Solvabilit II Larticle 47 et lactuaire Congrs annuel

Solvabilité II – L’article 47 et l’actuaire Congrès annuel de l’Institut des Actuaires Paris, 29 juin 2009 Seamus Creedon, Groupe Consultatif 1

Groupe Consultatif § § Etabli en 1978 Représentant 35 associations d’actuaires de 32 pays Représentant plus de 14000 actuaires Le Groupe est en relation avec: – Les institutions de l’UE – CEIOPS – Autres: CEA, CRO Forum, AMICE § Au sujet de Solvabilité II: – Presque 50 actuaires en 5 equipes: • • • Pillar 1 (vie) Pillar 1 (IARD) Pillar 5 (Pillar 2 & Pillar 3) Groupes Modeles internes 2

Article 47 – technical provisions 1. Insurance and reinsurance undertakings shall provide for an effective actuarial function to undertake the following: (a) to coordinate the calculation of technical provisions; (b) to ensure the appropriateness of the methodologies and underlying models used as well as the assumptions made in the calculation of technical provisions; (c) to assess the sufficiency and quality of the data used in the calculation of technical provisions; (d) to compare best estimates against experience; (e) to inform the administrative or management body of the reliability and adequacy of the calculation of technical provisions; (f) to oversee the calculation of technical provisions in the cases set out in Article 81; 81 (g) to express an opinion on the overall underwriting policy; (h) to express an opinion on the adequacy of reinsurance arrangements; (i) to contribute to the effective implementation of the risk management system referred to in Article 43, in particular with respect to the risk modelling underlying the calculation of the capital requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred to in Article 44. 2. The actuarial function shall be carried out by persons who have knowledge of actuarial and financial mathematics, commensurate with the nature, scale and complexity of the risks inherent in the business of the insurance or reinsurance undertaking, and who are able to demonstrate their relevant experience with applicable professional and other standards. 3

Article 47 – technical provisions 1. Insurance and reinsurance undertakings shall provide for an effective actuarial function to undertake the following: (a) to coordinate the calculation of technical provisions; (b) to ensure the appropriateness of the methodologies and underlying models used as well as the assumptions made in the calculation of technical provisions; (c) to assess the sufficiency and quality of the data used in the calculation of technical provisions; (d) to compare best estimates against experience; (e) to inform the administrative or management body of the reliability and adequacy of the calculation of technical provisions; (f) to oversee the calculation of technical provisions in the cases set out in Article 81; (g) to express an opinion on the overall underwriting policy; (h) to express an opinion on the adequacy of reinsurance arrangements; (i) to contribute to the effective implementation of the risk management system referred to in Article 43, in particular with respect to the risk modelling underlying the calculation of the capital requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred to in Article 44. 2. The actuarial function shall be carried out by persons who have knowledge of actuarial and financial mathematics, commensurate with the nature, scale and complexity of the risks inherent in the business of the insurance or reinsurance undertaking, and who are able to demonstrate their relevant experience with applicable professional and other standards. 4

Article 47 – technical provisions 1. Insurance and reinsurance undertakings shall provide for an effective actuarial function to undertake the following: (a) to coordinate the calculation of technical provisions; (b) to ensure the appropriateness of the methodologies and underlying models used as well as the assumptions made in the calculation of technical provisions; (c) to assess the sufficiency and quality of the data used in the calculation of technical provisions; (d) to compare best estimates against experience; (e) to inform the administrative or management body of the reliability and adequacy of the calculation of technical provisions; (f) to oversee the calculation of technical provisions in the cases set out in Article 81; (g) to express an opinion on the overall underwriting policy; (h) to express an opinion on the adequacy of reinsurance arrangements; (i) to contribute to the effective implementation of the risk management system referred to in Article 43, in particular with respect to the risk modelling underlying the calculation of the capital requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred to in Article 44. 2. The actuarial function shall be carried out by persons who have knowledge of actuarial and financial mathematics, commensurate with the nature, scale and complexity of the risks inherent in the business of the insurance or reinsurance undertaking, and who are able to demonstrate their relevant experience with applicable professional and other standards. 5

Article 47 – technical provisions 1. Insurance and reinsurance undertakings shall provide for an effective actuarial function to undertake the following: (a) to coordinate the calculation of technical provisions; (b) to ensure the appropriateness of the methodologies and underlying models used as well as the assumptions made in the calculation of technical provisions; (c) to assess the sufficiency and quality of the data used in the calculation of technical provisions; (d) to compare best estimates against experience; (e) to inform the administrative or management body of the reliability and adequacy of the calculation of technical provisions; (f) to oversee the calculation of technical provisions in the cases set out in Article 81; (g) to express an opinion on the overall underwriting policy; (h) to express an opinion on the adequacy of reinsurance arrangements; (i) to contribute to the effective implementation of the risk management system referred to in Article 43, in particular with respect to the risk modelling underlying the calculation of the capital requirements set out in Chapter VI, Sections 4 and 5 and the assessment referred to in Article 44. 2. The actuarial function shall be carried out by persons who have knowledge of actuarial and financial mathematics, commensurate with the nature, scale and complexity of the risks inherent in the business of the insurance or reinsurance undertaking, and who are able to demonstrate their relevant experience with applicable professional and other standards. 6

Potential scope of standards § § § Qualification standards - minimum educational and experience requirements (both initial education and continuing education); (e. g. Groupe Consultatif syllabus) Ethical standards - requirements as to ethical conduct, such as integrity, objectivity and avoidance of conflict of interest; (e. g. Groupe Consultatif code) Standards of duty and responsibility as a professional person, including: – Public interest standards - responsibilities towards those relying on actuarial output, and requirements to have regard to the interests of those affected by the advice; – Operational standards – requirements as to cooperation with and reliance on other experts, such as auditors and risk managers, quality control, peer review and whistle-blowing; and – Communication standards – standards concerning the communication of advice and reporting to the client and in public reports and statements of actuarial opinion. § Technical standards, including: – Interpretative standards - requirements regarding the detailed technical interpretation of all relevant forms of legislation or regulation in the context of the actuarial function; – Technical work standards – standards relating to how the function should be carried out, including choice of methodologies and assumptions, data standards, and appropriate ways of dealing with uncertainty; 7

Practitioner / Supervisor co-operation – a possible model § Practitioner (i. e. Groupe Consultatif) can initiate draft standards and expose these for consideration by supervisors and other stakeholders § Supervisor (i. e. CEIOPS) inevitably will be best placed to monitor compliance and enforce sanctions – probably to be achieved by endorsing standards as part of Level 3 guidance. Under de Larosiere, CEIOPS will have legal authority 8

Near –term work § § Stakeholder meeting – 6 July – Key level 2 issues Responding to Consultative Papers Standards Task Force QIS 5 Technical specification 9