I haven’t posted in a while; partly from a lack of inspiration but mostly from the fact that I’ve been eye-ball deep in Solvency 2 data related activity. However I thought it would be good to try and get back into the habit of posting as I find it helps my own thinking as well as being a useful vehicle to garner thoughts and comments from others. We’ll see how I get on.
There has been a lot of European debate around Solvency 2 and the timetables related to implementation of the directive and I don’t want to go into all the ins and outs but the simple fact is that it feels as though momentum has been lost somewhat. Especially given the fact of where we are in relation to the original implementation timescales. A lot of firms seem to be taking stock of where they find themselves and are using the time look back at where they’ve come from as well as reassessing where they are heading. I thought I’d do something similar and take a reflective look at some of the lessons (from a data management perspective) we can already take from the Solvency 2 journey that can be applied to any project. Part one looks at the ever important business case:- Continue reading →
I haven’t written a post about Solvency 2 (or Solvency II if you prefer) for a while and given it is still my primary focus with my current client I thought it was about time I gave a quick update.
For those of you who aren’t aware, most UK-based insurance firms (especially those applying to use their own internal models) will currently be concentrating on the FSA Solvency 2 ‘Data Audit’ and whilst they will all be at various stages in the process, they will be focusing on similar pieces of work and experiencing similar challenges. The ‘Data Audit’ is effectively a review requested by the FSA in which each firm is expected to undertake an independent audit (internal, external or a mixture of both) of their data management practices. The findings of this audit will subsequently form part of the FSA’s Internal Model Approval Process (IMAP) and help the FSA in its assessment of whether a firm is compliant with the standards for data as set out in the Solvency 2 directive. The scope of the review has been defined as all data (both internal and external) that could materially impact the Internal Model. Continue reading →
Working within the financial sector for the last eight years has meant that I have been involved in a number of projects dealing with regulatory imperatives. Something that has always infuriated me is the desire for many organisations to deliver only the minimum necessary to achieve compliance. Don’t get me wrong I understand the dangers associated with aspirational plans and the over-engineering of ‘gold-plated’ IT developments, but the desire for minimum can be even more dangerous. Continue reading →
Back in February the FSA published their Internal Models Approval Process (IMAP) Thematic review findings, a paper that brought together their collective findings after a period of discussion and probing of a number of insurance firms. The intention of this paper was to use the information to help identify the better practices being employed by firms, to help the FSA better understand the areas discussed and to give firms some much needed gen into the FSA’s thinking as they approach the pre-application phase of the IMAP. Continue reading →