David Rule: PRA Solvency II Conference - countdown to implementation
Speech by Mr David Rule, Executive Director for Prudential Policy of the Bank of England, at
the PRA Solvency II Conference, London, 17 October 2014.
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I would also like to extend my welcome and thanks to you for taking the time to attend this
conference today. I want to take this opportunity to formally introduce myself. I was
appointed Executive Director of Prudential Policy at the Bank of England in June having held
a variety of different roles across the Bank and FSA, most recently as a supervisor of large
UK banks.
This conference is entitled "countdown to implementation". We have reached a level of
stability in the policy making process for Solvency II, and the purpose of today is to share our
thinking and provide clarity where possible on those last remaining issues ahead of
implementation. You'll be hearing from experts across the technical areas and Victoria
Saporta, Director of Financial Policy will give you an overview of the policy areas where work
is still being finalised along with the timeline for completion.
I would like to take a step back from this and reflect more widely on what Solvency II is about
for the Bank.
To echo the Governor's words from his speech to the Institute and Faculty of Actuaries in
September "Insurance is at the core of the new Bank of England"...we have over
200 supervisors and 50 actuaries engaged in the implementation of Solvency II, not to
mention the contribution from numerous dedicated policy experts. In addition, with insurance
supervision now embedded in the Bank, supervisors benefit from the support of monetary
policy experts, credit risk analysts and macro-financial analysts.
The insurance sector plays a key role in the financial system and the economy. It protects
companies and individuals from perils they could not otherwise shoulder, managing and
spreading risk globally. Insurers are vital to efficient allocation and overall provision of capital,
they provide alternative sources of funding, increasing the diversity in the system.
The PRA has two primary statutory objectives: to promote the safety and soundness of all
banks, insurers and major investment firms and, a specific objective for insurers, of
contributing to the securing of an appropriate degree of protection for policyholders.
These objectives are the guiding principles that ultimately underpin our implementation of
Solvency II. The core objective of the new regime is greater policyholder protection.
Solvency II is a welcome modernisation of European regulatory standards. You will be
familiar with the UK's ICAS regime. Solvency II recognises many of the principles that form
the basis of that regime, and therefore introduces a level playing field with the rest of the EU.
Risk-based capital standards and robust valuation practices ensure resilience against
unexpected losses. The enhanced disclosure rules in turn aim to encourage the effective
exercise of market discipline through increased provision of information. Our approach to
third country branches will aim to ensure that they are operating to standards that give
branch policyholders an equivalent level of protection to policyholders of an
EEA-headquartered undertaking.
The three pillars of Solvency II not only provide a robust foundation to support the safety,
soundness and resilience of individual insurers, but also in turn support stability in the
system.
The financial services sector is more interconnected than ever before. Risks to the financial
system can affect all firms; we therefore need to ensure that our analysis is rigorous not just
within sectors but at a cross-sectoral level. With a number of mixed financial groups
undertaking insurance, banking, asset management and any number of other activities in
multiple locations across continents, it is vital for firms and regulators alike to understand the
interconnections and dependencies not only between different firms but within them as well.
This is just one reason why it is so crucial to get the new regime right. The introduction of
consolidated group supervision under Solvency II will ensure supervisors and firms have
greater clarity in their overall view of group business, and are able to recognise and therefore
manage risks that would not otherwise be visible.
In particular, we will be able to look across groups to ensure that they have adequate
resources, even if risks are being transferred to group companies located in countries with
different regulatory regimes, such as offshore centres. And we will be alert to regulatory
arbitrage, such as where risk transfer through reinsurance is negated through sliding scale
commissions.
The financial crisis, and the post-crisis regulatory reform agenda, have taught us many
lessons. The business models of insurers and banks are different, but those lessons have
informed and will continue to inform how we manage the implementation of Solvency II.
Perhaps most salient for this conference, is the difficult lessons we have learned from
experience with insurers and banks when it comes to the use of internal models. Many of you
in this room will be acutely aware of the demands of the Solvency II model approval process.
This rigour has a purpose. Use of internal models can be an effective means of harnessing
the better knowledge a firm has of its own risk profile to set risk-sensitive capital
requirements. But there are limits to our ability to model capital requirements. These are
more acute where the event - for example, a credit default or a windstorm - being modelled
happens infrequently and historical data is therefore scarce, where events cluster rather than
occur independently or where the underlying process behind the event - for example the
structure of the economy or the natural environment - may have changed, so that history is
an unreliable guide to the future. In such circumstances, significant uncertainty about model
outputs may call for a more prudent approach. And the temptation to add additional
parameters, making models more and more complicated, can often have the perverse effect
of weakening model performance. This is why, in addition to scrutinising the technical
components of models, we also look at the way they are used within firms. Only a good
model can play an important role in a firms' system of governance. Our expectations of their
quality are high as Solvency II specifies that they become an embedded part of the risk
management system of a firm. It is therefore not only important for us to rigorously assess
them but that senior management have ownership of these models and continuously do the
same. The Bank of England takes model approval very seriously indeed and we will not
hesitate to hold back approval for the use of models where there are risks that cannot
credibly be modelled or data are insufficient.
Throughout the implementation of Solvency II, we have worked hard to ensure that progress
in the regulatory agenda is not synonymous with unnecessary impediments on your ability to
grow and evolve your businesses. At all times, though, insurers must be capitalised to deliver
policyholder protection, and this must be commensurate with the risks they take.
A priority in this area is the revitalisation of robust securitisation markets in Europe, many of
which have yet to recover from the crisis. We have been working with the ECB and other
European authorities with the goal of encouraging securitisation as a means for lenders to
diversify funding and reduce concentrations - but not to arbitrage capital regulations. A
growth in "real money" investors, such as insurers, will increase the diversity of funding
providers to the real economy, avoiding the pre-crisis reliance on an unstable, leveraged
investor base. A key goal is to improve transparency, simplicity and consistency so that
investors can understand the risks associated with securitisations. For simple, transparent
and consistent securitisations, we are prepared to review whether post-crisis regulatory
requirements for investors and originators are too onerous.
That includes Solvency II, where we welcome a recalibration of capital requirements for such
simple, transparent and consistent securitisations, particularly at longer maturities. The
ongoing participation of insurers - a major source of long-term finance - in this debate will be
key to achieving results.
We have got to a stage now where the path to Solvency II is clear. We have come a long
way from the uncertainty that has seemingly dominated the past few years. But we need to
remain conscious of the new challenges and opportunities that are on our horizon.
Alongside the European process the wheels have been turning in the international space. A
common set of global standards for systemically important insurers are being worked on as
we speak.
Throughout the development of these standards, the Bank of England will continue with its
strong history of international engagement. We have made great strides in Europe with
Solvency II and we aim to ensure the complementarity of upcoming global standards with
what we have achieved with Solvency II.
Continued interaction with the industry is an essential part of good policy making so I'd like to
again thank you for your participation today. I hope that we can continue to work together
towards achieving a policy outcome at all levels that fulfils our objectives and in turn ensures
the stability, resilience and ultimately the prosperity of the insurance sector in the UK.