Integration of Financial Services

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Integration of Financial Services

  1. 1. Integration of Financial Services AIDA XI World Congress October 20-24, 2002 Germany Dr. Tobias Entzian 1. What is the current level of integration among commercial banking, investment banking and insurance in your country? Contrary to the situation in the US, the German regulatory system does not differentiate between commercial banks and investment banks. With a few exceptions (e.g. mortgage banks, building societies etc.) all German banks are “Universalbanken“ (universal banks) and as such authorised to carry out both commercial and investment banking. Germany has never known an equivalent to the “Glass-Steagall Act“ and hence commercial banking and investment banking in Germany has never been completely separated into two lines of business. Even though there are several banks that exclusively concentrate on investment activities and others that concentrate on commercial banking there are many banks that have an investment as well as a commercial and retail division. Banking and insurance industry are partially integrated in Germany. There is no clear tendency to combine banking and insurance activities in larger groups. In summer 2001 on the one hand Allianz and Dresdner Bank merged in a move, that was seen as the beginning of a wave of further mergers in the financial services sector. However, only in autumn 2001 Deutsche Bank and Zurich Financial Services Group agreed to swap some of their holdings not belonging to their respective core businesses. Thus, Zurich sold its asset manager Zurich Scudder Investments (excluding Threadneedle) and in return received Deutsche Bank’s insurance group Deutscher Herold. At the same time Deutsche Bank and Zurich agreed on close co-operation in the distribution of insurance, asset management and bank products and services. Even though in the case the of Allianz/Dresdner the investment division of Dresdner Bank will for the time being remain part of the Allianz group the tendency in other insurance groups is clearly to avoid the risks associated with investment banking and not to take on or start such activities. On the other hand commercial banking subsidiaries can still be found in large insurance groups and insurance subsidiaries can be found in groups dominated by banks. Integration does not necessarily mean the establishment of financial conglomerates but also can take lesser forms e.g. cross-holdings (e.g. AXA/PNB Paribas), specialised co-operations for the development of a certain range of products or for their distribution or establishment of a jointly operated data centre. All these kinds of integration also exist in Germany. The majority of the market (small and medium players) can be considered to be in a state of equilibrium. Potential synergies between banks and insurers will become more important after the State Pension Scheme which currently accounts for 81% of the entire pension volume in Germany will significantly decrease its payments in the next eight years. The gap resulting from this reduction is to be filled by private and corporate pension provision schemes that are supported by the state but will be administered by insurance companies and/or banks. According to press announcements by Allianz and Dresdner Bank their merger was driven to a large extent by the need to meet the requirements of the new market for private old-age provision. Some /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc
  2. 2. experts estimate that the current German life insurance market (Euro 60 billion) will grow by up to 50% as a result of the reduction of state pension. The new private pension products that qualify for state benefits require both actuarial as well as asset management know how which makes further mergers or co-operation agreements between German banks and insurers more likely in the future. 2. Compare the level of integration in the insurance industry in your country with the level of integration in developed countries generally. Explain, which aspects of the insurance industry are more or less well-integrated than others. The level of integration in Germany is similar to the level seen in other G7 nations. Especially life insurance and retail banking are deemed to be a good fit with a view to distribution of life insurance policies over the bank counter. Often such policies are used as tax efficient collateral for bank loans. Other classes such as motor vehicle, property casualty or the corporate clients division of insurers do not necessarily benefit from integration of banking and insurance. 3. What are the principal similarities between investment banking, commercial banking, and insurance? From a regulatory point of view there is no difference between investment banking and commercial banking as both activities are often carried out by the same corporate entity. If a bank concentrates on investment business or if a commercial bank has set up its separate investment entity, such entities basically have to comply with the same set of regulatory provisions as any commercial bank. From a principal and/or commercial point of view, the situation in Germany does not differ from other countries. In basic terms insurers as well as banks offer an “invisible product” consisting in the transfer, investment and re-transfer of money under specific terms and conditions. Banks, as well as insurers, have to build reserves for future liabilities. However, whilst such reserves reflect the main activity (coverage of risks) of insurers and are, therefore, subject to detailed insurance supervisory rules, banks with a view to their reserves basically have to comply with general accounting principles and banking supervision rather concentrates on the asset side of the balance sheet. As opposed to banks insurers do not need to refinance their activities. Both, banks and insurers, carry out substantial investment and asset management activity which in both sectors requires the same know-how and sophistication. However, whilst as a rule the customer of the bank decides where the money is to be invested and bears the risks related to such investment, a policyholder generally cannot influence the investment decision of the insurance company. Both, banks and insurers, must meet minimum capital requirements. However, the manner in which such capital requirements are computed differs between insurance and banking regulation. Typical banking risks (default risk, currency risk, liquidity etc.) can be attributed to the asset side of the balance sheet, hence, the capital adequacy of a bank is assessed by weighting the assets and applying the “Cooke Ratio” which requires that 8% of the weighted assets plus certain balance sheet items have to be covered by the banks own funds. It is likely that the capital rules for banks throughout Europe will more and more implement elements of the Risk Based Capital approach similar to the rules common in the US. As opposed to the balance sheet of a bank, the insurer’s main risk is reflected in the technical provisions (“coverage reserve”) on the liabilities side. A way to compute the solvency requirement of insurers differs between different classes of business. A life insurer, for example, has to cover roughly 4% of the coverage reserve with its own funds. /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc
  3. 3. Not only is the calculation of capital requirements different for insurance companies and banks but also the way in which capital is and may be invested differs. Whilst German banks are more or less free to determine their investment policy (provided they have sufficient own funds to cover the Cooke ratio), German insurers are subject to a tight investment régime which allows them, for example, to invest only up to 35% in the stocks. 4. To what extent do you agree or disagree with the following statement: investment banking, commercial banking and insurance are similar because they each involve (a) risk-management; (b) evaluating investments and managing financial assets on a large- scale basis; (c) large-scale investing on behalf of small clients (depositors, investors, and insured individuals)? (a) Until 1994 the German insurance market was regulated in a way which allowed insurance companies to concentrate any risk management efforts to the traditional aspects of insurance business, it’s managing underwriting risks, reinsurance structure, portfolio policies etc., products and premiums had been prescribed by the regulator in a way to a great extent protected insurers from entrepreneurial risks. After liberation of the European insurance market took place in 1994 and the deregulation of products and premiums, risk management in insurance companies increasingly comprises investment activities as well as non-insurance activities which are part of the service portfolio of larger insurance groups. Therefore, one can say that risk management increasingly becomes a common aspect of insurance and banking business. This development is also forced by the “Act on Control and Transparency in Commercial Businesses” (KonTraG) which came into force on May 1, 1998. This Act imposes on the Board the duty to implement a control system which enables the Board to recognise developments which may endanger the company early enough to take counter measures. Even though this Act requires all listed corporations to implement risk-management systems, it will enhance similarities in the way banks and insurers conduct their respective business. Asset-liability management has been acknowledged and has been implemented as important risk management tool has risen during the last decades in both sectors. Also, to some extent, insurers and banks offer risk management to their respective clients, either included in their genuine products or as additional service. (b) See answer to Q. 3. There are certain similarities between the investment activities of banks and insurers and thus, similar issues and questions arise when evaluating investments and managing financial assets. (c) Insurers, commercial banks as well as “Kapitalanlagegesellschaften” (investment fund management companies) act as financial intermediaries. However, as pointed out above (see answer to Q. 3) holders of traditional insurance policies cannot influence the investment decision of the insurer whilst the clients of commercial banks or investment companies in general specifically instruct where and how the money is to be invested. The new “Personal Pension Plan Act” (“Altersvermögensgesetz-AvmG”) which will come into force in January 2002 allows individuals to build up individual asset-backed pensions plans with the help of state benefits. Such personal pension plans can be offered by insurers as well as by banks and investment companies. The new Act is designed to fill up the gap created by the recent reduction of state pension and to some extent will result in “privatisation” of the German pension system. Insurers as well as commercial banks and Kapitalanlagegesellschaften have developed pension products which are bound to be similar as they have to meet the requirements of the new Act in order to entitle the clients to collect the state benefits. /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc
  4. 4. Thus, one can say that the new Personal Pension Plan Act will increase competition between banks and insurers in the pension sector. As a consequence “large-scale investing on behalf of small clients” will become a more common feature of insurers and banks. 5. What are the principal reasons for integration amongst commercial banking, investment banking and insurance in your country (circle all that apply)? Since commercial banking and investment banking are already thoroughly integrated in Germany the following answers only refer to the integration of banking and insurance: one of the most important reasons for integration in the past have been cross-marketing opportunities (e). Many insurers tried and some were successful in marketing insurance policies over the bank counter. Life insurance policies are often used as tax efficient instrument to secure and repay mortgages. Currently less than 10% of the life business are sold via the bank counter but some experts believe that this figure will approximately double within the next five years. Further, integration of banking and insurance is meant to achieve economies of scale (a) for example by combining investment and asset management activities. Furthermore, the economies of scope in operations (b) have played a role in recent mergers as well as the need to meet international competition (h) and to increase the overall market share (c) in the financial services sector. The reduction of risks associated with the insurance business (g) is not likely to have played a role in the integration of banking and insurance in Germany since insurance business is generally considered to be less risky than banking. 6. Are there significant regulatory obstacles to integration among investment banking, commercial banking and insurance businesses in your jurisdiction? Whilst investment banking and commercial banking can be combined in one legal entity, insurance business can only be carried out by specialised entities which are not allowed to diversify into other lines of business. Hence the need to establish financial conglomerates with separate entities that specialise into separate lines of business (e.g. insurance, commercial banking, leasing, factoring, securities, management of investment funds, venture capital etc.). There are no significant regulatory obstacles to establish such a financial conglomerate with a non-regulated holding entity as ultimate parent company. If either a bank or an insurer serves as holding entity such entity has to meet the general regulatory requirements with a view to minimum capital, investment limits, reliability of shareholders and/ or other regulatory restrictions. Another regulatory obstacle is e.g. the German Data Protection Act that restricts a free data flow between different legal entities even if they belong to the same group of companies. However, all in all the regulatory obstacles to integration of the two sectors in Germany can not be regarded as “significant”. 7. Are there significant cultural, economic or other non-regulatory obstacles to integration among commercial banking and insurance businesses in your jurisdiction? There are no cultural, economic or other non-regulatory obstacles specific to Germany that hinder integration amongst commercial banking and insurance businesses. As a result of their century long separation banks and insurers have developed and still have different corporate cultures that make integration difficult. However, the cultural gap e.g. between a large insurance corporation and small mutual insurer can well be more significant than the cultural gap between a large insurer and a large bank. The recent integration of the investment bank Dresdner Kleinwort Wasserstein in the Allianz group as a consequence of the merger between Alliance and Dresdner Bank will probably show that even though investment banking is considered to be more risky than insurance business, there are no insurmountable obstacles to integration. 8. In your view, what are the principal obstacles to integration, amongst investment banking, commercial banking and insurance businesses? Please rank the following in /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc
  5. 5. order of importance with the number 1 one indicating the most significant obstacle to integration and higher numbers indicating less significant obstacles to integration: 1. Lack of compelling business justification (however this may change as a result of the new business opportunities opened by reduction of state pensions); 2. Costs; 3. Business risks associated with taking on of new lines of business (especially from the point of view of an insurer); 4. Local cultural norms; 5. Regulatory obstacles unrelated to anti-trust concerns (prohibition for insurers to conduct non-insurance activities); 6. Anti-trust concerns (these are likely to emanate from EU law rather than from German Anti-trust Rules). 9. As a general matter, which industry is more heavily regulated in your country at the present time, investment banking, commercial banking or insurance? Insurance regulation has been tighter in the past than the regulation of banks. Even though one of the former main features of insurance supervision in Germany, the mandatory authorisation of all insurance products and premiums, has been abolished in 1994, still various restrictive provisions apply to the insurance industry that have no parallel in the banking sector. Examples are the tight regulations which govern the investment and asset management of insurance companies, the obligation of insurers to submit certain products (e.g. life and health) for authorisation, the blanket clause that allows the German Insurance Regulator to take any adequate measures to safeguard the interests of policyholders. These examples show that elements of the “Material Supervision” (Materielle Staatsaufsicht) are still playing an important role whilst there is a tendency to reduce the regulatory regime for insurers towards a mere “Financial Supervision” (Finanzaufsicht) mainly focussing on solvency and capital requirements, similar to the current level of regulation in the banking sector. 10. In your country what are the specific regulations which impose the highest costs on: (a) the commercial banking industry; (b) the investment banking industry and (c) the insurance industry? The highest costs are probably caused by the capital requirements in all three industries. 11. Describe the general nature of the regulations that govern the insurance industry in your country. Any insurance company that has its general place of business in Germany has to be authorised by the German Insurance Regulator (Bundesaufsichtsamt für das Versicherugnswesen - BAV). Insurers from other EU member states do have to apply for authorisation to conduct business in Germany with the regulator in their respective home country. They can carry out business either directly or via a branch. The German regulator as well as the regulators in other European Member States only grant approval if (i) the company has sufficient own funds to meet the capital requirements, (ii) the managers and owners of the company are “fit and proper” to conduct insurance business, (iii) a business plan shows that current and future obligations, under the policies and otherwise, can be met and (iv) certain other preconditions are fulfilled and notifications made. The scope of supervision exercised by the BAV after insurers have been licensed has decreased as a result of various European directives. Before deregulation took place in 1994 the terms and conditions of all insurance products marketed and sold in Germany had to be approved by the BAV that also exercised control on the premiums. As of 1994 the BAV is not allowed any more to control products or premiums except for certain classes of business (e.g. mandatory insurance and to a some extent life and health insurance). A principal task of the German regulator nowadays is the “financial supervision” which involves controlling the /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc
  6. 6. solvency margin, the investment activities, the building of sufficient reserves as well as the management and the owners of insurance companies. Further, a blanket clause in the Insurance Supervisory Act allows the BAV to intervene in case of irregularities that could be detrimental to the policy holders’ interests. 12. Is the insurance industry in your country regulated by the same regulatory agency that regulates commercial banking and/or investment banking? Not yet. Commercial banks and investment banks are supervised by the same regulator (Bundesaufsichtsamt für das Kreditwesen - BAKred) but insurance companies are currently still regulated by a separate authority (BAV). Plans to merge both regulatory agencies as of January 1, 2002 have been put on hold due to political reasons. In any case a future merged authority would continue to apply the two different sets of regulatory rules that currently govern the different industries. 13. If the insurance industry in your country is not regulated by the same regulatory agency that regulates commercial banking and/or investment banking, which regulatory agency is a) more efficient b) more technically competent c) more sophisticated d) more transparent e) more free of corruption, special interest groups pressures and/or political pressures? BAKred and BAV both are federal authorities. There are no differences to be observed with a view to the aspects raised by the question. 14. Which industry do you believe has been more profitable globally during the last decade, investment banking, commercial banking or insurance? Most likely investment banking has generated a better Return on Investment than insurance and commercial banking in the decade between 1990 and 2000. 15. Which industry do you believe has been more profitable in your jurisdiction during the last decade, investment banking, commercial banking or insurance? See answer to Question 14 above. 16. Which industry is likely to be more profitable over the coming decade, investment banking, commercial banking or insurance? Profitability in all three lines of business is subject to a variety of factors, such as development of the national and world economies as a whole (affecting all three businesses including insurance sector through capital income), politics (e.g. war, terrorism), development of the climate (e.g. natural disasters in relation to property insurance). 17. Which industry has been more risky during the last decade, investment banking, commercial banking or insurance? As the different businesses are subject to different risks, no general answer can be given. In Germany neither a commercial bank, nor an investment bank or an insurance company has filed for bankruptcy. /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc
  7. 7. 18. Which industry is likely to be more risky over the coming decade (2002 to 2010), investment banking, commercial banking or insurance? Miscellaneous risks may affect the various businesses. 19. What sort of firm would be riskier: An integrated financial services firm that offers investment banking, commercial banking and insurance services or an insurance company? An integrated financial services firm which includes investment and commercial banking is more likely to be affected by a possible decline of the overall economic situation than a mere insurance company (probably with the exception of insurance companies specialising in the classes credit and surety). This applies to Germany as well as globally. 20. What sort of firm would be riskier: An integrated financial services firm that offers investment banking, commercial banking and insurance services or a commercial bank? The question can not be answered in a general way. The risks related to investment banking may possibly be mitigated by the less risky insurance business. Thus, an integrated financial services firm will probably be as risky as a commercial bank. 21. What sort of firm would be riskier: An integrated financial services firm that offers investment banking, commercial banking and insurance services or an investment bank? Pursuant to the logic set forth in the answers to questions 19 and 20 (investment banking involving a higher risk, commercial banking a medium risk and insurance services a relatively low risk) an investment bank would be riskier than an integrated financial services firm that offers the complete range of financial services. However, modern economy is obviously too complex to allow such statements. Whether diversification helps to mitigate risks or rather leads to large corporate structures that make risk management increasingly difficult can not be answered ex ante, but has to be proven by future developments. It will always depend on the specific circumstances, the product portfolio of the integrated firm, the areas in which the investment bank is active, the overall economic situation, the legal framework etc. 22. Please respond to the following questions, which are related to the base in which issues of national identity are intertwined with the issues of financial integration: a) As a general matter, do you agree or disagree with the assertion that countries’ national identities are closely intertwined with certain industries? It can be observed that in some cases foreign observers or the national population do identify a nation with a “flagship industry”, with single corporations or with brands. b) If your answer to the above question is “yes”, please list the industries that you think are closely associated with national identity. Automotive, banking, chemical, media and insurance industry can be or become associated with national identity. c) Do you think that national identities are closely intertwined with certain industries in your country? /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc
  8. 8. See answer to question 22 a) above. In this respect, Germany is not different from other countries. d) If you think that national identities are closely intertwined with certain industries in your country, which particular industries are closely associated with national identity? See answer to question 22 c) above. In addition, there may be “latent flagship industries”, i.e. industries that become an issue of national identity once they are at risk to be taken over by foreign investors. In any case, the importance of a certain industry for national identity should not be overrated. The identification of the German population e.g. with a German national formula one pilot will be stronger than the identification with the make of his car. e) If you think that national identities are closely intertwined with certain industries in your country, do you think that regulators should have the power to block a cross- border merger on the grounds that such a merger would result in the elimination of a major firm in a “flagship industry”? Cross-border mergers should not depend on questions of national identity, but rather be assessed in commercial and economic terms as well as under anti trust aspects. f) Do you think that the insurance industry is a “flagship industry” in any country? It is very likely that the insurance industry in some countries is at least a “latent flagship industry” (see answer to Question 22 d) above). g) Do you think that the insurance industry is a “flagship industry” in your country? Recent mergers of German insurance companies with dominant foreign insurers (e.g. AMB Generali, Axa Colonia) have not raised significant concerns in the market place but have been well accepted. Thus, if one chooses the reaction of the German population to cross-border mergers one would rather not categorise the insurance industry as a German “flagship industry”, even though this obviously might not reflect the actual economic importance of the insurance industry in Germany. 23. The following questions relate to the integration of insolvency regulation by banks: a) Describe the way that insurance company insolvency is regulated in your country. An insurance company that becomes either insolvent or over-indebted has to notify the regulator of this fact. The regulator alone then has the right to initiate insolvency proceedings. Neither the board of the company nor its creditors have the right to file a notification with the insolvency court. The regulator decides which measures best safeguard the interests of the policy holders. All kinds of payments, especially insurance payments, distributions of profits and, in life insurance, surrender values or policy loans can be temporarily prohibited. The regulator can also reduce the obligations of a life insurance company, so that the remaining obligations correspond to the actual assets of the company. As a general rule German insurers do not contribute to a common guarantee fund. An exception applies for motor vehicle insurers that have to contribute in a national guarantee fund that covers claims of victims that, for certain reasons, can not take recourse. b) To the extent that you are familiar with insolvency regulation for commercial banks and investment banks, describe those regulations. /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc
  9. 9. Similar to the situation with insurance companies, only the banking supervisory agency (BAKred) and not the bank or its creditors can initiate insolvency proceedings, if the fulfilment of the obligations of the bank vis-à-vis its creditors is at risk. The banking authority can take any measures, e.g. prohibit the acceptance of moneys and the granting of loans, instruct the management of the bank or prohibit or restrict the activities of the management or the owners of the bank, if such measures are likely to remedy the situation. All private commercial and investment banks contribute to a guarantee scheme (Entschädigungseinrichtung Deutscher Banken GmbH) which has been established in 1998 as a response to a European directive which requires that in all Member States such scheme is set up in order to safeguard the claims of smaller depositors and investors. Compensation of bank clients under this scheme is limited to EUR 20,000. This minimum protection under the recently established guarantee scheme is topped up by three more guarantee funds operated by different groups of banks. Almost all banks contribute to one of these funds. Even though the funds do not grant direct claims to the banks or the creditors, it is commonly held that these funds are sufficient to protect the vast majority of the so called “small savers”. c) Regulators in general, and guarantee fund administrators in particular, have an interest in the solvency and stability of out-of-state (foreign) insurance companies operating within the jurisdiction, because they have a responsibility to the policy holders within their jurisdiction. Describe the extent to which regulators at the state level are able to enforce safety-and-soundness regulations, capital requirements and related insolvency regulations on foreign, e.g. out-of-state insurance providers. One has to distinguish between foreign insurance companies from other EU member states and foreign insurance companies from non EU member states. Insurers from EU member states are controlled by their respective home state authority regarding their financial soundness (so called “financial supervision”, see answer to Question 11 above). The powers of the BAV are restricted to supervise the way in which insurers from other EU member states conduct business in Germany (so called “legal supervision”). However, once such foreign insurer establishes an insurance subsidiary in Germany in order to conduct business, such subsidiary would be subject to the regular financial and legal supervision in the same way as all other German insurers. Foreign insurers that are not based in other EU member states have to apply with the BAV, if they intend to actively conduct business in Germany. Such insurers have to establish a branch in Germany, i.e. they must not sell policies by using independent brokers or agents without having a local organisation that allows them to collect premiums, administer the portfolio, do the claims handling and represent the company vis-a-vis the BAV. The foreign insurer must also provide evidence that it has accumulated uncommitted assets sufficient to cover the solvency margin that applies to German insurance companies. The calculation of the required solvency margin is based on the volume of business of the branch. At least a third of assets that cover the risks written in Germany must be located in Germany, whilst the other two thirds can be located in other EU member states. Foreign non EU insurers also have to make a deposit amounting to at least 25% of the required guarantee fund. Such deposit is counted towards the uncommitted assets. The branch of the insurer has to be organised in a way that allows the BAV to monitor that the capital requirements and investment regulations are continuously met also after the initial authorisation has been granted. d) To what extent does solvency regulation or concern over issues related to solvency affect cross-border-mergers of firms in the insurance industry? See answer to question 23 c) above. Within the European Internal Market solvency regulations have been adjusted to a similar level. Thus, cross-border M&A transactions /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc
  10. 10. are not significantly affected by solvency concerns, also because solvency regulations in the past applied mainly to the operative unit itself whilst solvency of the parent company and/or the whole group was only of limited importance. However, this will change when the proposed European Directive regarding the group solvency within financial conglomerates will become effective. Cross-border transactions involving EU and Non- EU companies can be more problematic since different solvency regulation, different accounting standards, different investment restrictions etc apply. Actual cross-border “mergers”, i.e. the merging of two legal entities with their respective corporate seat in different countries into one single unit are not practicable because of legal constraints under German corporate law (not related to solvency concerns). Similar effects, however, can be obtained by portfolio transfers from a German company (or the German branch of a foreign company) to the German branch of a foreign insurance company. As precondition for such transfer the BAV requests evidence that the foreign insurer and its German branch comply with German solvency and other regulatory requirements. e) To what extent does solvency regulation, or related concerns about solvency issues, affect mergers between firms in the insurance industry and firms in other industries, such as manufacturing, investment banking, and commercial banking? Insurance companies as a rule are not allowed to carry out non-insurance business and, therefore, can not “merge” with firms in other industries but can only establish or become part of a group of companies. As the solvency requirements apply to the insurance company itself (“solo supervision”), the solvency situation of the group as a whole only plays a minor role under the present regulatory régime and thus the establishment of a group with an insurance company as a member is not significantly affected by regulation specifically relating to solvency issues. /home/pptfactory/temp/20100512113803/integration-of-financial-services4208.doc

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