The Forum strongly believes the directive represents an important step toward implementing an advanced supervisory and solvency framework which will help strengthen the European insurance industry. The Forum now urges the European Commission to introduce clear and effective implementing measures that will deliver the directive's basic principles.
The Solvency II standard formula to calculate a company's Solvency Capital Requirement should present a balancing act between various targets such as simplicity, risk sensitivity and robustness. The CRO Forum believes the main principles of the current standard formula, namely to asses the sensitivity with respect to all material risk factors and to aggregate capital requirements allowing for diversification, are appropriate for this purpose and moreover set incentives towards risk mitigation strategies.
Risk capital charges in the Solvency II context reflect the 99.5% quantile on a 1-year horizon. The consistent application of risk capital charges in Solvency II to all sources of risk is imperative. Inconsistent application of risk charges creates perverse incentives for certain asset classes or insurance products.
as a basis for discussion on the implementing measures for articles 50-55 of the EU Solvency II Draft Directive. The CRO Forum advocates a principles-based approach: Section B of this paper establishes five main principles for public risk disclosure which should be adhered to by all undertakings.
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.