Wednesday 28 September 2011

Clear Path Analysis - Van Hulle interview, legislative path, Omnibus II and more

Fantastic body of work released by the guys at Clear Path Analysis (need to sign up) - extensive interviews with Karel van Hulle, EIOPA representation and insurance industry senior figures (and as a sponsored piece, surprisingly unaffected by hard selling!). A few revealing pieces from the van Hulle commentary;

  • Sovereign debt - confirms the Solvency II approach on zero capital for EU national debt instruments copies the CRD4 approach in banking and that "we need the same approach", while going on to say cryptically that "when events change then the regulation will have to change as well"
  • Go Live date - "believes it is the final revision"
  • Omnibus II - end of the year for clarity, once parliament and council conclude discussions, with "early 2012" down for the parliament vote
  • US equivalence - notes that "all discussions with the US are difficult" (saucer of milk?), but has optimism as they "seem to be moving in the direction of Solvency II". Not quite the message being sent across the Atlantic, even if true!
  • EU regulator - "We have to see how [EIOPA and sisters] work first before we can go to the next stage"
  • Transitionals - national regulators should not be able to vary the transitional measures to create regulatory arbitrage
  • EU Parliament's advice on reintroducing regulatory technical standards - "The Commission does not believe that this is necessary"
The following was also useful for calendar planning/expectation setting on your project plans;

  • Trialogues between Council, Parliament and Commission commence in November to develop common view on Omnibus II (my last point from van Hulle's comments I suspect will be high on the agenda!)
  • EIOPA major consultations will commence in November this year (on ORSA and the Reporting Package/templates) and mid 2012 on standards they are expected to write.
  • EIOPA still focused on Jan 2013, regardless of phased approach in Omnibus II

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