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Moore Stephens Insight Solvency II Pillar 3 challenges
April 2016
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Pillar III Reporting and Validation
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Pillar 3 – Disclosure & Regulatory reporting
Pillar 3 high level recap of the principles Pillar 3 – Disclosure & Regulatory reporting Aims to ensure consistent supervisory reporting and disclosure across the EU Detailed harmonised reporting requirements still to be finalised Insurers should be prepared to disclose more information publicly than at present Will require two different but complementary reports: Solvency and Financial Condition Report (SFCR) Regular Supervisory Report (RSR) Supported by Quantitative Reporting Templates (QRT) s 2
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Pillar 3 – Reporting overview
Private Public Contents Report to Supervisor (RSR) Solvency & Financial Condition Report (SFCR) Target audience different Documents to be stand alone RSR has additional level of granularity over the SFCR NB – Quarterly reporting for all Reporting speeded up Qualitative Annual Executive Summary Business and Performance System of governance Risk Management Capital Management Additional disclosures on Internal Model Annex - QRT Quantitative Annual (QRT) Annual SFCR Annex – some of the QRTs Summary data Own funds, MCR & SCR Balance sheet and P&L account Asset data Revenue analysis Life liability analysis Non-life liability analysis Risk analysis Quarterly © 2016 Moore Stephens LLP 3
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Solvency I Submissions Solvency II Submissions
Pillar 3 – PRA Reporting submissions timeline* 2015 2016 2017 Solvency I Submissions March 2016 Final Solvency I submission Solvency II Submissions Preparatory phase returns Cat 1-3 firms only Day 1 returns All Directive firms and groups On-going SII returns Solos 1 Jul 2015 Annual 25 Nov 2015 Qrtly 20 May 2016 One off 26 May 2016 Q1 25 Aug 2016 Q2 25 Nov 2016 Q3 25 Feb 2017 Q4 19 May 2017 Annual + NST Groups 15 Jul 2015 Annual 6 Jan 2016 Qrtly 20 May 2016 One off 7 Jul 2016 Q1 6 Oct 2016 Q2 6 Jan Q3 7 Apr 2017 Q4 30 Jun 2017 Annual + NST * For YE 3st December firms © 2016 Moore Stephens LLP 4
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The Reporting Challenge
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Interconnectedness of Submission
Pillar 3 Challenges 01 Scale of Submission 02 Speed of Submission 03 Interconnectedness of Submission
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01 Scale of Submissions Data Sets – Pillar 3 reporting encompasses the following data sets: Balance Sheet Asset Technical Provisions Expenses Inwards & Outwards Premium Claims Exposure RI Recoveries IBNR Capital Qualitative Submissions IT Systems – Pillar 3 returns are likely to extract data from various IT systems: Insurance Administration/Booking Systems Outward Reinsurance System Reserving System Capital Modelling Software Cover Holder System/s General Ledger Data Warehouse IT Systems – Pillar 3 submissions include the following number of forms*: Variant Solvency Return Asset Data Reinsurance Returns Total Annual 40 11 8 59 Quarterly 6 - 14 *Maximum number of forms
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01 Scale of Submissions Form S has 9 triangles to complete (gross, net, reinsurance) x (paid, incurred, RBNS) 16 SII COBs x 7 SII Currencies = 112 form variants 9 Triangles x 112 variants = up to 1008 triangles Producing a full Pillar 3 submission will be a sizeable undertaking in terms of TIME and RESOURCES © 2016 Moore Stephens LLP
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02 Speed of Submissions By 2019, annual P3 submissions will be due 8 weeks after YE Quarterly submissions will required 3 weeks after the end of each quarter Stress / Scenario test results may be requested by the PRA 2-3 weeks after the end of each quarter (to maintain consistency with some of their regulatory counterparts in Europe) National Specific Templates (NSTs) will be required in addition to regular submissions annually Unless reporting process is optimised and automated it will result in a severe drain on resources and pose a real risk of regulatory breach NOT possible to prepare these submissions within the allotted timeframes using existing methods without investment in INTEGRATION and AUTOMATION Data TPs Premiums Reinsurance Collate Data Store Data Transform Data Validate Data Adjust Data Sign Off Data Create XBRL Process Example: © 2016 Moore Stephens LLP
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Interconnectedness of Submissions
03 Interconnectedness of Submissions Form Validation Submissions require that validation rules are ‘passed’ EIOPA QRT submission is associated with over 500 validation rules / 3600 cross checks Inter form validation rules will demand appropriate cross team co-ordination NOT viable to adopt a segregated approach to Pillar 3 reporting process: Interdepartmental coordination and data validation imperative © 2016 Moore Stephens LLP
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MS SII Engine vs Competition
Functionality MS SII Engine FS Assist Tagetik SII Solution Full Pillar 1 SCR calculation and SII balance sheet SCR drill down analysis for all risk categories Solvency II Technical Provision TP, SII balance and SCR projections over multiple years Stress and Scenario testing for ORSA Custom Risk MI and graphs Functionality to easily add new lines of business and forecasted business plan Interfaces with SII data warehouse and Interal models (ETL capability) Manual adjustment possible at every stage but designed for automation of key tasks Pillar 3 quantitative reporting output (QRT, SFCR and RSR) and XBRL Full Audit trail and version control Full functionality and compatible with existing risk & capital models and data sources Limited functionality and flexibility (partial solution) Not available or require additional implementation package a
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A long term cost-benefit evaluation
Investment in Integrated SII Solution (MS SII Engine) Status Quo (persist with current processes & tools) Costs: Software and Implementation Alignment and integration of current systems to SII Repository (based on proportionality) Benefits: Complete automation of P1 calculations and P3 Reports Significant reduction in production times (Typically 70% reduction in manual data entry) Substantial savings in cost of deployed resources to meet regulatory submission deadlines Compliance with SII guidelines Fully audit-trailed and data mapped Costs (High Probability – High Severity): Opportunity costs of deploying unplanned resources (external / inter-departmental) at regular intervals to meet submission deadlines Substantial drain on resources to co-ordinate inter-departmental data flow Submission errors and related operational risks arising out of unplanned, ad-hoc resource allocation Audit trailing, control and reconciliations require significant manual resource co-ordination and strict adherence to procedural set-up Breach of SII regulations Regulatory intervention / penalties Reputational damage © 2016 Moore Stephens LLP
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Moore Stephens Solvency II engine Simplifying complex Solvency II Reporting
April 2016
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Partnership between Moore Stephens and Asseco in regards to SII for the London Market
London Market Actuarial Expertise Financial DWH Expertise SII Solution Expertise 9/17/2018
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Asseco Group – EU Top 10 software company
Established in 1991 employees +1,5 bln € annual turnover 9/17/2018
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Selected Asseco clients
RSA Nordic DIFI Bulgaria 9/17/2018 16
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Asseco – Delivering to the Insurance Sector
- Asseco Group 160+ More than 160 Insurance Clients 1000+ More than Insurance Professionals on board 20+ More than 20 years experience in delivering soutions for insurance sector Our products supporting all insurance business processes
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Asseco SII Engine – Tried and tested
- Asseco Group +60 +60 SII Engine Clients Denmark is moving ahead of EIOPA Insurance companies have since 1st January 2014 reported Annual on SII for 2013 and 2014 Quarterly on SII, 3 times during 2014, 2 times during 2015 Scenario analysis, stress test, reverse stress test SII Engine is the dominant Solvency II Solution with more than 35 Danish clients. Used by 60% of DK top-10 9/17/2018
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Key design challenge and our solution
Solvency II Pillar 3 Key design challenge and our solution 9/17/2018
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SII reporting – Same version of the truth
SII data warehouse SFCR QRT Standard formula Calculation Kernel Risk management Management information Economic capital allocation Regulatory capital ORSA Reward strategy Business strategy Risk mitigation Exposure management Outward Reinsurance Purchase Asset / Liability Management Investment Decisions Management of Business Product Development Underwriting & Pricing Business Planning Financial Plans / Statements 9/17/2018
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Pillar 3 Reporting – Desired Solution
Major solution characteristics: Produces accurate results Highly automated & cost effective Covers end to end reporting process Highly auditable e.g. version control of business rules/allocations/mappings Transparent with clear data lineage Consolidates data from multiple sources Allows user entered manual adjustments Gives early site of populated templates Automated source to target reconciliation Reload capability 9/17/2018
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Our proposed solution for SII reporting
Calculates all SCRrequirements using SF technical specifications TP module Pillar 2 stress tests In- built validation Rules based reporting All PRA QRT reporting ready Readily extend to other regulatory reporting Possible to Interfaces with leading stochastic models Handles both SF and IM Built in SII data mart (option) Flexible ETL Able to handle multiple data source Granular or aggregated data SII data mapping Data Integration Reporting Capital calculation Implementation 9/17/2018
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Quantitative reporting templates - areas
PIII Submissions Dates – YE 31st December Day 1 Quantitative reporting templates - areas Due Date PRA Template name Template Code Basic Information - General S 20/5/2016 Balance Sheet S Own funds S SCR S MCR S 9/17/2018
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Quantitative reporting templates - areas
PIII Submissions Dates – YE 31st December Quarterly Quantitative reporting templates - areas Due Date PRA Template name Template Code Basic Information - General S 1st quarterly sub : 26/5/2016 Quarterly thereafter: 25/8/2016 25/11/ /2/2017 Balance Sheet S Premiums, Claims and Expenses S Assets S (List of Assets) S (Collective Investment undertakings- look-through approach) S (Open Derivatives) S (Derivatives Transactions) Own funds S Technical Provisions S MCR S 9/17/2018
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PIII Submissions Dates – YE 31st December
Annually - 20/5/2017 Template name Template Code Basic Information - General S Technical provisions S.17. S.18. (Projection of future cash flows) Balance Sheet S.02. (Balance Sheet/ Assets and Liabilities by currency) S.19. (Non- Life insurance claims) S.03. (Off-balance sheet items) S.20. (Development of the distribution of the claims incurred) S (Activity by country) S.21. (Loss distribution risk profile/ Non-life underwriting peak risks/ Non-life underwriting mass risks ) Premium claims and expenses S.05. (Premiums, claims and expenses by line of business/ Premiums, claims and expenses by country) Reinsurance S.30. (Facultative covers / Outgoing Reinsurance program) Own funds/ Variation analysis S.23. (Own funds/ Detailed information by tiers on own funds / List of items on own funds) S.31. (Share of Reinsurer) SCR S.25. (Solvency Capital Requirement - Only SF) Excess of Assets over Liabilities S.29. (Excess of Assets over Liabilities) S.27. (Non-life catastrophe risk) IGT S.36 MCR S Assets S.06. (Summary of assets/ List of assets/ Collective investment undertakings - look-through approach) S.07. (Structured products) S.08. (Derivatives) S.09. (Income/ gains and losses in the period) S.10. (Securities lending and repos) S.11. (Assets held as collateral) 9/17/2018
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SII Engine Pillar 1 & Pillar 3
Fully EIOPA and PRA Compliant SF SCR All Day 1, Quarterly Solo and Quarterly Group 9/17/2018
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A Rules Engine for multiple regulatory regimes
SII Data areas Assets data Accounting Liabilities External Other input data Data Sources Actuarial tools Finance systems Asset man Port. Man. National Bank Rating agency Rates FX 1. Data sources 5. Reporting 4. Calculation 3. Preparation 2. Collection Load/ Unload ETL DWH Input adapter Output adapter Report Calc. 1a 3 5b 4 1b 5a 2a 2b Data repository EIOPA SII EIOPA SCR Partial internal model Non-SII models EIOPA QRT UK NST Lloyds Returns UK GAAP Custom reports Lloyds SII SII Other Regulatory Own Schemas 9/17/2018
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EIOPA SII Engine – Audited and Assured
Ready to use standard solution fully compliant with the Solvency II directive Proven - in production with +60 clients in 10 different countries 35 companies have used it for more than 200 regulatory reportings 120 Pillar II Stress tests Always EIOPA SII compliant – EIOPA updates guaranteed by Asseco Pillar III 90% of Pillar III data mapped Pillar I ISAE Auditors declaration Handles both Solo & Group Group Method 1 & 2 Highly flexible Legal Entitiy setup Full Pillar I SCR per Legal Entity Aggregation on multiple levels Partial portfolio calculations RFF, Matching adjustments Solo & Group 9/17/2018
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Key functionality Standard solution for advanced but flexible handling of calculations and reporting Spreadsheet flexibility for Finance, Risk Management & Actuarial Departments Takes in any spreadsheet model and puts it under control – 5 step process Flexible handling – formulas, parameters, matrices, Aggregation Apportionments/allocations User entered adjustments – controlled and with audit trail Full transparency and drill down capabilities with clear data lineage Covers end to end reporting process Highly automated Source to target reconciliation Extensive controls and Roles & Rights management Advanced audit trails and traceability Easy configuration of Company specific reports Integrates with Moore Stephens Insurance framework and other system infrastructure 9/17/2018
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Full flexibility in regards to integration/data sourcing
SII Data areas Assets data Accounting Liabilities External Other input data Data Sources Actuarial tools Finance systems Asset man Port. Man. National Bank Rating agency Rates FX Data sources Reporting Calculation Collection and preparation Asseco offers to deliver a SII data mart and to maintain this for you. Low maintenance and high flexibility re. data source and project planning Web based interface: manual entries and MS Excel uploads Point to point integration to: Actuarial kernels, Finance systems, Asset management, ALM systems, Automated Excel uploads E-T-L to/from your data repository: IBM Oracle Microsoft SAS Institute
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SII Engine Architecture
1. Data sources 2. Collection and Preparation 3. Calculation 4. Reporting SII Data areas Assets data Accounting Liabilities External Other input data Data Sources Insurance systems Finance Asset man EDW National Bank Rating agency Rates FX Send to Regulator in XBRL NL BE Manual Entry is also and option (Optional module) Load/ Unload ETL Output adapter NL BE & Run offs Claims prov. Cash flows Premium prov. Cash flows Data Mart Market Risk Counterparty Risk Health Risk Life Risk Own schemas
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Flexibility in regards to data sourcing - Example Non-life
Run Off input SCR Non-Life results input based on calc. outside in actuarial system Best Estimates via Claims and Premiums history Per LoB – Claims and Premium
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SII Engine – Integration experience
1. Data sources 2. Collection 3. Preparation 4. Calculation 5. Reporting SII Data areas Assets data Accounting Liabilities External Other input data Data Sources Actuarial tools Finance systems Asset man Port. Man. National Bank Rating agency Rates FX Asseco SII server AAE Always SII compliant No need to develop and maintain SCR calculation systems. No need to develop and maintain QRT and FSVS reporting systems. SII data model is maintained and upgraded We have experience in regards to integration to system infrastructure with: Microsoft DWH solutions SAS Institute solutions Teradata DWH MoSes Igloo Inhouse developed TP calc. systems (Schantz Valuation) (Mo.net) SimCorp Dimension Wall street systems Barrel One Output adapter QRTs SII Engine data mart SCR
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SII Engine – Reconciliation, validations and approvals
1. Data sources 2. Collection 3. Preparation 4. Calculation 5. Reporting SII Data areas Assets data Accounting Liabilities External Other input data Data Sources Actuarial tools Finance systems Asset man Port. Man. National Bank Rating agency Rates FX Source reconciliation Approval flows Approval workflows (multiple) can be set up in connection with: Data input Data output EIOPA Cross checks Generated results Generated reports Validations Customer specific cross checks Boundary checks Validation reports – compare and alert (Management by exception) alerts Roles & Rights management Everything is audit trailed Asseco SII server AAE Output adapter QRTs SII Engine data mart SCR
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Latest EIOPA QRTs EIOPA QRTs Day 1 reports SFCR and RSR Cross checks
35 EIOPA QRTs Annual Quarterly Solo Group Day 1 reports SFCR and RSR Cross checks Validations XBRL Custom reporting Lloyds Return UK NST
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Client Case RSA Nordic 9/17/2018 SII for +5 European countries
IBM RSA Nordic SAS SII for +5 European countries Detailing the SII data governance for the Group Both Internal model and Standard formula Solo and Group reporting for UK Group reporting for all European companies based on consolidated data and applied Group adjustments SII for 4 Nordic companies Both Internal model and Standard formula Reporting in 2 different countries Solo and Group reporting Delivering SII data to RSA HQ 9/17/2018
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Client Case SAS Client Case
Asseco integrates the SII data mart to your data warehouse, which enables you to: Full insight to required SII data input – SCR and QRTs Ease the identification of data gaps Prepare full data in own DW Reuse existing DW governance Reuse existing ETL Utilize existing data quality assurance routines Use existing SOP’s & system support correcting data Work on multiple reporting periods simultaneously Check completeness of input data set Validate data inputs Customize your own set of tables and add to SII Engine data mart Utilize SII data for other purposes (Internal reporting, BI, pricing modules etc. ) SAS Client Case SII Engine integrated to DW using data mart Integrated within 3 months 15-20 Asseco man-days (same for client). Deployed to SAS Technology DW Igloo actuarial kernel 99% of data volume is data sourced automatically 9/17/2018
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A coherent and controlled Solvency II performance
Client Case One solution Fast installation (1 week) – complementing existing systems Integrated Teradata DWH, SAS Institute Analytics, MoSes, Wall Street systems Secure Web based solution Easy & secure access, no matter the location. EIOPA compliant Always in accordance with Solvency II specifications by EIOPA Local flexibility Easy to adapt to National Specific requirem. Controls and audit trails User management, controls and complete audit trails across entire organization. Client Case SII Engine integrated to DW using data mart Integrated within 6 months 15-20 Asseco man-days Deployed to Teradata and SAS Technology DW MoSes actuarial kernel Partial internal model A coherent and controlled Solvency II performance
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Client Case – Life assurance firm
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Control the differences
Diverse reporting requirements HQ required templates EIOPA templates National specific templates Excel, XBRL, XML, Others Comply with requirements from HQ level to subsidiary level. HQ Regulator HQ QRT Sub 1 Reports Sub x Reports Control, transparency and audit trails All templates and reports can be shipped between different companies in the Group, fully controlled and in a complete transparent and auditable environment. Sub X Regulator QRTs Manage differences between subsidiaries, and make sure the group is compliant and coherent in all SII reporting matters HQ Reports SCR Calc.
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Stress and Reverse Stress testing
SII Engine Pillar 2 Capital projections Stress and Reverse Stress testing
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SII Engine – Pillar II Stress testing
Ready to use standard solution fully compliant with the Solvency II directive Proven - in production with +50 clients in 7 different countries 35 companies have used it for more than 200 regulatory reportings 100 Pillar II Stress tests Always EIOPA SII compliant – EIOPA updates guaranteed by Asseco Pillar I Pillar III 90% of Pillar III data mapped ISAE Auditors declaration Pillar II Stress test, reverse stress test and sensitivity analysis Forward looking - SCR - SII Balance Support of ORSA process System of Governance ORSA Reports Risk Appetite Etc.
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SII Compliance & Risk Management
Policies and Guidelines Process Capital planning Forward looking assesment Stress test & scenarios Risk identification Risk evaluation Risk handling Risk monitoring and reporting Risk appetite 7. Earnings risk 8. Strategic risk 9. Liquidity risk 10.Operational risik 11.Control risik 12.Settlement risk 13.Reputuational risk 1.Non-life risk 2.Life risk 3.Market risk 4.Counterparty risk 5.Health risk 6.Concentration risk 9/17/2018
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Forward looking assessment SCR and SII Balance sheet
Base year for the Forward Looking assesment is the current SCR calculations Base year Capital plan Input 3-5 year Strategy & Growth forecast
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Regulator’s predefined stress and reverse stress test scenarios
Base year Stress factors can e.g. include: Interest rate risk - yield curve Equity shocks Property shocks Spread risk - decrease in market value of bonds Type 1 Counterparty risk Premium growth - Line of Business volume changes Catastrophe risk - e.g. Windstorm Claims provision changes Premium provision changes Stress test module Multiple periods
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Multiple period stress testing - single factor and/or multi factor
Single period Single Factor Multi Factor Multi period Base year Stress test module Multiple periods
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Custom reporting MI All risks Company relevant risks Risk per risk group or risk driver Top 10 risks Risk maps Realised vs. Risk appetite Historic comparisons Reports per risk ambassador or risk owner Variables can be customised to client specific requirements. SII engine is very flexible and you customise the reporting to your operations. In summary its has functionality includes Base year SCR, SII Balance sheet and Own fund calculation SII Technical Provisions (TP) TP, SII balance and SCR projections over N number of years Year on year SCR for analysis for all risk categories – assist with better setting of risk appetite and decisions making Pillar 3 quantitative reporting output (QRT, SFCR and RSR) Manual adjustment possible at every stage but designed for automation of key tasks Stress and Scenario testing projections Interfaces with SII data warehouse Allows drill down risk MI Functionality to easily add new lines of business and forecasted business plan Produces Graphs of solvency ratio and other KRI output (we can bespoke to firms needs) Full Audit trail and version control AND NO NASTY EMISSIONS
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Further information Omar Ripon Partner omar.ripon@moorestephens.com
David Sweet Bo Ørskov Koldenborg
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