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16 | The South African Insurance Industry Survey 2016

Below, we outline some of the leading and lagging practices observed:

Observed leading practices from KPMG benchmarking               Observed lagging practices from KPMG benchmarking                       While some of the leading practices
                                                                                                                                        across themes are highlighted, it
ORSA is an integral part of business strategy and planning.     ORSA process is clearly disjoint from strategy setting and the          is important to note that no single
                                                                business planning process.                                              company was a leader across all the
Risk appetite and tolerance statements are expressed in                                                                                 assessment criteria, likewise, no single
terms of at least both Capital and Earnings Volatility and      Risk appetite and risk tolerance limits only cover capital targets set  company was lagging across all the
these are cascaded down to relevant sub-risks. Some             only at company level with the solvency target not being justified in   assessment criteria.
attempt is made to set tolerance levels for material            terms of the risk profile. Some still measure the target in terms of
qualitative risks.                                              current statutory capital measures.                                     Feedback from the Regulators
                                                                                                                                        SAM is principles based, so a firm
Material risk assessments cover both quantitative risks not     Material risk assessment is limited to quantitative risks covered by    needs to consider how to meet
included in the standard formula - such as liquidity risk - as  the standard formula.                                                   compliance in a way that best works
well as qualitative assessments with a clear description of                                                                             for the firm to achieve business value.
control measures in place for each material risk identified.    Stress and scenario testing is limited to a historic point in time      Our view is that for most companies,
                                                                - usually the chosen valuation date. No consideration is given to       the focus of the first mock ORSA
Stress and scenario tests are well articulated and cover the    reverse stress testing.                                                 report was to design and implement
business planning projection period. Better ORSAs also                                                                                  underlying processes and produce
consider knock-on effects in addition to the stress/scenario    There is no evidence of the ORSA being used in decision-making,         documentation to comply with the
test.                                                           which is to be expected where the mock ORSA was the result of           applicable requirements. They should
                                                                the first ORSA cycle.                                                   be used as a lessons learnt cycle by
ORSA projections are evidenced in business decisions, for                                                                               individual companies to improve future
example in the dividend setting strategy. ORSA results are      The need for and possible circumstances for performing an out-of-       cycles. Particular attention should
used in an assessment of future capital needs and as an         cycle ORSA is not covered in the ORSA report.                           be given with respect to ensuring
input to capital planning.                                                                                                              ownership, engagement and challenge
                                                                The process for identification, assessment, and prioritisation as       from Senior Management and the
Clear articulation of when an out-of-cycle ORSA would be        well as monitoring and reporting of risks is theoretically described,   Board so that they clearly understand
required.                                                       sometime as a future state.                                             and can affect their obligations once
                                                                                                                                        SAM is live.
Included an executive summary which covered business            Documentation is either not clear, accurate or complete.
planning, strategy setting and key results of the ORSA          Conclusions reached are not justified and can therefore not be
assessments.                                                    challenged at Board level.

The risk management system and how the ORSA process             Group-wide coverage does not focus appropriately on risks
fits in the overall ERM framework is summarised. Roles          emerging from group exposures. ORSAs generally do not
and responsibilities for the various steps in the process are   sufficiently consider risks associated with non-regulated entities.
clearly outlined.
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