Phil on Our Perspective: Current Issues 

PS My name is Phil Smart.  I’m a partner with KPMG and I lead our work on Solvency II.  We’re into 2011 now and we’ve seen a real step change in the way that programmes are moving from planning and preparation through to full scale implementation.  It’s clear from what we’re seeing on all of these programmes that both timelines and resources are under tremendous strain.  There are big demands in terms of meeting the requirements and getting everything done by the deadline at the end of 2012.

KPMG is working with a range of clients both in the UK and across Europe on a variety of Solvency II engagements, but we are seeing common themes emerging from all of those programmes. One of the first points which clients always talk to us about is the uncertainty around the final requirements emerging from the European Commission and EIOPA. We’ve recently seen the Omnibus II launched.  That’s provided some clarity around the requirements but it’s also raised questions.

We’ve got a number of concerns around the transitional arrangements which could potentially push out existing practices for up to ten years, and that’s giving real headaches in terms of how you deal with that as part of your programme.  The level 3 guidance is not expected to be finalised until 2012.  KPMG has got some insights in terms of where we think that’s going and how you should incorporate it into your programme, but it does give rise to further questions. 

But one of the overriding concerns that we’re seeing is how you actually engage with your regulator. 

Ultimately if you’re a UK insurer the FSA will have the final say on whether your model is approved or not.  Engagement with the FSA is proving difficult if you’re not one of the higher profile, higher priority firms which the FSA has selected.  KPMG is dealing with companies who are having a lot of active engagement with the FSA and others who are struggling to get that same level of dialogue. We can give you some insight in terms of how to deal with the regulator and how to proactively manage those meetings.

Finally, programme implementation issues. Resourcing is a recurring theme that we’re seeing coming through. Some programmes are more or less fully resourced, others are still lacking skills in certain, pretty scarce areas, and finding those skills out in the market is now proving to be quite difficult. The FSA has emphasised for a number of months there is a need to shift focus from Pillar 1 through to Pillar 2 and 3.  We’re starting to see that shift, but probably not as much as the FSA would like, so there is a need to continue to focus on, particularly Pillar 2, working on the ORSA and the Use Test.

And finally, IT and data: I think every programme that we’ve dealt with has raised this as being an area of concern.  There are going to be some pretty significant IT changes as a result of Solvency II.  Some of those are not going to be finished for some companies by implementation date.  What that means is you won’t see the benefits coming through until well beyond 2012 in some cases.

We can help you think about how you prioritise these different areas of your programme and try and get the benefits as quickly as possible.