Insurance Quarterly Legal And Regulatory Update - 1 April 2015 To 30 June 2015

Author:Dillon Eustace
Profession:Dillon Eustace

Solvency II

(i) The Central Bank's Consultation paper on "Domestic Actuarial Regime and Related Governance Requirements under Solvency II" (CP92)

On 15 April 2015 the Central Bank of Ireland ("Central Bank") issued a Consultation Paper on "Domestic Actuarial Regime and Related Governance Requirements under Solvency II" ("CP 92"). CP 92 discussed the requirement to notify the Central Bank of the person responsible for the Actuarial Function, called the Head of Actuarial Function ("HoAF") which will be known as a PCF position. This will be done by the Central Bank's Fitness and Probity regime and will require pre - approval. The new PCF position will be introduced from the 1st January 2016 and the existing PCF positions of Chief Actuary and Signing Actuary will no longer exist.

The HoAF is required to provide an opinion to the Central Bank on an annual basis on the technical provisions of the undertaking which will be referred to as the Actuarial Opinion on Technical Provisions. The HoAF is additionally expected to provide an Actuarial Report on Technical Provisions to the Board on an annual basis. The outline of this report is provided for in the CP92. The HoAF is required to provide an opinion to the Board on the adequacy of the scenarios, including financial projections, considered as part of the Own Risk and Solvency Assessment ("ORSA") process of the undertaking.

CP 92 also discusses the requirement for High impact Companies to establish a Reserving Committee which must meet on a quarterly basis. The Committee will have responsibility for overseeing the governance around the calculation of the Technical Provisions and compliance with reserving policies. All High, Medium High and Medium Low impact entities are also required to engage a Reviewing Actuary to conduct a peer review of the Technical Provisions. The Reviewing Actuary cannot be an employee of the undertaking however for Medium High and Low undertakings, the Reviewing Actuary may be from the same group. Where the Actuarial Function is outsourced, the Reviewing Actuary cannot be from the same firm. A peer review must be conducted at least every 2 years for a High Impact undertaking, every 3 years for a Medium Impact undertaking and every 5 years for a Medium Low undertaking.

The consultation was open from 2 April 2015 to 29 May 2015.

The full consultation paper is available via the following link:

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