The CRO Forum companies have developed internal capital models, which they expect to be approved by the regulators as a basis for setting the level of target capital ('SCR'). The CRO Forum companies have also participated in QIS4.
Over the past 3-4 years a tremendous amount of positive energy and resource has been expended in the name of improving the efficiency and effectiveness of the oversight of insurance entities, globally, by regulatory and supervisory bodies, industry associations and commentators alike. The CRO Forum is pleased at the pace and direction of the changes under consideration. However it has also become clear that in the course of the wider dialogue, confusion has sometimes arisen about the intended meaning about certain principles and elements of suggested implementation frameworks. Moreover, parallel discussions in the field of financial accounting have meant some terminology has dual meanings.
Thank you for your letter dated 3 June 2008 asking for our views on the European harmonisation of reporting formats. I am pleased to provide you with the CRO Forum answers on your specific questions. Concerning your first question; we agree that the suggested timetable should be in line with the Solvency II project. There are many good reasons for this. Firstly, the current framework differs across jurisdictions and the underlying data is not consistent as Members States apply different valuation bases. Therefore, using the current fragmented supervisory landscape as a starting point for a European wide reporting format would not be appropriate and we need the harmonization of principles that Solvency II brings.
It is obvious that the Standard Formula does not exhibit full risk sensitivity at every individual company level, as the sensitivity to risks is individually set e.g. through risk mitigation measures the company might have chosen. We welcome the steps taken in the framework directive to promote good risk management and want to encourage the Commission to appropriately reflect the diversity in risk exposure and risk profiles existing in the insurance industry. Solvency II should make use of data and expertise in the industry to the largest extent possible
Supervisory Powers - further advice' We welcome the opportunity to comment on this draft advice. The CRO Forum believes it is key to have appropriate harmonisation of supervisory powers, next to an adequate solvency system.
The CRO Forum companies have developed internal capital models, which they expect to be approved by the regulators as a basis for setting the level of target capital ('SCR'). The CRO Forum companies have also participated in QIS3.
We have been an active participant in the Solvency II discussions that have taken place before the publication of the Solvency II directive promoting a risk-based and economic approach. We have therefore published a number of own initiatives papers on issues covering the cost of capital approach to market value margin (MVM), diversification benefits, internal models and financial risk mitigation and has responded to CEIOPS consultation papers.
CRO Forum comments on Consultation Paper no. 20 "Pillar I issues - further advice" We welcome the opportunity to comment on this draft advice. The CRO Forum believes that the issues covered by this Consultations paper are key for the future solvency regulation. In this regard, the CRO Forum welcomes this Consultation paper, which develops further some of the points already discussed in the previous calls for advice. Since then, we believe that the QIS II exercise provided with a lot of useful information and feedback from the industry, and also that the political guidelines from the European Commission have been specified on a number of issues.
CRO Forum comments on Consultation Paper no. 16 "Pillar II issues relevant for reinsurance"
