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CEIOPS releases second set of Solvency II consultation papers
3 July 2009
The Committee of European Insurance and Occupational Pensions Supervisors (CEIOPS) has released for consultation its second set of Advice on Solvency II - Level 2 implementing measures. The consultation papers deal with a large number of Pillar I, Pillar II, Pillar III and group issues, which have been developed on the basis of the Solvency II Level 1 text adopted by the European Parliament on 22 April 2009.
After consultation, CEIOPS will finalise the papers for submission to the European Commission, taking into account the comments received and the lessons learned from the financial crisis.
The Consultation Papers are accompanied by a cover note, offering information on the topics consulted upon and the deadlines for comments.
During 2009, CEIOPS has already consulted on a first set of advice on Level 2 measures and will consult on one further set, expected at the beginning of November 2009.
CEIOPS invites stakeholders to email their comments, in English, to secretariat@ceiops.eu, using the templates provided. Comments received will be posted on CEIOPS’ website, except where respondents specifically request that their comments remain confidential. For more information go to www.ceiops.org (link to external website).
Rick Lester, lead partner on the UK Solvency II team at Deloitte, comments:
‘As with the first set of consultation papers this set also covers a range of topics across the entire Solvency II spectrum, on this occasion addressing aspects of MCR, SCR standard formula, internal models, own funds, reporting and the supervisory review process.
‘We welcome this opportunity for the industry to continue to engage in the development of Solvency II detailed regulations and encourage firms to respond to these papers so they can contribute to the final shape of the new requirements.’
Simon Sheaf, general insurance actuarial practice leader at Grant Thornton, says it is essential that firms review and provide feedback on those consultation papers that are relevant to them:
‘The danger of failing to do so is that a firm may end up with implementing measures that are inappropriate for its business. There is a particular danger that small to medium sized firms may decide against providing input to the consultation process due to a lack of resources. This could result in a set of implementing measures that are appropriate for larger insurers but inappropriate for smaller firms.
‘It is also important that firms provide feedback on the areas they agree with as well as those with which they disagree,’ adds Sheaf. ‘CEIOPS are not mind readers and can only respond to the feedback they receive which could mean that, if 99 per cent of firms agree with a particular measure but say nothing and 1 per cent disagree with it and say so, the vocal minority will get its way.
‘This is an important opportunity for insurers and reinsurers to have their say on Solvency II and it is crucial that they find the time to take that opportunity.’
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