JAMES OKARIMIA SOLVENCY II FOR DUMMIES PRESENTATION
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Transcript of JAMES OKARIMIA SOLVENCY II FOR DUMMIES PRESENTATION
JAMES OKARIMIA - Solvency II Solutions
Presented by James J Okarimia
Calculation kernel
The central method for quantifying and modelling risk and capital requirements in the internal model.
European Commission
The executive arm of the EU, responsible for initiating new legislation and the day‐to‐day running of the EU. It has been responsible for drafting the Solvency II Framework Directive, shaping the implementation measures and evaluating its enforcement.
European Council
• Made up of representatives from each of the EU’s member states. It provides the EU with political leadership and establishes the direction of European policy. The Council and the European Parliament are responsible for passing legislation, including the Solvency II Directive.
European Insurance and Occupational Pensions Authority (EIOPA)
The EU supervisory body for insurance. It was established in January 2011 as part of wider changes to the European financial services regulatory framework and replaces the Committee of European Insurance and Occupational Pensions Supervisors (CEIOPS). EIOPA has greater legislative powers than CEIOPS and continues as the regulatory advisory body to the European Commission on Solvency II.
European Insurance and Pensions Committee (EIOPC)
An EU committee of experts from Member State finance ministries. The Committee scrutinize the implementing measures in order to develop the legal text that will operationalize Solvency II.
European Parliament
Made up of Members of the European Parliament (MEPs) elected directly by European citizens. The Parliament and the European Council are responsible for passing legislation, including the Solvency II Directive.
Internal model
A risk management system developed by an insurer to analyze their overall risk position, to quantify risks and to determine the capital required to meet those risks. Under Solvency II, an insurer may use its internal model to calculate its Solvency Capital Requirement, with the approval of its national supervisor.
Individual Capital Adequacy Standards (ICAS)
The current capital adequacy requirements regime applicable to UK insurers. The ICAS regime will be replaced by Solvency II.
Gap Analysis
An exercise undertaken by insurers to compare their existing risk and capital management processes against those required by Solvency II to identify and remedy potential gaps.
International Association of Insurance Supervisors (IAIS)
The global regulatory standard setting body for the insurance industry. It represents insurance regulators and supervisors of some 190 jurisdictions, issuing global insurance principles, standards and guidance papers.
Internal Model Approval Process (IMAP)
A process established by the Financial Services Authority to assist insurers seeking to use internal models to calculate regulatory capital requirements. Internal models must be reviewed and approved by the regulator before they can be used to calculate regulatory capital under Solvency II.
Level 1 Framework Directive
The Solvency II Framework Directive which contains the basic principles underpinning Solvency II.
Level 2 Implementing Measures
Detailed rules that allow Solvency II principles to be put into practice. The main impact of Solvency II on EU insurers is shaped by Level 2 implementing measures.
Level 3 Guidance
Supervisory standards, guidelines and recommendations to enhance convergent and effective application of Solvency II. Unlike levels 1 and 2 they are not mandatory for Member States.
Level 4 Enforcement
Post‐implementation compliance with Solvency II provisions in national laws and regulations.
Minimum Capital Requirement (MCR)
The lower of the two capital levels required by Solvency II. It represents the minimum level of capital required to be held by an insurer before ultimate regulatory intervention is triggered.
Own Risk and Solvency Assessment (ORSA)
Own Risk and Solvency Assessment – An assessment of an insurer’s processes and procedures used to identify, assess, monitor, manage, and report the short‐and long‐term risks it faces or may face and to determine the own funds necessary to ensure that its overall solvency needs are met at all times.
Own Funds
Capital, as described under Solvency II. Basic Own Funds (BOF) is the excess of assets over liabilities as determined by the EBS with any qualifying subordinated debt added back. Some forms of off‐balance‐sheet finance may receive regulatory approval to qualify as Ancillary Own Funds (AOF). Both BOF and AOF are allocated to tiers of Own Funds depending on prescribed criteria, and the SCR and the MCR both have rules regarding the extent to which the tiers of Own Funds can be used as coverage of these requirements.
Pillar 1
The portion of Solvency II focused on all the quantitative capital requirements, which cover market‐consistent valuations of assets and liabilities, calculation of available capital, capital requirements, and internal model validation. This pillar aims to ensure firms are adequately capitalized with risk‐based capital. All valuations in this pillar are to be done in a prudent and market‐consistent manner. Companies may use either the Standard Formula approach or an internal model approach. The use of internal models will be subject to stringent standards and prior supervisory approval to enable a firm to calculate its regulatory capital requirements using its own internal model.
Pillar 2The qualitative requirements, which covers the principals of internal control, governance, risk management, ORSA process, and supervisory review process. The portion of Solvency II focused on imposing higher standards of risk management and governance within a firm’s organization. This pillar also gives supervisors greater powers to challenge their firms on risk management issues. It includes ORSA, which requires a firm to undertake its own forward‐looking self‐assessment of its risks, corresponding capital requirements, and adequacy of capital resources.
Pillar 3
Market discipline, which covers disclosure requirements, both private to the supervisors and public to the marketplace. The portion of Solvency II that aims for greater levels of transparency for supervisors and the public. There is a private annual report to supervisors, and a public solvency and financial condition report that increases the level of disclosure required by firms. Any current returns will be completely replaced by reports containing core information that firms will have to make to the regulator on a quarterly and annual basis. This ensures that a firm’s overall financial position is better represented and includes more up‐to‐date information.
Quantitative Impact Study (QIS)
An exercise to test the financial impact and suitability of proposed Solvency II requirements on insurers. QIS5 is the most recent QIS exercise, conducted in 2010.
Solvency and Financial Condition Report SFCR
A public disclosure report which is required to be published annually by all insurers and will contain detailed quantitative and qualitative elements.
Solvency Capital Requirement (SCR)
The higher of the two capital levels required by Solvency II. The SCR is the prudent amount of assets to be held in excess of liabilities and is an early warning mechanism if it is breached. The SCR is calculated using either the standard formula or an approved internal model.
Standard Formula
A risk‐based mathematical formula used by insurers to calculate their Solvency Capital Requirement under Solvency II. The standard formula is intended for use by most EU insurers, although they may use an internal model instead.
Supervisory College
A group of national supervisors monitoring the activities of a cross‐border insurance group. The college provides a platform for information sharing and co‐operation between regulators.
Supervisory Review Process (SRP)
An important element of Solvency II that guides the regulators review of an insurer’s risk management and governance. It aims to ensure an insurer is well run and meets risk management standards.
Technical Provisions
The amount of capital that an insurer needs to hold in order to meet its expected future obligations arising from insurance contracts.
Third Country Equivalence
Solvency II includes provisions for assessments of the solvency regimes and systems of group supervision of countries outside the EU (termed “third countries”). The purpose of these assessments is to determine whether assessed regimes and systems are equivalent to the comparable provisions of Solvency II.
Transitional Provisions
Legislative provisions that allow certain aspects of Solvency II to be deferred, giving insurers time to adjust and manage the transition to the new regime. Transitional provisions are included in the Omnibus II Directive.
European Institutional Framework and Supervisory Architecture
Insurance Companies Supervision – Solvency II
Insurance Companies are required to become solvency II compliant by addressing a wide range of requirements, both in qualitative and quantitative aspect:To implement solvency 2 there are increasing need to support this project with different specialist on different front:
• Gap analysis, Impact analysis, with Program Roadmap • Program Governance and Project Management• Outline the linkage between Actuary, Finance, Risk, Business ,Process , Systems to support Business Solvency II Implementation
Pillar 2• Governance analysis, Design• Implement Risk appetite, Risk Limits, and Translate to Business Change• Update of business functions such as Aactuary, Risk Management, Internal Control & Audit, Compliance • Implement ORSA and Use Test• Organisational changes, Risk Culture , Attitude and Behavior.Pillar 3Internal and External Reporting to DNB and Relation to Supervisors‐ IFRS and other Reporting standard
cretiseren Aanpassingen in functies Actuariaat, Risk Management, Internal Audit, Compliancplementeren
RM Associates can support you with:• Gap analysis SII requirements vs. Current state• Readiness assements of your process,
project organisation & Internal Control• Independent health checks of SII program• Support implementation of Gap analysis findinhgs• Program managemnt & Governance• Streamline role in SII subareas for implementation
e.g. Define Risk appetite – Risk Limits – KRI’s,ORSA, Risk Managememnt & Controls etc.
• Solvency II all Pillars Implementation• Solvency II documentation
Multi‐disciplinaire Support on Different Solvency II Parts
Solvency II Support:
:
• Balance sheet evaluation
• Solvency Capital Requirements (SCR)
• Minimum Capital Requirement (MCR)
Our Value Proposition ‐ Solution & Expertise
Solvency II – Three pillar based implementation approach.
Internal controls
Risk Management
Measures of supervision
Disclosure ofInformation onRisks
ScenarioAnalyses ofAssets andtechnical Pro‐visions
Insurance Risk
Investment /Market Risk
Operational Risk
Solvency IIProtection of Policyholders against Failure of Insurance Companies
Credit Risk
Asset ‐ LiabilityMismatch
Technical provisions
MCR – MinimumCapital Require‐ments
SCR – SolvencyCapital Require‐ments
Internal controls
Risk Management Own Risk & SolvencyAssessment ‐ ORSA Measures of
supervision
Disclosure ofInformation onRisks
ScenarioAnalysis ofAssets andTechnical Pro‐visions
Technical provisions
MCR – MinimumCapital Require‐ments
SCR – SolvencyCapital Require‐ments
Pillar IFinancial Resources
Pillar IIRegulatoryReview
Pillar IIIMarket discipline
Overall govenance arrangements1. Strategy and risk appetite
Oversight arrangementsUsers test, decision and planning support
2. Technical pricing and value contribution is core imput to product design and pricingMetric to identify underperforming portfolio
Risk identification Risk assessment and measurement Risk monitoring3. Cover all types of risk Single version of truth Industrialised
analysisIdentyfying emerging risk Reflects the risk presented Control of key risks
Risk reporting and Management information4 Information to drive business decision
Clear, concise and reflective of current statusData, IT, Infrastructure
5 Intergration of risk and finance system architectureData to be consistent, complete,accurate and auditablePolicis,standards, people and culture
6 Clear ownership of task and risk decisionconsistent policies and standards
Enterprise Risk Management Framework
Insurance Enterprise Risk Management (ERM) System
All Business Units
Data Sources/Applications
Integration/ETL
ConsolidatedData
Transformation/Calculation
ResultsData Marts
Decision Supporting/Reporting
Meta Data
Software Infrastructure
Development Environment and System Management
Enterprise Risk DataConsolidation
Market Value Assets &Liabilities
Monte CarloScenarios
Stress Test
EC / EV
VaR / TaR
Solvency & Capital Adequacy
Regulatory Compliance
ALM & Stochastic Planning
…
Asset Data• In‐force Business • Credit• Derivatives• Bond Duration & Convexity• Equities• Real Estate
Liability Data• Claims• Expense
Non‐market economic Data
Market Risk Data(Volatilies, Correlations)
Integration
Extractio
n –Tran
sformation ‐Loa
dRisk Engine
(e.g., DFA Advise, MoSes, Algorithmics)
Calculating Economic Capital (EC) is becoming an important tool for insurers in guiding risk‐based decision making
• EC defines the organisation’s capital to cover potential losses at a given risk tolerance level and time horizon.
Insurance Risk Credit Risk Liquidity Risk Market Risk Operational Risk
Mortality
Lapses
Reserves
…
Defaults
Spreads
Counterparties
…
Asset / Liability Mismatch
Hedging programs
Equities
Interest rates
Real Estate
…
Distribution
System
People
Risk Aggregation
Illustrative
In the US, the calculation of Economic Capital (EC) follows a “Best estimate” liability approach
• EC is the level of assets, in addition to the Best Estimate Liability, required to pay future policyholder benefits at the chosen Security Factor.
Best Estimate Liability
Runoff risk
Pricing riskEconomic
Capital
Needed Assets
Risk‐adjusted Value Based Management (VBM)
Market Values Balance Sheet
Integrated Risk & Finance Logical Architecture View
Example Measures: RAROC, VaR, RWA, Operational, Market & Credit ReportingData Warehouse: The Bank wide data warehouse stores the raw and processed data from the calculation engines. It holds transaction level data and enables views of the data by multiple dimensions e.g. counterparty, general ledger account, functional organization, product etc. data is extracted from the business units specific systems as frequently as is required to provide timely and meaningful bank wide views of risk
RAROCCapital
ELELExpensesvenue CROR Re
CreditData
Integration & enrichment
Risk & FINANCE DW (Economic Data)-Loans & Borrowings-Economic Capital-Revenue-Expense-Budgets-Risk Capital chargesRisk & FINANCE DW-Risk Capital- Prudential Limits (RWA)-RWA for exposures-Investment Portfolio-Expected Loss ELMETA DATA & BUSINESS RULESSUPPORT-Common meta data-Business rules definitions & support
Integration & enrichment
RWA (Regulatory) Engines
Analytics EnginesEOD Calculators-VaR-Stress Testing-Back Testing-Prudential Limits-Operational Risk (viaDashboard)
INTRADAY Calculators-VaR-Trade position -Real Time Limits-Desk Level Analytics-Operational Availability(via dashboard)
Accounting Engine-P&L-RAROC-Other Accounting Measures GL
Data Mart(RegulatoryReporting)
Data Mart(EconomicReporting)
Data Mart(Operational Risk
Dashboard)
Reporting Architecture
ReportingEngine
ReportingEngine
Services APIs
RISK DIMENSIONS:
-Market Risk
-Credit Risk
-Operational Risk
-Prudential & Operational Limits
-Risk Capital Charges & Measures
1
2
3
1. Example RAPM equation for illustration
2. This represents a shared architecture for both EOD & intraday pre deal analytics 3. RISK DASHBOARD for operational quantitative & graphical risk evaluations
Financial Data
Client riskData
Market riskData
ODS’sData
Business
Actors
Traders
Debt Managers
Operations
Accounting
Management
Regulators
Compliance
Pre deal RWA
Intraday / pre
deal
analytics
Contact details – For further information
James J Okarimia Partner,RM Associates –Partners in Enterprise Risk Management
E: [email protected]: +31 (0) 62 3192 655T: +31 (0) 30 2599 455