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14 | The South African Insurance Industry Survey 2016

2017 ORSA requirements                                      –– Guideline 10: the assessment of continuous            Category           Considerations
Additional requirements for 2017 cover areas                   compliance with the regulatory capital
such as Board challenging and signing off on                   requirements should include, at least, an             Risk               We considered the robustness of the risk
assumptions and methodology, out of cycle ORSAs                assessment of potential future changes in the         management         management process and how it is linked to the
and independent reviews. The full list of additional           risk profile under stressed situations; the quantity  system             ORSA together with the roles and responsibilities
requirements is set out below:                                 and quality of its own funds as well as the                              of the Board and Senior Management.
                                                               composition and changes of own funds across           Link to business
–– Paragraph 1.27 and 1.28: Board and senior                   tiers over the business planning period.              plan / strategy*   We explored how well the ORSA process was
   management are expected to:                                                                                                          integrated with the business planning and strategy
                                                            –– Guideline 11: the actuarial function should           Risk appetite and  setting processes.
      –– challenge the assumptions behind the                  provide input concerning the continuous               risk tolerance
          calculation of the SCR to ensure they are            compliance with requirements on the calculation                          We examined the spectrum of risk appetite and risk
          appropriate with regards to the insurer's            of technical provisions and the risks arising from    Material risk      tolerance statements and how these interlinked.
          risks; and                                           this calculation.                                     assessment
                                                                                                                     (qualitative and   We analysed the spectrum of risks, both qualitative
      –– use the insights gained from the ORSA              –– Guideline 14: the insurer should perform the          quantitative)      and quantitative, which insurers (groups) consider
          process to approve long and short term               ORSA at least annually and should perform a                              to be material to the business.
          capital planning.                                    non-regular ORSA if the risk profile changes          Assessment
                                                               significantly. The insurer should justify the         of solvency        We looked at how and over what time horizon
–– Paragraph 1.33: independent assessment should               adequacy of the frequency of the assessment           (solvency needs    insurers (groups) assessed own solvency position
   include an assessment of the ORSA process and               and demonstrate that the ORSA is embedded in          and capital        and needs together with which metrics were being
   whether the ORSA policy has been complied                   the business and used in strategic decisions.         projections)       used.
   with.
                                                            South Africa benchmarking                                Stress testing     We examined the type of stress and scenario tests
–– Paragraph 1.34 h) and m): the ORSA report                For many insurers, the 2015 mock ORSA cycle              and scenario       performed by insurers and the robustness
   should document the following respectively:              would have been the first or second cycle. For the       analysis           of underlying assumptions and knock-on effects.
                                                            largest insurance groups in South Africa, 2015 was
      –– Deviations between the insurer’s risk profile      the third or fourth iteration of the ORSA. Our view      Use in decision    Where available, we considered how the ORSA
          and the SCR assumptions as well as how the        is that most of the largest groups already have          making*            output was used in business decisions.
          insurer has reacted or will react to significant  well developed ORSAs. However, on average the
          deviations.                                       industry’s ORSAs are still being developed.              Out-of-cycle       Where available, we explored which common
                                                                                                                     ORSA*              triggers would initiate an out of cycle ORSA and
      –– The findings of the independent review of the      KPMG in South Africa has analysed over 15 mock                              how well defined these triggers were.
          ORSA, together with the Board and Senior          ORSA reports in the market, covering both life and       Documentation
          Management’s responses to these findings.         non-life insurance entities and groups of various                           We explored the overall quality of the ORSA reports
                                                            size and complexity. Though this represents only         Group-wide         and identified good practices.
–– Paragraph 1.54: an insurer is expected to                a small portion of the insurance market in South         coverage
   demonstrate the appropriateness of the standard          Africa, we believe that it is across a representative                       Where applicable, we considered the extent of
   formula for the risks inherent in its business and       sample of the South African market and therefore                            coverage of both regulated and non-regulated
   its risk profile.                                        the conclusions drawn should be reasonably                                  entities within the group, the emergence of risk
                                                            representative of the industry on average.                                  from these entities and how the solvency needs
–– Paragraph 1.55: submitted and approved SCR                                                                                           were aggregated at group level.
   undertaking-specific parameters have to be the
   same as those used in the overall solvency needs
   assessment.

                                                                                                                     *Not a requirement for the 2015 mock ORSA.
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