There are three main pillars of Solvency 2:
- Pillar 1 consists of the quantitative requirements (such as the amount of capital an insurer should hold).
- Pillar 2 sets out requirements for the governance and risk management of insurers, in particular the Own Risk and Solvency Assessment (ORSA) process.
- Pillar 3 focuses on the requirements for disclosure and transparency.
One of the key benefits is that products must be designed with consumer focus in mind. This means more stable pricing as insurers better understand the underlying risks and look to create a more stable inflow of income.
Demonstrating good conduct means that insurers need to be able to justify why new products are being brought to market or why changes are being made to existing products. In simple terms, changes should be made with the consumer in mind and not simply linked to financials.
In addition, much of the reasoning behind harmonising regulation through Solvency 2 is to promote confidence in the financial stability of the insurance sector and provide early warning to supervisors so that they can intervene promptly if capital falls below the required level. It also offers greater protection for consumers and should reduce the risk of an insurer not being able to meet claims.
A company that is compliant will have put in place a robust framework that analyses their risks and will have increased their in-house expertise of risk analysis to help them do so.
At Health Shield, we very much welcome this regulation. It forces insurers to embed actuarial expertise, long-term planning and greater transparency into their product design and financial planning process. Companies will need to explain where they are holding their capital, why they have made their decisions and the associated risks behind those decisions. For example, if a firm’s board increased the risk exposure within its investment strategy it would need to justify the reasons, explain the additional capital requirements to stakeholders and perform thorough sensitivity and scenario testing to ensure the risk taken is not beyond the insurer’s risk appetite.
People must be reassured that products are designed to meet their needs and that companies will deliver on their promises. To that end, it is only right that financial firms have to submit themselves to the rigorous testing involved in Solvency 2 preparations.
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