CBI has issued a Consultation paper on CP92
“Domestic Actuarial Regime and Related Governance Requirements under Solvency II”
Consultation paper overview
The CBI has issued a consultation paper on “Domestic Actuarial Regime and Related Governance Requirements under Solvency II” (CP92). The consultation is open from the 2nd of April to 29th of May 2015 and feedback can be sent to the CBI via email to firstname.lastname@example.org.
Key issues covered include:
- A requirement to notify the CBI of the person responsible for the Actuarial Function, called the Head of Actuarial Function (HoAF) which will be a PCF position. This will be done via the Central Banks Fitness & Probity regime and will require pre-approval. The new PCF position will be introduced from the 1st of January 2016 and the existing PCF positions of Chief Actuary and Signing Actuary will no longer exist from 1st January 2016.
- The HoAF is required to provide an opinion to the CBI on an annual basis on the Technical Provisions of the undertaking, which is referred to as the Actuarial Opinion on Technical Provisions. Additionally the HoAF is also required to provide an Actuarial Report on Technical Provisions to the Board on an annual basis. The contents of each report are outlined in the consultation paper.
- The HoAF is also required to provide an opinion to the Board on the adequacy of the scenarios, including financial projections, considered as part of the ORSA process of the undertaking.
- High impact companies have to establish a reserving committee which is required to meet on a quarterly basis. Powers will be delegated to it by the Board. The committee will have responsibility for overseeing the governance around the calculation of the Technical Provisions and compliance with reserving policies.
- All High, Medium High and Medium Low Impact entities are required to engage a Reviewing Actuary to conduct a peer review of the Technical Provisions. The Reviewing Actuary cannot be an employee of the undertaking, but for Medium High and Medium Low undertakings, the Reviewing Actuary may be from the same Group. Where the Actuarial Function is outsourced, the Reviewing Actuary cannot be from the same firm. A peer review has to be conducted:
- For High Impact undertakings at least every 2 years;
- For Medium Impact undertakings at least every 3 years;
- For Medium Low undertakings at least every 5 years.
How can we help
To the extent you have any questions in relation to CP92 above or you would like to discuss how we could potentially help you close any gaps arising as a consequence of the proposed requirements above, please feel free to give us a call or arrange a face to face meeting with us.
Deloitte’s Actuarial & Insurance Solutions practice has grown substantially since its inception 4 years ago. Our team now comprises almost twenty actuarial professionals and we have access to an international network of over 1,000, thus giving us both strength and depth in terms of our knowledge and experience.