WNS brings to you an extremely informative whitepaper on Solvency II, an European Union Directive that covers 30 countries. With the revised compliant deadline for Solvency II now set to January 1, 2014, this whitepaper talks about the required framework, internal models, risk management, information technology and data management, and reporting compliance and disclosures. Whitepaper is also available here http://bit.ly/9EI3o4
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Solvency II's Impact will Affect Process Efficiency in Insurance
1. Solvency II Implementation
Solvency II's Impact will Affect
Process Efficiency in Insurance
Will Your Operational Viability and
Reputation Survive in a Solvency II World?
wns.com
2. Solvency II Implementation
Solvency II's Impact will Affect
Process Efficiency in Insurance
Will Your Operational Viability and
Reputation Survive in a Solvency II World?
The Solvency II framework is based on the three-pillar
approach, almost similar to Basel II – the banking
regulation.
The three pillars of the Solvency II directive focus on
the following areas:
Pillar I – Estimation of the QUANTITATIVE
requirements
Calculation
n of Solvency Capital Requirements (SCR)
Minimum
n Capital Requirements (MCR) using
standard or internal controls
Pillar II – Evaluation of QUALITATIVE requirements
Governance
n and risk management
Self-assessment
n of capital needs and capital
n management
Risk processes and procedures
Pillar III – Disclosure of the institution's solvency and
financial situation
Ensure
n transparency and adherence to the Directive
3. Solvency II Implementation
Solvency II's Impact will Affect Process Efficiency in Insurance
Will Your Operational Viability and Reputation Survive in a Solvency II World?
Solvency II Implementation
A Daunting Task Ahead for Insurers
Implementation of Solvency II is the biggest-ever The new directive introduces a Solvency Capital
exercise in establishing a single set of rules Requirement (SCR) that is different from the
governing insurer credit-worthiness and risk target level that exists in most countries. Given
management. This European Union Directive, the various levels of maturity and sophistication
which covers over 30 countries, primarily at which the member countries are operating,
concerns the amount of capital that EU implementing the directive will be a daunting task
insurance companies must hold to reduce the for insurers and a possible operational headache!
risk of insolvency. The appropriate amount of
The challenge for implementation is both at the
capital is determined according to a set of
qualitative and quantitative levels and insurers
principles and rules.
will need to attain new capabilities or at least
This planned regulatory overhaul for European transform existing systems and processes for a
insurers is well underway and the compliant successful and meaningful implementation of
deadline has been revised to January 1, 2014. the directive. Robust systems and procedures
must be in place by the revised deadline of
According to a recent Deloitte survey, many
January 1, 2014.
insurers are still grappling with the possible
implications of Solvency II for their businesses. The challenges relate to the requirements and
The survey reveals that for insurers the implications approaches of the Solvency II directive are
will be at the levels of capital requirements, shown in the diagram below:
company structures and revising products.
Estimation of the Evaluation of
I II III QUALITATIVE
QUANTITATIVE
requirements requirements
n Calculation of Solvency n Governance and risk
Capital Requirements management
(SCR) n Self-assessment of capital
n Minimum Capital needs and capital
Requirements (MCR) n Risk management
using standard or processes and procedures
internal controls
Disclosure of the institution's solvency and financial situation
n Ensure transparency and adherence to the Directive
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4. Solvency II Implementation
New Opportunity for Insurers
While Solvency II implementation presents some Requirement (SCR) below which an insurer will
strategic and tactical challenges, it also opens likely need to discuss remedies with the regulator.
up new opportunities for insurers to innovate and
adopt a well-thought-out approach for a According to the Solvency II Directive, firms
successful implementation. Insurers who are have an option to submit regulatory capital
agile enough to respond swiftly to the changing requirements (SCR / MCR) using the standard
scenario will clearly be at a competitive or an internal model. Although the standard
advantage to outperform. formula is, by definition, more general and
straightforward, there is a view that an internal
model provides far wider business benefits such
As a part of an insurer's compliance as reduced regulatory capital, improved / wider
efforts, an integrated capital risk management, operational effectiveness,
stakeholder assurance and building a more
performance and risk management
risk-aware business culture.
framework should be implemented
to augment the insurer's capital There is no exact regulatory definition of the
'Internal Model' as such. Broadly speaking,
models to meet regulatory however, the Internal Model is the collection of
requirements. processes, systems and calculations that together
quantify the risks faced by the business. Activities
that will need carrying out include:
To be able to achieve this goal, capabilities will
need to be overhauled in the following areas. Development
n of actuarial systems (Prophet /
1. Internal models Moses / MgAlfa / Igloo) to calculate best
2. Risk management estimate liabilities, risk margins and stresses
3. Information technology and data
4. Reporting compliance and disclosures
1. Internal Models
The Draft Directive of Solvency II suggests a
two-tier approach for determination of regulatory
capital adequacy. The first tier is the Minimum
Capital Requirement (MCR), the threshold below
which an insurer would not be able to write
business. The second tier is Solvency Capital
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5. Solvency II Implementation
Solvency II's Impact will Affect Process Efficiency in Insurance
Will Your Operational Viability and Reputation Survive in a Solvency II World?
Development
n and testing of various
components of the Internal Model running
various risk scenarios and calculations,
replicating models, providing operational risk
reporting and tax and capital rules, economic
capital calculation engine / simulation,
aggregation and diversification rules
Testing
n requirements for supervisory approval:
The Use Test - The insurer will have to show
that the model is used as a decision tool in
the company's daily risk management work
The Calibration Test - The model must be
calibrated using the risk measure and While an approved full internal model measures
calibration level defined under Solvency II 'quantifiable' risks, the ORSA should consider all
The Statistical Test - It must be risks. ORSA is part of a wider risk management
demonstrated that the model is based on system requiring all risks to be identified,
relevant and quality-assured data measured, monitored, managed and reported.
Management
n training and awareness Rating agencies, analysts, shareholders, and
workshops around the internal models regulators are all taking more interest in capital
models and risk management. Effective risk
2. Risk Management management acts as the common link between
According to the Pillar II requirements, balance sheet strength, operating performance
organisations need to conduct an Own Risk and and business profile.
Solvency Assessment (ORSA) to consistently
The key components of effective risk
assess their overall solvency needs and
management programme are as follows:
compliance with capital requirements.
Align
n risk appetite and strategy
The Solvency II Framework Directive proposal Enhance
n risk response decisions
describes ORSA as a tool for risk management
systems that require insurance companies to Reduce
n operational surprises and losses
properly assess their own short- and long-term Identify
n and manage multiple and
risks and the amount of own funds necessary to cross-enterprise risks
cover them. Improving
n the deployment of capital
With Pillar II it is crucial that an insurer We assist clients in developing ORSA framework,
demonstrates that it has an effective risk embedding its implementation within a firm's
management system embedded in the business. decision-making process at management and
Conforming to this requirement of embedding operational level and developing effective MI for
risk management into the business or all the stakeholders.
implementing the 'use test' requires significant
time and resources.
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6. 3. Information Technology and Data The European Insurance and Occupational
Pensions Authority (EIOPA) has set out a number
Solvency II sets out the requirements for
of requirements for assessing the quality of data.
companies to establish systems, processes and
controls for effective risk management. Ensure
n appropriateness, completeness and
It influences many existing IT applications and accuracy of data used in the valuation of
requires development of additional functionality. technical provisions
It is prudent for insurers to take early action in Implement
n a robust quality management
investigating their company's data availability framework, including definition of the data,
and quality. In addition to data systems, the assessment of the quality of data, resolution
insurance industry is expected to make of material problems identified and
significant investments in actuarial models, monitoring data quality
IT and risk management systems.
Establish
n a comprehensive data policy for the
Insurers may need to seek assistance with collection, storage and processing of data,
implementing the information systems and including the data provided by third parties
technology requirements across the three pillars (intermediaries, for instance) or through
of the Solvency II framework. electronic sources (Internet for instance)
Agree
n with the role of internal and external
Effective Data Management auditors in validating data quality
Data is at the very core of meeting Solvency II Assess
n data deficiencies and analyze options
requirements, and it is clear that any Internal to increase the quality and quantity of
Model Approval Process (IMAP) will focus internal data, including the review of
heavily on the quality of data inputs to the internal processes
models. It is widely recognised that the increase
Document
n the adjustments made to the
frequency of Solvency II reporting will require
historical data, in particular the correction of
firms to collect and prepare data faster and
any data errors and omissions, and use of
accurately than they do today. Moreover, they
external data / market benchmarks
need to aggregate or segment data in new ways
and source additional data which they have not External
n data and market information used to
done previously. complement internal data needs to be
assessed on data quality – appropriateness,
completeness and accuracy
An Integrated Approach
For most insurers, a detailed assessment of
current systems capability brings forth two
important observations:
1. Most insurance companies maintain multiple
databases by source and function (risk,
finance, actuarial and so on). This makes
data integration and getting a single view of
customers, a challenging task.
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7. Solvency II Implementation
Solvency II's Impact will Affect Process Efficiency in Insurance
Will Your Operational Viability and Reputation Survive in a Solvency II World?
2. Considering the requirements that the will now be required to work together,
directive spells out, it will be a challenging changing the existing systems as necessary
proposition to have a single end-to-end and adding new tools where existing
technology solution to meet all Solvency II technology cannot be used to meet Solvency
requirements. An integrated approach is what II requirements.
will be the most appropriate. A schematic view of IT architecture in a
Insurers will need to deploy teams of post-Solvency II environment can be depicted
actuaries, business stakeholders and IT as follows:
specialists to integrate existing systems that
Compensation Details Real-time Access to Data
Flexing Reporting Formats
New Data Elements Historic Information
Product Systems PMS GL MIS
Integrated Layer
Integrated Layer
Integrated Layer
Channel Management Claims Statutory
Risk Management Reporting
New Business DW Customers
Customer Data Group Aggregation Board
Actuarial
Ratings Historic Client Data Reconciliation Automated Risk Calculation
4. Reporting Compliance and follow a prescribed structure developed by
The Committee of European Insurance and
Disclosures
Occupational Pensions Supervisors (CEIOPS)
Under the Solvency II regime Pillar III deals with covering the following areas: Business
the requirements for supervisory reporting and and Performance, System of Governance,
public disclosure. The objectives are to Risk Management, Regulatory Balance Sheet
harmonize reporting, promote comparability of and Capital Management
valuation and reporting rules with International
Accounting Standards and ensure efficient Reports to Supervisor (RTS)
supervision of insurance groups. The RTS is not public and is communicated
only to the firm's supervisor. In broad terms, the
The key reporting requirements are as follows: private RTS requires information on the following
Solvency and Financial Condition Report (SFCR) example areas which are not included in the
Public disclosure is expected to be made public SFCR such as business strategy, legal
available via electronic publication. The SFCR and regulatory issues, variance against plan,
will be required within three months of an projections of future solvency needs, and future
insurer's financial year end. The SFCR must risk exposure
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8. Insurers must implement a robust Pillar III Disclosure Design
programme covering the following main themes: Design the structure and principles of the
Solvency II reporting regime
Disclosure Impact Assessment
Identify the impact of the proposed requirements Disclosure Reporting Building
on existing reporting procedures (systems, data, and Implementation
people, processes and controls) Implement changes to the reporting framework
to deliver the Solvency II requirements
In Conclusion
Insurers are spending millions in order to comply Insurers who are agile enough to respond swiftly
with the impending Solvency II regulatory to the changing scenario will clearly be at a
regime. Solvency II should be seen as competitive advantage to outperform.
opportunity to refine internal processes rather
than merely a tick-box exercise, and those who Insurers able to meet this challenge will find
embrace the regime will be able to demonstrate themselves in a position to achieve significant
sound operational control and efficiency. competitive advantage and improved stakeholder
confidence. The solution in place to address
Many European insurers will not only benefit operational efficiency needs to have the
from reduced operational risk and capital flexibility to take your organization to Solvency II
adequacy requirements, but also lower operating and beyond, providing a platform for continuous
costs, improved customer service and greater process improvement and operational viability.
operational insight and to look at outsourcing as
a business strategy.
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