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19 March 2012 Alastair Evans, Head Government Policy & Affairs, Lloyd’s Reforming european and uk financial regulation
© Lloyd’sReforming European and UK Regulation 19 March Contents 1.Insurance Legislative and Regulatory Environment 2.Reform of UK Financial Regulation 3.Solvency II
© Lloyd’sReforming European and UK Regulation 19 March Insurance Legislative and Regulatory Environment Lloyd’s Formidable array of debates, challenges and change internationally, affecting both the substance and architecture of insurance regulation. Individual countries, e.g. US (Dodd-Frank, establishment of FIO). EU: ESRB, EIOPA, Solvency II, revision of Mediation Directive, insurance guarantee schemes, data protection, anti-discrimination proposals (gender, age and disability) Globally: work of IAIS on systemic risk, regulation of internationally active insurance groups.
© Lloyd’sReforming European and UK Regulation 19 March Global environment IOPS WTO WB IMF NAIC OECD UNEP NCOIL European Parliament Council/ EU Presidency European Commission EIOPA FSC Economic & Social Committee FCC EFC SANCO EMPL EU EFRAG EIOPC ENV ARC IASB TAXUD COMP TRADE ENTR TREN AGRI European Central Bank ECON EMPL ENVI ITRE INTA JURI Insurance mediation Occupational pensions Solvency II Insurance groups IFRIC = central bodies = representation of States Financial stability ECJ IAIS IMCO MARKT The Lobbying Environment FSB IAA/EAG Joint Forum G 20 CESR Lloyd’s ESRB
© Lloyd’sReforming European and UK Regulation 19 March Reform of UK Financial Regulation Reforms were principally a response to the banking crisis. Government’s first condoc (July 2010): insurance supervision hardly mentioned. Insurance has different features from banking (business model, performance during crisis). New structure applies across the financial sector.
© Lloyd’sReforming European and UK Regulation 19 March Reform of UK Financial Regulation (cont’d) Main issues identified in our responses: FPC should have access to sufficient levels insurance expertise. PRA should include a separate insurance division headed by individual of same level of seniority as for banking. PRA and FCA must be under obligation to publicly consult on rules.
© Lloyd’sReforming European and UK Regulation 19 March Reform of UK Financial Regulation (cont’d) The regulatory bodies’ rule making process must be subject to the full range of statutory safeguards that exist under FSMA. There must be proper co-ordination between the new regulatory authorities. There must be proper co-ordination between the authorities in making input into EU debates. Transitional arrangements must be well managed given other regulatory challenges currently faced by the insurance industry PRA should prudentially supervise Lloyd’s market. Supervisory co- operation arrangements between regulator and Lloyd’s should continue.
© Lloyd’sReforming European and UK Regulation 19 March Reform of UK Financial Regulation (cont’d) These concerns largely taken on board by Government in recent condocs, in draft Financial Services Bill and proposed Memorandum of Understanding between the regulators. Welcome establishment of shadow PRA and FCA teams within FSA. Will continue to monitor draft Financial Services Bill closely.
© Lloyd’sReforming European and UK Regulation 19 March Solvency II Complete overhaul of EU system of insurance supervision. Objectives Three Pillars Omnibus II/Level 2 measures. Challenging Legislative Timetable Some unresolved issues (length of provisional equivalence period for third countries, currency risk). Lloyd’s: £300m expenditure on preparation. Supportive of overall regime. 2014: implementation date for firms.
© Lloyd’sReforming European and UK Regulation 19 March
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