EIOPA: Potential macroprudential tools and measures to enhance the current insurance regulatory framework

The European Insurance and Occupational Pensions Authority (EIOPA) initiated in 2017 the publication of a series of papers on systemic risk and macroprudential policy in insurance. So far, most of the discussions concerning macroprudential policy have focused on the banking sector. The aim of EIOPA is to contribute to the debate, whilst taking into consideration the specific nature of the insurance business.

With this purpose, EIOPA has followed a step-by-step approach, seeking to address the following questions:

  • Does insurance create or amplify systemic risk?
  • If yes, what are the tools already existing in the current framework, and how do they contribute to mitigate the sources of systemic risk?
  • Are other tools needed and, if yes, which ones could be promoted?

While the two first questions were addressed in previous papers, the purpose of the present paper is to identify, classify and provide a preliminary assessment of potential additional tools and measures to enhance the current framework in the EU from a macroprudential perspective.

EIOPA carried out an analysis focusing on four categories of tools:

  1. Capital and reserving-based tools;
  2. Liquidity-based tools;
  3. Exposure-based tools; and
  4. Pre-emptive planning.

EIOPA also considers whether the tools should be used for enhanced reporting and monitoring or as intervention power. Following this preliminary analysis, EIOPA concludes the following (Table 1):

Table 1 Macro

It is important to stress that the paper essentially focuses on whether a specific instrument should or should not be further considered. This is an important aspect in light of future work in the context of the Solvency II review. As such, this work should be understood as a first step of the process and not as a formal proposal yet. Furthermore, EIOPA is aware that the implementation of tools also has important challenges. In this respect this report provides an overview of tools, main conclusions and observations, stressing also the main challenges.

Table 2 puts together the findings of all three papers published by EIOPA by linking

  1. sources of systemic risk and operational objectives (first paper),
  2. tools already available in the current framework (second paper)
  3. and other potential tools and measures to be further considered (current paper).

Table 2 Papers

The first paper, ‘Systemic risk and macroprudential policy in insurance’ aimed at identifying and analysing the sources of systemic risk in insurance from a conceptual point of view and at developing a macroprudential framework specifically designed for the insurance sector.

The second paper, ‘Solvency II tools with macroprudential impact’, identified, classified and provided a preliminary assessment of the tools or measures already existing within the Solvency II framework, which could mitigate any of the sources of systemic risk.

This third paper carries out an initial assessment of potential tools or measures to be included in a macroprudential framework designed for insurers, in order to mitigate the sources of systemic risk and contribute to the achievement of the operational objectives.

It covers six main issues:

  1. Identification of potential new instruments/measures. The tools will be grouped according to the following blocks:
    • Capital and reserving-based tools
    • Liquidity-based tools
    • Exposure-based tools
    • Pre-emptive planning
  2. Way in which the tools in each block contribute to achieving one or more of the operational objectives identified in previous papers.
  3. Interaction with Solvency II.
  4. Individual description of all the tools identified for each of the blocks. The following classification will be considered:
    • Enhanced reporting and monitoring tools and measures. They provide supervisors and other authorities with additional relevant information about potential risks and vulnerabilities that are or could be building up in the system. Authorities could then implement an array of measures to address them both at micro and macroprudential level (see annex for an inventory of powers potentially available to national supervisory authorities (NSAs)).
    • Intervention powers. These powers are currently not available as macroprudential tools. They are more intrusive and intervene more severely in the management of the companies. Examples could be additional buffers, limits or restrictions. They are only justified where the existing measures may not suffice to address the sources of systemic risk identified.
  5. Preliminary analysis per tool.
  6. Preliminary conclusion.

Four initial remarks should be made.

  1. First, although in several instances the measures and instruments are originally microprudential in nature, they could also be implemented as macroprudential instruments, if a systemically important institution or set of institutions or the whole market are targeted.
  2. Secondly, analysing potential changes on the long-term guarantees (LTG) measures and measures on equity risk that were introduced in the Solvency II directive, although out of the scope of this paper, could contribute to further enhance the framework from a macroprudential perspective. The focus of this paper is essentially on new tools, leaving aside the analysis of potential changes in the current LTG measures and measures on equity risk, which will be carried out in the context of the Solvency II review by 1 January 2021.
  3. Thirdly, when used as a macroprudential tool, the decision process may differ, given that there are different institutional models for the implementation of macroprudential policies across EU countries, in some cases involving different parties (e.g. ministries, supervisors, etc.). This paper seeks to adopt a neutral approach by referring to the concept of the ‘relevant authority in charge of the macroprudential authority’, which should encompass the different institutional models existing across jurisdictions.
  4. Fourthly, there seems to be no single solution when it comes to the level of application of each tool (single vs. group level).

Concerning the different proposed monitoring tools, in the follow-up work, the structure and content of the additional data requirements should be defined. This should then be followed by an assessment of the potential burden of collecting this information from undertakings.

It is important to stress that this paper essentially focuses on whether a specific instrument should or should not be further considered. This is an important aspect in light of future work in the context of the Solvency II review. As such, this work should be understood as a first step of the process and not as a formal proposal yet.

Figure ORSA

Click here to access EIOPA’s detailed discussion paper

Failures and near misses in insurance – Overview of the causes and early identification

General approach

The approach to dealing with failures of financial institutions has witnessed significant changes since the eruption of the financial crisis in 2008, both from the crisis prevention and the crisis management perspective. A changing perspective in the interpretation of the causes, early identification and corrective measures used in the context of (near) failures may create difficulties when trying to compare past failures with current ones, particularly with the advent of recovery and resolution frameworks in finance.

EIOPA has developed its own conceptual approach, which is followed throughout this report. It should be stressed that there is not a conceptual approach which is universally agreed. The aim of the present chapter is to explain the approach followed by EIOPA, in order to achieve a common understanding and support the classification of the different cases of insurance failures and near misses.

This chapter focuses on the following two issues:

  • The definition of the concepts of “failure” and “near miss”, which are essential to understanding the database construction process and the scope of the cases to be included.
  • The need to have a common understanding of the framework for crisis prevention and management, as well as the recovery and resolution tools to be used.

In terms of crisis prevention and management, the fundamental approach followed by EIOPA can be understood as part of a continuum of supervisory activities. Illustration 1 below summarizes the whole process: During business as usual, and in the normal stages of supervision, an initial problem can be identified, and insurers may seek to implement measures to overcome the problem. Supervisors would, in turn, normally intensify supervision and follow-up more closely on the developments of the insurer. Should the initial problem become a real financial threat (e.g. being in breach of, or about to breach, solvency capital requirements) the insurer enters into a new stage, which is linked to an increased risk of failure, i.e. a near miss situation. In this context, the insurer should trigger certain recovery actions to restore its financial position, while supervisors can intervene more intrusively. In general, there should be a reasonable prospect of recovery if effective and credible measures are implemented. Nevertheless, if the situation of distress is extremely severe and the measures taken do not yield the expected results, the insurer enters into resolution.

Eventually, the insurer (or parts of it) is (are) wound-up and exits the market.

EIOPA - Resolution

Near miss

In the context of this report, a near miss is defined as a case where an insurer faces specific financial difficulties (for example, when the solvency requirements are breached or likely to be breached) and the supervisor feels it necessary to intervene or to place the insurer under some form of special measures.

The elements to identify a near miss are the following:

  • The insurer is still in operation under its original form;
  • Nevertheless it is subject to a severe financial distress to an extent that the supervisory authority deems it necessary to intervene; and
  • In the absence of this intervention, the insurer will not survive in its current form and may eventually go into resolution or be wound-up.

Underlying is the idea of success of the measures taken. As such, it should not involve public money or policyholders’ loss.

In other words, a near miss presupposes that the supervisory intervention, either directly (e.g. replacing the management) or indirectly (e.g. request for an increase in capital), contributed in a clear way to overcome the insurer’s financial distress and bring it back to a “business-as-usual” environment. Shareholders generally keep their rights and could potentially oppose any of the measures undertaken.

On a day-to-day basis, insurers and NSAs might have to take different actions that require a certain degree of coordination. A “near miss” in the sense described in this report should be distinguished from these type of situations. Near misses only refer to cases where severe problems were detected or reported and supervisory measures were necessary to ensure the viability of the insurer.

Near misses actually constitute an area of particular interest for this report. In effect, their correct reporting and analysis would allow valuable lessons to be learned from successfully managed distress situations – prospective failure of an insurer and supervisory actions that permitted recovery.

Insurance failure

A failure, for the purposes of the present database, exists from the moment when an insurer is no longer viable or likely to be no longer viable, and has no reasonable prospect of becoming so.

The processes of winding-up/liquidation, which are usually initiated after insolvency, either on a balance sheet basis (the insurer’s liabilities are greater than its assets) or cash-flow basis (the insurer is unable to pay its debts as they fall due), are also encompassed within the definition of failure for the purposes of the database. Failure is thus triggered by “non-viability”.

The failed insurer ceases to operate in its current form. Shareholders generally lose some or all of their rights and cannot oppose to the measures taken by the authority in charge of resolution, which has formally taken over the reins from the supervisory authority.

For classification purposes, any case is considered as a failure (regardless of the final result of the intervention) when:

  • Private external support (e.g. by means of an insurance guarantee system (IGS)) has been received.
  • Public funds by taxpayers were needed for policyholders’ protection or financial stability reasons.
  • Policyholders have suffered any type of loss, be it in financial terms or in a deterioration of their insurance coverage.

The following are examples of resolution tools that may be used by authorities in a case of failure:

  • Sale of all or part of the insurers’ business to a private purchaser. A particular case is the transfer of an insurers’ portfolio, moving all or part of its business to another insurer without the consent of each and every policyholder.
  • Discontinue the writing of new business and continue administering the existing contractual policy obligations for inforce business (run-off).
  • Set-up a bridge institution as a temporary public entity to which all or part of the business of the insurer is transferred in order to preserve its critical functions.
  • Separate toxic assets from good assets establishing an asset management vehicle (i.e. a “bad insurer” similar to the concept used in banking) wholly owned by one or more public authorities for managing and running-down those assets in an orderly manner.
  • Restructure, limit or write down liabilities (including insurance and reinsurance liabilities) and allocate losses following the hierarchy of claims.

This also includes the bail-in of liabilities when they are by converted into equity.

  • Closure and orderly liquidation of the whole or part of a failing insurer.
  • Withdrawal of authorisation.

Lastly, it should be mentioned that the flow of events shown in Illustration 1 does not necessarily take place in a sequential way. For example, there could be cases in which an insurer goes directly into resolution. Thus, what is relevant for the classification of a particular case is whether the insurer recovers (which would then be considered as a near miss or as a case resolution/return to market if some kind of resolution action/tool is used) or has to be fully resolved and/or liquidated.

EIOPA - Sharma Risks

Click here to access EIOPA’s detailed report

Risk Dashboard for fourth quarter of 2017: Risk exposure of the European Union insurance sector remains stable

Risks originating from the macroeconomic environment remained at a high level in Q4 2017, although most indicators improved slightly comparing with Q3. Positive developments in forecasted real GDP growth and increased expected inflation closer towards the ECB target contributed somewhat to a decrease in risk, as well as a slight reduction in the accommodative stance of monetary policy. Swap rates recently increased but remained low by historical standards. The credit-to-GDP gap was the only indicator to deteriorate since the previous assessment, moving further into negative territory.

Credit risks remain constant at a medium level in Q4 2017. Since the last assessment spreads have decreased across all bond segments, except for unsecured financial corporate bonds. Concerns about potential credit risk mispricing remain.

Market risks were stable at a medium level in Q4 2017. Most market indicators changed only little when compared to the previous risk assessment, except for investments in equity. Volatility of equity prices increased, with a temporary peak in February. A slight decline was reported for the price-to-book value ratio (PBV). In addition, Q4 Solvency II data seems to indicate a slight increase in median exposures to bonds and property and an increase of exposures to equity for insurers in the upper tail of the distribution.

Liquidity and funding risks remained constant at a medium level in Q4 2017, with most indicators pointing to a stable risk exposure.

Profitability and solvency risks remained stable at a medium level in Q4 2017. Annual figures for some profitability indicators show a slight deterioration when compared to annualised Q2 indicators, but are broadly at the same level as in Q4 2016. Solvency ratios remain well above 100% for most insurers in the sample. A slight increase in the quality of own funds has also been observed.

EIOPA1

Risks related to interlinkages and imbalances remain stable at a medium level in Q4 2017. Main observed developments relate to a slight decrease in median exposures to domestic sovereign debt and to a mild increase in the share of premiums ceded to reinsurers. Investment exposures to banks, insurers and other financial institutions remained broadly unchanged.

Insurance risks remained stable at a medium level when compared to Q3 2017. The impact of the catastrophic events observed in Q3 on insurers’ technical results still weights on the risk assessment.

EIOPA2

Market perceptions remained stable at a medium level since the last assessment. Positive developments related to the performance of insurers’ stock prices relative to the overall market and a decrease in the upper tail of the distribution of price-to-earnings ratios contributed to decreased risk, but this was partially compensated by a deterioration of some insurers’ external rating outlooks. Other indicators, such as insurers’ CDS spreads and external ratings remained largely unchanged.

Summary

Click here to access EIOPA’s detailed Risk Dashboard – April 2018

EIOPA3

EIOPA Risk Dashboard January 2018

Risks originating from the macroeconomic environment remained stable and high. Improvements have been observed across most indicators, but were not sufficient to change the overall risk picture. The improving prospects for economic growth still contrast with the persistence of structural imbalances, such as fiscal deficit. The accommodative stance of monetary policy has been reduced only very gradually, with low interest rates continuing to put a strain on the insurance sector.

Credit risks remained constant at a medium level whereas observed spreads continued to decline. The average rating of investments has seen some marginal improvements. Concerns on the pricing of the risk premia remain.

Market risks remained stable at a medium level despite a reduction of the volatility on prices was observed. Only price to book value of European stocks moved in the direction of risk increase.

Liquidity and funding risks were constant at a medium level in 2017 Q3 and remained a minor issue for insurers. Catastrophe bond issuance significantly decreased when compared to the record high registered during the previous quarter. The low volume of issued bonds made the indicator less relevant.

Profitability and solvency risks remained stable at a medium level. A deterioration of the net combined ratio was observed in the tail (90 percentile) of the distribution mainly populated by reinsurers in this quarter. SCR ratios have improved across all types of insurers mainly due to an increase of the Eligible Own Funds. This has been especially marked for life solo companies.

Interlinkages & imbalances: Risks in this category remained constant at a medium level. Investment exposures to banks and other insurers increased slightly from the previous quarter.

Insurance risks increased when compared to 2017 Q2 and are now at a medium level. This was essentially driven by the significant increase in the catastrophe loss ratio resulting from the impact of the catastrophic events observed in Q3 mainly on reinsurers’ technical results. This is also reflected in the loss ratio. Other indicators in this risk category still point to a stable risk exposure.

Market perceptions remained constant, with the improvement in external rating outlooks outweighing the observed increase in price to earnings ratios. Insurance stocks slightly outperformed the market, especially for life insurance, and CDS spreads reduced.

Riskdashboard 12018

Click here to access EIOPA’s Risk Dashboard January 2018

EIOPA’s Supervisory Statement Solvency II: Solvency and Financial Condition Report

  • The majority of insurance undertakings and groups published the (Solo/Group) SFCR on a timely basis and generally complied with the relevant Solvency II requirements. In some cases Groups went the extra mile to make the Group SFCR accessible to all stakeholders: The SFCRs are generally easy to find in the websites of most of the disclosing entities. However, some undertakings still do not own a website. In the websites of the insurance groups, in general, in addition to the Group SFCR, the solo SFCRs of the major entities of the group are also available at the same address and versions in English are available which facilitates access regarding the full group. The reports follow the structure as of Annex XX of the Delegated Regulation, but for non-applicable items, it is important to have a clear indication that the information is not applicable.
  • The use of different language styles and different formats to disclose SFCR information makes difficult the definition of a common disclosure approach to all types of stakeholders: EIOPA expects that care is taken when deciding the content and language style of the SFCR and in particular of the Summary of the SFCR. The Summary is the part of the SFCR that will most interest the policyholders. They should be the main addressees of this part of the Report. In the remaining sections of the SFCR it is not expected that the full content of EU or national legislation is reproduced in the SFCR. The Report should instead include relevant undertaking-specific information under each section to make it easy to efficiently identify and read the relevant specific information.
  • The need for a more fit-for-purpose ‘Summary’: EIOPA encourages insurance groups/undertakings to improve the content and clarity of the Summary. The SFCR Summary should encompass relevant SFCR areas and briefly provide relevant information. Given the importance of the SFCR Summary for the policyholders and the range of different approaches EIOPA clarifies the expectations on its minimum content from a supervisory perspective.
  • Quantitative Reporting Templates (QRTs) in the context of the SFCR: The placement of QRTs in an Annex to the SFCR, although a good practice, should not prevent undertakings/groups from providing quantitative and qualitative information into the body of the SFCR. Relevant information covered by the QRTs and additional information not covered by the QRTs in the Annex to the SFCR, such as background information that allows the reader to understand the information in the templates should be included in SFCR. If appropriate, parts of the QRTs should be repeated, or complemented through the narrative information of the SFCR.
  • Information on the own-risk and solvency assessment (ORSA) under the SFCR is by its very nature undertaking/group specific. This means that undertaking/group specific information needs to be included, even when referring only to the process and not to the outcome: The information disclosed should go beyond repeating the laws, regulations and administrative provisions on how the ORSA needs to be integrated into the organisational structure and decision making process.
  • The information on the risk sensitivity to different scenarios or stresses, should be better structured and more comprehensive: The information regarding the SCR and risk sensitivity is not comparable across different undertakings/groups. It is expected that the reporting of sensitivities to different scenarios or stresses is disclosed in a more structured format. The sensitivity to the different risks should be shown under the section ‘Risk Profile’. In addition under each risk section information on the overall impact should be provided.
  • Information on the bases, methods and main assumptions used for the valuation for solvency purposes should include undertaking/group specific information and address the uncertainties around the valuation: the SFCR should include more relevant, undertaking/group specific information, in particular regarding valuation of investments, valuation of deferred tax assets and deferred tax liabilities and valuation of technical provisions. Regarding the later the SFCR should provide a description of the level of uncertainty, by linking it at least to the assumptions underlying the calculation, such as economic and non-economic assumptions, expected profits in future premiums, future management actions and future policyholder behaviour.
  • Information on eligible own funds: EIOPA encourages undertakings/groups to disclose information about the management of the own funds in the context of the undertaking’s/group’s strategy and business model, including information on the time horizon used for business planning and on any material changes over the reporting period. The information of the eligible own-funds items, classified by tiers should be complemented by explanations of the most material own-funds items, including the extent to which they are available, subordinated, as well as their duration and any other feature that is relevant for assessing their quality.
  • In next year’s SFCR undertakings/groups should also include comparative information in certain areas of the SFCR. EIOPA expects that when providing comparative information the format of tables is used as much as possible in the narrative part of the SFCR. These tables could include amounts for both reporting years or focus on the material differences between both reporting years. Qualitative information on material differences between two reporting years are also expected to be included in the report. Publication of QRTs for current and the previous reporting year as an Annex alone is not sufficient to be considered compliant with the comparison requirement.

 

Click here to access EIOPA’s SFCR report

EIOPA Insurance Market Risk Dashboard October 2017

Key observations:

  • Risks for the insurance sector remain overall stable and some slight improvements are observed in the solvency ratios of groups and life solo undertakings.
  • Profitability of the sector has shown some positive signs both for life and non-life.
  • Despite these positive signs, the continuing low-yield environment and the observation that market fundamentals might not properly reflect the underlying credit risk, still represent important concerns for the EU insurance industry.
  • Underwriting risks remain of limited concern; however the impact of the recent nat cat events has not yet been reflected in this risk dashboard release and might affect (re)insurers exposed to the non-life business. At this stage no final conclusion can be made.
  • Market perception improved driven by the outperformances of the insurance stocks and the reduction of the CDS spreads. Ratings and rating outlooks remain stable.

Risk Dashboard Oct 2017

The macroeconomic environment characterised by enduring low-yields remains fragile. Inflation rate forecast is decreasing inverting the positive trend observed till March 2017, whereas unemployment rates continued to decrease. Despite slightly increasing policy rates in some jurisdictions, the balance sheets of central banks are still expanding (even if the increasing trend is reducing) with potential effects on the pricing of risk premia.

Credit risk is still not properly reflected in market prices where the observed spreads are close to the historical low. The investment portfolio of the undertakings, largely composed of investment grade assets, remains stable in terms of credit quality.

Market risks remain at a medium level. The slight increase of the volatility in the bond markets is counterbalanced by the reduction of the volatility in equity markets. Insurance specific indicators confirm the stable risk exposure.

Risks relating to liquidity and funding remain constant in Q2 2017. However, the increase of the average coupon/maturity indicator, despite affecting a minority of the market, shows an increased challenge for insurers to raise debt funding. Q2 2017 reports a material increase in the cat bond issuance to back potential effects deriving from the hurricane season. Nevertheless the overall assessment of the risk category shows that liquidity is not a major issue for the insurance industry.

Indicators of profitability and solvency signal slight signs of improvement. SCR ratios slightly increased for groups and life solo undertakings whereas non-life solo undertakings reported stable values. Profitability of the sector has shown some positive signs both for life and non-life business.

Insurance risks remain unchanged. Concerns rise from the potential impact on the industry of the recent nat cat events observed in the US and in some European countries. Those events are not yet reflected in the specific metrics and any conclusive change on the impact is premature.

Click here to access EIOPA’s detailed dashboard

 

Solvency II : First experiences with SFCR reporting – Germany, UK, Ireland

In May 2017, all German solo insurance companies were required for the first time to publish selected reporting forms as part of Solvency and Financial Condition Reporting (SFCR) – insurance groups followed at the end of June. These reports did not only include a huge amount of data on specific Solvency II risk figures but also comprehensive information about

  • general business development,
  • qualitative explanations on the presented figures and on the financial, solvency and business situation.

Aside from the obligation to publish own Solvency II results, insurance companies now for the first time have the opportunity to compare their Solvency II results with direct competitors.

The publication of SFCR reports also gives stakeholders access to Solvency II reports who did not have insight into these results before, for instance

  • rating agencies,
  • sales partners,
  • customers,
  • media
  • and creditors.

The extension of the target group has two main consequences for insurance companies:

  1. Firstly, Solvency II results need to be explained to an audience that has little experience with Solvency II – unlike insurance supervisors who had exclusive access to Solvency II results until now.
  2. Secondly, the solvency ratio becomes increasingly important as a material piece of information from SFC reports.

Due to the flood of information available in the SFC reports and the lack of experience of many market participants, it can be expected that processing Solvency II results will be mainly restricted to the evaluation of the solvency ratio as the core result of Solvency II. In particular, it was revealed that individual insurance companies are already actively using the solvency ratio in sales.

The attention given to the solvency ratio by the public will increase even further in the future if ratios approach the critical 100% threshold due to reduced interim measures.

Due to its increasing importance, the solvency ratio is no longer regarded as a pure reporting figure but as a value that requires active management. A variety of degrees of freedom and options in the calculation of Solvency II results allow insurance companies both to adjust their business policies and to influence SII results through suitable calculation methods. Due to the short history of Solvency II, there is little understanding of the impact mechanisms “behind” the solvency ratio at the moment, which is why not all optimization potentials are currently leveraged and insurers are still actively searching for solvency ratio levers.

In light of the extended information basis, decisions about

  • the use of interest rate measures,
  • an internal model (instead of the standard model),
  • simplified calculation methods
  • and the use of company-specific parameters

can be reassessed.

SFCR Germany

Click here to access Zeb Control’s detailed report

In a survey of the Solvency and Financial Condition Reports (SFCRs) and public Quantitative Reporting Templates (QRTs) for 100 of the top non-life insurers in the UK and Ireland the aim of the review was twofold – to analyse the numbers disclosed by firms for the first time and to consider how well firms have dealt with the narrative reporting required of them under Solvency II.

The survey team has also drawn upon our Pillar 3 roundtables with insurers and reinsurers across the market to understand how the first year of submissions has worked in practice.

Their key conclusions are:

  • Insurers are generally sufficiently capitalised, but the buffers firms have in place to protect against balance sheet volatility may not be enough to prevent them from having to recapitalise over the short term.
  • Motor insurers typically have the least financial headroom, compared with other insurers.
  • Brexit is on the agenda for many insurers, with some firms setting up internal steering groups to ensure they are well placed to access the European Market after the UK leaves the EU.
  • Uncertainty around the Ogden discount rate used to calculate personal injury compensation payments poses a material risk to some insurers, with two firms disclosing that the recent change required them to recapitalise significantly.
  • Firms must work harder to publish better quality QRTs, with over a quarter of the firms we reviewed disclosing QRTs containing obvious errors.
  • Some firms’ SFCRs are not fully compliant with the Solvency II regulations, with particular areas of weakness including disclosure around sensitivity testing of the SCR and uncertainty within technical provisions.

SFCR UK IRL

Click here to access LCP’s detailed survey analysis