dr. onur acar risk manager mapfre genel insurance risk management practices in solvency ii
TRANSCRIPT
Dr. Onur ACARRisk ManagerMapfre Genel Insurance
Risk Management Practices in Solvency II
• It is the proposed new EU legislation which will govern the capital requirements of insurance companies.
• Disadvantages of Solvency I which entered into force in 1970s:– Capital is not adequately directed to risks– Rules conflict with good risk management– A lack of harmonisation across the EU
• Solvency II is an opportunity for a better and more appropriate risk based solvency regime
What is Solvency II?
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Solvency II : 3 Pillars
• It is not only a capital calculation system but it is based on 3 Pillars:
- Pillar I, which focuses on quantitative requirements
- Pillar II, which focuses on qualitative requirements and supervisory activities
- Pillar III, which addresses supervisory and public disclosure of financial and other information
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Solvency II: 3 Pillar Approach
SOLVENCY II
Governance
Supervisory review
PILLAR 1
Financial reporting
Transparency
QualitativeRequirements Market discipline
PILLAR 2 PILLAR 3
SCR and MCR
Technical reserves
Own funds
GROUP ISSUES
Quantitativerequirements
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Aims of Solvency II
• Strong, effective policyholder protection with optimal capital allocation
• Proportionate, risk-based approach to supervision with appropriate treatment both for small and large companies
• To incentivise more sophisticated risk management tools
• To increase competition within the EU insurance markets and the global competitiveness of the EU insurers
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Where do we stand in the Solvency II process?2005 2006 2007 2008 2009 2010 2011
Directive Development(Commission)
Directive Adoption(Council &
Parliament)
Level 2 & 3(EC & CEIOPS)
CEIOPS work on Pillar I
CEIOPS work on Pillars II and III
CEIOPS advice on Implementing Measures
QIS5QIS 1 QIS 2 QIS 3 QIS 4
CEIOPSadvice on
Proportionality& Groups
Industry gets prepared
CEIOPS work on L3
2012
Transposition1 Jan 2014 ?
Risk-based economic model• A risk-based economic model implies an increased accuracy of the
solvency assessment, closer to the true risk profile of the insurance company.
• The main principles of a true economic risk-based model are:
- A Total Balance Sheet approach: market consistent valuation of all assets and liabilities in the balance sheet
- Addressing risk diversification effects: within the same risk, between risks, between companies, between geographical areas
- Addressing risk mitigation effects: reinsurance and ART
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Solvency Capital Requirement (SCR)Target Capital that an entity should aim to meet under normal operating conditions
Dropping below SCR does not necessarily require immediate supervisory intervention
Minimum Capital Requirement (MCR)Reflects a level of capital below which ultimate supervisory action could be triggered
Ladder of InterventionAn appropriate ladder of intervention if the available capital falls below SCR
Internal Model
Standard Approach
Market -consistent Value of
Liabilities
Level of MCR
Level of SCR
Ladder of Intervention
Solvency II: Capital Requirement Levels
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SCR
BSCR SCRop
SCRintangSCRhealth SCRnon-lifeSCRdef SCRlife
Adj.
SCRmarket
MktfxHealthSLT
HealthNonSLT
HealthCAT
NLPrem&Res
HealthMort
HealthLong
HealthDisMorb
HealthExp
HealthSLTLapse
HealthRev
HealthPrem&Res
LifeMortLifeMort
LifeLong
LifeDis/Morb
LifeLapse
LifeExp
Mktprop
Mktint
Mkteq
Mktsp= adjustment for the risk mitigating effect of future profit sharing
HealthCAT
HealthNSLTLapse
Mktilliq
SCR CALCULATION
System of Governance in Solvency II
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The functions included in the system of governance are considered to be key functions and consequently also important and critical functions.
• The system of governance should:– be proportionate to the nature, scale and complexity of the operations of
the insurer– include an adequate transparent organisational structure with a clear
allocation and appropriate segregation of responsibilities and an effective system for ensuring the transmission of information
– be subject to regular internal review
• Governance is crucial because:– Solvency II is a flexible system– There are risks that cannot be properly quantified– There are internal models
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System of Governance in Solvency II
Management Body
Fit and Proper Requirements
Internal Control
Internal Audit
Actuarial Function
Management body has the ultimate responsability to establish an effective system of governance which provide for sound and prudent management of the business.
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Governance – Management Body
Risk Management
All persons who effectively run the undertaking or have other key functions should be fit and proper.
Their professional qualifications, knowledge and experience should be adequate to enable sound and prudent management (fit)
They should be of good repute (proper)
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Governance – Fit and Proper RequirementsManagement Body
Fit and Proper Requirements
Internal Control
Internal Audit
Actuarial Function
Risk Management
Companies should have an effective internal control function that should include:
administrative and accounting proceduresappropriate reporting arrangements at all levels of the company a compliance function
Compliance function should include:
advising the management body on compliance with laws, regulations and administrative provisions an assessment of the possible impact of any changes in the legal environment on the operations of the company
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Governance – Internal ControlManagement Body
Fit and Proper Requirements
Internal Control
Internal Audit
Actuarial Function
Risk Management
Companies should have an effective internal audit function that should:
include an evaluation of the adequacy and effectiveness of the internal control system and other elements of the system of governance. be objective and independent from the operational functions.
Any findings and recommendations of the internal audit should be reported to the management body which should determine what actions are to be taken.
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Governance – Internal AuditManagement Body
Fit and Proper Requirements
Internal Control
Internal Audit
Actuarial Function
Risk Management
Companies should have an effective actuarial function to:
ensure the appropriateness of the methodologies and models used in the calculation of technical provisionsinform the management body regarding the reliability and adequacy of the calculation of technical provisionsexpress an opinion on the overall underwriting and reinsurance policycontribute to the effective implementation of the risk management system
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Governance – Actuarial FunctionManagement Body
Fit and Proper Requirements
Internal Control
Internal Audit
Actuarial Function
Risk Management
Companies should have an effective risk management system comprising strategies, processes and procedures necessary to identify, measure, monitor, manage and report the risks they face.
It needs to be integrated into the decision making process of the company.
The management body should have the ultimate responsibility for ensuringthat the implemented risk management system is suitable, effective andproportionate to the nature, scale and complexity of the risks.
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Governance – Risk ManagementManagement Body
Fit and Proper Requirements
Internal Control
Internal Audit
Actuarial Function
Risk Management
Tasks of the Risk Management Function
• Assisting the management body in the effective operation of the risk management system
• Monitoring the risk management system• Maintaining an organisation-wide and aggregated view on the risk profile
of the company• Reporting details on risk exposures and advising the management body
with regard to risk management matters• Identifying and assessing emerging risks
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Operational Risk
The risk of loss arising from inadequate or failed internal processes, personnel or systems, or from external events
Liquidity Risk
The risk that the company is unable to realise investments and other assets in order to settle its financial obligations when they fall due
Underwriting Risk
The risk of loss in the value of insurance liabilities, due to inadequate pricing and provisioning assumptions
Market Risk
The risk of loss in the financial situation resulting from fluctuations in the level and in the volatility of market prices of assets, liabilities and financial instruments
Credit Risk
The risk of loss in the financial situation, resulting from fluctuations in the credit standing of counterparties or issuers of securities
Concentration Risk
All risk exposures with a loss potential which is large enough to threaten the financial position of the company
Risks To Be Covered by Risk Management
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Effective Risk Management System
Adequate written policies
Appropriate processes and procedures
Appropriate procedures and feedback loops
Appropriate management reporting
Clearly defined and well documented Risk management strategy should include:
risk management objectives
key risk management principles
general risk appetite
assignment of risk management responsibilities across all the activities of the company
It should be consistent with the company’s overall business strategy.
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Effective Risk Management System
Appropriate processes and procedures
Appropriate procedures and feedback loops
Appropriate management reporting
Clearly defined and well documented
Written risk management policies should include:
definition and categorisation of the material risks faced by the company
definition of acceptable risk limits
implementation of risk strategy and control mechanisms
Written policies should at least cover:
underwriting and reserving
asset–liability management (ALM)
investments
liquidity and concentration risk management
operational risk management
reinsurance
Adequate written policies
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Effective Risk Management System
Adequate written policies
Appropriate procedures and feedback loops
Appropriate management reporting
Clearly defined and well documented Main risk management strategies and
policies should be approved by the management body.
Processes and procedures should include:
risk identification
risk assessment
risk measurement
risk monitoring
risk reporting
Appropriate processes and procedures
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Effective Risk Management System
Adequate written policies
Appropriate processes and procedures
Appropriate management reporting
Clearly defined and well documented Information on the risk management system
should be actively and continuously monitored and managed by the management body and by all relevant staff
Appropriate reporting and feedback loops
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Effective Risk Management System
Adequate written policies
Appropriate processes and procedures
Appropriate procedures and feedback loops
Clearly defined and well documented Material risks faced by the company and the
effectiveness of the risk management system should be reported to the management body
Appropriate reporting to the management
Supervision of the Risk Management System
• The company is required to demonstrate to the supervisor that it has an effective risk management system which is:
– capable of identifying, monitoring and mitigating both current and future risks in line with its risk tolerance levels. Stress testing and scenario analysis can be used to determine the effect of these risks.
– an integral part of its business strategy
– subject to regular internal review by the management body
– proportionate to the nature, scale and complexity of its business
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Supervision of the Risk Management System
• The disclosure to the supervisor could include:
– material risks and their potential effects– any perceived emerging risks to the company’s solvency position– the scope and nature of risk and capital measurement systems– the structure and organisation of the relevant risk and capital
management systems– details of organisational structure and staff responsible for the risk
management system– qualitative measures for risks which are not quantifiable, such as
liquidity risk and operational risk
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Thank you …
Onur Acar, Ph.D.
Mapfre Genel Sigorta
Risk Manager