Consultation papers from EIOPA and the FSAIn the first half of November a number of key consultation documents were published by EIOPA and the FSA. EIOPA published CP008 on the ORSA and CP009 on reporting and public disclosure. While the FSA launched two public consultations, CP11/23: Solvency II and linked long-term insurance business, and CP11/22 the first of two documents on the transposition of Solvency II into UK law.
EIOPA CP008 – consultation paper on the ORSALaunch 7 November 2011 Close: 20 January 2012 The purpose of this public consultation is to gain insights on the impacts, costs and benefits of the ORSA and not, according to EIOPA, to revisit the conclusions that were drawn in the impact assessment undertaken on the Solvency II Directive. CP008 stated that the consultation will also assess the potential impact of the ORSA on “pricing, design and availability of insurance products, the corresponding effects for consumers and the wider social or economic impacts even if indirectly.” EIOPA said it did not expect the current discussions on the Omnibus II Directive and the future adoption of the proposal for a Delegated Act by the European Commission to affect the ORSA consultation. The Omnibus II text is expected to be finalised by the end of Q1 2012. CP008 – Consultation Paper On the Proposal for Guidelines on Own Risk and Solvency Assessment and a template for comments are available on the consultation papers section of the EIOPA website.
EIOPA CP009 – consultation paper on Pillar III reporting and public disclosureLaunch 8 November 2011 Close: 20 January 2012 CP009 covers the Quantitative Reporting Templates (QRTs) and guidelines on Narrative Public Disclosure & Supervisory Reporting, Predefined Events and Processes for Reporting and Disclosure. The consultation is based on the latest status of the draft Delegated Act (Level 2 text), in the form of working documents circulated to EIOPA by the European Commission. This Delegated Act is not yet finalized and has not yet been made public. According to the cover note issued with the consultation, “While these adjustments should not have a material impact on the content of the QRTs and the guidelines, it is expected that the impact from the following elements will have to be taken into account:
- a. Possible introduction of counter-cyclical & matching premiums;
- b. Treatment of Expected Profits Included in Future Premiums (EPIFP);
- c. Treatment of Participations;
- d. Treatment of Ring-Fenced Funds (RFF);
- e. Treatment of Branches of 3rd country (non-EEA) undertakings;
- f. Modification of certain SCR modules (e.g. property risk, structured products risk, CAT risk).
- g. Adaptations in regular financial stability-oriented analysis.”