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    WHITE PAPER

    Accelerating Solvency II Compliance with SASBuilding the bridge to competitive advantage

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    SAS White Paper

    Table of Contents

    Executive Summary 1

    Solvency II 1From Planning to Implementation 1

    Evolving or Future Flexibility 2

    SAS: Building a Bridge to Compliance 2

    Implementation in the Spotlight 3

    Challenge 1: Data Management 3

    Challenge 2: Meeting Solvency II Capital Requirements 4

    Challenge 3: Risk Management 5

    Challenge 4: Compliance Reassurance 5

    Challenge 5: Reporting 6

    Challenge 6: IFRS Reconciliation 7

    SAS: Our Expertise, Your Solvency II Solution 7

    The SAS Solvency II Framework 8

    An Integrated, End-to-End Solvency II Data Management Solution 9

    A Robust Risk and Capital Modeling Solution 9

    Integration o Solvency II and ORSA 10

    Reporting 10

    Alignment o Solvency II with IFRS Accounting 10

    Conclusion and Next Steps 11

    The Five Steps to Solvency II Compliance 11

    About SAS 14

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    Accelerating Solvency II Compliance with SAS

    Executive Summary

    Solvency II, the biggest transormation o European insurance legislation in almost

    40 years, is set to come into eect on January 1, 2014 Designed to introduce a

    harmonized, EU-wide insurance regulatory regime that will protect policyholders

    and minimize market disruption, the legislation sets stronger requirements or capital

    adequacy, risk management and disclosure

    The recent proposal to extend the deadline or Solvency II compliance by one year

    reects the fnding o a report by the Financial Services Authority (FSA) in the UK that

    many insurers have much to do beore they reach the Solvency II standards1

    While the proposed deadline would give frms more time to prepare, it should not

    be cause or complacency The challenges o meeting Solvency II requirements are

    incredibly complex, regardless o whether insurers are using their own internal capital

    model or the Solvency II standard ormula Embedding new solvency capital models,data management processes and reporting systems into day-to-day business, across

    multiple business lines and subsidiaries, is a complicated and sophisticated task The

    extension should, thereore, be viewed as an opportunity to take a structured approach

    to the Solvency II transormation project; to use the space to make considered

    decisions that will not only lead to compliance, but also inorm strategy and drive

    competitive advantage in the long term

    SAS has worked closely with customers in the insurance industry or more than 30

    years Our extensive experience with regulatory change means that we are able to

    understand the needs o insurers and the solutions to those needs Through this

    experience and knowledge, we have developed a complete Solvency II ramework to

    help our customers accelerate the compliance process, reduce the cost o the project

    and reduce the risk in their Solvency II transormation process

    In this paper, we share our insight into the challenges customers are acing in the

    countdown to Solvency II, and we outline the SAS solutions that are helping insurers

    to prepare

    Solvency II

    From Planning to Implementation

    Once implemented, Solvency II will provide a solid risk- and capital-based oundation

    or the insurance industry or many decades to come The EU-wide legislation will

    improve capital adequacy, risk management and accountability, thereby increasing

    protection or policyholders, giving clarity on insurers creditworthiness and reducing

    the risk o market disruption and business ailure It will replace the current 14 EU

    insurance directives with a single regulatory standard that will harmonize the rules or

    the insurance industry across Europe

    1 FSA Solvency II: Internal Model Approval Process Thematic review fndings, February 2011, p. 4.

    www.sa.gov.uk/pubs/international/imap_fnal.pd

    The extension is an opportunity

    to take a structured approach to

    the Solvency II transormation

    project; to use the space to

    make considered decisions that

    will not only lead to compliance,

    but also inorm strategy and

    drive competitive advantage in

    the long term.

    http://www.fsa.gov.uk/pubs/international/imap_final.pdfhttp://www.fsa.gov.uk/pubs/international/imap_final.pdf
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    SAS White Paper

    But the short-term challenges o meeting Solvency II requirements are numerous and

    complex Beyond compliance, Solvency II solutions must be woven into an insurers

    daily operations The deadline or compliance may potentially be delayed by a year, but

    insurers should not be lulled into a alse sense o security Failure to act now will only

    result in increased pressure in a years time

    Since the inception o Solvency II, many insurers have seen it as an opportunity to

    make important strategic decisions or the uture Much time and energy has been put

    into planning how the transormation to Solvency II can improve operational efciency,

    or how new internal capital models can help insurers understand their business better,

    develop new product lines and gain competitive advantage

    However, the reality is that despite the time spent in planning the transormation to

    Solvency II, many insurers have ound that the toughest challenge is implementation

    Embedding new models, rules and processes into their multiaceted businesses is

    proving to be complicated and expensive How can they build a platorm that works orall stakeholders rom actuarial to fnance to risk and IT? And how can they build it cost-

    eectively and on time?

    Evolving for Future Flexibility

    There are many changes required to meet the Solvency II standards, including fnancial,

    actuarial, capital, risk management, audit management and management o the overall

    insurance group Unortunately, clarity and guidance rom the EU and the European

    Insurance and Occupational Pensions Authority (EIPOA) will not be available or

    some time yet,2 and insurers may also need to incorporate changes imposed by the

    revised International Financial Reporting Standards (IFRS) This means that platorms,

    systems and processes built now must be exible enough to absorb changes to the

    requirements in the uture

    In the short term, this transormation has become a necessary compliance exercise But,

    by building a platorm that can be quickly and cost-eectively adapted later, insurers

    can still invest in their long-term competitive advantage Insurers are, thereore, seeking

    to build exible IT platorms and data management rameworks that both enable them to

    be compliant now and provide a solid oundation or uture innovation and development

    SAS: Building a Bridge to Compliance

    SAS understands the complexities o the data and IT inrastructure transormationneeded or insurers to be Solvency II compliant In more than 30 years o business,

    we have worked with more than 1,000 insurers in more than 50 countries, and have

    supported numerous fnancial institutions through regulatory change programs

    We also understand that Solvency II is not just about capital management Strong

    corporate governance and risk management are at the very heart o Solvency II, and or many

    companies, these present a greater compliance challenge than the Pillar 1 requirements

    2The EUs Level 2 Implementing Measures and Binding Technical Standards are not due or publicationuntil summer 2012, and EIOPAs Level 3 Guidance documents cannot be published until ater the Level 2is published.

    Embedding new models,

    rules and processes into their

    multiaceted businesses is

    proving to be complicated and

    expensive.

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    Accelerating Solvency II Compliance with SAS

    Based on our extensive experience, our solutions will help you meet the minimum

    Solvency II requirements within the time rame and help to transorm your companys

    culture Using SAS, you can connect the actuarial, risk, fnancial and IT unctions o

    your business to build a single ramework that meets all o the regulatory standardsThis ramework can provide a solid oundation or improved capital and cost-efciency,

    and continuous product innovation, into the uture

    Implementation in the Spotlight

    At SAS, we regularly engage with our insurance customers to understand the

    challenges that Solvency II presents What is increasingly clear is that the more

    progress insurers make, the more they realize they have to do

    This anecdotal evidence is supported by the fndings o the FSAs Solvency II: Internal

    Model Approval Process Thematic review, which ound that some frms judgedthemselves to be already close to Solvency II standards but, on closer questioning,

    were not able to provide evidence to justiy this

    By combining the experience o our customers with the FSAs fndings, we have

    identifed six key challenges that insurers must address immediately to meet Solvency

    II standards in time

    Challenge 1: Data Management

    Data management or more precisely, managing the quality and consistency o data

    is undamental to Solvency II compliance The directive requires data to be accurate,

    timely and appropriate or all stakeholders, across actuarial, risk and fnancial unctionsBut, in many frms, siloed use has led to disjointed data This is an issue that must be

    addressed or frms to be Solvency II compliant

    Many insurers have made plans or improved data management, but have stumbled at

    the implementation phase The FSA commented that most frms have overstated their

    current level o preparedness against Solvency II criteria

    The regulator noted that insurers had started to create data dictionaries to help with

    companywide classifcation o data These data dictionaries will help to convert data

    into the inormation each stakeholder needs whether that be risk profling or reporting

    inormation and ensure that everyone is compliant

    However, the FSA also commented that there is little evidence o timely maintenance

    and consistent use o the data dictionaries across the business It thereore

    recommends that one or more data experts should be the custodians o data quality

    and management or the entire frm

    In addition, the regulator views multiple spreadsheets as an area o risk, leading to an

    uncoordinated approach and a lack o cross-unctional alignment and not the best

    route to compliance A centralized sotware solution is thereore essential to ensuring

    consistent use and easy maintenance o data, as well as reliable monitoring and

    reporting

    Insurers are, thereore, seeking

    to build exible IT platorms

    and data management

    rameworks that both enablethem to be compliant now

    and provide a solid oundation

    or uture innovation and

    development.

    Data dictionaries will help

    to convert data into the

    inormation each stakeholder

    needs whether that be

    risk profling or reporting

    inormation and ensure that

    everyone is compliant.

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    SAS White Paper

    But with multiple stakeholders, and limited resources, how can companies ensure

    policywide compliance in the remaining time?

    SAS Recommendation

    Solvency II compliance is a massive and multiaceted exercise, but it does not require

    frms to tackle data management at a policy-by-policy level Insurers using the

    regulators standard ormula will fnd that homogenous risk groups are acceptable

    We advise that others should prioritize the data that has a material impact on their

    compliance issues, and ensure that these are clearly defned in the data dictionary

    Our Solvency II solution eatures products that enable data experts to quickly, easily and

    cost-eectively improve data quality, harmonize the data dictionary and meet the basic

    requirements or compliance Firms can use these tools or all uture data management,

    maintenance and reporting as they develop their data dictionary

    Read about SAS end-to-end Solvency II data management solution on page 8

    Challenge 2: Meeting Solvency II Capital Requirements

    In the past, insurers have used numerous, separate actuarial models to calculate capital

    requirements and project cash ow or individual products or subsidiaries This siloed

    approach has meant that balance sheets and thereore regulatory capital have not

    always truly reected all o the risk undertaken by the business (eg, market, credit,

    underwriting, liquidity and operational risk)

    Solvency II requires all insurers to integrate the models used to calculate their solvency

    capital requirement (SCR) to produce an accurate balance sheet that is reectiveo all risk taken at product, subsidiary and corporate levels This applies to all frms,

    regardless o which approach insurers base their capital requirement calculations on:

    internal model, standard ormula or a combination o the two

    However, there are very ew sotware solutions on the market that can apply these

    complex calculations in a compliant and harmonized way And with the delays to

    the publication o the directive, there is still uncertainty as to the exact calculation

    requirements o the uture

    SAS Recommendation

    Insurers must develop a central risk calculation engine that will analyze risk and

    calculate capital requirements in line with both Solvency II and company strategy This

    engine should be quick and easy to use whenever frms need to measure actuarial risk

    at a subsidiary or corporate level Furthermore, it should not only be used or capital and

    risk calculations, but also or aggregation and stress testing, as well as or validation and

    reporting purposes

    SAS oers an out-o-the-box solution, SAS Risk Management or Insurance, which both

    integrates and accelerates the risk and capital modeling process We use a standard,

    predefned ormula, but oer the exibility to adapt the calculations to accommodate

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    SAS White Paper

    But, as we have already noted, the regulators (in this case, the FSA) ound that frms

    oten judged themselves to be ready or Solvency II, but were unable to provide

    sufcient evidence to justiy this In the midst o a massively complex actuarial and IT

    transormation program, how can insurers quickly and easily document and record

    their journey to Solvency II compliance?

    SAS Recommendation

    Because the SAS Solvency II ramework helps insurers to establish the business

    processes required or ull Solvency II compliance, we also ully support compliance

    sel-assessment and progress monitoring An intuitive project management interace

    enables frms to quickly access evidence o Solvency II compliance processes and

    ormula development Results can be used or both external and internal audit, saving

    time and giving valuable insight into Solvency II implementation

    For more inormation, on SAS Enterprise GRC see page 9

    Challenge 5: Reporting

    Greater transparency through public disclosure and reporting requirements is one

    o the central oundations o Solvency II Insurers will be expected to produce more

    reports than ever beore such as capital calculation and risk management results

    on a monthly, quarterly and annual basis both or internal, regulatory and market

    scrutiny

    Not only will frms need to produce more reports, but turnaround times have now

    been cut rom months to a matter o days Also, fnal reporting requirements will not be

    defned until Solvency II enters the fnal Guidance phase

    Meeting the new reporting standards will require an unprecedented amount o work, in

    a time o immense pressure and limited resources For many insurers, reporting is the

    fnal hurdle to compliance and they stand to ail i they do not put sufcient reporting

    tools in place now

    SAS Recommendation

    Managing separate reporting systems or regulatory, market and management

    reporting will not be practical or cost-efcient once Solvency II legislation comes into

    eect Insurers must save time and money by integrating their reporting system to

    produce consistent, timely and relevant inormation or all stakeholders

    Only SAS oers a predefned Solvency II compliant reporting ormat SAS Risk

    Management or Insurance with all the necessary data structures or both internal

    and external reporting SAS Risk Management or Insurance oers the opportunity

    to develop meaningul management and market inormation to meet the needs o

    all stakeholders In addition, it can be easily updated as new regulatory reporting

    requirements are defned No other sotware provider can oer a complete reporting

    solution out o the box To fnd out more about the reporting capabilities o SAS Risk

    Management or Insurance, please see page 9

    Insurers should develop one

    calculation engine to helpproduce both the SCR and the

    economic capital requirements

    under the ORSA.

    Companies that conduct

    sel-assessments o their own

    compliance with the rules have

    better relationships with the

    FSA, are less at risk o fnes

    or censure, and ultimately

    have a lower overall cost

    o compliance.

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    Accelerating Solvency II Compliance with SAS

    Challenge 6: IFRS Reconciliation

    The move to Solvency II and the upcoming IFRS accounting changes will both have

    huge implications or how insurers measure their perormance and are viewed by the

    fnancial markets and regulators Failure to communicate capital management and

    value creation eectively will lead to greater market scrutiny and an increased cost o

    capital Firms must thereore be able to report both standards clearly, and help the

    market and regulators understand any discrepancies the two methodologies create

    SAS Recommendation

    The crossover o the implementation o Solvency II with the IFRS changes presents

    an opportunity to integrate the two reporting rameworks The logistics o this will

    present huge challenges However, expense and risk associated with managing them

    separately make reconciliation the most prudent long-term strategy

    SAS believes that insurers should consider IFRS evolution and Solvency II compliance

    as part o the same process Using SAS Financial Management, insurers can manage

    and plan operational budgets and regulatory capital under one reconciled view For

    more inormation, see page 10

    SAS: Our Expertise, Your Solvency II Solution

    SAS is the leader in business analytics and sotware services, and the largest

    independent vendor in the business intelligence market For more than 30 years,

    we have worked closely with our 1,000 insurance industry customers to understand

    their needs and develop solutions that help them to do more with increasingly limitedresources We also have extensive experience with regulatory change, having enabled

    more than 100 Basel II implementations worldwide

    Thats why no other vendor can oer the comprehensive, end-to-end risk management

    capabilities you get with SAS Unlike other solutions, SAS provides a single, integrated

    risk platorm that supports the entire Solvency II process rom data management

    through to advanced risk analytics and reporting

    With the SAS Solvency II ramework, you can:

    Accelerate Solvency II compliance projects with a robust risk analytics ramework

    Improve data quality or an accurate risk profle and better-inormed decision

    making

    Reduce the impact o risks and mitigate losses using advanced analytics

    Lower your cost o ownership with a single integrated solution

    Ensure transparency and traceability across the entire process

    You can also save money and gain competitive advantage by using the same solution

    or advanced, non-regulatory measures and ully integrating the system into your

    business decision making Plus, our solution is uture-prooed; it is exible enough to

    quickly and easily meet any regulatory changes as they occur

    Greater transparency

    through public disclosure and

    reporting requirements is one

    o the central oundations o

    Solvency II.

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    SAS White Paper

    The SAS Solvency II Framework

    The SAS Solvency II approach starts with a exible, modular ramework that can be

    integrated into insurers existing actuarial tools where required We use a phased

    implementation approach to bridge any compliance gaps in legacy systems, data

    stores and data models

    Because the solution is modular, you can implement only those components that

    address your specifc business needs, and then expand the solution over time as your

    needs change With SAS, you can adopt a single platorm or compliance across all

    three pillars o Solvency II, plus achieve real business benefts now and in the uture

    The crossover o the

    implementation o Solvency II

    with the IFRS changes presents

    an opportunity to integrate the

    two reporting rameworks. The

    logistics will be challenging, but

    the expense and risk associated

    with managing them separately

    make reconciliation the most

    prudent long-term strategy.

    StressTesting

    RiskA

    ggregation

    TechnicalProvisions

    Standard Formula

    Internal Model

    Pillar 1Risk-BasedMeasures

    Risk

    Appetite

    SupervisoryReview

    Model Change

    Asset and LiabilityManagement

    Pillar 2

    Portal

    Run Models Risk Dashboard Distribute Reports

    Risk Management

    Do

    cumentManagement

    Workow

    Risk-BasedMeasures

    Pillar 3

    Regulatory Reporting

    Internal MI

    Financial Reporting

    Monitoring / AuditReconciliation

    Business Glossary

    Conguration

    Data Quality Data Deciencies Data Warehouse

    DATA

    Data Dictionary Data Proling Data Lineage

    Metadata Management

    Liabilities Third Party Finance Other SourceAssets

    DATA

    DATA

    DATA

    DATA

    DATA

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    Accelerating Solvency II Compliance with SAS

    An Integrated, End-to-End Solvency II Data Management Solution

    Only SAS oers an integrated, end-to-end data management solution or Solvency II

    compliance We can provide:

    A single process or data management and data quality throughout the ramework

    Deployment o a Solvency II data warehouse or a complete insurance data model

    A preconfgured Solvency II analytical data model or the capital management

    process

    Integration o a risk management ramework into the internal model process

    A result-reporting data model

    Repository o quantitative regulatory reporting (by company or group)

    Metadata management or improved controls and governance, data lineage rom

    source to report, with a data dictionary o business and technical metadata

    Data profling capability with built-in data quality management routines to ensure

    data integrity and drive maximum value or the business Full audit control unctionality via a simple user interace

    Workow management, including escalation o tasks and automation o processes

    to and rom actuarial models

    A Robust Risk and Capital Modeling Solution

    SAS Risk Management or Insurance is designed to perorm risk analysis and

    risk-based capital calculations or lie, property and casualty, and health insurance

    companies

    As a modular approach, it can be exible in line with a frms changing needs It can

    also provide open data interaces to import liability cash ows rom third-party actuarialapplications

    The application supports the standard ormula and the internal model approaches,

    enabling insurers to perorm complex risk calculations, defne control measures and

    maintain compliant capital ratios It can provide the platorm or the calculation o:

    Technical provisions

    Market risk

    Counterparty deault risk

    Underwriting risk

    Risk margin

    Operational risk

    Firmwide risk (SCR/minimum capital requirement)

    Group risk capital

    Concentration risk

    Stress-testing analysis

    Regulatory and internal risk model reporting

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    SAS White Paper

    Integration of Solvency II and ORSA

    SAS Enterprise GRC provides a Web-based application that enables insurers to

    identiy, collect, measure, manage, monitor, analyze and report on all exposure to risk

    That inormation can be applied across your Solvency II implementation and as part o

    an ongoing internal risk management process

    Business strategy is an integral part o the application, so SAS Enterprise GRC will

    enable better-inormed decision making based on a coherent, accurate risk profle

    and expected changes to this and SCR

    The solution also oers:

    Integration o business planning into the risk profle or use in the capital modeling

    process

    Risk identifcation and assessment at group or subsidiary level

    Control testing and assurance reporting in line with both regulatory and businessrequirements

    Mitigation action alerts or policy management purposes

    Risk monitoring using key risk indicators

    Stress testing and scenario planning using advanced analytics

    Remediation and action plan management to report and mitigate identifed issues

    Reporting

    SAS Risk Management or Insurance includes standard and ad hoc reporting

    capabilities that are critical or disseminating risk inormation to regulators or Solvency

    II compliance and to senior management or improved risk decision making The

    application provides unctional, data and reporting components o the SAS Solvency II

    ramework to deliver:

    Aggregation o results rom solo to group level

    Solvency and fnancial condition reporting and reports to supervisors

    Internal reporting and management inormation

    Risk reporting

    Alignment of Solvency II with IFRS Accounting

    SAS Financial Management is designed to meet Solvency II fnance unction

    requirements, including statutory consolidation, fnancial reporting, budgeting andplanning

    By implementing this solution, insurers can greatly reduce the workload involved in

    complying with multiple reporting standards ie, IFRS, local GAAP and Solvency

    II SAS Financial Management can accommodate any specifed structure, and the

    solution enables separate hierarchies to be defned, or example, or local and/or group

    reporting

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    Accelerating Solvency II Compliance with SAS

    The application enables fnancial managers to:

    Easily handle currency conversions, intercompany eliminations, reconciliations,

    minority interests, new acquisitions, etc

    Use either a top-down or bottom-up approach (or a combination o the two) orthe budgeting process

    Customize budget orms to allow users exibility on how they submit budgets

    eg, via Excel or a Web page

    Automatically calculate results based on the latest approved data or a more

    dynamic operational environment

    Conclusion and Next Steps

    As we have seen, time is o the essence i insurers are to meet minimum requirements

    to be Solvency II compliant by January 2014 And there is still much to do

    While considered an exceptionally ambitious project, Solvency II was designed to

    generate benefts or policyholders, the market and insurance companies themselves

    Its implementation should make the European insurance industry more competitive

    while opening the door to many new opportunities

    The SAS Solvency II ramework builds a bridge to compliance and provides a solid

    oundation or frms to reap the benefts o a truly EU-wide insurance industry We are

    the only sotware company that can oer a exible ramework to meet the needs o all

    insurers, large and small, regardless o which ormula they have chosen or where they

    are along the path to implementation

    The Five Steps to Solvency II Compliance

    1 Review your Solvency II program with SAS

    2 Incorporate the SAS Solvency II ramework into your existing architecture

    3 Deploy a exible Solvency II platorm to meet solo and group compliance

    4 Take a phased approach to ensuring completeness and cultural change

    5 Deliver regulatory reports, and improve business management inormation

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    SAS Institute Inc. World Headquarters +1 919 677 8000

    To contact your local SAS ofce, please visit:www.sas.com/ofces

    SAS and all other SAS Institute Inc. product or service names are registered trademarks or trademarks o SAS Institute Inc. in the USA

    and other countries. indicates USA registration. Other brand and product names are trademarks o their respective companies.

    Copyright 2011, SAS Institute Inc. All rights reserved. 105485_S82559_1211

    About SAS

    SAS is the leader in business analytics sotware and services, and the largest independent vendor in the business intelligence market

    Through innovative solutions delivered within an integrated ramework, SAS helps customers at more than 50,000 sites improve

    perormance and deliver value by making better decisions aster Since 1976 SAS has been giving customers around

    the world THE POWER TO KNOW