Gibraltar Solvency II Questionnaire responses. Michael Oliver Head of Insurance Gibraltar FSC 30 th September, 2009

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1 Gibraltar Solvency II Questionnaire responses Michael Oliver Head of Insurance Gibraltar FSC 30 th September,

2 Outline of presentation Provide a summary of the findings of the 16 questions that were raised under the headings: 1. Current Preparation 2. Capital 3. Internal Models 4. Risk Management 5. Data Quality 2

3 Of the 61 insurers currently licensed by the FSC 48 responded to the questionnaire 4 did not respond to the questionnaire 4 are in liquidation 5 are in run-off 3

4 1.1 Who is responsible for preparing the implementation of Solvency II? MD/CEO 9 Executive Director 10 Manager 16 Actuary 3 Other 10 NB Not all firms have a MD/CEO. Manager includes manager staff who are also EDs. Others includes Solvency II subcommittee, Working Parties and various committees. 4

5 1.2 What preparatory work has been undertaken? QIS 3 and 4 participation Attendance at seminars Contacts with actuarial / professional service consulting firms Involvement in GIA SII subcommittee Review of CEIOPS CPs 5

6 1.3 Implementation Plan developed? Yes - 3 Before 31/12/09-8 In ??

7 1.4 What costs do you expect to incur? Major items Actuarial Insurance Manager Capital modelling software Costs Most had not estimated 50k to 100k quoted by several medium / medium large sized insurers 7

8 1.5 Have you participated in QIS 3 and 4? Have participated: QIS 3-4 QIS 4-6 QIS4 retrospective - 5 expect to complete 17 Total QIS 4 will be 28 if plans are followed 8

9 1.6 Do you intend to complete QIS5? Yes - 38 No - 3 Maybe - 7 9

10 1.7 What guidance do you require? 10 Regulatory Internal models Timings Model Approval Pillar II Principles ORSA requirements Proportionality Captives Exemptions General Gibraltar specific guidance All matters relating to SII MCR and SCR Calculation

11 1.7 What guidance do you require? Professional Service Providers Actuarial input on technical reserves Building partial/internal models Completing QIS4 and QIS5 11

12 2.1 Consideration of future capital needs Mixed responses Existing shareholders will provide We are already well capitalised We will cease dividends until we are sure we are adequately capitalised We will revise investment portfolio to reduce risk We expect to self fund future capital requirements 12

13 2.2 Have you considered Simplified Proxies? Yes - 24 No - 20 Not sure - 3 MBO footnote simplifications may not be that simple 13

14 3.1 Have you given consideration to using an internal model? Yes - 35 No

15 3.2 Do you expect to adopt a standard, partial or internal model? Standard - 12 Partial - 2 Internal - 6 Not sure

16 3.3 When will you make your decisions to use a standard, partial or internal model? Although several companies are undecided they would expect to use the standard model Others are conducting further research, including looking at off-the-shelf and consultant s models Others are seeking consultant s guidance (actuarial or insurance manager) Some have indicated that they are awaiting further CEIOPS guidance. This is especially true for a number of captive insurers. In terms of time late 2010 or even 2011 has been suggested 16

17 4.1 Systems of Governance Most indicated that they consider themselves to be well positioned now Proposed improvements Solvency II teams will review Refine risk register Refine risk management processes Formalise and document procedures Strengthen board committees 17

18 4.2 Internal audit Many do not have such a function now Proposals for the future: Introduce own internal auditor Use Group audit Outsource audit Rely on insurance manager Await guidance on proportionality 18

19 4.3 Actuarial function Many do not have such a function now Proposals for the future: Recruiting own in-house actuary Use Group resources Outsource to actuarial consultant Rely on insurance manager Await guidance on proportionality 19

20 5.1 Data quality Many satisfied with current quality Has been acceptable to auditors Others (larger insurers) indicated SII subcommittee to review Data quality project in place Using external consultants to review data quality Will be assessed as part of QIS5 20

21 Gibraltar Solvency II Questionnaire responses Michael Oliver Head of Insurance Gibraltar FSC 30 th September,

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