The Solvency II preparation finish line is close

Solvency II – the European Union prudential capital regulation – will come in to effect in January 2016 after more than a decade of preparation. For many European insurers it means they are reaching the end of the long road of deep preparation but others have already turned their preoccupations in other directions. For instance the Solvency II regulation came in to effect already this year in Denmark and their level of preparation allowed Danish insurers to adapt to the new regulation. But let’s recall what Solvency II is and why it is an important regulation for the European insurance industry. Solvency II is the set of regulatory requirements for insurance firms that operate in the European Union. The rationale is to facilitate the development of a single insurance market in Europe while securing an adequate level of consumer protection. It is based on three pillars:
  • The first pillar defines capital requirements. It quantifies the minimum capital requirement (MCR) and the solvency capital requirement (SCR).
  • The second pillar provides qualitative requirements in terms of supervision and review. Indeed, the European Commission wants to emphasize the need for insurance companies to implement efficient risk management systems.
  • The third pillar introduces the market discipline concept. Insurance companies have to promote transparency and support risk-based supervision through market mechanisms.
What makes Solvency II a comprehensive regulation is the fact it includes all types of risks and is not restricted to purely insurance risk. With this it better captures the reality of what an insurer’s risk profile is. Key elements of this approach is of course the diversification effect and this is why we see consolidation among small insurance players who lack diversification in their business (notably small mutuals in France for instance). Going forward we expect other geographies to follow the same principles and we think it is important that multinational companies learn from their European preparation. Of course Celent and Oliver Wyman have been working on Solvency II in the recent past. We have also published research providing our views and opinions on this topic. A recent report has been published by Oliver Wyman in collaboration with Morgan Stanley looking more particularly at various consequences and notably on cash for insurers. If you are interested to know more here is an abstract: European Insurance: Generating Cash in a Volatile Solvency II World. For the insurance companies that are interested to better understand the vendor landscape we have published a report profiling vendors with a Solvency II offering a few years ago: Solvency II IT Vendor Spectrum: 2012 Edition.  

On the cusp: regional integration in Asia

It’s 2015, the mid-point of the decade and a good time to start looking at major trends in Asian financial services over the next five to ten years. One of the major themes will be regional integration, which is another way of saying the development of cross-border markets. There are at least two important threads here: the ongoing internationalization of China’s currency, and the development of the ASEAN Economic Community (AEC) in Southeast Asia. RMB internalization is really about the loosening of China’s capital controls and its full-fledged integration into the world economy. And everyone seems to want a piece of this action, including near neighbors such as Singapore who are vying with Hong Kong to be the world’s financial gateway to China. The AEC is well on its way to becoming a reality in 2015, with far-reaching trade agreements designed to facilitate cross-border expansion of dozens of services industries, including financial sectors. While AEC is not grabbing global headlines the way China does, we see increasing interest in Southeast Asia among our FSI and technology vendor clients. From Celent’s point of view, both trends will open significant opportunities across financial services. In banking, common payments platforms and cross-border clearing. In capital markets, cross-border trading platforms for listed and even OTC products. In insurance, the continued development of regional markets. Financial institutions will be challenged to create new business models and technology strategies to extract the opportunities offered by regional integration. It’s the mid-point of the decade, and the beginning of something very big.

Engaging the NAIC on Emerging Insurance Technologies

“If the regulators aren’t with you, expect insurance innovation to take longer and cost more.” This comment surfaces repeatedly in Celent’s research. We believe this is true and have seen this occur in the past (credit scoring, predictive analytics, telematics). In order to address this issue, we at Celent have begun to proactively engage regulators around emerging technology topics. Last week, I presented at the fall annual meeting of the National Association of Insurance Commissioners. Addressing the Property & Casualty Committee, the topic was “Emerging Technologies and Their Potential to Impact the Insurance Industry”. I observed that regulators are eager to receive information about this topic. This is understandable, as budget constraints make it very difficult to divert resources from the day-to-day crush of filing and approvals to concentrate on the future. However, mentioned in the session, it does the industry absolutely no good if the first time a regulator learns about a new technology is in a new filing! Celent is tracking several technologies with the promise to change insurance proposition in important, fundamental ways. For example, digital capabilities allow customer engagement to shift from periodic (only at time of renewal or a claim) to continuous (daily lifestyle suggestions). Another trend we see is a movement from “pay as you rate” to “pay how you use”. The introduction of telematics in the Auto line is the best example of this. Several case studies from around the world were used to illustrate how, in other regulatory environments, technology is being applied to insurance. The digital customer experience platform built by Tokio Marine was shown as an example of continuous customer engagement. AXA’s use of public and private data sources to change the FNOL reporting process was offered as a case of a transition from reactive to proactive claims management. Celent will continue to be involved in briefing regulators on these issues. We encourage insurance technology providers to do the same. We are all on this journey together and will get their faster and more effectively if we communicate actively.

Capital Opportunities

AM Best came out today with a revision for the reinsurance sector from stable to negative as the reinsurance market continues to soften. When it comes to reinsurance, it’s been a buyers’ market. Competition in the global reinsurance industry is fierce as there is significant excess capacity. Reinsurers have experienced lower than anticipated cat losses despite some well publicized events earlier in the year. There’s also been robust use of alternative capital as cat bonds continue to increase.   What this means for carriers is that they have opportunities to take advantage of falling prices and get improved coverage across all lines of business. In addition to low prices, terms and conditions are improving. Carriers are able to purchase increased coverage because of the low prices and lock in multi-year deals for portions of their reinsurance coverage. They’re negotiating more customized reinsurance programs – lasering out specific exposures. And even property cat renewals are getting improved prices and terms. With pressures on growth, carriers who retreated from catastrophe exposed coastal areas in earlier years are reassessing the potential opportunities and looking for tools to help them re-enter a potential growth market.   The question is how long can reinsurers keep this up? Is the bottom of the soft market emerging? Private reinsurance capital is now competing at a level comparable to current government roles in some areas. AM Best isn’t the only rating agency that is posting negative outlooks on the reinsurance market. Primary carriers are starting to look more aggressively to determine if they should consider locking in lower rates and favorable terms for longer periods. Especially as reinsurance becomes even more of a strategic decision since regulators are increasing their use of economic capital modelling. Many carriers find rating agency capital requirements are driving a higher capital constraint and therefore are becoming a leading factor in strategic decisions about how insurers manage capital and make reinsurance decisions.   But reinsurance is a unique area in an insurance carrier typically managed by a small unit with one or two gurus who have the knowledge of the programs preserved in their heads. Although reinsurance programs are becoming increasingly complex, large numbers of carriers rely on excel spreadsheets to manage these programs which are rife for error.     As carriers structure more complex programs because prices and terms are favorable, we’re seeing increased interest in reinsurance software to help manage these complex programs. Modeling potential programs, automating premium and commission calculations, processing complex inurements and improving claims recoveries are helping many find huge returns when investing in these types of systems.

2014 Latin America Outlook

The following text was published today in Inter-American Dialogue’s Financial Services Advisor under the title: “What is driving the insurance market in Latin America?” I provided my view to FSA in advance, and now that it is out there I thought it made sense to share it with you through our blog. Growth continues to be a common theme throughout the region, though not at the same pace that before and not equally in all countries. The Pacific Alliance countries have been growing faster than Mercosur countries, for example. Insurance in Latin America has its own dynamics and has been growing year over year, even beyond GDP increase, and is expected to continue this trend through 2014. A growing middle class is driving insurance buoyance in the region, with Brazil much setting the tone. Estimates indicate that 40M people have gone from living in poverty to the middle class in the past decade in Brazil. Nevertheless, there is a large number of people in the base of the pyramid (BoP) which is also of interest of insurers. Infrastructure investments, trade, and group life and benefits to attract employees are key drivers for commercial insurance growth. We are seeing moves towards consolidation in certain countries which are imposing stronger capital requirements and also acquisitions and new entrants into high growth potential markets, such as Brazil, Colombia and Peru. Competition is increasing and new segments are being targeted with more focus. All this is driving higher investments from insurers as well as competition for qualified talent in the marketplace. Some countries are moving towards a stricter risk-based capital measurement, and the rest should move in the same direction as part of a global and regional trend. In many countries sales practices are far from innovative and what customers expect to be. There is a need to evolve in the use of distribution channels and provide a better customer experience. Most insurers are still tied to legacy systems that impose a burden to become more competitive, efficient and smart. Rising inflation, weakening of financial market due to lower quality of loans (as they compete for the raising middle class); lower demand of products from China (mostly commodities), Europe and USA, and risk aversion from foreign investors are some of the concerns shadowing the region’s potential.

FIO Report – Confirmation of the Hybrid Model

The Treasury’s Federal Insurance Office released its report on federal insurance regulation (http://www.treasury.gov/press-center/press-releases/Pages/jl2245.aspx). As predicted in the Celent Boardroom Series Report issued on August 10, 2009, the report calls for a “hybrid model” of regulation, or as Celent described it, a coordinated effort between the states and the federal government.  (Celent subscribers can access the report here: http://www.celent.com/reports/boardroom-series-us-federal-regulation-insurance-are-we-ready). Over the next few days, insurers, interest groups, legislators and industry analysts (including Celent) will be examining the report to determine short, medium and long term impacts on companies.  At this point, we have seen nothing to invalidate our other previous prediction – that greater federal involvement will require greater (and new) reporting requirements to which insurers will have to respond.  Organizations wishing to get a jump on future compliance will invest in data management processes and tools.    

SEC Busts Broker Dealer Offering Securities on LinkedIn

The Securities and Exchange Commission (SEC) announced yesterday that they have brought charges against a broker dealer for offering fictitious securities for sale on social sites. There are several good messages involved with this announcement. First, the person charged was caught before completing a sale. There is no more proactive protection than that. Second, this demonstrates that the people responsible for overseeing financial transactions are active on social media and that they are “listening”. I continue to be concerned that budget constraints will negatively affect social media monitoring and enforcement. Finally, it is a chance to reinforce the regulations that FINRA already has in place for the use of social media for legitimate purposes.

The announcement is located at http://sec.gov/news/press/2012/2012-3.htm The posting also includes a useful summary of compliance issues for companies to consider regarding social media (a National Examination Risk Alert titled “Investment Adviser Use of Social Media”).

I wish the authorities all the best in continuing to be successful in these endeavors. If there is a next Bernie Madoff, let him do his damage outside the realm of social sites.

Count down to RDR – Are you having pre-exam jitters?

We are now in the final stages of our report on the opportunities and challenges facing the Life & Pensions industry resulting from the UK’s Retail Distribution Review (RDR – see my June blog entry ) and will publish shortly. In total, we have conducted 22 interviews from across both the industry and technology partners supporting the implementation of RDR and surveyed 5 of the top product providers to understand their level of readiness.

What is interesting to me is the seemingly low levels of confidence that some firms have in their own post-RDR business strategy and operating model. Clearly, there is still a lot of uncertainty over what the winning strategies post-RDR might look like and what this could mean for the end consumer. What is clear, however, is that the industry is taking it seriously and that there could ultimately be more than one winning strategy as the market segments further.

Even with all of the good preparatory activity underway across the industry, there is still a feeling of nervousness in the air. It reminds me of taking my exams. You’ve done your homework, you’ve focused on revising the things that you think are important (and probably aligned to what you know best in the hope that it will come up as a question), you have a clear plan in place for sitting the exam…but you haven’t yet sat the exam. Adding to the anxiety, in the case of RDR, the examining body hasn’t yet released all of the chapters in the core reference text from which to revise. Hopefully, the guidance on commission for legacy products and the time-table for cash rebates will be released by the FSA soon.

As we approach the final two months of 2011 and you work through your 2012 budgets and detailed implementation plans, why not join us together with the FSA, Focus Solutions, Altus and AT8 for an additional revision session on the 15th November 2011 at the Barber Surgeon’s Hall?

Follow this link to register Count-down to RDR – Are you ready?

Solvency II delayed

Getting back to December 2008, I wrote a blog post mentioning that Solvency II was under threat and that we could expect some more delays of its effective implementation. Last week the FSA in the UK announced that it is likely that the effective date of the new regulation implementation will have to be delayed by a year and enter into force certainly in January 2014. Actually this decision comes following the request from The Lloyd’s of London insurance market and the Association of British Insurers to obtain more clarity around the Solvency II implementation by FSA.

This is certainly good news for insurance companies as it gives them more time to prepare and take advantage of the Solvency II implementation not only to comply with the new regulation but also to understand the opportunities for risk management process and resources improvements and consequently make the right decision to mitigate their risks. With the change of the Solvency II roadmap I also expect from insurance companies to spend more money on preparation and change programs in order to promote a smooth transition. This delay will also allow insurers to dedicate more time to navigate the Solvency II IT vendor landscape. According to me, the Solvency II application landscape can be difficult to navigate for insurers even though some vendors have managed to bind strategic partnerships recently (acquisition of Algorithmics by IBM for instance). For more information about this market I encourage you to read the following report Celent has published last year: Solvency II IT Vendor Spectrum.

The big question mark going forward is whether the economic situation for the next two to three years will allow the regulator and insurance companies to work in a more stable environment to operate this transition.

Count down to RDR – How ready is the UK Life & Pensions Market?

With less than 400 working days to go until ‘go live’ for the UK Retail Distribution Review, many Life and Pensions companies are deep in the middle of planning their implementation. Due to start on 31st December 2012, this legislation will introduce major changes to the way that new long-term savings and investment products are sold across the UK.

Its broad aims are to improve professional standards of investment advisors, improve the clarity around how firms describe their services, and to address the potential for commission to influence advice decisions. Practically, this means subscription to a new code of ethics including new definitions for advice, raised levels of professional education, and an end to traditional ways of charging commission for investment related products in favour of transparent fees.

Many industry analysts and commentators are already predicting structural changes within the market once consumers, armed with new information about how much they are being charged for advice, begin to shop around and start to ask tough questions about the value they are receiving from both the advisor for the advice fee paid and the performance of underlying products.

Technology has a critical role to play in helping organisations remain fighting fit in a post-RDR world.

Meeting the basic compliance needs

  • Ensure that underlying systems are able to manage both fee based services as well as commission. Both of these approaches will need to run in parallel post-RDR as the legislation only applies to investment related business transacted after the ‘Go Live’ date.
  • Ensure that only RDR compliant propositions are available for sale post 31st December 2012. Web-sites, other channel systems and channel partners all need to be changed.
  • Ensure that Platforms comply with the final set of rules on charging and rebates due to be released in Q3 this year, and offer essential services such as re-registration.
  • Update internal management reports and operational controls to track performance of business initiated both pre and post RDR.

Demonstrating value and positioning for growth

  • Developing new propositions including new channels to market, such as D2C, and access to new funds.
  • Employing innovative uses of technology to build stickier relationships with the end consumer (such as improved UIs, online tools, mobile apps and social media).
  • Transforming the cost base to compete head-on with new entrants, such as greater use of straight through processing and strategies to isolate or remove the legacy to prevent it becoming a drag on resources.

Navigating the change

  • Balancing competing priorities between now and ‘Go Live’ date – such as Solvency II, the EU Gender Directive and other internal strategic change programmes.
  • Being ready to react once the final set of rules on Platforms are published in Q3 2011.
  • Securing the investment and the team – including the right mix of capabilities to exploit the opportunities for growth.

Over the coming months, Celent will be researching the impact that RDR will have on technology strategy for organisations and evaluating the readiness of the market to implement the change. For more information or inclusion in this research, please feel free to get in contact with me.

And for those of you outside of the UK looking in thinking that this does not apply to me, beware! The European Community is revising its plans for the Insurance Mediation Directive (IMD) and Packaged Retail Investment Products (PRIPs) initiatives, and no doubt will look to see what lessons it can learn from the UK’s RDR. So, watch this space!