.

 Tools and Processes – What will firms use to achieve purpose and scope

 Frequency of Validation – Apply proportionality to determine frequency and event limit triggers
 to check validity

 Governance of Results – Risk management function responsible for validation policy, but can
 delegate. Clarify ownership of validation tasks. Clarify involvement of senior management in
 validation policy. Clarify escalation criteria.

 Limitations and Future Developments – Firms must set out any known limitations and any
 parts of model not covered. An iterative process of validation policy development. Specify planned
 developments of policy.

 Documentation - Process must be documented in an understandable way for knowledgeable
 third parties

 Independent Review – Essential to effective validation as it creates challenge. Must clarify the
 independent review process. Explain strategy to maintain independence over time.


                                               33
Solvency II Update –
  Documentation




         34
Documentation – What to Achieve?


Documentation of the internal model should incorporate the following:


      The interaction of disciplines across the organisation

      Experience and understanding of the needs across all levels of a company

      Effective project planning integrated within the business

      The potential limitations of models in practical business situations
      An understanding of the relevant data, assumptions and parameters as applied to
      each individual recipient
      Appropriate level of granularity
      Appropriate knowledge in the application of the use of judgement

      Knowledge of the strengths and weaknesses of the modelling methods

      Processes, controls and governance of internal models.



                                          35
Documentation – Demonstrate compliance with ‘The Tests’



 Article 125 - “Insurance and reinsurance undertakings shall document the design and
                        operational details of their internal model.”

 Level 2 Advice - “Sufficiently detailed and sufficiently complete to satisfy the criterion
 that an independent knowledgeable third party could form a sound judgment as to the
 reliability of the internal model and the compliance with Articles 120 to 126”:



     Use test
     Statistical quality
     Calibration
     P&L attribution
                                                     Documentation
     Validation
     External Models




                                           36
Mazars Independent Documentation Process – MiDoc


Our approach is based on application of our proven model documentation tool,
MiDoc, which has been implemented in documentation projects for a number of
clients.

There are three key stages namely:




                                     37
Solvency II Update – Captives




             38
Solvency II update – Captives


Some of the characteristics of captives do not fit easily into Solvency II.

   ►   Specialist underwriters limiting risks to those of the owners
   ►   The law of large numbers may not apply where the number of risks is limited
   ►   Policy wording often bespoke to the owner
   ►   Investment strategy can be limited to a small number of assets
   ►   Many operational processes are outsourced
   ►   Captives do not always follow the insurance market cycle
   ►   Lack of resource

 The SCR calculation was designed to represent a 1 in 200 likelihood of insolvency
 over a one-year period for ‘average’ companies in the insurance industry. Not
 designed for niche or specialist insurers with alternative structures. SCR unlikely to
 reflect the nature of the captive risk profile.

 A failed captive should not leave behind exposed policyholders.

 In response CEIOPS has produced some simplifications for captives.


                                           39
Solvency II update – Challenges facing Captives


 Some of the challenges facing captives
   ►   Gearing Solvency II to reflect the nature, scale and complexity of the captive
   ►   Resource costs; lack of resource cannot be used as a reason for not meeting
       regulatory standards
   ►   Impact on investment strategy
   ►   Formulation of an optimum strategy under Solvency II legislation, in particular
       following the QIS5 exercise
   ►   Internal model or standard formula?
        • Will internal model reduce capital requirement?
        • Cost of internal model including resource to meet tests
        • Finding a suitable model at a suitable price for a limited line captive insurer.
   ►   Internal model validation. There will be a need to achieve a successful approval
       process with the regulator.
   ►   Board members are expected to demonstrate that they understand Solvency II.
       Many of them do not have technical insurance backgrounds.
Solvency II update – Captive Simplifications


 Captives must meet prescribed requirements to use simplifications.

 In addition each simplification must be proportionate to the nature, scale and
 complexity of the risks inherent in the business.

 Simplifications apply to:
   ►   Interest rate risk
   ►   Market spread risk
   ►   Concentration risk
   ►   Non-life underwriting risk, including aggregate limits

   The simplifications are still quite complex and may not reduce the capital requirement.


 For cedants to captive reinsurers there are simplifications for counterparty risk.
Solvency II Update – The
   Actuarial Function




           42
Article 48 of the level 2 directive:



 Insurance and reinsurance undertakings shall provide for an effective actuarial function to:


 a)   Coordinate the calculation of technical provisions;
 b)   Ensure the appropriateness of the methodologies and underlying models used as well as the
      assumptions made in the calculation of technical provisions;
 c)   Assess the sufficiency and quality of the data used in the calculation of technical provisions;
 d)   Compare best estimates against experience;
 e)   Inform the administrative or management body of the reliability and adequacy of the calculation
      of technical provisions;
 f)   Oversee the calculation of technical provisions in the cases set out in Article 82;
 g)   Express an opinion on the overall underwriting policy;
 h)   Express an opinion on the adequacy of reinsurance arrangements;
 i)   Contribute to the effective implementation of the risk management system referred to in Article
      43, in particular with respect to the risk modelling underlying the calculation of the capital
      requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred to in Article
      44.


                                                   43
Article 48 of the level 2 directive: Summary



 Insurance and reinsurance undertakings shall provide for an effective actuarial function to:

       Technical
 a)   Coordinate the calculation of technical provisions;
       Reserves
 b)   Ensure the appropriateness of the methodologies and underlying models used as well as the
      assumptions made in the calculation of technical provisions;
 c)
                               Opinion on
      Assess the sufficiency and quality of the data used in the calculation of technical provisions;
 d)
                              Underwriting
      Compare best estimates against experience;
                                Policy
 e)   Inform the administrative or management body of the reliability and adequacy of the calculation
      of technical provisions;
                                                        Opinion on
 f)   Oversee the calculation of technical provisions in the cases set out in Article 82;
                                                       Reinsurance
 g)   Express an opinion on the overall underwriting policy;
                                                      Arrangements
 h)   Express an opinion on the adequacy of reinsurance arrangements;
 i)                                                                        Contribution to
      Contribute to the effective implementation of the risk management system referred to in Article
                                                                            Risk Modelling
      43, in particular with respect to the risk modelling underlying the calculation of the capital
                                                                              and Capital
      requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred to in Article
      44.                                                                   Requirements


                                                   44
Article 48 of the level 2 directive – “Actuaries”


Who carries out the Actuarial function:

 “The actuarial function shall be carried out by persons who have knowledge of
 actuarial and financial mathematics, commensurate with the nature, scale and
 complexity of the risks inherent in the business of the insurance or reinsurance
 undertaking, and who are able to demonstrate their relevant experience with
 applicable professional and other standards.”

  so in theory at least they don’t actually have to be qualified actuaries!

 but how do you assess what are ‘applicable professional and other
 standards’?




                                           45
How is the non-life actuary’s work likely to change?


 Case study: an actuary formerly employed by a medium sized general
 insurance company in a role that required

   ►   Quarterly formal reserve valuations and reports to the Board of Directors
   ►   Attendance and actuarial input to monthly underwriting and pricing meetings
   ►   Attendance and actuarial input to quarterly reinsurance review meetings


 Calculation of technical reserves is still king. The first six of the nine tasks
 required of the actuarial function are technical reserve related.

 However, the Solvency II requirements do make specific reference to the need
 for assessing the appropriateness, accuracy and completeness of the
 available data with a requirement to convey recommendations on improving
 data quality. This is likely to represent an additional set of duties to the normal
 actuarial workload.



                                               46
How is the non-life actuary’s work likely to change?


 The seventh actuarial function requirement is:

    ►   Express an opinion on the overall underwriting policy;


 A real departure from existing actuarial tasks.

 Expressing an opinion on underwriting will require a detailed and close
 understanding of how underwriters operate. The opinion does not need to
 cover every single policy, but the underwriting policy in general.

 Underwriting comes in several different varieties, sometimes within the same
 insurer. So the actuary’s involvement may vary considerably.

 Diplomacy may be tested in underwriter led organisations.


                                               47
How is the non-life actuary’s work likely to change?


 The eighth actuarial function requirement is:

    ►   Express an opinion on the adequacy of reinsurance arrangements;


 Probably less of a departure from existing tasks than the opinion on overall
 underwriting policy

 The guidance states that “ ... the opinion to be expressed by the actuarial
 function should include an opinion on the adequacy of the reinsurance and
 other mitigation techniques strategy in relation to the underwriting policy and
 the adequacy of the technical provisions arising from reinsurance.”

 The opinion on adequacy of technical provisions should arguably belong to
 the first six actuarial function requirements which deal specifically with
 technical reserve adequacy.


                                            48
How is the non-life actuary’s work likely to change?


 The final actuarial function requirement is:

    ►   Contribute to the effective implementation of the risk management system referred to in
        Article 43, in particular with respect to the risk modelling underlying the calculation of the
        capital requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred
        to in Article 44.


 According to the solvency II directive it is the risk management function which
 is responsible for the design, implementation, testing and validation of the
 internal risk model. However, the actuarial function is in no way precluded
 from assisting in these tasks!




                                               49
Conflict of interest?


 The IP mentions that the actuarial function can be involved in performing the
 functions and taking decisions in areas which it is required to opine on (e.g.
 underwriting policy).

 The IP also states that “In forming and formulating its own actuarial view the
 actuarial function shall be objective and free from influence of other functions
 of the administrative, management or supervisory body and provide its
 opinions in an independent fashion.”

 An outsourced actuarial function may help to bring the independence required




                                       50
Summary


 The role of the actuary is set to expand

 Resources are likely to be stretched

 Involvement in non traditional actuarial areas

 Potentially a challenge for the actuarial profession

 BAS and Groupe Consultatif developing guidance

 A cultural shift may also be needed. There will be a greater need for the
 actuary to get his/her hands dirty and report their findings




                                        51
Solvency II Update – ORSA




           52
ORSA Building Blocks

The Eight Dimensions of Risk
                                                       Strategy
and Performance Management
                                                     Comprehensive
                                                  strategy that leads to
                        Treatment of Model        operational decisions
                            Limitations                                      Risk Appetite and
                         Well understood risk                                 Risk Tolerance
                          and performance
                                                                            Better aligned business
                              indicators
                                                                                   decisions


               Governance and
             Control Environment                             Risk                          Risk and
              Integrated governance                                                      Performance
               structure and control             Performance
                                                                                         Measurement
              environment are crucial                                                    Better informed
                  for the Use Test                                                    management decisions



                                                                           Capital Allocation and
                            Reporting
                                                                            Internal Competition
                       Integrated view on risk
                                                                                 for Capital
                          and performance
                                                                             More effective us of
                                                   Integrated with                 capital
                                                 Business Processes
                                                  Better fit of business
                                                 processes and strategy
ORSA Requirements
     Definition of ORSA



      ►   CEIOPS Issues paper 27 May 2008 defines the ORSA

9.    The entirety of the processes and procedures employed to identify, assess,
      monitor, manage, and report the short and long term risks a (re)insurance
      undertaking faces or may face and to determine the own funds necessary to
      ensure that the undertaking’s overall solvency needs are met at all times

      ►   What is the ORSA?
           •   Risk management tool
           •   For assessing risks and own funds required to back them
           •   ‘ORSA process’ versus ‘ORSA outcome’
           •   More than a just a calculation engine!
      ►   Proportionality principle
CEIOPS guidance
 ORSA principles



               The ORSA is the responsibility of the undertaking and should be regularly
Principle A   reviewed and approved by the undertaking's administrative or management
                                                 body.

              The ORSA should encompass all material risks that may have an impact on
Principle B
               the undertaking's ability to meet its obligations under insurance contracts

               The ORSA should be based on adequate measurement and assessment
Principle C     processes and form an integral part of the management process and
                          decision making framework of the undertaking

              The ORSA should be forward-looking, taking into account the undertaking's
Principle D
                                  business plans and projections


               The ORSA process and outcome should be appropriately evidenced and
Principle E
                     internally documented as well as independently assessed
Solvency II credentials – experience - Mazars



 Actuarial consulting
   ►   Building models under UK’s ICAS framework at international (re)insurers
   ►   Responsible for Individual Capital Assessments (ICA) - under ICAS at international
       (re)insurers
   ►   Benchmarking ICAs
   ►   QIS 2, 3 and 4 submissions and review
   ►   Assisting with transition to Solvency II technical reserving
   ►   Validation of internal models under ICAS and Solvency II
   ►   Embedding and integration of modelling throughout insurance business through board level
   ►   Solvency II training
   ►   Solvency II gap analysis

 Cross functional activities
   ►   Solvency II project management
   ►   Solvency II implementation
   ►   Change management
   ►   Business process re-engineering
   ►   Management information systems and data mapping

                                              56
Mazars Actuaries & Consultants LLP is a subsidiary of Mazars LLP
Mazars LLP is the UK firm of Mazars, an international advisory and accountancy
group.
The information provided during this presentation is intended to provide only a general
outline of the subjects covered. Accordingly, Mazars Actuaries & Consultants LLP,
Mazars LLP and Mazars accept no responsibility for loss arising from any action taken
or not taken by anyone attending this presentation.
The information in these slides will have been supplemented by matters arising from
the oral presentation by us, and should be considered in the light of this additional
information.
If you require any further information or explanations, or specific advice, please
contact us and we will be happy to discuss matters further.




                                        57
Mazars Worldwide


                            Worldwide
         Mazars is an integrated organisation
      of 12,500 professionals in 56 countries,
                generating revenues of more
                           than €767 million.

      With Praxity, the international alliance
           of which it is a founding member,
  Mazars has access to and additional14,000
       professionals 22 additional countries.



                                                 Europe
                                                 26 countries                6,600 professionals

                                                 Mazars is the 7th largest audit firm in Europe.

                                                 It provides services to more than 15% of the
                                                 FTSE Eurofirst 100 and to more than 200 other
                                                 listed clients in Europe.

                                                 Integrated international teams are available over
                                                 our entire range of services.
Mazars in Ireland


 Team
  ► 18 partners

  ► Over 200 professionals



 Offices: Dublin, Galway and Belfast

 Market Position
  ► One of Ireland’s largest audit and advisory firms



 Business fields
  ► Audit, Tax, Consulting, Business Advisory



 Clients
   ► Banking & insurance sectors

   ► Industry sector

   ► Public and Not for Profit sectors

   ► SME sector

   ► Higher education sector
Address:
Contacts :

Mark Kennedy – Partner                  Block 3 - Harcourt Centre
mkennedy@mazars.ie                      Harcourt Road
+353 1 4494442                          Dublin 2
                                        Ireland
Adam Brunskill – Partner
adam.brunskill@mazars.co.uk
+44 207 063 4200                        Tower Bridge House
                                        St Katharine’s Way
Dale Lee - Partner                      London
dale.lee@mazars.co.uk                   E1W 1DD
+44 207 063 4199                        United Kingdom

Peter Gatenby – Partner
peter.gatenby@mazars.co.uk
+44 207 063 4474



             Join Mazars Ireland Solvency II Group on

                                   60

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Solvency II presentation Dublin July 2010

  • 1. Solvency II Update Dublin – 6 July 2010
  • 2. Solvency II update – Agenda Current position and the key milestones over the next couple of years? Quantitive Impact Studies (QISs) past and present Internal Models and Model Validation Documentation Captives The Actuarial Function Own Risk and Solvency Analysis (ORSA) 2
  • 3. Solvency II Update – Current Position & Key Milestones 3
  • 4. Solvency II update - Scope and Structure of Solvency 2 ► Unified prudential regulation of insurers and reinsurers ► Beyond quantitative measures ► Overall risk management ► Overhaul of European supervisory structure ► Transparency and market discipline ► Increase policyholder protection and minimise regulatory burden ► Non-zero failure regime ► Three pillar structure, based on Basel II and CRD ► Link to IASB work on insurance contracts? ► Employs Lamfalussy arrangements
  • 5. Solvency II update – Three Pillars Solvency II Three Pillars of Corporate Governance Pillar 1 Pillar 2 Pillar 3 Adequate Financial Reporting Systems Governance Resources Requirements Quantitative Qualitative Disclosure Requirements Requirements Balance Sheet Corporate Governance Disclosure Evaluation Requirements Risk Management Reserves Transparency on Documentation, Risk Appetite Minimum Capital Systems and Controls & Risk Strategy Requirements (MCR) Stress Testing Solvency Capital Requirements (SCR) ORSA Supervisory Review Process
  • 6. Solvency II update - Timeline Solvency II Level 2 Draft Framework Framework implementation in force – Directive published – Directive approved approved – Oct 2012 Jul 2007 – CEIOPS H2 2011 CEIOPS reports Apr/May2009 provides final on Groups and advice on Proportionality implementation Level of – May 2008 – Jan 2010 effort QIS 3 report – QIS 4 report – CEIOPS Nov 2007 Nov 2008 finalises Level 3 guidance – H2 2011 MILESTONES 2007 2008 2009 2010 2011 2012 TIMELINES QIS 4 – QIS 5 Sol II project Apr to Jul Aug to lead – Mar 2008 Nov 2009 Firms to notify 2010 Dry runs of Submission to Model of intention to models for for approval – approval seek internal approval – Oct 2011 effective model approval Jun to Nov – Jun 2009 2010
  • 7. Solvency II Update – Quantitative Impact Studies 7
  • 8. Solvency II update - Quantitative Impact Studies QIS 1 QIS 2 CP 20 QIS 3 QIS 4 Draft QIS 5 Focused on First calibration formula Analysis and comments on Second calibration formula Simplification of the Fourth calibration technical reserves and approach for the QIS 2 and preparation for approach, option to formula SCR calculation QIS 3 use entity-specific parameters Third calibration 3 levels of prudence to SCR per risk and total formula be calculated : 60th, 75th, SCR obtained by taking Focus on group 90th percentiles into account risk reporting issues correlation and diversification effects Autumn 2005 Summer 2006 Winter 2006 Spring 2007 Spring 2008 15th April 2010 Next step: Final technical specifications for QIS 5 was due to be published on 1 July 2010 with study being run between August and November 2010 8
  • 9. Solvency II update - Quantitative Impact Studies QIS are a good opportunity for entities to kick off their Solvency 2 project: ► At an organisational level • Launch of a «Solvency 2» project, setting up of a solvency committee • Implementation of a global and consistent approach. • Early identification of areas where internal processes, procedures and infrastructure need improvement ► At a technical level • Quantification of levels of prudence in reserves • Risk study and mapping • Improved risk measurement tools • Optimisation of capital, asset allocation ► At a financial level • Further perspective on risk management tools: reinsurance, ALM, derivatives,… • Sources of capital: securitisation, super-subordinated securities 9
  • 10. Solvency II update - Overview of the Economic Balance Sheet ASSETS LIABILITIES Excess Available Solvency capital for Capital Market SCR/MCR MCR Requirement value (SCR) of total MVM assets Market- (MVA) consistent Expected value of future cash liabilities flows (MVL) Valuation of MVL
  • 11. Solvency II update - Solvency II Balance Sheet Solvency I Solvency II Unrealised gains, … Surplus Surplus The SCR should deliver a level of capital that enables an insurer to SCR – MCR absorb significant unforeseen losses and gives reasonable assurance to policyholders that payments will be made as they fall Margin due. The MCR reflects an absolute minimum level of required capital Level of MCR below which supervisory action will automatically be triggered. prudence Risk Eligible margin Market-consistent valuation The « Best Estimate » equals the expected present value of future assets cash flows, using the relevant risk free yield curve, based upon current and credible information and realistic assumptions. Technical Best Estimate of The risk margin covers the risk of variability in future cash flows Reserves relating to insurance liabilities. technical reserves It is equivalent to the cost of providing an amount of capital equal to the SCR necessary to support the insurance liabilities over the life time thereof. Non- Hedgeable hedgeable 11
  • 12. Solvency II update – Two Capital Requirement Levels Two capital requirement levels Add-On Surplus Level of margin expected by the supervisor Adjusted SCR SCR Standard formula Graduated and normalised regulatory Constituted intervention SCR margin SCR Internal Model MCR Authorisation withdrawn MCR : Minimum Capital Requirement SCR : Solvency Capital Requirement Adjusted SCR More complex formula than Standard formula (European Add-on: the supervisory authorities Solvency 1 coefficients), or can, following review of the insurer’s Between two percentages of the Internal models, or own risk assessment, require the firm SCR Partial models plus elements of to hold additional capital Ultimate regulatory sanction to be standard formula Some actions can be taken to reduce applied if breached Graduated regulatory measures the level of Add-Ons 12
  • 13. Solvency II update – QIS4 Framework 13
  • 14. Solvency II update – Draft QIS 5 Framework
  • 15. Solvency II update - SCR General formula SCR = Overall Standard Capital Requirement = BSCR + SCRop BSCR = ∑ ij Corr i,j ×SCR i ×SCR j + SCRintangibles CorrSCR= SCR mkt SCR def SCR life SCR health SCR nl SCR mkt 1 0.25 0.25 0.25 0.25 SCR def 0.25 1 0.25 0.25 0.5 SCR life 0.25 0.25 1 0.25 0 SCR health 0.25 0.25 0.25 1 0 SCR nl 0.25 0.5 0 0 1 SCRop = Capital charge for operational risk SCRintangibles = Capital charge for intangible assets = factorIA * fair_value_intangible assets, where factorIA = 80% 15
  • 16. Solvency II update – Causes of Insolvencies An AM Best survey has summarised the main causes of insolvencies in the United States between 1969 and 1998: Nuber o f Main causes of insolvency Compnies in % impacted Insufficient reserves / Inadequate pricing 143 22.4% Underwriting risks Too rapid growth 86 13.5% 41.5% Catastrophic losses 36 5.6% Overstated assets 40 6.3% Asset risks Failure of reinsurance cover 22 3.4% 9.7% Subsidiaries and other related entities 26 4.1% Significant change in core busisness 28 4.4% Alleged Fraud 44 6.9% Miscellaneous 44 6.9% Unidentified causes 169 26.5% Total 638 100% Illustration : Example of risks leading to insolvency Source : AM Best 16
  • 17. W or ke r 's co Millions € m pe ns 0 1 2 3 4 5 6 7 at io n H M ea ot or lth M l ot iab or ili co ty llis io G N n en on- er Li fe Le al l ga ia l bi lity N pro D at te E* ur ct al io Un di n de sa rw st C r er at iting as ri D t E* rop sk SC he R ris N k on -L In Fo ife te rE re x st ri ra s k te E q ri s k Solvency II update – SCR Components Example ui t Sp y ris re k ad C ris D lu k E* ste S C r ri s D Rm k E* ar ba ke O si t pe c SC ra R t in g SC R SC R
  • 18. Calculation of the SCR – Concentration Risk The definition of market risk concentrations is restricted to the risk regarding the accumulation of exposures with the same counterparty. It does not include other types of concentrations (e.g. geographical area, industry sector etc.) To determine the loading needed to cover the concentration risk, calculate the surplus exposure of each security risk (e.g. shares, bonds). Ratingi CT  Ei  AA-AAA 3.00% XSi = max0; − CT   Assetsxl  A 3.00% BBB 1.50% BB or lower 1.50% Credit Quality Ratingi gi Step Conci = Assetsxl • XSi • gi AAA 1 0.12 AA A 2 0.21 BBB 3 0.27 BB or lower, 4 – 6, - 0.73 Mktconc = ∑ (Conci2 + ∑0.25 * Conc * Conc ) j i j unrated i 18
  • 19. Solvency II update - Elements of the Solvency Margin The principles of eligibility and of Nature classification of capital – “own funds” are Basic capital Ancillary capital Quality defined in the Directive. High Tier 1 Tier 2 Each element has a different capacity to Medium Tier 2 Tier 3 absorb losses. Low Tier 3 - These elements of capital are classified in three levels or « tiers » based on some qualitative considerations (nature of elements and capacity to absorb losses). Tier 3 Tier 2 Tier 1 Quality of capital Other contractual Unpaid called up capital Capital arrangements 40% Supplementary premiums Reserves 60% Supplementary premiums Perpetual subordinated notes Unrealised gains Letters of credit 19
  • 20. Solvency II update – Elements of the Solvency Margin The following elements constitute basic capital: ► The surplus of assets over liabilities, as evaluated in conformity with the Directive (at “market value“); ► Subordinated liabilities; ► Reduced by the amount of any investment in own shares. Ancillary capital is composed of other elements that can be used to cover losses. This includes the following elements, as far as they are not part of basic capital: ► Unpaid called up capital; ► Letters of credit or guarantees; ► Any other legally binding commitments e.g. calls for supplementary contributions (mutual or mutual-type associations) When an item of ancillary capital is paid up, it stops being ancillary capital and becomes part of basic capital. The amount of the ancillary capital to be taken into consideration is subject to prior supervisory approval. Authorities will base their approval on an assessment of the following: ► The status of the relevant counterparty, with regard to its ability and willingness to pay; ► The recoverability of the funds, taking into account the legal form of the item in question and any conditions which might prevent the funds being successfully paid up; ► Any relevant information on the outcome of similar calls for ancillary capital in the past.
  • 21. Solvency II update - Elements of the Solvency Margin The use of some tiers of capital is restricted for solvency purposes: At most 1/3 Tier 3 Remaining share only Tier 2 Remaining share SCR Tier 2 MCR At least 50% At least 1/3 Tier 1 Tier 1 No tier 3 items can be used to cover the MCR Hybrid instruments may be tier 1 capital but they should not account for more than 20% of tier 1 capital 21
  • 22. Solvency II update - Example French non-life company SolvencyI I Solvabilité Solvency -II – 4 Solvabilité II QIS QIS 4 18 000 16 165 1 6 00 0 1 4 95 5 16 000 1 4 00 0 14 000 1 2 00 0 12 000 1 0 00 0 10 000 8 41 4 8 00 0 8 000 6 00 0 6 000 4 361 4 000 4 00 0 2 32 3 2 000 2 00 0 - - Exigence minimale de Fonds propres MC R SC R Fon ds p elements Eligible ropres S1 minimum requirement Own funds marge de solvabilité x 178% x 370% x 645% 22
  • 23. Solvency II Update – Internal Models and MIMAP 23
  • 24. Solvency II update – Internal Models Asset / Liability ORSA Management Assumptions Reward Investment Strategy Data Systems (Internal and External) Decisions Economic Business Reserving Risk Cat Model Scenario Strategy Models Register Generator Management of Business Calculation Kernel Product Development Risk Mitigation Economic Risk Management Regulatory Capital Management Information Capital Allocation Underwriting & Pricing Exposure Management Outward Reinsurance Financial Plans / Business Purchase Statements Planning 24
  • 25. Internal Models – Validation Market Credit P&C Operational Risk Life Risk Risk Risk Risk Use Test Statistical Quality Standards Calibration Standards P & L Attribution Validation Standards Documentation Standards 25
  • 26. Model Validation – Specific Tests Gaining approval to use internal model to calculate SCR not a trivial process ► undertakings should develop models that inform significant risk management and business decisions Six Tests: ► Use test ► Statistical quality ► Calibration ► P&L attribution ► Validation ► Documentation Validation of all quantitative and qualitative processes of internal model Validation is a set of tools and processes Must document how validation will take place and why it is an appropriate approach 26
  • 27. Mazars Independent Model Approval Process - MIMAP A bespoke approach that complements the ‘Dry Run’ process MIMAP Benefits of our process: • A proven process Q • Uses skills and experience of the I Technical Governance Panel (TGP) • Meets clients’ specific requirements S • Supported by technical models 5 • Based on practical experience 27
  • 28. MIMAP - Planning • Kick Off workshops • Current status • Detailed scoping • Training • Integration of TGP • Stage 1 results and feedback 28 28
  • 29. MIMAP – Technical Validation • Calibration • Validation tools • Stress / reverse stress testing • P&L attribution • Back testing • Standard SCR comparison • Stage 2 results and feedback 29 29
  • 30. MIMAP – Governance & Use • Risk coverage • Model governance • Statistical quality • Data policy • Use test • Model change 30 30
  • 31. MIMAP – Validation Policy • Define purpose & scope • Monitoring & performance • Testing & tools • Documentation • Future developments 31 31
  • 32. Model Validation – Process & Controls Validation Scope Materiality Validation Tools Frequency Model Change Policy Roles and Responsibilities Independent Validation Escalation / Reporting 32
  • 33. Model Validation - Validation Policy Purpose and Scope – Extent to which firms gain comfort and how achieve it. Tools and Processes – What will firms use to achieve purpose and scope Frequency of Validation – Apply proportionality to determine frequency and event limit triggers to check validity Governance of Results – Risk management function responsible for validation policy, but can delegate. Clarify ownership of validation tasks. Clarify involvement of senior management in validation policy. Clarify escalation criteria. Limitations and Future Developments – Firms must set out any known limitations and any parts of model not covered. An iterative process of validation policy development. Specify planned developments of policy. Documentation - Process must be documented in an understandable way for knowledgeable third parties Independent Review – Essential to effective validation as it creates challenge. Must clarify the independent review process. Explain strategy to maintain independence over time. 33
  • 34. Solvency II Update – Documentation 34
  • 35. Documentation – What to Achieve? Documentation of the internal model should incorporate the following: The interaction of disciplines across the organisation Experience and understanding of the needs across all levels of a company Effective project planning integrated within the business The potential limitations of models in practical business situations An understanding of the relevant data, assumptions and parameters as applied to each individual recipient Appropriate level of granularity Appropriate knowledge in the application of the use of judgement Knowledge of the strengths and weaknesses of the modelling methods Processes, controls and governance of internal models. 35
  • 36. Documentation – Demonstrate compliance with ‘The Tests’ Article 125 - “Insurance and reinsurance undertakings shall document the design and operational details of their internal model.” Level 2 Advice - “Sufficiently detailed and sufficiently complete to satisfy the criterion that an independent knowledgeable third party could form a sound judgment as to the reliability of the internal model and the compliance with Articles 120 to 126”: Use test Statistical quality Calibration P&L attribution Documentation Validation External Models 36
  • 37. Mazars Independent Documentation Process – MiDoc Our approach is based on application of our proven model documentation tool, MiDoc, which has been implemented in documentation projects for a number of clients. There are three key stages namely: 37
  • 38. Solvency II Update – Captives 38
  • 39. Solvency II update – Captives Some of the characteristics of captives do not fit easily into Solvency II. ► Specialist underwriters limiting risks to those of the owners ► The law of large numbers may not apply where the number of risks is limited ► Policy wording often bespoke to the owner ► Investment strategy can be limited to a small number of assets ► Many operational processes are outsourced ► Captives do not always follow the insurance market cycle ► Lack of resource The SCR calculation was designed to represent a 1 in 200 likelihood of insolvency over a one-year period for ‘average’ companies in the insurance industry. Not designed for niche or specialist insurers with alternative structures. SCR unlikely to reflect the nature of the captive risk profile. A failed captive should not leave behind exposed policyholders. In response CEIOPS has produced some simplifications for captives. 39
  • 40. Solvency II update – Challenges facing Captives Some of the challenges facing captives ► Gearing Solvency II to reflect the nature, scale and complexity of the captive ► Resource costs; lack of resource cannot be used as a reason for not meeting regulatory standards ► Impact on investment strategy ► Formulation of an optimum strategy under Solvency II legislation, in particular following the QIS5 exercise ► Internal model or standard formula? • Will internal model reduce capital requirement? • Cost of internal model including resource to meet tests • Finding a suitable model at a suitable price for a limited line captive insurer. ► Internal model validation. There will be a need to achieve a successful approval process with the regulator. ► Board members are expected to demonstrate that they understand Solvency II. Many of them do not have technical insurance backgrounds.
  • 41. Solvency II update – Captive Simplifications Captives must meet prescribed requirements to use simplifications. In addition each simplification must be proportionate to the nature, scale and complexity of the risks inherent in the business. Simplifications apply to: ► Interest rate risk ► Market spread risk ► Concentration risk ► Non-life underwriting risk, including aggregate limits The simplifications are still quite complex and may not reduce the capital requirement. For cedants to captive reinsurers there are simplifications for counterparty risk.
  • 42. Solvency II Update – The Actuarial Function 42
  • 43. Article 48 of the level 2 directive: Insurance and reinsurance undertakings shall provide for an effective actuarial function to: a) Coordinate the calculation of technical provisions; b) Ensure the appropriateness of the methodologies and underlying models used as well as the assumptions made in the calculation of technical provisions; c) Assess the sufficiency and quality of the data used in the calculation of technical provisions; d) Compare best estimates against experience; e) Inform the administrative or management body of the reliability and adequacy of the calculation of technical provisions; f) Oversee the calculation of technical provisions in the cases set out in Article 82; g) Express an opinion on the overall underwriting policy; h) Express an opinion on the adequacy of reinsurance arrangements; i) Contribute to the effective implementation of the risk management system referred to in Article 43, in particular with respect to the risk modelling underlying the calculation of the capital requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred to in Article 44. 43
  • 44. Article 48 of the level 2 directive: Summary Insurance and reinsurance undertakings shall provide for an effective actuarial function to: Technical a) Coordinate the calculation of technical provisions; Reserves b) Ensure the appropriateness of the methodologies and underlying models used as well as the assumptions made in the calculation of technical provisions; c) Opinion on Assess the sufficiency and quality of the data used in the calculation of technical provisions; d) Underwriting Compare best estimates against experience; Policy e) Inform the administrative or management body of the reliability and adequacy of the calculation of technical provisions; Opinion on f) Oversee the calculation of technical provisions in the cases set out in Article 82; Reinsurance g) Express an opinion on the overall underwriting policy; Arrangements h) Express an opinion on the adequacy of reinsurance arrangements; i) Contribution to Contribute to the effective implementation of the risk management system referred to in Article Risk Modelling 43, in particular with respect to the risk modelling underlying the calculation of the capital and Capital requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred to in Article 44. Requirements 44
  • 45. Article 48 of the level 2 directive – “Actuaries” Who carries out the Actuarial function: “The actuarial function shall be carried out by persons who have knowledge of actuarial and financial mathematics, commensurate with the nature, scale and complexity of the risks inherent in the business of the insurance or reinsurance undertaking, and who are able to demonstrate their relevant experience with applicable professional and other standards.” so in theory at least they don’t actually have to be qualified actuaries! but how do you assess what are ‘applicable professional and other standards’? 45
  • 46. How is the non-life actuary’s work likely to change? Case study: an actuary formerly employed by a medium sized general insurance company in a role that required ► Quarterly formal reserve valuations and reports to the Board of Directors ► Attendance and actuarial input to monthly underwriting and pricing meetings ► Attendance and actuarial input to quarterly reinsurance review meetings Calculation of technical reserves is still king. The first six of the nine tasks required of the actuarial function are technical reserve related. However, the Solvency II requirements do make specific reference to the need for assessing the appropriateness, accuracy and completeness of the available data with a requirement to convey recommendations on improving data quality. This is likely to represent an additional set of duties to the normal actuarial workload. 46
  • 47. How is the non-life actuary’s work likely to change? The seventh actuarial function requirement is: ► Express an opinion on the overall underwriting policy; A real departure from existing actuarial tasks. Expressing an opinion on underwriting will require a detailed and close understanding of how underwriters operate. The opinion does not need to cover every single policy, but the underwriting policy in general. Underwriting comes in several different varieties, sometimes within the same insurer. So the actuary’s involvement may vary considerably. Diplomacy may be tested in underwriter led organisations. 47
  • 48. How is the non-life actuary’s work likely to change? The eighth actuarial function requirement is: ► Express an opinion on the adequacy of reinsurance arrangements; Probably less of a departure from existing tasks than the opinion on overall underwriting policy The guidance states that “ ... the opinion to be expressed by the actuarial function should include an opinion on the adequacy of the reinsurance and other mitigation techniques strategy in relation to the underwriting policy and the adequacy of the technical provisions arising from reinsurance.” The opinion on adequacy of technical provisions should arguably belong to the first six actuarial function requirements which deal specifically with technical reserve adequacy. 48
  • 49. How is the non-life actuary’s work likely to change? The final actuarial function requirement is: ► Contribute to the effective implementation of the risk management system referred to in Article 43, in particular with respect to the risk modelling underlying the calculation of the capital requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred to in Article 44. According to the solvency II directive it is the risk management function which is responsible for the design, implementation, testing and validation of the internal risk model. However, the actuarial function is in no way precluded from assisting in these tasks! 49
  • 50. Conflict of interest? The IP mentions that the actuarial function can be involved in performing the functions and taking decisions in areas which it is required to opine on (e.g. underwriting policy). The IP also states that “In forming and formulating its own actuarial view the actuarial function shall be objective and free from influence of other functions of the administrative, management or supervisory body and provide its opinions in an independent fashion.” An outsourced actuarial function may help to bring the independence required 50
  • 51. Summary The role of the actuary is set to expand Resources are likely to be stretched Involvement in non traditional actuarial areas Potentially a challenge for the actuarial profession BAS and Groupe Consultatif developing guidance A cultural shift may also be needed. There will be a greater need for the actuary to get his/her hands dirty and report their findings 51
  • 52. Solvency II Update – ORSA 52
  • 53. ORSA Building Blocks The Eight Dimensions of Risk Strategy and Performance Management Comprehensive strategy that leads to Treatment of Model operational decisions Limitations Risk Appetite and Well understood risk Risk Tolerance and performance Better aligned business indicators decisions Governance and Control Environment Risk Risk and Integrated governance Performance structure and control Performance Measurement environment are crucial Better informed for the Use Test management decisions Capital Allocation and Reporting Internal Competition Integrated view on risk for Capital and performance More effective us of Integrated with capital Business Processes Better fit of business processes and strategy
  • 54. ORSA Requirements Definition of ORSA ► CEIOPS Issues paper 27 May 2008 defines the ORSA 9. The entirety of the processes and procedures employed to identify, assess, monitor, manage, and report the short and long term risks a (re)insurance undertaking faces or may face and to determine the own funds necessary to ensure that the undertaking’s overall solvency needs are met at all times ► What is the ORSA? • Risk management tool • For assessing risks and own funds required to back them • ‘ORSA process’ versus ‘ORSA outcome’ • More than a just a calculation engine! ► Proportionality principle
  • 55. CEIOPS guidance ORSA principles The ORSA is the responsibility of the undertaking and should be regularly Principle A reviewed and approved by the undertaking's administrative or management body. The ORSA should encompass all material risks that may have an impact on Principle B the undertaking's ability to meet its obligations under insurance contracts The ORSA should be based on adequate measurement and assessment Principle C processes and form an integral part of the management process and decision making framework of the undertaking The ORSA should be forward-looking, taking into account the undertaking's Principle D business plans and projections The ORSA process and outcome should be appropriately evidenced and Principle E internally documented as well as independently assessed
  • 56. Solvency II credentials – experience - Mazars Actuarial consulting ► Building models under UK’s ICAS framework at international (re)insurers ► Responsible for Individual Capital Assessments (ICA) - under ICAS at international (re)insurers ► Benchmarking ICAs ► QIS 2, 3 and 4 submissions and review ► Assisting with transition to Solvency II technical reserving ► Validation of internal models under ICAS and Solvency II ► Embedding and integration of modelling throughout insurance business through board level ► Solvency II training ► Solvency II gap analysis Cross functional activities ► Solvency II project management ► Solvency II implementation ► Change management ► Business process re-engineering ► Management information systems and data mapping 56
  • 57. Mazars Actuaries & Consultants LLP is a subsidiary of Mazars LLP Mazars LLP is the UK firm of Mazars, an international advisory and accountancy group. The information provided during this presentation is intended to provide only a general outline of the subjects covered. Accordingly, Mazars Actuaries & Consultants LLP, Mazars LLP and Mazars accept no responsibility for loss arising from any action taken or not taken by anyone attending this presentation. The information in these slides will have been supplemented by matters arising from the oral presentation by us, and should be considered in the light of this additional information. If you require any further information or explanations, or specific advice, please contact us and we will be happy to discuss matters further. 57
  • 58. Mazars Worldwide Worldwide Mazars is an integrated organisation of 12,500 professionals in 56 countries, generating revenues of more than €767 million. With Praxity, the international alliance of which it is a founding member, Mazars has access to and additional14,000 professionals 22 additional countries. Europe 26 countries 6,600 professionals Mazars is the 7th largest audit firm in Europe. It provides services to more than 15% of the FTSE Eurofirst 100 and to more than 200 other listed clients in Europe. Integrated international teams are available over our entire range of services.
  • 59. Mazars in Ireland Team ► 18 partners ► Over 200 professionals Offices: Dublin, Galway and Belfast Market Position ► One of Ireland’s largest audit and advisory firms Business fields ► Audit, Tax, Consulting, Business Advisory Clients ► Banking & insurance sectors ► Industry sector ► Public and Not for Profit sectors ► SME sector ► Higher education sector
  • 60. Address: Contacts : Mark Kennedy – Partner Block 3 - Harcourt Centre mkennedy@mazars.ie Harcourt Road +353 1 4494442 Dublin 2 Ireland Adam Brunskill – Partner adam.brunskill@mazars.co.uk +44 207 063 4200 Tower Bridge House St Katharine’s Way Dale Lee - Partner London dale.lee@mazars.co.uk E1W 1DD +44 207 063 4199 United Kingdom Peter Gatenby – Partner peter.gatenby@mazars.co.uk +44 207 063 4474 Join Mazars Ireland Solvency II Group on 60