Cp19/23

This will result in:. The draft SI published by HMT in June gives cp19/23 PRA the power to make additional rules governing the MA and it had been expected that additional controls would be introduced to counter-balance some of the cp19/23 of restrictions, cp19/23. This has indeed been the case, in particular in the context of limits on the use of assets with non-fixed cash flows, expectations in respect of the use of sub-investment grade assets and the new matching cp19/23 attestation, cp19/23.

A lot is riding on this. The Government is hoping that the Solvency II reforms, of which this consultation is a significant part, will free up billions of pounds of capital for investment. As is generally the case with regulatory reform of this importance, the changes that insurers, and others, will welcome come with significant strings attached. There is a lot to work through in the consultation, and insurers will need to establish whether the increased costs are proportionate to the additional returns and risks that might accrue. We look forward to working with insurers and our clients more generally to help them consider the proposals.

Cp19/23

These key areas are:. Given the short timelines available to make model changes before YE24, firms will need to quickly form a view on their approaches to each of the areas described above. Firms should identify changes needed for the end of the year and those that could be made later and prioritise accordingly. This will help minimise nasty surprises close to year-end and provide valuable insight on the net effect on capital and solvency of the overall reforms. Board members, senior executives, and actuaries of UK insurers with MA and Internal Model approvals who work on balance sheet management, pricing, reporting, capital optimisation, risk, finance, and compliance. In this blog, we discuss the main implications of these proposals for Internal Models. These are relevant for firms with both MA and Internal Model approvals, including all the current UK bulk purchase annuity BPA providers and firms that are planning to enter the market 2. Firms are not explicitly required to calibrate their Internal Model stresses using notched ratings, but those that choose not to would need to be able to justify differences in the granularity of ratings in their base MA and SCR calculations. Notably, among other considerations, firms may need to demonstrate that there is no significant bias in the asset mix towards the lowest notch at each credit rating. Some firms will have had investment limits in place to mitigate such a bias during the investment decision stage, but other firms may have not considered this and therefore may find it more difficult to justify not including notched ratings within the Internal Model. Firms that opt to introduce notched ratings in Internal Models should consider whether this will increase the sensitivity of the Internal Model to modelled downgrades and therefore increase the SCR. The Solvency UK reforms remove this requirement. This will improve the economic attractiveness of holding SIG assets, which could be particularly relevant for firms investing in illiquid assets, where there tends to be a larger concentration of SIG assets. Whether or not firms do increase their holdings in SIG assets will ultimately depend on their risk appetite, strategic asset allocation objectives and competitiveness considerations. Removal of the SIG cap within the Internal Model would be expected to provide a reduction in capital, even if firms have minimal holdings of SIG assets.

These restrictions will potentially make investment in assets with non-fixed cash flows a less attractive prospect than cp19/23 have been anticipated from the HMT response document, cp19/23.

Charlie Finch , Partner. James Silber , Principal. The final consultation proposals have now been published on the UK's transition from Solvency II, which determines the capital reserves insurers are required to hold. Will it improve pricing and insurer capacity? Will it water down policyholder security? The insurance regulator the PRA has published the final two consultation papers in recent months:. In the rest of this blog we focus on the second consultation paper and the proposed changes to asset eligibility.

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Cp19/23

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Please note that you do not have to give your consent to the publication of your name. Firms would still be expected to submit the evidence they consider necessary for the PRA to reach a decision and would be asked to confirm that they have done so. The appropriateness of the resulting FS would then be expected to be explicitly considered as part of the attestation process. FS add-ons. This is because each MA portfolio should be organised and managed separately from the other activities of the undertaking [x] of MA regulations. It specifies that:. The proposed changes would enable them to restore compliance in a more proportionate manner while still bearing adverse consequences for serious or sustained breaches. The PRA considers that the increase in supply in debt financing from insurers may reduce the cost of capital for these projects, proving an economic benefit to the project sponsors. The Government has also confirmed its intention to legislate to ensure that the PRA has the powers to implement the reforms in this CP in line with its November statement. Other prudential regulation releases. This is most apparent in the investment flexibility proposals where the choice has been deliberately made to allow simplified modelling of FS additions and best estimate cash flows for assets with HP cash flows. This is where it considers that the provisions will cease to be relevant or appropriate in the new regime. With the consultation only recently published, it remains too early to say definitively what the changes will mean for schemes exploring buy-ins. The insurance regulator the PRA has published the final two consultation papers in recent months:.

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The PRA is therefore focusing its expectations in this regard on assessing potential bias in internal credit assessment outcomes relative to CRA issue ratings rather than asset by asset outcomes in isolation. These proposals would provide firms with a clear framework to include additional types of assets in their MA portfolios, and to make appropriate allowance for the additional risks involved. This preserves the current FS calibration for assets where no adjustment for differences in credit quality by rating notch is required, and also allows firms some flexibility in terms of how a notched FS is implemented. This is hoped to, among other things, increase investment in green and digital assets. This is summarised below:. Read full bio. Despite her deep technical skills, clients have appreciated her ability to make complex matters accessible to less technical users. Source: The PRA footnote [30]. If it is not possible or desirable to deliver these changes by the end of , an option for firms is to keep the SIG cap in place, accepting that this would mean no reduction in SCR, until further development can be completed. This material is provided for general information only. This widening of MA eligibility will allow insurers to invest in assets that may earn higher expected yields than the existing universe of MA eligible assets for a given level of risk. The PRA considers that this is the case here: the attestation measure is needed because applying the published FS calibration to all assets based solely on their rating introduces significant sector-wide model risk, requiring firms to consider the appropriateness of the FS and the level of confidence they have over earning the MA will reduce this model risk. Given the lower reliance of this type of modelling on asset-specific data, the PRA expects sophisticated modelling the FS addition for these assets to be more common, albeit complemented by a standard approach that is expected to be a useful backstop to prevent delays in making initial investments while models are developed. Accordingly, the PRA proposes to introduce an expectation that firms consider carefully whether the expected cash flows on their SIG exposures can be sufficiently relied upon for the purpose of cash flow matching given the higher and more uncertain default rates and potential additional risks associated with such assets.

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