This presentation serves as study notes for the e-learning material titled: "South African Hedge funds and international developments"
These notes focus on Solvency II and its Impact on the Hedge Fund Industry.
http://www.hedgefund-sa.co.za/solvency-ii
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1. Study Notes Solvency II
2. What is Solvency II European regulatory framework for
insurance and reinsurance and is based on the economic principles
regarding the measurements of assets and liabilities improved
customer protection, increased supervision, market integration and
competitiveness three pillar model European Union (EU) focus but
with a worldwide ripple effect International benchmark effective
from January 2014
3. Aims of Solvency II Improved Customer Protection To provide
policyholders across the EU with A greater degree of protection and
an increased level of consistency reduce the losses suffered by
policyholders in the event the insurance firm is unable to meet its
claims fully.
4. Aims of Solvency II (cont.) Modernised Supervision
Supervisory Risk Review To implement procedures to Identify,
measure, and manage risks levels by introducing a comprehensive
risk measurement framework to determine the required level of
capital. The Need to readdress weaknesses in the system create
consciousness towards a more modernised industry standard improve
industry risk management practices.
5. Aims of Solvency II (cont.) Deepened EU Market Integration
Potentially change the competitive outlook of the insurance
industry through capital allocations which will impact pricing and
product innovations. This combined with customer protection may
provide policyholders with greater confidence in insurer
products.
6. Aims of Solvency II (cont.) Increased International
Competitiveness of EU Insurers EU subsidiaries of non-EU parent
company or group of companies must adhere to supervision
requirements aims to protect all policyholders of European insurers
readily transferable capital from risk associated with coverage
from the wider group of which they are apart of. EU parent
companies with non-EU subsidiaries will have to face changes under
the new Solvency II
7. The three pillars Similar to the banking industrys Basel II
Three Pillar framework include quantitative and qualitative
requirements as well as market discipline focus on risk, capital,
supervision and disclosure according to KPMG (2011) Different
applications and requirements for Solvency II
8. Pillar I: Capital Requirements Quantitative quality Divided
into 1) Solvency Capital Requirements (SCR) 2) Minimum Capital
Requirement (MCR) is to ensure firms have risk-based capital
calculated using an internal model, a standard formula or a
combination of the two Three tests to be passed Statistical Quality
Calibration and Use test
9. Pillar I: Capital Requirements (SCR) (cont.) Internal Model
approach Standard Formula approach sets out various tests to
determine compliance attempts to provide for arrange of risks faced
by the insurer and is intended for use by small to medium sized
enterprises complex and costly and the regulations had to provide
for all members of the industry risks are categorized whereby
separate Solvency Capital Requirements are determined value-at-risk
is determined by the changes to a pre-specified shock [Private
Equity and Venture Capital Association (2011)] value-at-risk is
determined by the changes to a pre-specified shock Combination
approach (Internal Model and Standard Formula) Same requirements as
those of the Internal Model Narrower scope for the combination
approach than that of Internal Model
10. Pillar I: Capital Requirements (SCR) The Statistical
Quality Test evaluates the base quantitative methodology of the
internal model insurer must be able to show the relevance of this
methodology including the choice of model inputs and parameters,
rationalize the assumptions underlying the model. The Calibration
Test must show the regulatory capital requirement determined by the
internal model, fulfils the requirements set out in the modelling
criteria by the supervisor. Internal model results assessed and
insurers regulatory capital requirements compared to the to those
of other insurers. The Use Test requires the model, methodologies
and results are incorporated in the risk strategy and operational
processes of the insurer
11. Pillar I: Capital Requirements (MCR) According to KPMG
(2011): designed to be the lower solvency calculation,
corresponding to a solvency level, below which policyholders and
beneficiaries would be exposed to an unacceptable level of risk, if
the insurer were allowed to continue its operations. The Minimum
Capital Requirements are calculated a linear function of specified
variables and MCR limits, cannot be 25% below insurers SCR limit
Above 45% insurers SCR limit
12. Pillar II: Governance and Supervision Qualitative quality
to ensure a higher risk management system by enforcing a higher
degree of standards of risk management and governance within a
firms organisation. Greater powers (for supervisors) to challenge
risk management issues of the firm with Supervisory review and
intervention. Includes Own Risk and Solvency Assessment (ORSA),
requires the insurer to determine self-assessment risks for future
endeavours, the necessary consequent capital requirements, and
13. Pillar II: Governance and Supervision (cont.) The
qualitative requirements are determined according to: (KPMG (2011))
1. An overall responsibility of risk management 2. A clearly
defined risk strategy which is linked to the business strategy 3.
An ongoing management and control over the companys risk-bearing
capacity. Organizational setup and all the processes relating to
management of the business environment must be documented and
formalized in order to be communicated to a supervisory
authority.
14. Pillar III: Disclosure Requirements regarding disclosure of
both 1. public to the market place public report is a solvency and
financial condition report: enhances the level of disclosure needed
by the insurer 2. private to the supervisor The private report is
an annual report: made to supervisors concerning various matters
relating to the firm Requires insurers to publish details regarding
the risks facing the insurer regarding their capital adequacy and
risk management. Ensures an insurers general financial position is
better represented with more recent and relevant information Thus
transparency of the insurance industry in the market environment
and Greater discipline on the industry as whole.
15. Pillar III: Disclosure Pillar III is similar to that of
Pillar I as it refers to quantitative information as opposed to
Pillar IIs qualitative information. Requires insurers to produce a
Solvency and Financial Condition report on a yearly basis. firms to
characterize and update the company disclosure report, technical
requirements, and complete Solvency II documentation on the
procedures to be followed and implement the reporting cycle run.
Other Solvency II impacts?
16. The Impact of Solvency II on the Private Equity Investing
Facet Europe Insurers with excess capital together with a
compelling financial position and diversified portfolios pertaining
to high risk bearing capacity are unlikely to be affected by
Solvency II (European Private Equity and Venture Capital
Association (2011)) Solvency II may provide opportunities for
investment into the asset class national insurance regulation that
deters investments in private equity across Europe, as a result,
Can be used to combat the restrictions placed by those insurance
regulations because of its prudent person principle approach
17. Private Equity Investing Facet (cont.) Asset managers and
investors Certain investments will be preferred in comparison to
others which are seen as too capital consuming due to the capital
requirements on investment risks. The introduction of capital
charges on investment risks may cause insurers to take less
investment risks than before. insurers condensing their shares in
property and equities opt to increase their share of higher rated
fixed-income securities to reduce capital requirements within their
investment portfolio. No exclusion on the various classes of assets
Must prove that the assets comply with the Prudent Person
Investment Principle (PPIP) PPIP states that investors are able to
invest in any asset of its choosing provided the risks involved are
understood, proper provision is made for the risk or
18. The Impact of Solvency II on the Private Equity Investing
Facet (cont.) Asset Managers direct and indirect effect which will
result in insurers reviewing their asset allocation. Ernst &
Young (2012) suggest that asset managers should assist insurance
clients in managing their balance sheets by creating their own
adaptation of the Solvency Capital Requirement (SCR). SCR is a risk
based approach affects the investment decision making process as it
takes into consideration the return after the risk and the capital
cost of the risk.
19. Non-EU parent companies with European subsidiaries firms
operating within Europe will be required to display their groups
ability to accurately measure their risks manage the risks.
Irrespective of where the parent company is situated For Solvency
II equivalents, the global insurance firm will need to prove its
ability to cover its risks with sufficient capital so as to not
pose a risk to European policyholders. KPMG (2011) states that
global insurers doing this will Provide the lead regulator in
Europe with a look into the entity Need to show the lead regulator
that they intend to harmonize with the groups supervisory
requirements ito the Solvency II directive.
20. What becomes of non-EU subsidiaries with EU parent
companies Subsidiary companies from the United States (U.S) of an
EU parent company obliged to consolidate with their EU parent
company and adhere to the Solvency II groups requirements
applicable to their European parent company. For other
significantly held non-EU subsidiaries of an EU parent company will
have to comply with vital aspects of the Solvency II regime
locally. Complying will impact the risk management, capital
administration, data and system implications of the
subsidiary.
21. Solvency II implications for South Africa Although Solvency
II is aimed at restructuring the insurance industry in Europe, it
will cause a ripple effect worldwide. EU requires the ability to
understand (KPMG 2011) key risks facing an organization and the
controls and processes put in place to manage those risks Capital
requirements to cover those risks by proving them Main components
of EU factors: 1. Establishing the main intergroup transactions
that exist between the overseas organisation and the European
entity. 2. Determining key group risks that could potentially
impact the European entity. 3. Identifying the shared services
provided to the European entity and the plans to ensure Solvency
II
22. Solvency II implications for South Africa (cont.) The
Financial Services Board (FSB) currently in the process of
implementing a risk-based supervisory regime for the prudential
regulations of the insurance industry in South Africa. Solvency
Assessment and Management (SAM) is the Solvency II equivalent
Noteworthy changes (using SAM) to both long-term and short-term
insurers ito: establishing their technical provisions, capital
adequacy and their ability to manage risks in the business and
transparency through reporting to the public and the Regulator. SAM
Steering Committee has formulated a Tax Task Group to deliberate
the tax implications that are to occur under SAM and
23. Implication of Solvency II for the hedge fund industry the
investment strategy of the insurer, Interaction between insurer,
and investment managers and other service providers are of
importance when fulfilling the Solvency II requirements. review as
to what Solvency II means for the hedge fund industry. a) could
result in insurers taking potentially penalizing capital charges
against their hedge fund holdings however it also provides
uncertainty in the market place and may result in b) insurers may
postponing hedge fund allocations due to market place uncertainty
Penalises portfolios that do not provide clarity as to their
underlying assets. Without details regarding the portfolios
holdings and risk exposure hedge funds are classified as other
equities in the standard formula and are thus subjected to a 49%
capital
24. Implication of Solvency II for the hedge fund industry
(cont.) However Solvency II News (2012) (www.solvencyiinews.com)
states that hedge fund can steer clear of the 49% capital charge
with Insurance firm (investing in the hedge fund) build an internal
model to showcase that funds risks do not call for a 49% capital
charge. Ito Pillar II (governance and supervision) in Solvency II,
hedge fund managers and insurers will need to create a new service
level agreement that will be able to factor in the needs of
Solvency II Thus allow for a compliant relationship ito the act.
Insurers need to confirm that their investment managers or hedge
fund managers are operating effectively and efficiently and are
under continuous
25. Implication of Solvency II for the hedge fund industry
(cont.) Deloitte (2010) state Quarterly deadlines ito reporting
under the Pillar III framework Will create a deadline issue in
acquiring the necessary data within that time frame and Made worse
for firms that outsource their back-office activities. specific
types of data supplied by the investment manager need to be
re-evaluated in order to determine the capital charges required ito
Pillar I and ensure that there is a level of disclosure regarding a
greater degree of the information pertaining to the investments.
Hedge fund managers can use data management
26. Conclusion The implementation of the Solvency II regime
will bring clarity and assurance to policyholders whilst being a
complex procedure for current industry members. Status: The regime
is currently running behind schedule, Thus insurance industry and
others affected by the new regulations, have an opportunity to
better prepare themselves for the institution and impact of
Solvency II not only locally but globally.