On 11 April, the Prudential Regulation Authority (PRA) issued a Consultation Paper in which it sets out its proposal to consider applications from internal model firms that include a Dynamic Volatility Adjustment. This proposal is relevant to Solvency II firms in the UK and the Society of Lloyd’s and its managing agents. It is also relevant to firms with, or seeking, Volatility Adjustment approval that use, or may develop in the future, a full or partial internal model to determine the Solvency Capital Requirement (SCR). Milliman’s Robert Bugg and Lyndsay Wrobel offer some perspective in this briefing note.
Solvency II went live on 1 January 2016 and introduced a number of new disclosure requirements for European insurers. Each insurer is now required to publish annually a Solvency and Financial Condition Report, including some Quantitative Reporting Templates. This European analysis of the non-life market by Milliman’s Marcin Krzykowski and Jarosław Lech covers 140 companies from 11 countries, which together comprise more than €141 billion of gross written premium (GWP) and nearly €224 billion of gross technical provisions, and our Polish analysis is based on 14 solo companies pursuing non-life business in Poland, representing circa 89% of the GWP of the Polish non-life market in 2016.
Solvency II came into effect on 1 January 2016 and introduced a number of disclosure requirements for European insurers. Under the new requirements, the majority of European insurers were required to publish detailed Solvency and Financial Condition Reports for the first time in May 2017. This analysis of the European life insurance market by Milliman’s Marcin Krzykowski and Jarosław Lech covers 200 companies from 13 countries, representing approximately €475 billion in gross written premium and approximately €4,700 billion of gross technical provisions.
For a number of years now, legislators from around the globe have poured huge energy and resources into assisting with the development, and in some cases complete reworking, of their prudential regulatory regimes. Local regulatory authorities have been similarly active in the implementation of these changes. Finally, the dust is starting to settle on this latest wave of change, with the likes of Solvency II for insurers now in place in Europe, and the Own Risk and Solvency Assessment (ORSA), in its various guises, firmly recognised globally as a key cornerstone of best practice when it comes to sound solvency management.
Now attention is slowly but surely starting to turn to conduct, the second key function of regulatory authorities, and legislators have become active again. Recent years have seen conduct risk push its way ever higher up the agenda. What do we mean by conduct risk though? The International Association of Insurance Supervisors (IAIS) has succinctly described it as ‘the risk to customers, insurers, the insurance sector or the insurance market that arises from insurers and/or intermediaries conducting their business in a way that does not ensure fair treatment of customers.’ The chair of the Financial Stability Board (FSB) has stated that ‘the scale of misconduct in some financial institutions has risen to a level that has the potential to create systemic risks.’ Such observations have served to further place conduct risk management in the spotlight, not just in the insurance industry but across the whole spectrum of financial services firms.
So what has been happening in this space? At a global level, the IAIS and the FSB have both been active. The IAIS has, through its Insurance Core Principles (ICPs), set out a number of key conduct requirements, namely suitability of persons (ICP5), corporate governance (ICP7), risk management and internal controls (ICP8) and conduct of business (ICP19). The FSB, charged with developing and promulgating global financial policies designed to minimise the likelihood of another financial crisis, has published a number of reports on measures to tackle misconduct in financial services. In May last year, it published a report setting out the next steps in its work to consider the role that governance frameworks have to play in reducing misconduct. It listed the following five themes as key elements of conduct risk management:
1. Clearly defined corporate strategy and risk appetite with relevant controls.
2. Appropriate expertise, stature, responsibility, independence, prudence, transparency and oversight on the part of board members and control functions.
3. Corporate culture.
4. Effective control environment.
5. Appropriate people management and incentives.
Solvency II represents a radical shift in the way that European insurance regulation works, and the authors of a new Milliman paper believe it will fundamentally change the way European insurers view risk and returns. In this paper, Milliman consultants Ed Morgan and Jeremy Kent introduce a new methodology for measuring new business value and new business profitability in this Solvency II world.
In February 2017, the Central Bank of Ireland published letters on its website relating to its review of the consistency of Solvency II life insurance pricing and reserving assumptions. This briefing note by Milliman’s Aisling Barrett and Sinéad Clarke summarises the contents of these letters. The authors also reference the contents of the December 2016 industry letter on the standard formula Solvency Capital Requirement.