Solvency II

Reporting and Disclosure

Tim OHanrahan

Overview
What reports will be required?
What is in those reports?
Are the reports Public or Private?
Process
Frequency
Submission Dates
Format
Sign-off/Audited
Groups
Proportionality
Open Questions


2
Important Note
The presentation is based on a combination of the
Directive, Draft Level 2 Implementing Measures and
current early drafts of Level 3 Guidance.

The resulting requirements will evolve and develop over
time and all undertakings should keep up to date with
developments.


3

Art. 35 Supervisory reporting
Regular Supervisory Report (RSR)

-All information necessary for the purposes of
supervision
-Narrative Report
-Quantitative reporting templates
Solvency and Financial Condition Report
(SFCR)
- Publicly disclosed data
-Narrative Report
-Quantitative reporting templates

What reports will be required?
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What is in those reports?
i) SFCR and ii) RSR



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Contents of SFCR and RSR
A) Business,
External
Environment and
Performance
B) Governance
and
Remuneration
Policy
C) Risk Profile
1. Business and
external
environment
2. Underwriting
Performance
3. Investment
Performance
4. Performance
from other
activities
1. Governance
Arrangements
2. Fit and Proper
3. Risk
Management &
ORSA
4. Internal Control
5. Internal Audit
6. Actuarial
7. Outsourcing
8. Any other
disclosures
Following risks
1. Underwriting
Risk
2. Market
3. Credit
4. Liquidity
5. Operational
6. Other material
Risk Exposures
7. Any other
disclosures
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Contents of SFCR and RSR
D) Valuation for Solvency
Purposes
E) Capital Management
1. Assets
2. Technical Provisions
3. Other Liabilities
4. Other Disclosures
1. Own Funds - structure,
amount & quality
2. MCR and SCR
3. SCR differences if
standard formula or
internal model used
4. Non-compliance with
SCR/MCR
5. Other Disclosures
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What do you disclose for Underwriting
Performance?
SFCR (Public) RSR (Private)
1. The undertakings
underwriting performance by
material line of business and
geographical area;
2. The undertakings
underwriting expenses by
material line of business and
geographical area over the
year and compared to the
prior year.
1. A discussion and analysis by the
administrative, management or
supervisory body of the undertakings
overall underwriting performance;
2. Details of the undertaking's
underwriting performance by line of
business against plan, and significant
factors affecting deviations from plan;
3. Projections of the undertaking's
underwriting performance over the
business planning period with details of
significant factors that might affect
underwriting performance;
4. Details of any reinsurance, ART and
finite reinsurance programmes
purchased, including those currently
not being claimed on.
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Contents of SFCR and RSR
And also...
Quantitative forms
1. Current draft, 59 different forms!!!
2. Including forms on:
Profit and Loss Account
Balance Sheet
Off Balance Sheet
Solvency Capital Requirement
List of each investment held
List of each derivative
Technical Provisions
Risk Profile
Loss Profile
3. All forms will be reported annually, a subset will be
reported every quarter.

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Example List of Investments
Each investment held with details such as:
1. Identification
a) ID Code
b) Security Type
c) Issuer Name, Sector, Country
2. Price & Quantity
a) Price
b) Valuation Method
c) Cost
3. Risk Section
a) External Rating
b) Rating Agency
c) Underlying of Securitisation
d) Duration




Reporting required on other occasions?

Predefined events
Predefined events are those that can lead to material
changes to an undertakings risk profile
May require supervisory authorities to reassess the
frequency and intensity of supervisory actions.
Supervisory Enquiries
Supervisors may request any information required to
assess the situation of an undertaking
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Are the reports Public or Private?
Public Private for
Supervisors
SFCR Yes
RSR No Yes
Predefined Events
Yes for items such as
non-compliance with
MCR or significant non-
compliance with SCR
and no satisfactory
action taken in required
timeline
Yes
Supervisory
Enquiry
Generally no but may
give rise in certain
circumstances to a
public disclosure
Yes
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Process of Reporting
Process of
Reporting
Frequency of
Reporting
Submission
dates
Format of
Reporting
External
auditing
requirements
13
Process of Reporting Frequency and
Submission Dates
SFCR RSR Quantitative
Forms
Frequency Annual 1) Full report
at least every
3 years or
when required
by Supervisors
2) Material
Updates
Annually
Quarterly and
Annual
Submission
Date
14* weeks
after year end
14* weeks
after year end

Quarterly 6*
weeks after
end.
Annual 16*
weeks after
year end
14
* There is a limited extension until 2015
Process of Reporting Submission
Dates
Due dates Year end 31/3/13 Year end
31/12/13
SFCR Annual
Narrative &
Quantitative


Mid July 2013 April 2014
RSR
Narrative &
Quantitative

Quarterly
Quantitative

Mid July 2013


Mid August 2013 for
Q1 ended 30/6/13



April 2014


Mid May 2013 for Q1
ended 31/3/13

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Process of Reporting Frequency and
Submission Dates
SFCR RSR Quantitative
Forms
Format Common
Template as
developed by
CEIOPS
Common
Template as
developed by
CEIOPS
Common
Template as
developed by
CEIOPS
Sign off -
internal
administrative
or
management
body
Yes Yes Yes
Sign off
external
auditing or
verification
No No Yes to be
developed
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Group reporting
Solvency
and
Financial
Condition
Report
Report to
Supervisors
Quantitative
Forms
Group
Yes

Same as Single
entity +
additional
requirements
Yes

Same as Solo
+ additional
requirements

Yes

Same as Solo
+ additional
requirements

Subsidiary
Could include in
Group report
(subject to
agreement) i.e.
Subsidiary
would not have
to complete
Yes Yes
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Proportionality
How is Proportionality
Demonstrated

Regular Supervisory
Reporting (RSR)
Frequency of RSR is not required
annually

Qualitative forms
Qualitative reporting and
disclosure requirements are
principled based
Quantitative Forms
You do not have to complete
forms that are Not applicable

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Open Questions
Audit requirements : scope ? level of assurance ?

Public disclosure of some templates : which ones ?

National specificities : content ? role of EIOPA ? Can
local GAAP be used for Solvency II ?

Proportionality : less requirements for small or less
complex undertakings ? impact on comparability &
aggregation of data ? automaticity of proportionality ?


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Overview
What reports will be required
What is in those reports
Are the reports Public or Private
Process
Frequency
Submission Dates
Format
Sign-off/Audited
Groups
Proportionality
Open Questions


20
Thank you