February 2nd, 2010
Solvency II: CEIOPS Third Set of Advice, An Overview
Posted at 8:03 PM ET
Frank Achtert, Managing Director, Financial Intelligence Team
The Committee of European Insurance and Occupational Pensions Supervisors (CEIOPS) published its final and third set of advice to the European Commission (EC) at the end of January. The advice notably excluded final advice on non-life underwriting risk.
CEIOPS Delivers Third Set of Final Advice: Summary
The new set of advice from CEIOPS incorporates the considerable feedback received from various stakeholders on CEIOPS’ third wave of consultation papers. The feedback dealt with the increase in calibration of the Solvency Capital Requirement (SCR) standard formula charges compared with Qualitative Impact Study (QIS) 4 charges. Market risk, equity risk and correlation assumptions are addressed in this final advice.
The market risk charges seem to be based on a combination of the rigid approach suggested in the consultation papers (CP) issued by CEIOPS in November 2009 and the integration of feedback received from the industry. Thus, the interest rate stresses have been significantly lowered compared to the 2009 proposal and the volatility shock is now determined as volatility stresses of 12 percent in the upward direction and 3 percent in the downward direction, to be applied as additive stresses to implied volatility. Interest rate stresses and volatility shocks are assumed as non-correlated. Also credit risk spreads for corporate bonds have been diminished.
Concessions on the equity stress impact are marginal, retaining the 45 percent for “global” equities and a slight reduction in the stress assumptions from 60 percent to 55 percent for stocks categorized as “other.” The equity volatility stress test has been lowered.
Diminished interest rate stresses and more favorable correlation parameters for market risk reduce the size of the capital charges for bonds from that of the November proposal.
Status Quo Non-Life Underwriting Risk
It is noteworthy that Non-Life Underwriting Risk is not covered in this final advice. Although CEIOPS has already undertaken a major effort to refine its calibration proposal by collecting data and revising its assumptions, it still needs to collect more data and to perform further evaluation of practical proposals. One area needing further refinement is more accurate reflection of non-proportional reinsurance in the standard formula. In this respect, more clarity on the underwriting risk calibration is expected by the end of March 2010, when the draft QIS 5 technical specifications are scheduled to be available. Consequently, the trend towards increased capital requirements as suggested in CP71 “SCR Standard Formula – calibration of non-life underwriting risk,” appears to still apply to non-life underwriting risk. CP71 has substantially increased the premium and reserve risk factors for non-life insurance and reinsurance from the QIS 4 levels.
Factors for all classes of business have been massively increased and even doubled for non-proportional reinsurance resulting in an estimated increase of the underwriting capital charge by 35 percent on average compared to the charge with QIS 4. Catastrophe risk factors within the standard formula also have been strengthened by CP71. Guy Carpenter will soon publish additional publications that will shed more light on these issues:
- Solvency II – Rationale for the Capital Requirement Increase for Underwriting Risk
- Higher Pressure on Cat Risk under Solvency II
Additional pressure on risk capital levels for non-life underwriting risk comes from the correlation assumption (0.25) between catastrophe and premium and reserve risk which was just re-confirmed by CEIOPS on its final advice regarding correlations as well as the abolishment of geographical diversification effects.
As QIS 5, the likely final all-embracing quantitative Solvency II exercise, is approaching, non-life carriers are still a bit uncertain as to how severe the calibration of the non-life module will be. For the asset side, insurers and reinsurers now have a better understanding of the loadings. They will be more severe than QIS 4, but less severe than initially suggested in 2009. For non-life underwriting risk, more clarification is expected by the end of March.
This briefing was prepared by Guy Carpenter’s Financial Intelligence Team (FIT). Questions regarding this briefing may be directed to any of the FIT members, listed below.
Susan Witcraft, Managing Director, Minneapolis +1 952.832.2143
Frank Achtert, Managing Director, Munich +49 89.28.66.03.361
Eddy Vanbeneden, Managing Director, Brussels +32 2.674.98.11
David Flandro, Senior Vice President, London +44 (0)20 7357 3267
Benoît Butel, Vice President, Paris +33 22.214.171.124.26
Sebastien Portmann, Vice President, Zurich +41 44.285.9322
Guy Carpenter & Company, LLC provides this report for general information only. The information contained herein is based on sources we believe reliable, but we do not guarantee its accuracy, and it should be understood to be general insurance/reinsurance information only. Guy Carpenter & Company, LLC makes no representations or warranties, express or implied. The information is not intended to be taken as advice with respect to any individual situation and cannot be relied upon as such. Please consult your insurance/reinsurance advisors with respect to individual coverage issues.
Readers are cautioned not to place undue reliance on any historical, current or forward-looking statements. Guy Carpenter & Company, LLC undertakes no obligation to update or revise publicly any historical, current or forward-looking statements, whether as a result of new information, research, future events or otherwise.
Statements concerning tax, accounting, legal or regulatory matters should be understood to be general observations based solely on our experience as reinsurance brokers and risk consultants, and may not be relied upon as tax, accounting, legal or regulatory advice, which we are not authorized to provide. All such matters should be reviewed with your own qualified advisors in these areas.
This document or any portion of the information it contains may not be copied or reproduced in any form without the permission of Guy Carpenter & Company, LLC, except that clients of Guy Carpenter & Company, LLC need not obtain such permission when using this report for their internal purposes.
The trademarks and service marks contained herein are the property of their respective owners.
Guy Carpenter & Company, LLC Terms and Conditions of Use
PLEASE READ THESE TERMS AND CONDITIONS OF SERVICE (“TERMS”) BEFORE USING THIS SITE.
By continuing to access or use this site, or any service on this site, you signify your acceptance of the TERMS. From time to time, Guy Carpenter & Company, LLC (“Guy Carpenter”) may modify the TERMS. Accordingly, please continue to review the TERMS whenever accessing or using this site. Your use of this site, or any service on the site, after the posting of modifications to the TERMS will constitute your acceptance of the TERMS, as modified. If, at any time, you do not wish to accept the TERMS, you may not use the site. Any terms or conditions proposed by you that are in addition to or which conflict with the TERMS are expressly rejected by Guy Carpenter and shall be of no force or effect.
1. User Assent to Terms and Conditions of Service
You represent that you have read and agree to be bound by the TERMS for GCCapitalIdeas.com. You further agree: (i) to comply with U.S. law regarding the transmission of any data obtained from the Service (as defined herein) in accordance with the TERMS; (ii) not to use the Service for illegal purposes; and (iii) not to interfere or disrupt networks connected to the Service.
All content provided on this Web site is based upon information which we believe to be reliable and should be understood to be general insurance information only. It is not intended to be taken as advice with respect to any individual situation and cannot be relied upon as such. Consult your reinsurance/insurance advisors with respect to individual coverage issues.
Guy Carpenter makes no representations or warranties, express or implied, with respect to the accuracy or reliability of the content contained on this Web site. Readers are cautioned not to place undue reliance on any historical, current or forward-looking statements. Guy Carpenter undertakes no obligation to update or revise publicly any historical, current or forward-looking statements, whether as a result of new information, research, future events or otherwise.
Statements concerning, tax, accounting, legal or regulatory matters should be understood to be general observations based solely on our experience as reinsurance brokers and risk consultants, and may not be relied upon as tax, accounting, legal or regulatory advice which we are not authorized to provide. All such matters should be reviewed with your own qualified advisors in these areas.
3. Intellectual Property
This Web site, including, but not limited to, text, content, photographs, video, audio, and graphics (the “Service”), is protected by copyrights, trademarks, service marks, international treaties and/or other proprietary rights and laws of the U.S. and other countries. The Service is also protected as a collective work or compilation under U.S. copyright and other laws and treaties. All individual articles, columns and other elements making up the Service are also copyrighted works. You agree to abide by all applicable copyright and other laws, as well as any additional copyright notices or restrictions contained in the Service.
4. Restrictions on Use
You may not use the Service for any illegal purpose or in any manner inconsistent with the TERMS. You agree to use the Service solely for the use and benefit of your own organization, and not for resale or other transfer to, or use by or for the benefit of, any other person or entity. You agree not to use, transfer, distribute or dispose of any information contained in the Service in any manner that could compete with the business of Guy Carpenter. You acknowledge that the Service has been developed, compiled, prepared, revised, selected and arranged by Guy Carpenter and others (including certain other information sources) through the application of methods and standards of judgment developed and applied through the expenditure of substantial time, effort and money and constitutes valuable intellectual property and trade secrets of Guy Carpenter and such others. You agree to protect the proprietary rights of Guy Carpenter and all others having rights in the Service during and after the term of this agreement and to comply with all reasonable written requests made by Guy Carpenter or its suppliers of content, equipment or otherwise (“Suppliers”) to protect their and others’ contractual, statutory and common law rights in the Service. You agree to notify Guy Carpenter in writing promptly upon becoming aware of any unauthorized access or use of the Service by any party or of any claim that the Service infringes upon any copyright, trademark or other contractual, statutory or common law rights.
5. Further Restrictions on Use
You may not copy, reproduce, recompile, decompile, disassemble, reverse engineer, distribute, publish, display, perform, modify, upload to, create derivative works from, transmit or in any way exploit any part of the Service, except that you may download material from the Service and/or make print copies for use within your organization, provided that all copies retain all copyright and other proprietary notices. The analysis and presentation included in the Service may not be recirculated, redistributed or published by you without Guy Carpenter’s prior written consent. Modification of the Service’s content would be a violation of Guy Carpenter’s copyright and other proprietary rights. Additionally, you may not offer any part of the Service for sale or distribute it over any other medium including but not limited to over-the-air television or radio broadcast, a computer network or hyperlink framing on the internet without the prior written consent of Guy Carpenter. The Service and the information contained therein may not be used to construct a database of any kind. Nor may the Service be stored (in its entirety or in any part) in databases for access by you or any third party or to distribute any database services containing all or part of the Service. You may not use the Service in any way to improve the quality of any data sold or contributed by you to any third party. Furthermore, you may not use any of Guy Carpenter’s names or marks in any manner that creates the impression such names or marks belong to or are associated with you or imply any endorsement by Guy Carpenter, and you acknowledge that you have no ownership rights in and to any of these names or marks. You will not use the Service, the information contained therein or any of Guy Carpenter’s names or marks in unsolicited mailings or spam material and will not spam or send unsolicited mailings to any person or entity using the Service.
You acquire no rights or licenses in or to the Service and materials contained therein other than the limited right to utilize the Service in accordance with the TERMS.
7. Rights Reserved
All present and future rights in and to trade secrets, patents, copyrights, trade names, trademarks, service marks, databases, know-how and other proprietary rights of any type under the laws of any governmental authority, domestic or foreign, including rights in and to all applications and registrations relating to the Service (the “IP Rights”) shall, as between you and Guy Carpenter, at all times be and remain the sole and exclusive property of Guy Carpenter. All present and future rights in and title to the Service (including the right to exploit the Service and any portions of the Service over any present or future technology) are reserved to Guy Carpenter.
8. Disclaimer and Limitation of Liability
You agree that your use of the Service is at your sole risk and acknowledge that the Service and anything contained therein, including, but not limited to, content, services, goods or advertisements (the “Items”) are provided “AS IS” and that Guy Carpenter makes no warranty of any kind, express or implied, as to the Items, including, but not limited to, merchantability, noninfringement, title or fitness for a particular purpose or use. Guy Carpenter does not warrant that the Service is compatible with your equipment or is free of errors or viruses, worms or “Trojan horses” and is not liable for any damage you may suffer as a result of such destructive features. You agree that Guy Carpenter, its Suppliers and its third-party agents shall have no responsibility or liability for: (i) any injury or damages, whether caused by the negligence of Guy Carpenter, its employees, subcontractors, agents, Suppliers or otherwise arising in connection with the Service; or (ii) any fault, inaccuracy, omission, delay or any other failure in the Service caused by your computer equipment or arising from your use of the Service on such equipment. The content of other Web sites, services, goods or advertisements that may be linked to the Service is not maintained or controlled by Guy Carpenter. Guy Carpenter is therefore not responsible for the availability, content or accuracy of other Web sites, services or goods that may be linked to, or advertised on, the Service. Guy Carpenter does not: (a) make any warranty, express or implied, with respect to the use of the links provided on, or to, the Service; (b) guarantee the accuracy, completeness, usefulness or adequacy of any other Web sites, services, goods or advertisements that may be linked to the Service; or (c) make any endorsement, express or implied, of any other Web sites, services, goods or advertisements that may be linked to the Service. Guy Carpenter is also not responsible for the reliability or continued availability of the telephone lines and equipment you use to access the Service. You understand that Guy Carpenter and/or third-party contributors to the Service may choose at any time to inhibit or prohibit their content from being accessed under the TERMS.
9. Limitation of Liability
UNDER NO CIRCUMSTANCES, INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE, SHALL GUY CARPENTER, ITS SUPPLIERS OR ITS THIRD-PARTY AGENTS BE LIABLE TO YOU OR ANY THIRD PARTY FOR DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, PUNITIVE OR EXEMPLARY DAMAGES EVEN IF AN AUTHORIZED REPRESENTATIVE OF GUY CARPENTER HAS BEEN ADVISED SPECIFICALLY OF THE POSSIBILITY OF SUCH DAMAGES, ARISING FROM USE OF OR INABILITY TO USE THE SERVICE OR ANY LINKS OR ITEMS ON THE SERVICE OR ANY PROVISION OF THE TERMS, SUCH AS, BUT NOT LIMITED TO, LOSS OF REVENUE OR ANTICIPATED PROFITS OR LOST BUSINESS. (Applicable law may not allow the limitation or exclusion of liability or incidental or consequential damages.)
10. Representations and Warranties
You represent, warrant and covenant that you: (i) have the power and authority to enter into this agreement; (ii) are at least eighteen (18) years old; (iii) shall not use any rights granted hereunder for any unlawful purpose; and (iv) shall use the Service only as set forth in these TERMS.
You agree, at your own expense, to indemnify, defend and hold harmless Guy Carpenter and its employees, representatives, Suppliers and agents, against any claim, suit, action or other proceeding, to the extent based on or arising in connection with your use of the Service, or any links on the Service, including, but not limited to: (i) your use or someone using your computer’s use of the Service; (ii) a violation of the TERMS by you or anyone using your computer; (iii) a claim that any use of the Service by you or someone using your computer infringes any IP Right (as herein defined) of any third party, or any right of personality or publicity, is libelous or defamatory, or otherwise results in injury or damage to any third party; (iv) any deletions, additions, insertions or alterations to, or any unauthorized use of, the Service by you or someone using your computer; or (v) any misrepresentation or breach of representation, warranty or covenant made by you contained herein. You agree to pay any and all costs, damages and expenses (including reasonable attorneys’ fees) and costs awarded against or incurred by or in connection with or arising from any such claim, suit, action or proceeding.
Either you or Guy Carpenter may terminate this agreement with or without cause at any time and effective immediately. You may terminate by discontinuing use of the Service and destroying all materials obtained from the Service. This agreement will terminate immediately without notice from Guy Carpenter if Guy Carpenter determines, in its sole discretion, that you have failed to comply with any provision of these TERMS. Upon termination by you or upon notice of termination by Guy Carpenter , you must promptly destroy all materials obtained from the Service and any copies thereof. Sections 2, 3, 4, 5, 8, 9, 11, 12, and 13 shall survive any termination of this agreement.
13. Governing Law
These TERMS shall be governed and construed in accordance with the laws of the United States of America and the State of New York, without giving effect to conflicts-of-law principles thereof. You agree to submit to the personal jurisdiction of the state and federal courts located in New York County with respect to any legal proceedings arising out of this agreement and waive any objection to the propriety or convenience of venue in such courts. If any provision of the TERMS is found by a court of competent jurisdiction to be invalid or unenforceable, such provision shall be enforced to the maximum extent permissible and the other provisions of the TERMS shall remain in full force and effect.
14. Access Outside the United States
If you choose to access the Service from outside the United States, you are responsible for compliance with foreign and local laws. Software from the Service may be subject to United States export controls that prohibit downloading, exportation or re-exportation: (i) into (or to a national or resident of) Cuba, Iraq, Libya, Iran, Syria, Sudan, or any other country to which the U.S. has embargoed goods; or (ii) to anyone on the U.S. Treasury Department’s Table of Deny Orders. By using the Service, you represent and warrant that you are not located in, controlled by or a national or resident of any such country or on any such list.
You acknowledge that Guy Carpenter has the right to change the content or technical specifications of any aspect of the Service at any time at Guy Carpenter’s sole discretion. You further accept that such changes may result in your being unable to access the Service.
16. Official Correspondence
Official Correspondence must be sent via postal mail to: Guy Carpenter & Company, LLC, 1166 Avenue of the Americas, New York, NY 10036, Attn: Legal Department.