solvency ii briefing 7 october 2015 - deloitte us · pdf filesolvency ii briefing 7 october...

© 2015 Deloitte

Solvency II Briefing7 October 2015

Leading business advisers

© 2015 Deloitte

Donal LehanePartner

© 2015 Deloitte

Agenda

3

1 Actuarial Function

by Sinead Kiernan, Director

2 Standard Formula Appropriateness

by Eamon Howlin, Senior Manager; and Maaz Mushir, Manager

3 Data Management

by John Kilbride, Director

© 2015 Deloitte

Actuarial Function

Sinéad Kiernan

Director

© 2015 Deloitte© 2015 Deloitte

Introduction

Actuarial Function

Outsourcing the Actuarial Function

2015 Requirements

CP92 – Feedback Statement

5

© 2015 Deloitte

IntroductionActuarial Function

The Actuarial Function is a Key Function under Solvency II. Companies will be

required to comply with all requirements for the actuarial function under Solvency II

as well as any additional requirements as specified by the CBI’s requirements

relating to the “Domestic Actuarial Regime Under Solvency II”.

The Central Bank’s consultation paper ‘Domestic Actuarial Regime Under Solvency

II Consultation’ was published by the Central Bank on 2 April 2015. The Central

Bank’s feedback statement was published on 6 October.

Additional requirements introduced by the Central Bank are in green text.

6

© 2015 DeloitteORSA Briefing7

The main sources of the Actuarial Function requirements are:

• Solvency II Directive (Article 48)

• Delegated Acts (Articles 272 and 308)

• EIOPA Guidelines on System of Governance

• CBI Guidelines on Preparing for Solvency II – System of Governance

• CBI’s Consultation Paper 92 and Feedback Statement – Domestic Actuarial

Regime and Related Governance Requirements under Solvency II

The slides which follow provide a summary of our interpretation of the

requirements for the Actuarial Function. We recommend that you refer to

the Directive, Delegated Acts, and the relevant guidelines to develop your

understanding of the regulatory requirements.

Understanding and implementing the requirements for the Actuarial FunctionSources of Regulatory Requirements


Introduction

Actuarial Function


2015 Requirements


8

© 2015 Deloitte

Actuarial FunctionResponsibilities

• Co-ordinate calculation of technical

provisions;

• Inform the Board of the adequacy of

calculation;

• Provide opinion & accompanying

report to the CBI;

Actuarial

Function

(HoAF)

Technical

Provisions

Underwriting

Reinsurance

Risk

Management

• Prepare opinion on overall

underwriting policy;

• Prepare opinion on adequacy of

reinsurance arrangements;

• Contribute to effective risk

management system;

• Provide opinion to the Board on

range of risks & adequacy of the

scenarios considered as part of the

ORSA;

Sources: SII Directive, Delegated Acts, CP92 9

Actuarial

Function

Report

© 2015 Deloitte

Actuarial FunctionHead of Actuarial Function

1. The actuarial function shall be carried out by persons who:

a) have knowledge of actuarial and financial mathematics,

commensurate with the nature, scale and complexity of the risks

inherent in the business, and

b) are able to demonstrate their relevant experience with applicable

professional and other standards, as outlined in Article 48 (2) of

the 2009 Solvency II Directive.

2. Head of Actuarial Function:

a) Person with responsibility for Key Function

b) One individual within the undertaking

c) PCF role under Fitness & Probity regime

Sources: SII Directive, CP92 10

Actuarial

Function

(HoAF)

© 2015 Deloitte

Actuarial FunctionTechnical Provisions

Actuarial

Function

(HoAF)

Technical

Provisions

Underwriting

Reinsurance

Risk

Management

Co-ordinate the calculation of

Technical Provisions

Comparison to

current SAO

regime

Comparison to

current appointed

actuary regime

• Ensure appropriateness of

methodologies, models and

assumptions

Similar Similar

• Assess sufficiency & quality of data Similar Similar

• Procedures are sufficiently

supported by IT systems

New New

• Compare best estimate against

experience

Similar Similar (for

assumption setting)

• Conclude on adequacy and

reliability of calculation

Similar Similar

• Identify sources and degree of

uncertainty

Similar New

• Disclose use of material judgments Similar Similar

• Perform sensitivity analysis Similar New

• Provide opinion & accompanying

report to CBI

Similar Similar (provide to

Board)

There are several similarities between the above requirements and the current SAO and AA

regimes, however we note that the definition of technical provisions is different under Solvency

II. Sources: SII Directive, Delegated Acts, ESAP2 Working Draft, CP92 11

© 2015 Deloitte

Actuarial FunctionUnderwriting Opinion

Actuarial

Function

(HoAF)

Technical

Provisions

Underwriting

Reinsurance

Risk

Management

Sources: SII Directive, Delegated Acts, ESAP2 Working Draft, CP92 12

Opinion on Underwriting Policy

• Prepare opinion on overall underwriting policy

• Assess sufficiency of premiums in totality. AA currently provides

opinion on sufficiency of new business premiums in total.

• Assess variability surrounding expected profitability and

consistency of variability with risk appetite

• Review response to changing experience

• Conclude on risk of anti-selection

• Assess consistency of the underwriting policy with other policies

• Assess consistency of underwriting assumptions with those used

for technical provisions and reinsurance

• Comment on relationship between business plan and risk

appetite

There are no requirements related to Underwriting Opinion in the current SAO regime, all of the

above requirements are therefore considered ‘New’ requirements. However, the AURR requirement

in the current SAO regime is related to the analysis underlying the Opinion on Underwriting Policy.

Most of the requirements are new under AA regime.

© 2015 Deloitte

Actuarial FunctionReinsurance Opinion

Actuarial

Function

(HoAF)

Technical

Provisions

Underwriting

Reinsurance

Risk

Management


Opinion on adequacy of reinsurance arrangements

• Prepare opinion on adequacy of reinsurance arrangements,

outlining any concerns

• Provide recommendations to improve reinsurance

arrangements, including advantages and disadvantages of

any alternatives

• Assess consistency with risk appetite, risk profile,

underwriting policy and technical provisions

• Assess credit standing of reinsurance counterparties

• Assess response under stress tests, e.g. for catastrophe

claims, risk aggregations

• Appropriateness of the calculation of amounts recoverable

from reinsurance contracts and special purpose vehicles

There are no requirements related to Reinsurance Opinion in the current SAO and AA regimes,

all of the above requirements are therefore considered ‘New’ requirements.

© 2015 Deloitte

Actuarial FunctionRisk Management

Actuarial

Function

(HoAF)

Technical

Provisions

Underwriting

Reinsurance

Risk

Management


Contribution to effective risk management system

• Description of areas of material contribution to risk management,

including contribution to risk modelling underlying calculation of

capital requirements.

• Provide recommendations for future improvements

• Opinion to the Board on range of risks and adequacy of

scenarios, including financial projections, considered as part of

each ORSA process

• FCR report currently required under AA regime

There are no requirements related to Risk Management in the current SAO regime, all of the

above requirements are therefore considered ‘New’ requirements. However, we would note

that as part of the current SAO regime, the Signing Actuary is required to consider material

risks around the best estimate of reserves.

© 2015 Deloitte

Actuarial FunctionBoard considerations

15

• Challenge of the Actuarial Function Report

• Education

− Best estimate > volatility

− Risk margin

− SCR target capital

− Capital coverage ratio on a Solvency I vs Solvency II basis

• Insights provided by the actuary

− Changes over time

− Materiality

− Presentation

− New communication challenges


Introduction

Actuarial Function


2015 Requirements


16

© 2015 Deloitte

Outsourcing the Actuarial FunctionMaintaining responsibility

1. Key functions under Solvency II, e.g. Actuarial Function, can be outsourced in

line with the Board approved outsourcing policy.

2. Responsibility for the function cannot be outsourced and a designated person

from within the company must assume overall responsibility for the outsourced

function. This designated person will be PCF role and must:

a) Be notified to the CBI;

b) Be fit and proper as assessed by the CBI;

c) Possess sufficient knowledge and experience regarding the outsourced

function to be able to challenge the person and results.

3. This PCF should ensure close interaction with the outsourced actuarial function

in order to ensure effective oversight and challenge as required under the

guidelines.

4. Companies who currently outsource their annual reserve reviews should re-

assess their relationship with their actuarial service provider, including

ownership of the relationship, to ensure it is fit for purpose under Solvency II.

17


Introduction

Actuarial Function


2015 Requirements

CP92 – Additional Requirements

18

© 2015 Deloitte

Next StepsRequirements for 2015

• All companies are required to comply with the CBI’s preparatory guidelines from 1

January 2015.

• The CBI has confirmed that, in line with guideline 40, “an actuarial report should

be submitted by the actuarial function of a low or medium-low undertaking to the

board of directors in 2015”.

• This report should document all tasks that have been undertaken by the actuarial

function in 2015 including their results, clearly identifying any deficiencies and giving

recommendations as to how such deficiencies should be remedied.

• All areas of the actuarial function should be covered:

o Co-ordinate the calculation of Solvency II technical provisions;

o Provide an opinion on the underwriting policy;

o Provide an opinion on the adequacy of reinsurance arrangements;

o Comply with all other requirements of article 48.

19

© 2015 Deloitte

Next StepsRequirements for 2015 YE

• As at 2015 YE all companies are required to have complied with the CBI’s preparatory

guidelines regarding the Actuarial Function.

• Therefore, by 31 December 2015 it is expected that all companies will have

complied with the requirements for an Actuarial Function under Solvency II

excluding additional requirements from CP 92.

• Heads of Actuarial Function need PCF approval by 1 January 2016.

• Companies will be required to calculate Solvency II technical provisions as at 31

December 2015 as part of the Solvency II Day 1 QRT reporting with a valuation date of

31 December 2015.

• Additionally, companies will be required to provide an Statement of Actuarial opinion to

the Central Bank of Ireland under Solvency I.

20


Introduction

Actuarial Function


2015 Requirements


21

© 2015 Deloitte

CP92 Feedback Statement 6 October 2015Key changes and clarificationsGeneral Requirements

• Outsourcing

− The CBI has clarified that the HoAF role may be outsourced for low, medium low and medium

high undertakings, but for high impact undertakings this must be an internal role.

• Role

− Some respondents queried wither the role of HoAF must be held by an actuary. The CBI has

amended the requirements to state that it expects “that the HoAF be a member of a

recognised actuarial association and have the appropriate level of experience

commensurate with the requirements of the role and the sophistication of the methodologies

and techniques appropriately employed by the undertaking.”

• ORSA

− The ORSA must address at least the following areas

• The range of risks and the adequacy of stress scenarios considered as part of the ORSA

process;

• The appropriateness of the financial projections included within the ORSA process;

• Whether the undertaking is continuously complying with the requirements

regarding the calculation of TPs and potential risks arising from the uncertainties

connected to this calculation.

− The CBI has confirmed that it won’t prescribe a form for the ORSA opinion22

© 2015 Deloitte

CP92 Feedback Statement 6 October 2015Key changes and clarifications

Actuarial Opinion on Technical Provisions

• Independence

− Respondents asked whether the HoAF should be separate from the person calculating the TPs.

The CBI has clarified that the “Actuarial Function is not excluded from calculating the TPs…”

“In cases where both calculation and validation of technical provisions is done by the actuarial

function the undertaking should have in place processes and procedures in order to avoid

conflicts of interest and ensure appropriate independence.”

• Aggregate vs LoB

− The CBI has clarified that the AOTP should be on a Solvency II Line of Business Level.

• Form of AOTP

− The CBI will issue the form of the AOTP with the final Requirements.

23

© 2015 Deloitte


Actuarial Report on Technical Provisions

• Risk Margin

− Scope of HoAF role around SCR had been unclear – wording now amended; “A description of

how the SCR, as calculated by the undertaking, has been adjusted and projected in order to

calculate the Risk Margin, including a justification of any approximation methods used in the

projection.”

• Claims Handling

− CP92 referred to “the HoAF’s opinion on the stability of the claims handling process over time”.

This has been amended to a consideration of the stability of business processes and claims

handling processes over time.

• Timing

− At least a summary of the ARTP should be provided to the Board at the same time as the

AOTPs.

Reserving Committee

• The CBI has clarified that this applies only to high impact non-life companies.

Reserving Policy

• A typo has been removed as follows: [the policy will include the] undertaking’s approach to

calculating TPs and the related objectives.24

© 2015 Deloitte


Peer Review

• ORSA

− The CBI has no plans to include the ORSA opinion within the scope of the review.

• Timing

− “The current Peer Review cycle will not recommence on implementation of these

requirements”.

• Rotation

− “Undertakings shall not commission the same Reviewing Actuary, or another actuary from the

same firm, for more than three consecutive peer reviews”.

• Independence

− “The Board of the undertaking shall be satisfied, and be in a position to demonstrate, that the

RA is appropriately independent to perform the role”.

• Independent calculations

− An independent recalculation of the TPs is not necessary but a justification should be provided if

a recalculation is not performed. ”For material non-life Lines of Business a recalculation of the

TPs is expected.”

25

© 2015 Deloitte

CP92 Feedback Statement 6 October 2015Key changes and clarification

Fitness & Probity

• The Role of the Head of the Actuarial Function (the “HoAF”) will be a PCF role and the Central Bank

is in the process of completing the due requirements to make the HoAF a PCF role.

• The CBI has commented that “where a person in situ in an insurance undertaking (on or before 31

December 2015) is performing the role of HoAF (irrespective of the title provided to that role) then,

as per the Central Bank Reform Act 2010, that person will not have to apply for approval for that

PCF role upon the commencement of the amending F&P Regulations. The Central Bank will issue

guidance regarding F&P changes under Solvency II.”.

26

© 2015 Deloitte

Standard Formula Appropriateness

Eamon Howlin, Senior Manager and

Maaz Mushir, Manager

© 2015 Deloitte© 2015 Deloitte28 Solvency II

• The undertaking should asses whether its risk profile deviates from the assumptions underlying the

Solvency II SCR calculated with the standard formula and whether these deviations are significant.

• The undertaking may as a first step perform a qualitative analysis and if that indicates that the

deviation is not significant, a quantitative assessment is not required.

Deviation from assumptions underlying the SCR calculation (EIOPA Guideline 12, CBI Guideline 15)

• Paper describing standard formula assumptions published by EIOPA

• Differences due to

‒ risks not considered and;

‒ risks that are either under or overestimated by the standard formula compared to risk profile

• Assessment process expected to include:

‒ Analysis of risk profile and why standard formula is appropriate;

‒ Analysis of sensitivity of standard formula to changes in risk profile;

‒ Assessment of the sensitivities of SCR to main parameters, including USPs;

‒ Appropriateness of standard formula parameters;

‒ Justification for simplifications;

‒ How results of standard formula are used in decision making process.

• Unlikely to directly compare SF SCR and ORSA capital e.g.

‒ may include different items, calculated on different bases, different confidence levels or different

time horizons.

Considerations

Standard Formula AppropriatenessRegulatory requirements for FLAOR/ORSA

© 2015 Deloitte

• What is EIOPA trying to achieve through asking firms to assess the

appropriateness of Standard Formula?

• Standard does not mean “one size fits all”

• What is a significant deviation?

• What if there is a significant deviation?

Solvency II

Assessing appropriateness of Standard Formula - IntroductionSF is not just a default option – it requires justification

© 2015 Deloitte

• What is a significant deviation?

Article 37 (Directive) – Capital Add-on

Following the supervisory review process supervisory authorities may in exceptional circumstances set a

capital add-on for an insurance or reinsurance undertaking by a decision stating the reasons. That

possibility shall exist only in the following cases:

• (a) the supervisory authority concludes that the risk profile of the insurance or reinsurance

undertaking deviates significantly from the assumptions underlying the Solvency

Capital Requirement, as calculated using the standard formula in accordance with Chapter

VI, Section 4, Subsection 2 and:

Article 279 (Delegated acts) – Add-ons in relation to deviations from Solvency Capital Requirement

assumptions:

‒ Where the modified Solvency Capital Requirement as calculated under Article 282(a) exceeds the Solvency

Capital Requirement as calculated under 282(b) by 10 percent or more, supervisory authorities shall

conclude that the risk profile of the insurance or reinsurance undertaking deviates significantly from the

assumptions underlying the Solvency Capital Requirement within the meaning of Article 37(1)(a) and (b) of

Directive 2009/138/EC, unless they have strong evidence that this is not the case on the basis of the

factors set out in article 276.

‒ Where the modified Solvency Capital Requirement as calculated in Article 282(a) exceeds the Solvency

Capital Requirement as calculated in 282(b) by 15 percent or more, supervisory authorities shall conclude

that the risk profile of the insurance or reinsurance undertaking deviates significantly from the assumptions

underlying the Solvency Capital Requirement within the meaning of Article 37(1)(a) and (b) of Directive

2009/138/EC.

Solvency II

Assessing appropriateness of Standard Formula - IntroductionSF is not just a default option – it requires justification

© 2015 Deloitte

Identification of all risks

Rank risks Immaterial Risks

Is the risk captured in

Standard Formula

Qualitative assessment

Is the risk quantifiable?

Quantitative Assessment

Remedial action as necessary

Reporting and documentation

Y N

Y

Y

N

N

Assessing appropriateness of Standard FormulaFramework

Solvency II

© 2015 Deloitte

• Key messages:

‒ Identify all risks company is exposed

to. These should already be

documented in the risk register.

‒ Identify risks that are immaterial

either individually or in combination

with other risks.

‒ Rank the remaining risks. A

qualitative approach may be taken to

rank risks, but a quantitative

approach is preferable.




Standard Formula






Y N

Y

Y

N

N


Solvency II

© 2015 Deloitte

• Key messages:

‒ Perform qualitative assessment for

all risks captured within Standard

Formula.

‒ Refer to EIOPA’s publication on

assumptions underlying the Standard

Formula to assist in identifying risks

not captured within the Standard

Formula.

‒ Qualitative assessment includes

• Relevance of data used to calibrate

SF to insurer’s risk profile

• Risk ranking

• Justification of simplifications

• Materiality considerations

• Analysis of how SF results are

used in decision making




Standard Formula






Y N

Y

Y

N

N


Solvency II

© 2015 Deloitte

• Key messages:

‒ Perform a quantitative assessment if

the qualitative assessment indicates

potential for material deviation or if

the risk is material.

‒ Quantitative assessment of risk

includes:

• Sensitivity of SF to changes in risk

profile, including risk mitigation

• Sensitivity of SF to parameter

changes

• Appropriateness of parameters,

including aggregation

• Assessing consistency of

parameters

‒ The detail of the assessment should

be proportional to the significance of

the risk (i.e. more rigour for more

significant risks).




Standard Formula






Y N

Y

Y

N

N


Solvency II

© 2015 Deloitte

• Key messages:

‒ For risks not captured within the

Standard Formula, assess whether

the risks are quantifiable.

‒ Perform quantitative assessment for

quantifiable risks.

‒ Document and manage non-

quantifiable risks.




Standard Formula






Y N

Y

Y

N

N


Solvency II

© 2015 Deloitte

Assessing appropriateness of Standard FormulaExamples of indicators for inappropriateness

Life insurers Non life insurers

• Mass lapse

• Asset volatility

• Longevity risk

• Contract boundaries

• PPOs

• Reinsurance

• CAT Risk

• Concentration, default, and spread risk for sovereign bonds

• Regulatory risk

• Operational risk

• Contagion risk

Solvency II

© 2015 Deloitte

• Zero capital charge on sovereign bonds for

‒ Concentration risk

‒ Default risk

‒ Spread risk

• Several insurers have captured this risk as part of their ORSA

• Difficult to calibrate a 1-in-200 scenario for this risk

Assessing appropriateness of Standard FormulaExample – sovereign bonds

Solvency II

© 2015 Deloitte

• The underlying assumptions for the operational risk module are as follows:

‒ The overall assumption in the operational risk module is that a standardised level of

risk management is present.

‒ For unit-linked businesses the characteristics are similar to those of other life

products. Therefore, the parameters will evolve in line with the life parameter.

‒ In relation to the expense volume measure for unit-linked business, it is assumed that

acquisition expenses are exclusively relating to insurance intermediaries, which do

not give rise to any operational risk.

• The main challenge is to make an assertion on these assumptions without any

benchmarking.

Standard Formula Advantages Standard Formula Limitations

• Easily understood

• Simple and easy to apply

• Cheap implementation

• Could understate capital

• Could provide a false sense of security

• Not aligned to risk profile of the

company

• Limited business applications and

benefits

Assessing appropriateness of Standard FormulaExample – operational risk

Solvency II

© 2015 Deloitte

Entities could build their own operational risk model incorporating any

internal controls/mitigation techniques

‒ Risk types based ORIC* or Basel groupings. ORIC risk groupings are

specific to insurers, whereas Basel risk groupings are specific to banks.

‒ Parameters based on judgements of relevant business experts

‒ Companies will need explicit assumptions regarding frequency, severity and

correlation

*Operational Risk Insurance Consortium, formed by Association of British Insurers (ABI).

Assessing appropriateness of Standard FormulaExample – operational risk

Solvency II

© 2015 Deloitte

• Based on the results of the

assessment companies could:

‒ Align risk profile to Standard Formula

‒ Monitor and control risks that cannot

be quantified

‒ Mitigate risk through avoidance,

transfer or diversification

‒ Address the shortcomings of

standard formula by increasing

capital targets and tolerances

(Solvency Coverage Ratio)

‒ Move to partial internal model,

internal model or undertaking specific

parameters

‒ Take additional actions based on the

outcome of the ORSA process




Standard Formula






Y N

Y

Y

N

N


Solvency II

© 2015 Deloitte

• Key messages:

‒ Full details of the assessment are not

necessary in the ORSA main report

but should be part of the ORSA

record.

‒ The process followed for assessing

appropriateness of SF, and the

results of each element of the

assessment, both qualitative and

quantitative, should to be

documented in the ORSA main

report.

‒ Documentation should include

remedial actions, if any.

‒ If relevant, highlight any particular

circumstances that could result in

significant deviations in the future.




Standard Formula






Y N

Y

Y

N

N


Solvency II

© 2015 Deloitte

Solvency II Data Management

What are the sample project deliverables ?

Solvency II

Initiate Design Develop Implement Operate

Project Definition

• Scope & Objectives

• Deliverables & Quality

• Roadmap & Phasing

• Resource & Budget

Data Architecture &

Strategy

• Define Architecture

Principles

• As Is Assessment

• As Is Data Audit

Drivers/Gap Analysis

• Regulatory Translation

Directive / level 2

• Standards for Data Quality

Data Governance Model

• Organisational Design

• Roles & Responsibilities

• Governance Committees

• Governance & Control

Process

To Be

• Target Maturity Levels

• To Be Architecture

• Org & process Design

• Map High Level E2E

functional Flows

• Controls & Monitoring

definition

• System/ Tool selection

• BI Requirements & Design

Data Dictionary

• ID materiality criteria

• Prioritise data flows

Data Policy

• Governance & People

• Systems, Process &

Controls

• Reporting & Metrics

Data Lineage, Mapping &

Control & Documentation

• Map detailed data flows

• Develop Technical &

Business controls

• EUC controls

Process & People

• Develop Issue identification

and Remediation process

• Update job specifications

BI & Data Metrics

• Identify DQ Indicators

• Develop Reports / BI

Data Industrialisation

• Value chain SLAs

• DWH / ETL / DQ tools

IT & System Readiness

• SIT / UAT

• E2E Dry Run

• Integrate into up and

downstream SII process

e.g. SCR / QRT

• Testing with External

Providers

Operational Readiness

• Implement Operating

Model including Data

Function, R&R, process

and Tools

• Roll out documentation

/procedures

• Business User / Model

Office Testing

• Training & Development

Sustain

• Monitor & Control

• Review policy, process

and procedures

• Monitor SLA with external

parties

• Embed Cultural change

© 2015 Deloitte

Solvency II - The Data Integration Challenge

How to differentiate Solvency II vendor solutions for data integration?

Solvency II

© 2015 Deloitte

Solvency II - The Pillar 3 Challenge

How to differentiate Solvency II vendor solutions for Pillar 3 reporting?

Solvency II


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