SAI responds to CBI Consultation on the Domestic Actuarial Regime under Solvency II

The Society has responded to the Central Bank of Ireland’s Consultation Paper 92: “Consultation on Domestic Actuarial Regime and Related Governance Requirements under Solvency II”.

The response includes the following comments:

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  The proposed role of Head of Actuarial Function (HoAF) is a broader role, with greater responsibility, than the actuarial function role envisaged under Solvency II. We strongly recommend that the Central Bank require that the role of HoAF be performed by an actuary.  Failing that, the requirements as proposed would represent a weakening of the regulatory framework, which currently requires that Appointed, Signing and Reviewing Actuaries be fully qualified actuaries.
• We further recommend that the HoAF should be required to be a member of a recognised European actuarial association – specifically, an association that is a member of the Actuarial Association of Europe (AAE).  All AAE member associations are required to have in place an education system that meets certain minimum standards, as well as a Code of Conduct and a Disciplinary Scheme.  In addition, with the participation and support of member associations, the AAE is currently developing a suite of Solvency II-related European Standards of Actuarial Practice (ESAPs) that will foster consistency and high quality in Solvency II-related actuarial work.
• We offer suggested amendments to clarify what responsibilities are carried by the HoAF and what responsibilities are carried by the Risk Function or the Board.
• We recommend that the CP92 requirements should include an explicit obligation on the undertaking to provide the HoAF with such information, and such access to other persons, as he or she may require for the performance of work required under CP92.
• We request clarification on whether the 2014 Reserving Requirements will cease to apply for companies that are within the scSome of the provisions of CP92 seem more relevant to non-life business than life business. We have drawn on the AAE draft ESAP on the Actuarial Function Report to suggest revisions to some paragraphs of CP92 that we think could usefully be edited to make the provisions more generalised. ope of Solvency II (or altogether) and if so, from what date. 
• We encourage the Central Bank to make arrangements for PCF applications for the new role of HoAF to be processed in a timely manner, in advance of Solvency II coming into effect. 
• We would welcome clarification as to whether current legislative requirements for life assurance companies to appoint or engage an “appointed actuary” will cease to apply for companies that are subject to Solvency II.
• The Consultation Paper 92 is available from http://www.centralbank.ie/regulation/poldocs/consultation-papers/Pages/default.aspx
• Full details of the Society’s response to Consultation Paper 92 are available here.