Bermuda Monetary Authority Business Plan 2014
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Bermuda Monetary Authority Business Plan 2014



Bermuda Monetary Authority Business Plan 2014

Bermuda Monetary Authority Business Plan 2014



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Bermuda Monetary Authority Business Plan 2014 Bermuda Monetary Authority Business Plan 2014 Document Transcript

  • 01 04 11 13 CEO Introduction Supervision International Engagement Operations and Resourcing Contents
  • Business Plan 2014 Bermuda Monetary Authority 01 In its simplest form, a business plan is a formal statement of a set of business goals and an explanation of how those goals will be reached in the year ahead. In that sense, our 2014 plan is unlikely to disappoint those seeking guidance on what to expect from the Bermuda Monetary Authority and its approach to financial services regulation and supervision. A product of close and continuing consultation with all stakeholders, the document assesses the impact of specific supervisory initiatives, reviews the availability of resources required to execute and deliver them, and offers insight on the challenges and opportunities associated with each. The plan also acknowledges the unique qualities and characteristics of our financial services industry, favouring solutions and timeframes appropriate to the Bermuda marketplace rather than automatically adopting measures used elsewhere. Additionally, it reflects the harsh realities of the current economic climate in Bermuda, an awareness of the cost of regulation and supervision and a strong focus on spending and efficiency. That said, there’s more to our business than a business plan. Important though it is, a tight focus on execution and delivery, by definition, allows little room for discussion of non-operational factors. However, some of these raise questions and issues of critical significance and I’d like to address a few of them now. Despite the fact that this will mean departing from our traditional Business Plan introduction format, I would like to provide a clear understanding of the policy perspectives that underpin our strategic targets. Perhaps the most alarming of these questions and issues arises from the almost universal misconception of the regulator’s role. As a result, regulators are seen as part of a problem rather than part of a solution. This is often driven by the disappointing frequency with which market surveys around the world consistently report that CEOs regard regulation and regulators as being among the biggest threats to the future of their businesses. Time and time again we read that regulation is what keeps private sector leaders awake at night. Time and time again we hear that burdensome regulation is increasing the cost of doing business, stifling innovation, interfering with corporate decision making and generally fostering a climate of uncertainty which hinders growth and job creation. If this is the point at which I’m expected to launch into denial mode and argue that supervisors cannot be held accountable for the unintended consequences of regulation, I’m about to disappoint. The plan acknowledges the unique qualities and characteristics of our financial services industry, favouring solutions and timeframes appropriate to the Bermuda marketplace. ” CEO Introduction “
  • 02 I believe regulators can and should be accountable. I believe Bermuda in general and the Authority in particular have an opportunity to change this misconception and to model a system of supervision capable of delivering tangible benefits. This should be a system designed not to blindly lay down layers of regulation, confident that our bill for this effort will be paid by the companies we regulate. To do otherwise would just further demonise the regulators. The time has come, in my view, to find a way to partner more closely with industry. This partnership should be aimed squarely at shaping a regulatory agenda capable of supporting the national economy as well as private sector goals. It goes without saying that the prime focus of such a system would remain unchanged, namely the protection of those who trade with our regulated entities. Can we achieve both sets of objectives? I believe we can, though I recognise this will take a coalition of the willing. What is clear is that the reputation of the global regulatory community needs a saviour, an approach that clearly demonstrates that a working partnership between the regulator and the regulated can succeed and can be held accountable for results while delivering value for money. A successful system of quality regulation in Bermuda could be the answer, offering a guiding light in an otherwise murky environment. Of course change is never easy, especially when it involves changing the value proposition of an entire global movement. I understand the nature of the challenge I am proposing and the price that will have to be paid to rise to it. I know too that there will be some in the regulatory world who will see me as a maverick who has broken ranks with his fellow supervisors. But doing nothing to help improve a system that is consistently failing to realise its full potential carries a much higher price than the cost of breaking ranks with those who still support it. The point of this introduction is to provide an insight on some of the thinking that has already gone into the 2014 Business Plan and the kinds of ideas and thought processes that could influence further developments at the Authority. Regulation and regulators should be seen not as threats but as solution providers. Among the solutions reviewed on the following pages you will find reference to: the proposed financial stability framework for Bermuda, the opt-in regime for Bermuda’s fund sector, enhanced statutory electronic filing for Limited Purpose Insurers and our participation in the NAIC’s qualified jurisdiction process, which is helping to reduce reinsurance collateral requirements. Given its importance for our economy, work underway in preparation for the IMF review scheduled for 2016 is worth a special mention. The Authority is placing high priority on the task of embedding the findings of the national risk assessment and will be revising guidance notes to reflect new AML/ATF recommendations by the Financial Action Task Force. Regulation and regulators should be seen not as threats but as solution providers. ” “
  • Business Plan 2014 Bermuda Monetary Authority 03 A world class financial services industry such as Bermuda’s requires the support of a world class financial services regulator capable of assuming a leading role at a global level. My goal and the goal of our leadership team is to ensure that the Authority not only remains the world class regulator that our industry and our country demands, but that it raises the bar on regulation at home and abroad for the benefit of all stakeholders, including other regulators. Jeremy Cox Chief Executive Officer As part of this effort, we will be assisting the National Anti-Money Laundering Committee to make changes to legislation and regulations to ensure that they reflect current international requirements. Additionally, on the domestic front, I have made a personal commitment to raise the Authority’s profile as a top employer of choice with a creative and adaptive culture of learning and innovation modelled on the technology sector. These are just a few of the initiatives which will be providing tangible benefits and value to Bermuda and to its international business sector during 2014. A world class financial services industry such as Bermuda’s requires the support of a world class financial services regulator capable of assuming a leading role at a global level. ” “
  • Quality Supervision for Bermuda: Embedding an Effective, Globally Recognised Framework The Authority’s success with maintaining a high level of international cooperation while developing regulation for Bermuda with an independent perspective continues. Moving forward in 2014, we will build on work completed to date with such developments, further embedding key framework enhancements across the regimes we apply to all sectors of Bermuda’s financial services market. In addition, as we continue to engage on the international front, we will leverage our expanded in-house macroprudential surveillance and policy resources to ensure we proactively identify and monitor regulatory risks and trends, both here and overseas. This work, while valuable for supporting our own supervisory efforts, will also inform jurisdictional initiatives with other authorities in Bermuda, particularly regarding financial stability developments related to the broader economy. Insurance Sector: Balanced Approach, Progressive Implementation In 2014 the Authority will continue to embed progressive framework enhancements throughout Bermuda’s insurance regimes at a pace that is appropriate for the firms operating here. We will accomplish some major milestones during the year, including implementing group capital requirements for Bermuda’s insurance groups; applying the BSCR to Long-Term insurers, modified after extensive consultation SUMMARY OF SUPERVISORY INITIATIVES 2014 04 Supervision Banking, Trust, Corporate Services & Investment • Continue Basel III consultation • AIFMD compliance – Opt-in Regime • Special Resolution Regime • Updating of Investment Funds Act and Investment Business Act • Complete implementation of Corporate Service Providers (CSP) regime • Review our framework for Money Service Businesses (MSB)/Payment Services Insurance • Implement enhanced capital requirements: Insurance Groups and Long-Term insurers • Internal Capital Models • Implement enhanced reporting and e-filing for Limited Purpose Insurers • Consult on Bermuda Solvency Capital Requirement (BSCR) enhancements • Consult on policyholder protection Other • Continue input and support for National Risk Assessment • Enforcement: Complete rollout of enhanced powers to the investment sector
  • Business Plan 2014 Bermuda Monetary Authority 05 We remain committed to the regulatory equivalency process in relation to Solvency II for our commercial insurance sector and are well advanced with our regulatory change programme. Group Supervision Group supervision has been in effect and implemented on a phased basis for Bermuda’s largest insurance groups since 2011. The Authority will continue the roll out of the framework in 2014, extending group supervision to groups where the Designated Insurer will be Class C, D, E and 3A insurers. In addition, having concluded market consultation last year, we will implement group capital requirements in 2014. This requirement will apply for 2013 year-end financial reporting and will be phased in over a five-year period. The Authority has established a revised BSCR for application to insurance groups in order to assess regulatory capital requirements for such entities. However, insurance groups will also have the option to apply to have their required regulatory capital calculated via their own internal models. We have also concluded consultation on new Group Actuary Opinion requirements that will come under the group supervision framework. The Authority will publish guidance for the market on this requirement in 2014, and will subsequently begin accepting applications for Group Actuary approvals during the year. This process will take place in time for the first Group Actuary opinion filings for year-end 2014 financial reporting, which are due in May 2015. The Authority’s schedule of supervisory colleges will also continue throughout 2014. We will both participate in colleges and host such sessions, in the latter case in relation to groups for which the Authority is Group Supervisor. Our experience with colleges to date has reinforced the benefits of continuing to conduct these meetings using both virtual and in-person sessions, to ensure there are no impediments to regular ongoing dialogue taking place between the Authority and our regulatory counterparts about groups of mutual interest. Long-Term Insurer Regime The major element of our work to bring Bermuda’s Long-Term insurers within scope of the Authority’s enhanced risk-based solvency framework is now complete. The Authority’s modified BSCR, specifically tailored to account for the particular risk characteristics of life (re)insurers, and incorporating valuable input from extensive market consultation, will take effect in 2014 for commercial Long-Term firms (Class C, D, and E). This will be the first year of a three-year phased implementation for this sector, enabling the market to make necessary adjustments as they transition to the full enhanced capital requirement. Internal Capital Models (ICM) The Authority began accepting ICM applications in 2013, and will continue to review submissions received throughout 2014, for both General Business and Long-Term insurers and Groups. In addition, to build on the in-house skills and knowledge we have developed in this area, the Authority will assess our capabilities and capacity to review internal models for other segments of Bermuda’s financial services sector. to account for the life sector’s specific risk characteristics; continuing to accept and review applications for group internal models; and establishing enhanced statutory electronic filing for captive insurers. We also anticipate further progress on a milestone achieved at the end of last year. In 2013 the Authority was invited to participate in an expedited assessment for the National Association of Insurance Commissioners’ (NAIC) Qualified Jurisdiction process. This process, developed to evaluate the reinsurance supervisory systems of non-US jurisdictions for reinsurance collateral reduction purposes, resulted in Bermuda being one of four jurisdictions to be granted qualified jurisdiction status at the end of 2013. There is already direct benefit to Bermuda-based reinsurers to be derived from achieving this status, and the Authority looks forward to participating in the full NAIC Qualified Jurisdiction assessment in 2014. On the other side of the Atlantic, we continue to monitor developments in relation to Europe’s Solvency II Directive. EIOPA’s equivalence assessment of Bermuda for Solvency II found our regulatory framework for commercial (re) insurers to be largely equivalent with the Directive. That position remains in place. EIOPA’s subsequent confirmation that they have the ability to grant ‘bifurcated’ equivalence also still stands. This means Bermuda’s regime for captives can remain out of scope for final equivalence confirmation, placing Bermuda in an ideal position given the nature of our market. The Authority has also confirmed that it will not apply any Solvency II-type regime to Bermuda captives.
  • within Bermuda’s captive market. These legislative changes come on the heels of a successful e-filing trial-run of the Authority’s Enhanced Statutory Financial Return in 2013. In addition to creating greater efficiencies in the filing process for companies and the Authority, this enhanced data collection will provide for further robust analysis of Bermuda’s captive market to ensure an appropriate level of supervision is maintained for this sector. The enhanced Statutory Financial Return contains more detailed reporting regarding cells in segregated accounts companies (SACs). Similar reporting will be introduced to the commercial classes where SACs exist. Banking and Corporate Services Supervision Basel III The Authority’s measured approach to implementing Basel III in Bermuda will continue throughout 2014. We remain committed to ensuring that the enhanced capital and liquidity rules are implemented in a pragmatic manner across the sector. In Q4 2013, we issued a Consultation Paper that further articulated our approach to applying revised regulatory capital and liquidity standards to Bermuda’s banking sector. The Paper also addressed key industry comments from our initial consultation. In 2014 we will continue industry consultation on the new standards. This work will involve reviewing industry feedback on our latest proposals as well as holding meetings with banks on such issues as revised reporting standards, with a view to begin phased implementation in 2015. Corporate Service Provider (CSP) Regime With the passing of the Corporate Service Provider Business Act 2012, and subsequently issuing a draft Statement of Principles and market guidance, the Authority will advance preparations for full implementation of the CSP regime in 2014. This work will include refinements to the supporting policy framework, and additional market consultation and industry outreach sessions on various technical aspects of the regime. Any additional legislative approvals will be confirmed during the year, which will facilitate full implementation of the regime by year-end. The Authority will also consult on a Corporate Governance Policy for CSPs during the year. Money Service Businesses The Authority will review the licensing and supervision of Bermuda’s money services business sector during the year. The Authority’s intent with this review is to ensure that the regulation and supervision of this sector remains effective given increased interest among such businesses to provide new service offerings, such as payment services. Following the review, we will issue proposed refinements to the legislative and supervisory regime for money service businesses for industry comment, to ensure that the regime remains appropriate for the evolving nature of the market. Special Resolution Regime Work to establish a Special Resolution Regime (SRR) for Bermuda’s banking sector will continue in 2014. The SRR seeks to establish a comprehensive bank insolvency framework that aligns with international standards and is designed to operate independently from Bermuda’s Enhancing our Supervisory Toolkit Throughout 2014 the Authority will further develop our supervisory toolkit to ensure that Bermuda’s insurers are supervised appropriately. Major pieces of the toolkit are already in place including the BSCR; eligible capital; and enhanced reporting requirements. The Authority plans to progress its position on an economic balance sheet for commercial insurers by continuing discussions with the respective industry associations and monitoring ongoing developments at international standard-setters, i.e. the Financial Accounting Standards Board and International Accounting Standards Board. Specifically for the BSCR, the Authority will continue discussions with industry throughout 2014 and 2015 about enhancing the model as deemed appropriate. Proposals for consultation are expected in 2015 for implementation in 2016 for year-end 2015 filings. Enhanced Reporting for Limited Purpose Insurers To maintain an effective and practical regulatory environment for captive insurers, in Q2 2014, the Authority will amend Bermuda’s insurance legislation to refine the content and process of filing requirements. Specifically, an Enhanced Statutory Financial Return will become an annual statutory requirement for limited purpose insurers. The Return consolidates previous submissions to the Authority and also includes a risk self-assessment. In addition, the Class 3 insurer filing period will be amended to fall in line with the other classes. Further, aggregated data will also be published to support the Authority’s statistical analysis of the characteristics and trends 06
  • Business Plan 2014 Bermuda Monetary Authority 07 Investment Funds Managers Directive (AIFMD), and will cover such items as reporting requirements and remuneration disclosures. The Authority will also finalise and issue the Corporate Governance Policy for Funds during the year. We established a formalised policy covering corporate governance requirements for banks, trust companies, fund administrators and investment businesses in 2013. Similar requirements will now be extended to the funds sector via this new Policy, which will include principles and related guidance covering key areas such as board practices, the role of senior management, risk management and internal controls, and disclosure and transparency. AIFMD Compliance - Opt-in Regime In 2014 the Authority will determine the implications of establishing an opt-in regime for Bermuda’s fund sector to comply with the full requirements of the AIFMD. This follows our completion of the first phase of Bermuda’s AIFMD- related initiatives, namely signing the ESMA (European Securities and Markets Authority) Memorandum of Understanding (MOU) with EU member states last year. For the next phase, we will develop an opt-in regime for Bermuda-based alternative investment fund managers (AIFMs) who conduct business in Europe. This opt-in regime will assist Bermuda AIFMs who wish to register with an EU member state and be permitted to market funds throughout the EU by way of “passporting”. This passporting option will become available to non-EU countries (third countries) in 2015. Establishing an opt-in regime will enable Bermuda-based AIFMs to maintain seamless operations across the European market. The addition of an opt-in regime will also further enhance Bermuda’s regulatory regime and provide for a wide range of fund activity for the market operating from here, within an internationally recognised regulatory framework. general insolvency law, as a measure to further strengthen the jurisdiction’s financial safety net. In 2014 the Authority will continue consulting on a number of technical measures resulting from initial market consultation on this regime. Along with finalising the legislative framework, the Authority will subsequently publish guidance for the market on the SRR before the end of the year. Asset Management: Forward- Looking Regulation Investment Funds Act and Investment Business Act Amendments The Authority will conduct a review of the Investment Funds Act 2006 (IFA) and Investment Business Act 2003 (IBA) in 2014. This review is part of our overall framework enhancements, which last year included the addition of two new exempted classes of funds (Class A and Class B) under the Investment Funds Amendment Act 2013. The goal of such ongoing enhancements is to ensure Bermuda’s framework remains appropriate and effective for this market, while also reflecting relevant international regulatory standards and facilitating continued business development in the market. We will review the IFA and IBA to consider developments in international standards promulgated by the International Organization of Securities Commissions (IOSCO), the international standard setter for the investment sector. The review will also consider the impact on Bermuda’s funds sector of developments within Europe as regards the Alternative
  • 08 20142015 Q1Q2Q3Q4Q1Q2Q3Q4 INSURANCE EconomicBalanceSheet Furthermarketconsultation:GeneralBusinessandLong-Term InternationalRegulatoryCooperation ParticipationinGlobalSystemicallyImportantInsurersBasicCapitalRequirement (G-SIIBCR)andInsuranceCapitalStandard(ICS)fieldtesting EligibleCapital/OwnFunds Implementation:ClassCandD● BermudaSolvencyCapitalRequirement(BSCR) Consultationonpossibleenhancementsforallcommercialclasses GroupSupervision TrialRun:GroupsupervisionforClassC,D,Eand3A● Phasedimplementation:Enhancedcapitalrequirement Long-TermFramework Phasedimplementation:Enhancedcapitalrequirement● LimitedPurposeInsurerReportingRequirements Legislation:Class1,2,3,AandB● SACreportingconsultationonextensionoflimitedpurposeinsurerproposalsto commercialclasses ● BANKING,TRUST,CORPORATESERVICESANDINVESTMENT BaselIII Consultwithmarket● TransitiontoBaselIII● CorporateServiceProviderRegime Implementation●
  • Business Plan 2014 Bermuda Monetary Authority 09 20142015 Q1Q2Q3Q4Q1Q2Q3Q4 BankingInterventionPowers SpecialResolutionRegime:ConsultationCompleted● Legislationcompleted● GuidanceandCodefinalised● CorporateGovernanceCode-CSPsandInvestmentFunds IssueConsultationPaper● ImplementAmendmentstoActs● InvestmentRegime Consultwithmarket-AIFMDopt-inregime● ReviewIBA&IFAlegislation● DevelopPaymentServicesLegislation IssueDiscussionPaper● Followupconsultation● Draftlegislation● OTHER MacroprudentialSurveillance CommencementandImplementation:FinancialStabilityFramework● EnhancedEnforcement Implementation:IFA,MoneyServiceBusiness● Anti-MoneyLaundering/Anti-TerrorismFinancing IssueInvestmentBusinessGuidance●
  • 10 Committee (NAMLC). A significant aspect of the national risk assessment is the compilation of quantitative and qualitative data that will assist the Authority to focus and refine its activities specifically in relation to AML/ATF supervision. In addition to contributing to the national risk assessment initiative, the Authority will perform on-site AML reviews of regulated entities as required, and we will also conduct on going desk-based reviews throughout the year. Our series of outreach training seminars for the market will also continue to provide briefings on legislative changes and to deal with issues particular to Bermuda. Enforcement The final stage of the Authority’s plan to embed its enhanced enforcement framework across all primary segments of Bermuda’s financial services sector will take place in 2014. The Authority will complete introduction of enforcement powers into the Investment Funds Act during the year, via amendments to the Investment Funds Act 2006. These amendments will reflect the uniform set of enforcement powers that already apply across Bermuda’s banking, insurance, investment business and trust sectors. The Authority will also consider applying similar enforcement powers to money service businesses as part of the overall review of the licensing and supervisory regime in place for that sector. The Authority is also considering our role in ensuring that international sanctions relevant to Bermuda are fully met within the financial sector, and there will be added focus on this work during the year. This will involve both reviewing and updating methods to ensure that the financial firms are fully informed of the details of current sanctions, and also identifying processes to monitor compliance with these obligations. Financial Stability For much of 2013, the Authority has worked towards establishing a financial stability framework for the jurisdiction. The framework will be led by the Authority. It is designed to drive development of a financial stability policy for Bermuda, with the objective of identifying, monitoring and responding to emerging vulnerabilities and risks in the Bermudian financial sector, and in the Bermuda economy as a whole. The framework will involve two key groups: a high-level Financial Policy Council and a Financial Stability Committee. The Financial Policy Council will assess the macroprudential state of the jurisdiction and determine any relevant actions to be taken if issues are identified. The Financial Stability Committee will provide analysis and recommendations to the Council. The data provided to these groups will include information based on microprudential material the Authority collects as part of its regulatory function and additional indicators collected from other agencies. Formal arrangements will be put in place to establish clear protocols for the sharing and reporting of data and information between parties under the framework, respecting all existing statutory confidentiality provisions. It is anticipated that all of these elements, which establish the supporting infrastructure for the financial stability framework, will be in place before the end of 2014. Anti-Money Laundering/ Anti-Terrorist Financing Throughout 2014, the Authority will continue to make preparations for the next International Monetary Fund review of Bermuda’s regulatory framework, which will include a detailed assessment of the jurisdiction’s Anti-Money Laundering/Anti-Terrorism Financing (AML/ATF) regime. A large part of this preparatory work will be completing a national risk assessment, which the Authority is conducting in conjunction with Bermuda’s National Anti-Money Laundering
  • Business Plan 2014 Bermuda Monetary Authority International Engagement 11 range of technical presentations; making contributions to emerging global financial policy proposals and market surveys; and conducting supervisory colleges to support group supervision of entities in the banking, insurance and investment sectors. In particular for the US, having successfully achieved conditional status as a designated NAIC Qualified Jurisdiction for Bermuda in advance of the full assessment process for non-US domiciles, we look forward to building on that position further during the year. We will also continue a high level of dialogue with the NAIC as well as individual State commissions to maintain awareness and understanding about regulatory developments in Bermuda. Regarding major relevant insurance- related matters in Europe, we will maintain our active dialogue with regulatory counterparts in the European Insurance and Occupational Pensions Authority (EIOPA). The recent developments towards implementation of Solvency II have not altered Bermuda’s position. EIOPA’s decision confirming broad equivalence for our commercial insurance supervisory framework remains in place. The Authority still intends to achieve full equivalence for our commercial insurance sector regimes under the Directive. Our interactions in Europe will also have developments on the AIFMD as a priority for the funds sector. We will focus on advancing Bermuda’s position as a signatory to the ESMA’s MoU, related to the AIFMD. We intend to maintain a high level of dialogue with ESMA and specific EU states as we finalise regime refinements in Bermuda to ensure compliance with the AIFMD requirements for the long term, and well in time for the passporting arrangements that will be available as of 2015 to fund managers from non-EU countries marketing funds in Europe. Conditions in the global regulatory arena remain dynamic and challenging – both for regulators and the financial services markets they supervise. From a regulators perspective, the focus remains on continually assessing the evolving demands, impacts and convergence of international standards relevant to financial jurisdictions. Regulators must evaluate what this environment means for regulatory changes in their own markets. In addition, the global momentum to establish more effective macroprudential supervision within and across markets has increased. Regulators must therefore make a meaningful commitment to active supervisory cooperation and coordination with their counterparts overseas to support this effort. This is placing greater focus on ensuring they monitor the impacts of interconnected companies or markets, to address identified regulatory gaps effectively, and to mitigate systemic risks that could de-stabilise global markets. The Authority’s high level of international engagement, and effective advocacy strategy, supports Bermuda’s long- standing commitment in this context. During 2014 we will continue targeted, proactive international cooperation, while staying focused on balancing global changes and expectations with applying pragmatic regulation in Bermuda. Our international interaction, advocacy and supervisory cooperation activities will be primarily focused on the US and UK/Europe. Specifics will include active participation in key committees of international standard setting bodies; a
  • 12 HIGHLIGHTS – INITIATIVES FOR INTERNATIONAL ENGAGEMENT IN 2014 International Cooperation and Financial Stability • Build on Bermuda’s current NAIC Qualified Jurisdiction status for the US and participate in full assessment process for third countries • Maintain dialogue with the US Federal Insurance Office • Continue participation on Bermuda’s behalf to provide contributions to global policy initiatives as member of the IAIS Financial Stability Committee • Ongoing input to IAIS policy developments and supervisory approach for internationally active insurance groups • Participate in Group of International Financial Centre Supervisors and the International Organisation of Securities Commissioners • Provide continued assistance for raising the standard of global insurance supervision by conducting technical presentations and training seminars for supervisors overseas Advocacy • Extend strategic engagement with supervisory counterparts in the UK/Europe and the US • Maintain working relationships with EIOPA • Extend outreach programme to ESMA, aligned with Bermuda funds regime enhancements • Continue engagement with Caribbean Financial Action Task Force regarding ongoing AML/ATF global standards development Supervisory Cooperation • Conduct supervisory colleges programme to support group supervision of entities in the banking, insurance and investment sectors • Pursue additional Memoranda of Understanding with relevant regulatory counterparts as deemed appropriate The following table provides highlights of the Authority’s international engagement programme for the year:
  • Business Plan 2014 Bermuda Monetary Authority 13 Leveraging Technology The Authority’s IT strategy continues to evolve with a focus on leveraging technology in new ways to achieve our supervisory objectives. With ERICA (Electronic Regulatory Information Compliance Application) fully embedded into our IT infrastructure as of last year, the Authority will enter into a new phase of IT development in 2014 focused on data-driven supervision. ERICA supports efficiencies both for the Authority and for firms by streamlining the reporting, collection and analysis of data required for regulatory processes. The system initially facilitated e-filing submissions of the BSCR data in 2011. E-filing capabilities were extended to the funds sector in 2013. In 2014, we will extend this functionality across the insurance sector. Part of that work will be completion of the Enhanced Statutory Financial Return process for limited purpose (captive) insurers. As mentioned previously in this plan, this initiative will bring efficiencies in the filing process for insurers and the Authority. It will also support further detailed analysis of Bermuda’s limited purpose insurer sector in order for the Authority to maintain an appropriate level of supervision for such companies. Resourcing The Authority will continue to leverage our resources strategically during 2014, with a view to maintaining operational and staff effectiveness. Our work during the year will focus specifically on succession planning and leadership development. Having successfully recruited highly- skilled individuals to join our technical teams in recent years, our focus will now shift from aggressive recruitment to optimal use of our existing staff. This means that in 2014 we will place further reliance on our in-house expertise in risk assessment, macroprudential surveillance and supervision to execute the Authority’s supervisory programmes. The organisational restructuring that took place in 2013 reflects our objective to align our teams and talent pool more effectively with a view to delivering high quality supervision for the long term. This work will continue in 2014, as we use the multi- disciplinary skills established within our cross-sectoral supervisory teams - and a highly coordinated approach to supervision - to target technical resources and conduct ongoing analysis across market sectors. For our succession planning programme, we will continue combining the experience of senior members in our team with initiatives that actively address the ongoing development of our leadership pool. The Authority’s succession planning programme is directly aligned with the longer term strategic goals of the organisation. An updated workforce plan will be developed in Q3 2014 in support of this next phase of the programme, as will ongoing delivery of a leadership development curriculum as part of our learning and development framework for employees. Operations And Resourcing
  • 14 Jeremy Cox Chief Executive Officer Ricardo Garcia Assistant Director, Actuarial Services, Property & Casualty Christopher Killourhy Internal Models Specialist, Actuarial Services David Lawler Assistant Director, Insurance Supervision Richard May Assistant Director, Actuarial Services, Long-Term Moses Muoki Assistant Director, Insurance Supervision Montgomery Nearon Assistant Director, Macroprudential Risk Thomas O’Rourke Assistant Director, Financial Groups Gina Smith Assistant Director, Actuarial Services, Property & Casualty Gary Thomas Assistant Director, Actuarial Services, Long-Term Donald Treanor Assistant Director, Actuarial Services, Property & Casualty Christopher Tribley Assistant Director, Investment Groups Supervision Craig Swan Managing Director Andrew Gibbs Director, Insurance Supervision Marcia Woolridge-Allwood Director, Banking, Trust, Corporate Services & Investment Niall Farrell Deputy Director, Insurance Supervision David Theaker Deputy Director, Actuarial Services Suzanne Williams Deputy Director, Insurance Supervision Leanne Alami-Merrouni Assistant Director, Investment Business & Funds Tamara Anfossi Assistant Director, Trust & Corporate Service Providers Laila Burke Assistant Director, Insurance Supervision Eric Donkoh Assistant Director, Insurance Supervision Gerald Gakundi Assistant Director, Insurance Supervision BMA Management Team - as at January 2014
  • Business Plan 2014 Bermuda Monetary Authority 15 Operations Shanna Lespere Director Pat Phillip-Fairn Deputy Director, Corporate Governance & Communications Mesheiah Crockwell Deputy Director, Head of Human Resources Terry Pitcher Deputy Director, Head of Finance & Currency Operations Management Services John Dill Director Organisational Development Verna Hollis-Smith Assistant Director Senior Advisor Roger Scotton International Affairs Licensing & Authorisations Shelby Weldon Director Leslie Robinson Assistant Director, Licensing Melissa Morton Acting Assistant Director, Authorisations Akilah Wilson Acting Assistant Director, Licensing Legal, Policy & Enforcement Shauna MacKenzie Director Thomas Galloway Deputy Director, Enforcement Marcelo Ramella Deputy Director, Policy Ifor Hughes Assistant Director, Policy Yvette Pierre Assistant Director, Policy Dina Wilson Assistant Director, Legal Services
  • 10 Notes
  • BMA HOUSE 43 Victoria Street Hamilton HM 12 Bermuda P.O. Box 2447 Hamilton HM JX Bermuda tel: (441) 295 5278 fax: (441) 292 7471 email: