14 Mar 2012
Solvency 2 has become a moving target and getting that target in their sights is costing insurers a fortune. That was the unequivocal message delivered to the All Party Parliamentary Group on Insurance & Financial Services yesterday.
As the group chairman, Jonathan Evans, observed in setting the scene at the beginning of the meeting, Solvency 2 has suddenly become a political issue following the Prime Minister's intervention over the threat by the Prudential to relocate to Hong Kong, a threat the company reiterated yesterday when reporting its results. This is a serious and understandable threat in the face of the proposed treatment of non-EU (especially US) risks, a point that was emphasised by Sean McGovern, director of North America and general counsel of Lloyd's, speaking to the group yesterday. The 85 syndicates currently operating at Lloyd's have almost half of their business in the US and Canada, he said, and many will have to consider moving to non-EU domiciles such as a Bermuda if the regulations are not amended.
This is not just an issue for British insurers as several major European groups such as Aegon, Axa and Allianz have also raised the same issue and are putting pressure on the Brussells bureaucrats to think again. The trouble is a re-think will take time and will probably delay the introduction of the Solvency 2 regime still further, adding significantly to the already painful costs. It has already been delayed once – pushed back from January 2013 to January 2014 – but even this new deadline is starting to look optimistic. The next hurdle in the European Parliament (pictured) just before Easter looks daunting: there are over 400 amendments tabled to the detailed regulations required to activiate the regime and if these are not all dealt with then the implementaion date will start to come under pressure. This is before you throw in having to deal with the question of non-EU liabilities and the intense lobbying from the French mutual sector which is seeking significant exclusions from the new regime.
The costs are already causing huge concern, as Martin Shaw, chief executive of the Association of Financial Mutuals, told the group. At an estimated £2bn for implementaion alone this represents £10 per policy for every policyholder, a cost that cannot be justified, he argued, especially in the UK. "The UK's previous approach was based on successfully pursuing a more risk based approach than the rest of Europe...therefore UK consumers will see less benefit for their £10 per policy". It was, he said, "doing the same things in a more expensive way".
The consequences among mutuals could be more mergers, off-loading some books of business, a de-risking of investment portfolios, which could impact on the equity markets, and more sharing of costs, for example through the use of external actuaries.
Paul Clarke, Solvency 2 European leader for PricewaterhouseCoopers, the technical consultants to the group, attempted to put the cost into context, arguing that some of it would be "incurred anyway and will end up making businesses more efficient", citing Amlin as an example saying that processes had been improved and a refined reinsurance programme put in place as a result of the preparatory work done for Solvency 2.
While the UK regulators were generally praised for being supportive over Solvency 2, all the presenters agreed that the Financial Services Authority's proposals for non-executive directors was setting the bar too high. Mr McGovern said "they almost expect non-execs to train as quasi-actuaries" and this combined with the suggestion that even for smaller companies they should spend 35-45 days a year on board duties will "turn off potential non-execs".
Mr Evans said the All Party Group will be returning to the subject of Solvency 2 after the Easter recess when it hoped to hear from both the Association of British Insurers and the Prudential. Perhaps by then we might have a little bit more certainty on some of the detail and whether the revised target date of January 2014 remains realistic.
22 Feb 2011
About the Author
David has been a financial journalist for 30 years and is currently Group Editorial Services Director at Incisive Media.
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