1. 4. Solvency II – Own Risk and Solvency Assessment (ORSA)
Insurance and Reinsurance Stakeholder Group meeting
12 December 2011

2. Solvency II - ORSA Development process of EIOPA guidelines on ORSA
General framework
objectives and means
details on the ORSA requirements
Towards a formal opinion from the Insurance and Reinsurance Stakeholder Group

3. Development process of EIOPA guidelines on ORSA
2008:
CEIOPS Consultation Paper on ORSA
January-March 2011:
Pre-consultation on draft guidelines
June 2011:
Pre-consultation stakeholders meeting
November 2011 –
20 January 2012:
Public consultation
Discussion with Insurance and Reinsurance Stakeholder Group
IRSG to provide formal opinion by 20 January
EIOPA has received quite positive feedback from the industry and clarified following issues were clarified:
What are quantifiable and non-quantifiable risks under the part of the overall solvency needs.
What is a significant deviation from the assumptions underlying the SCR: this is only about whether material quantifiable risks are not covered by the SCR and does not take into account the overall situation of the undertaking.
Supervisory reporting will be separated from the Regular Supervisory Report to allow immediate reporting following the conclusion of an ORSA.
Third-country undertakings are not required to produce a solo ORSA, but this does not preclude them from being captured as part of the group ORSA.
Although the consolidation method includes implicitly the impact of diversification benefits, it remains highly valuable, both for undertakings and supervisors, to provide an appropriate explanation of the sources of diversification benefits.

4. General framework Solvency II Directive contains high-level principles
Recital 36 => important background information on ORSA
Art. 36 => ORSA will be reviewed by supervisor
Art. 45 => principles for the ORSA
Art. 246 => group ORSA
No Delegated Act details expected
Guidelines from EIOPA to specify the expectations

5. Objectives of ORSA in Solvency II
ORSA is a tool to improve the risk management of EU (re)insurers by
promoting a better understanding of the company’s overall solvency needs
disclosing sufficient and clear information on a company’s risk profile
enhancing the board responsibility not to take on more risks than the capital base is allowing.

6. It all starts from the top …
EIOPA
It all starts from the top …
It is a core responsibility of the board not to take on more risks than the capital base is allowing
Share
holder
Share
holder
Share
holder
Owners
Capital base
Selection of representatives
Capital for running the company e.g. mitigating risks
Elected board
Day-to-day operation
Organisation

7. … and forms an integral part of the business strategy …
EIOPA
… and forms an integral part of the business strategy …
Employees need to be “fit” to execute their tasks
By written procedures
Implementation
Reporting
Control
Audit
Commentary
What are the requirements corresponding to the risk appetite of the supervisory body?
The requirements reflect how important the individual elements are.
Board of directors
Strategy
Policies
Executive team
Delegation
Business processes
Employees
Day to day business

8. … by asking the right questions….
Identifying risks
Decision on capital
Sensitivity analyses
Undertaking specific stresses
External stress
Going concern
Impact on SCR?
Quantification and mgt actions
Process steps
B: ”What are the risks that this company might face during the strategic planning period (e.g. 3-5 years)?”
E: Delivers an overall picture of the risks pronounced in quantitative figures and qualitative terms
B: Decision on which risks are mitigated by capital and which are mitigated by management actions only (e.g. reputational risk) E:
B: Asks to quantify risks and develop suitable management actions for non-capital covered risks
E: Quantifies risk by use of the organisation and develops suitable management actions
B: “How robust is the assessment of risks? What is the quality of key processes involved (e.g. claims handling)?
E: Conducts sensitivity analyses and calculates impact on capital needs
B: “What are possible future scenarios that we will have to navigate and what is the likely impact?”
E: Conducts undertaking specific stress tests and calculates impact on capital needs as well as developing suitable management actions
B: “What external stresses have not been taking into account already?”
E: Conducts external stresses, some of which might be contained in the SCR-calculation, and calculates impact on capital needs as well as developing suitable management actions
B: “What are the key assumptions underlying going concern?”
E: Identifies key assumptions
B: “Is the resulting understanding of risks and assumptions reflected in the basis (assumptions, structure, model) for the standard SCR-calculation or internal model, respectively
E: Evaluates impact and modifies SCR-calculation if needed
B ꞊ Board of directors
E ꞊ Executive team (by use of the organisation)

9. … and finding the right solutions…
Risk picture
Overall solvency needs
Identifying risks
Decision on capital
Sensitivity analyses
Undertaking specific stresses
External stress
Going concern
Impact on SCR?
Quantification and mgt actions
Insurance
risk
Credit
Market
Liquidity
Operational
Risk aggregation
Capital requirement
Expressed in quantitative and qualitative terms
Connects business planning to overall solvency needs
Explicit identification of possible future scenarios
Managing external stress
Assess quality of processes and input
Others
and with mgt. actions
“Proof” of SCR-calculation
Meet with capital
Review assumptions for SCR-calculation
Review risk picture in SCR-calculation
Management actions for future scenarios:
Develop risk awareness and contingency planning on a regular basis
Impact on strategy
Review assumptions for business model
Review control and governance

10. … for “solo” undertakings and groups.
Scope of the group ORSA:
Includes third country undertakings, regulated non-EEA and non-regulated undertakings
Overall solvency needs of the group:
Covers all group-specific risks and interdependencies taking into account the specificities of the group
Key drivers of diversification
Group ORSA report:
Language of the Group RSR, in case of single possibility to rquire translation of solo parts for solo supervisors
For single ORSA report: explanation on how subsidiaries are covered and board has been involved in group ORSA

11. To conclude: ORSA in a nutshell
EIOPA
To conclude: ORSA in a nutshell
ORSA is a risk management process owned by the board which changes the viewing angle from bottom-up to top-down and connects business strategy and capital planning.
Two main goals: The board should know that the company can “afford” its strategic plan 3-5 years ahead including bumps on the way and the board should know how to execute its strategic plan
Introducing ORSA is a demanding task for the board
There is no fixed recipe for an ORSA
ORSA is not an internal model, nor a capital add-on
ORSA is an integral part of the business strategy and needs to be performed at least annually, has to be performed whenever the risk profile changes significantly, has to be documented and has to be reported internally and to the supervisor

12. Towards a formal opinion of the IRSG: areas of attention
Style Question 1 Are the guidelines and recommendations clear and will they help the undertaking understand what they are expected to achieve under the requirements of the Solvency II Directive? Content Question 2 Are there any other areas in the scope of Articles 45 and 246 of the Directive where guidelines and recommendations would be useful? Question 3 Are there any practical or operational issues with the application process which can be identified by undertakings? If so, how could they be addressed?

13. Areas for discussion with the IRSG
Impact
Question 4 Do you agree with the analysis of the costs and benefits for the implementation of the guidelines and recommendations? Are there other costs and negative impacts EIOPA should consider? What benefits may flow from the proposed guidelines and recommendations?
For example, what would be the potential impact of ORSA on the pricing, design and availability of insurance products, the corresponding effects for consumers and the wider social or economic impacts even if indirectly?
Other?

14. Thank you!