CRO Forum comments on Draft advice on Consultation Paper no. 19 "Safety measures (Limits on Assets)" The CRO Forum appreciates CEIOPS' further development of principles for the formulation and application of the supervisory tool 'Pillar II capital add-on', and welcomes the opportunity to comment on this draft advice.
We welcome this discussion document from the FSA and HMT which contains very useful principles for prudential supervision of groups in Solvency II.
While the exercise has highlighted a number of areas which require further consideration and discussion, the CRO Forum believes CEIOPS has achieved an important step in providing this new basis for discussion.
This presentation is based upon the consolidated responses of the Chief Risk Officer Forum and Comité Européen des Assurancesto CEIOPS-CP-03/06, "Draft Advice to the European Commission in the framework of the Solvency II project on subgroup supervisions, diversification effects, cooperation with third countries and issues related to the MCR and SCR in a group context."
The Chief Risk Officer Forum ('CRO Forum') comprises risk officers of the major European insurance companies and financial conglomerates, and was formed to address the key relevant risk issues. It is a technical group focused on developing and promoting industry best practices in risk management.
The Chief Risk Officer (CRO) Forum's Emerging Risk Initiative is committed to continuously improving risk management. This paper advocates as best practice a process whereby insurers and reinsurers re-examine their assumptions about frequency, severity, loss trends and how the risks in their portfolios are interconnected and generally stress test their internal processes for hitherto "unthinkable" dimensions of risks. The paper seeks to address rating agencies, analysts, governments, regulators, intermediaries and risk modelling firms alike. This study is non-binding and for reference purposes only.
The CRO Forum highly appreciates Fitch's bold and innovative step in the evolution of the assessment of an insurer's capital adequacy. We strongly support Fitch's directional move in explicitly reflecting sound economic principles. The CRO Forum is also very pleased that Fitch strongly supports company internal models for measuring capital adequacy (subject to admissibility requirements) including explicit reflection of diversification and risk mitigation.
The Chief Risk Officer Forum is delighted to be presenting the study "Financial Risk Mitigation in Insurance - Time for Change". The Chief Risk Officer Forum comprises risk officers of the major European insurance companies and financial conglomerates, and was formed to address the key relevant risk issues for its industry. It is a technical group focused on developing and promoting industry best practices in risk management.
As stated earlier, under the development of Solvency II, there is agreement amongst most parties involved that the assets and liabilities should be measured on a consistent basis for solvency purposes and this basis should be market value. In order to determine the market consistent value of liabilities, it is agreed, we need to determine a market value margin (MVM) to be added to the expected present value of future liability cash flows.
This presentation is based upon the consolidated responses of the Chief Risk Officer Forum to CEIOPS-CP-06/05, “Consultation Paper No. 9 - Draft Answers to the European Commission on the third wave of Calls for Advice in the framework of the Solvency II project.”
