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SA3- legislation (Lloyd's (Funds at Lloyd's
Money from Names.…
SA3- legislation
Lloyd's
Capital assessed at three levels:
- Overall
- Syndicate
- Member/names
Overall
Capital made up of New Central Fund plus other central assets. Combined with FALs this must be able to withstand solvency test against total of all syndicate's exposure
Capital requirements for Lloyd's syndicates
Submit SBF and Lloyd's Capital Return (LCR) (contains detailed info on SCR)
Lloyd's scrutinises SBF and asks questions.
Ultimate SCR used to set capital on behalf of each syndicate. May be loaded if not high enough. Multiplied by 35% (to maintain Lloyd's credit rating_ and called Economic Capital Assessment
Lloyd's allocates capital amount needed to be be put up to Lloyd's Names/members
Funds at Lloyd's
Money from Names. Held in trustLodged as assets or Letter of Credit from bank. LoC must meet:
- Appropriate level of rating of the bank
- Be available throughout a specified period usually four year- 'evergreen'
- Under SII must be approved as ancillary funds
Members can get LoC at low cost by collaterising other assets. But can invest these assets in higher paying investments. Works out less expensive but bank will charge rate for LoC representing investment risk of collaterised assets
FAL held at member level, just for open YOAs not for each YOA separately. Credit given for diversification between syndicates. Detailed simulation model used to model experience of each member. From this, an overall distribution of losses beyond FAL is derivedLloyd's SCR calculated on two bases:
- Market Wide SCR- all capital consumed in 1 in 200 whatever the source
- Central SCR- central capital needed at 1 in 200
Once each member's capital requirements has been calculated a minimum of 40% of Overall Premium Income Limit (member capacity)= premium gross of RI and net of brokerage.
In line- members tested twice a year that they have at least FAL equal to capital requirement
Solvency deficits- if liabilities are greater than Premium Trust Funds the members have solvency deficits. Counted against FAL. If member's FAL can't meet PRA test then central assets may be earmarked
Coming into line- Lloyd's has power to require members to lodge further assets
SAO
Produced under Lloyd's valuation of liabilities rules which are influenced by actuarial guidance.
Solvency II
A risk based approach to prudential requirements which brings harmonisation at the EEA level.
Aims to provide good incentives for risk management
Applies if gross premium income greater than 5m euro or gross TPs greater than 25m euro
Pillars
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Pillar II
Need effective corporate governance which provides sound and prudent management of business
Organisational structure must have clear segregation of responsibilities. Written policies in respect of:
- risk management
- internal control
- internal audit
- actuarial
Risk management function
Need strategies, processes and reporting procedures to identify, measure, monitor, manage and report the risks they could be exposed to. Must cover each risk type. If have internal model then needs to cover all aspects of internal model e.g. test, document
Internal control
- administrative and accounting procedures
- internal control framework
- appropriate reporting arrangements at all levels of the undertaking
- compliance function
Internal audit
Evaluates adequacy and effectiveness of internal control system. Must be objective and independent
Actuarial function
- coodinate the calculation of TPs
- ensure the appropriateness of the methodologies and underlying models used as well as the assumptions made in the calc of TPs
- assess the sufficiency and quality of the data used in the calc of TPs
- compare past best estimates against experience
- inform the supervisory body of the reliability of the calculation of the TPs
- express opinion on overall underwriting policy
- express opinion on adequacy of RI
- contribute to effectiveness of the risk management system
ORSA
Own risk and Solvency Assessment- goes beyond the MCR and SCR
Requires identification of all risks to which the firm is subject to- will likely include more than just those modelled in Section I
Must quantify ability to continues to meet the MCR and SCR over the business planning horizon, allowing for new businessIncludes the following components:
- assessment of overall solvency needs (considering specifics to the firm)
- compliance with capital requirements and TPs
- consideration of extent of deviation of risk profile from that assumed in modelling
Performed annually and must be reported to regulator.Looks at all the stuff you'd expect and need to document all this- data, methodology, sensitivity, uncertainty, peer review
Pillar III
Reporting and public disclosureReporting
- Quantitative templates
- Regulatory Supervisory Report (RSR) which includes solvency calculation details and risk management details
- ORSA
Public Disclosure
Solvency and Financial Condition Report (SFCR). Quantitative templates, solvency calculation details and risk management processes
SFCR and RSR includes
- system of governance applied by undertakings
- business they are pursuing
- valuation principles
- risks faced
- risk management systems
- capital structure
- system of governance
Application to insurance groups
Solvency II enables supervision more efficiently through a 'group supervisor' in the home country. Each group must cover group SCR, allowing for diversification benefits across the group. Each subsidiary needs to cover its own SCR
'Third country'- country outside EEA. If group based here additional rules apply but if country has similar rules then can get 'third country' equivalence.
Impact
- optimal business mix and product design
- optimal asset mix
- corporate structure (think diversification benefits)
- management info changes
- impact on market of external disclosures
Regulatory frameworks
Supervisory tools
Statutory actuarial roles
Two roles requiring practising certificates:
- Chief actuary
- Lloyd's Actuary/Syndicate Actuary
Need:
- Technical competency- provide evidence to show they are fit for role
- Financial and criminal background check
- Confirm you apply with current actuarial standards and codes
- Prove you have done required CPD in last 12 months
Chief Actuary
Two certificates- non life with Lloyd's and non life without Lloyd's Specific technical requirements:
- Considering appropriate reserving bases and methodologies for valuing assets and liabilities
- Pricing bases
- RI arrangements
- Measuring, managing and mitigating issues and risk to which an insurer is exposed
- Assessing capital requirements
Lloyd's Actuary
Provide details about the work you have done in the last four years , particularly last 12 months, which demonstrates experience of setting reserves in London MArket
Rulebooks
Sets out rules that a company must abide by:
- communication- how they can market
- data holding
- sales e.g. cooling off period
- claims e.g. how quickly claims must be paid
Solvency II requires a large number of info items before a policy can be written
Reporting requirements
So the regulator can monitor certain characteristics of a company. Reporting requirements can be both qualitative and and quantitative
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