Why don’ t we yet have
Solvency II?
FERMA Forum on Risk Management
Maastricht, 30 September 2013

Prof. Karel Van Hulle
KU...
Insurance Regulation: a challenge
• The insurance sector is the only major economic
•
•

•

sector for which there is not ...
Insurance in a risky world
• Insurance risks (ageing, health, natural
catastrophes, new technologies)
• Regulatory risks (...
Insurance Risks
• Privatisation of parts of social security

(health insurance, long term care)
• New challenges: pensions...
Regulatory risks (1)
Solvency reform
• Growing awareness that a risk based

solvency regime is necessary
• Fear for the co...
Regulatory risks (2)
Consumer protection
• Changes in supervisory architecture (twin

peaks and others): link between
prud...
Regulatory risks (3)
SII’s
• Are insurers systemically relevant?
• Is it possible to distinguish between

different types ...
Regulatory risks (4)
Banking agenda
• Financial crisis started in banking
• Low interest rates are there to help banks
to ...
Regulatory Risks (5)
The international agenda
• Common Framework for the supervision of
internationally active insurance g...
Low interest rate environment
• Solvency I does not require insurers to

take account of the consequences of a low
interes...
Lack of knowledge about the
insurance business model
• Insurers are not the best communicators
• Insurance is complex
• Lo...
Solvency II: the magic solution?
• Enthusiastic reception of 2007 Commission
proposal
• Key elements of that proposal:

– ...
Solvency II: 3 pillars and a roof
Group supervision
& cross-sectoral convergence
Groups are recognised as an economic enti...
Solvency II: the real world
•
•
•
•
•

Financial crisis also relevant for insurers?
Is the proposed confidence level too h...
S II: limits of economic theory
• Extreme observations come from off-model events, not
•
•
•
•
•

from improbable events w...
Omnibus II and Solvency II
• Sectoral adaptation of insurance legislation to
•
•
•
•

the new supervisory architecture
Pro...
The problem of the long term
• Role of the insurance industry in long term
investment
• Role of the insurance industry in ...
Negotiations of Omnibus II
• Lisbonisation of Solvency II
• Equivalence and transitional equivalence
• Financial crisis:
–...
Omnibus II and Solvency II
• It needs two to tango
• Priority given to the urgent resolution of a

difficult banking regul...
Solvency II: for when?
• Failure to agree on Omnibus II has stalled
•

•
•

•

further developments since 2009
Entry into ...
Role of EIOPA
• From CEIOPS to EIOPA
• Leadership role for technical issues

concerning insurance supervision (RTS)
• Repr...
Concluding Remarks
• Insurance remains the great unknown
• The insurance industry will become

increasingly important in t...
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FORUM 2013 Keynote Karel Van Hulle

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FORUM 2013 Keynote Karel Van Hulle

  1. 1. Why don’ t we yet have Solvency II? FERMA Forum on Risk Management Maastricht, 30 September 2013 Prof. Karel Van Hulle KU Leuven and Goethe University Frankfurt Former Head of Insurance and Pensions EC
  2. 2. Insurance Regulation: a challenge • The insurance sector is the only major economic • • • sector for which there is not yet an agreed international accounting standard nor an agreed international solvency framework Insurance regulators usually have less resources that their banking colleagues Insurance and insurance regulation are not considered very exciting Insurance is the most complex sector in financial services Prof. Karel Van Hulle 2
  3. 3. Insurance in a risky world • Insurance risks (ageing, health, natural catastrophes, new technologies) • Regulatory risks (new solvency regime, consumer protection, SII’s, banking agenda) • Low interest rate environment • Lack of knowledge about the insurance business model Prof. Karel Van Hulle 3
  4. 4. Insurance Risks • Privatisation of parts of social security (health insurance, long term care) • New challenges: pensions – climate change • New technologies: will the system function as we have designed it? Will human beings function as planned? Prof. Karel Van Hulle 4
  5. 5. Regulatory risks (1) Solvency reform • Growing awareness that a risk based solvency regime is necessary • Fear for the consequences of the risk logic • Can we model everything? • Difficult dialogue between actuaries, supervisors and the industry • Cultural shock: first major reform since 30 years Prof. Karel Van Hulle 5
  6. 6. Regulatory risks (2) Consumer protection • Changes in supervisory architecture (twin peaks and others): link between prudential and market conduct supervision • Increased recognition of consumer protection after financial crisis • Reflection in agenda’s of FSB, IAIS, OECD, EU and EIOPA • Increasing number of regulatory initiatives Prof. Karel Van Hulle 6
  7. 7. Regulatory risks (3) SII’s • Are insurers systemically relevant? • Is it possible to distinguish between different types of insurers? • What is traditional insurance? • What policy measures should be applied to SII’s? • Should there be a resolution regime for SII’s? Prof. Karel Van Hulle 7
  8. 8. Regulatory risks (4) Banking agenda • Financial crisis started in banking • Low interest rates are there to help banks to recover • FSB tends to focus its regulatory agenda on banking with a distant look at insurance • Insurers are often seen as the ideal solution for providing capital to banks Prof. Karel Van Hulle 8
  9. 9. Regulatory Risks (5) The international agenda • Common Framework for the supervision of internationally active insurance groups • Do we need a global capital standard? • Relationship between IAIG’s and SII’s • Extension of IAIG regime to other insurers? • Enforcement of ICP’s and role of FSAP’s Prof. Karel Van Hulle 9
  10. 10. Low interest rate environment • Solvency I does not require insurers to take account of the consequences of a low interest rate environment • Impact on life assurance and non-life • Role of insurance supervisors (see EIOPA) • Japanese scenario? • Future of long term guarantees? Prof. Karel Van Hulle 10
  11. 11. Lack of knowledge about the insurance business model • Insurers are not the best communicators • Insurance is complex • Lobby around long term guarantees not always to the point • Lobby around calibration of investments in the context of Solvency II not always in line with sound risk management Prof. Karel Van Hulle 11
  12. 12. Solvency II: the magic solution? • Enthusiastic reception of 2007 Commission proposal • Key elements of that proposal: – Market consistent valuation – Total balance sheet approach – Two capital requirements – Confidence level: 99,5% VaR over one year – Possibility to use internal models Prof. Karel Van Hulle 12
  13. 13. Solvency II: 3 pillars and a roof Group supervision & cross-sectoral convergence Groups are recognised as an economic entity => supervision on a consolidated basis (diversification benefits, group risks) Pillar 1: quantitative requirements 1. Harmonised calculation of technical provisions 2. "Prudent person" approach to investments instead of current quantitative restrictions 3. Two capital requirements: the Solvency Capital Requirement (SCR) and the Minimum Capital Requirement (MCR) Pillar 2: qualitative requirements and supervision Pillar 3: prudential reporting and public disclosure 1. Enhanced governance, internal control, risk management and own risk and solvency assessment (ORSA) 1. Common supervisory reporting 2. Strengthened supervisory review, harmonised supervisory standards and practices Prof. Karel Van Hulle 2. Public disclosure of the financial condition and solvency report (market discipline through transparency) 13
  14. 14. Solvency II: the real world • • • • • Financial crisis also relevant for insurers? Is the proposed confidence level too high? Different confidence levels for life and non-life? Is VaR the right measure? Does it produce procyclicality? Should the calibration of risks only be based on mathematical calculations or should it also look at the business reality? Prof. Karel Van Hulle 14
  15. 15. S II: limits of economic theory • Extreme observations come from off-model events, not • • • • • from improbable events within models Limits to probabilistic reasoning The importance of stewardship Is the efficient market hypothesis still justified? Do we have a “homo economicus”? Actuaries should exercise more judgement and frame this in convincing narratives rather than to rely on spuriously accurate mathematical projections based on past experience (John Kay) Prof. Karel Van Hulle 15
  16. 16. Omnibus II and Solvency II • Sectoral adaptation of insurance legislation to • • • • the new supervisory architecture Proposed by the EC in February 2011 as amendment to Solvency II Directive of 2009 Specification of powers of EIOPA Transitional measures for Solvency II Change in date of entry into force of Solvency II from 1 November 2012 until 1 January 2013 Prof. Karel Van Hulle 16
  17. 17. The problem of the long term • Role of the insurance industry in long term investment • Role of the insurance industry in providing long term guarantees • Who will bear the tail risk for life and pension products offered by the insurance industry? Prof. Karel Van Hulle 17
  18. 18. Negotiations of Omnibus II • Lisbonisation of Solvency II • Equivalence and transitional equivalence • Financial crisis: – Market turbulence produces artificial volatility in calculation of long term guarantees – Low interest rate environment – Problems of transition from Solvency I to Solvency II (discount rate) Prof. Karel Van Hulle 18
  19. 19. Omnibus II and Solvency II • It needs two to tango • Priority given to the urgent resolution of a difficult banking regulatory agenda • Quick fix Directive of September 2012 moves start date from 2013 to 2014 • Intense lobbying creates uneasiness in the Council and in the EP Prof. Karel Van Hulle 19
  20. 20. Solvency II: for when? • Failure to agree on Omnibus II has stalled • • • • further developments since 2009 Entry into force likely to move from 2014 to 2016 Trilogue negotiations likely to finish in October 2013 EIOPA to issue guidelines in 2014 in order to assist insurers and supervisors Levels 2 and 3 measures to follow quickly after publication of Omnibus II Prof. Karel Van Hulle 20
  21. 21. Role of EIOPA • From CEIOPS to EIOPA • Leadership role for technical issues concerning insurance supervision (RTS) • Representation in colleges of supervisors • Binding mediation, peer reviews • Supervisor for cross-border insurance groups? Prof. Karel Van Hulle 21
  22. 22. Concluding Remarks • Insurance remains the great unknown • The insurance industry will become increasingly important in this risky world • Without sound riks management and a risk based solvency regime, insurers will not be able to deliver • Not everything can or should be regulated Prof. Karel Van Hulle 22

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