Ireland: Central Bank Update - June 2015

The Central Bank publishes latest edition of Solvency II Matters newsletter

The Central Bank published the latest edition of its Solvency II Matters newsletter on 27 May 2015.

The newsletter notes that the Central Bank's Online Reporting System opened to receive formal submissions of Solvency II preparatory phase reporting on 14 May 2015.

The newsletter also notes that during 2015 and 2016 insurance undertakings are required to report to the Central Bank on both a Solvency I and a Solvency II basis. Despite concerns regarding the issue of duplication of reporting in Q3 and Q4 of 2015, the Central Bank has decided that there will be no exemptions from Solvency I quarterly reporting requirements granted to undertakings.

The newsletter also provides an explanation of the correspondence from the Central Bank to all high and medium risk undertakings in relation to their 2014 Forward Looking Assessment of Own Risk submissions. This correspondence is composed of a general feedback letter to the industry and an undertaking specific appendix.

The newsletter provides an outline of Solvency I and Solvency II reporting required in 2015 and 2016.

To view the full text of the newsletter, please click here.

Central Bank publishes six Solvency II information notes to assist undertakings in preparing for Solvency II implementation

The Central bank has issued a number of Solvency II information notes. Six of these information notes have been published by the Central Bank to date.

The six information notes are:

  • Information Note 1 – Article 308a Approvals
  • Information Note 2 – Preparatory Reporting Phase
  • Information Note 3 – Article 308a Approvals - Part 2
  • Information Note 4 – Undertaking-specific parameters
  • Information Note 5 – Special Purpose Vehicles
  • Information Note 6 – CBI Approach to Set 1 of the Solvency II Guidelines

Article 308a approvals, referred to in Information Notes 1 and 3 above relate to the application processes for approvals regarding internal models. Information Note 6 indicates that the Central bank intends to comply with all of the Set 1 Guidelines and will be incorporating these into its supervisory practice where appropriate.

The six information notes can be found on the Central Bank Solvency II introduction page, which can be found here.

Central Bank announces enforcement priorities for 2015

The Central Bank announced its enforcement priorities for 2015. It noted that its enforcement strategy is focused on deterring breaches of requirements, securing compliance and promoting the behaviours and high standards expected from regulated firms in order to protect consumers and safeguard the stability of the wider financial system and the economy.

The Central Bank identified its cross-sector priorities as:

  • prudential requirements;
  • systems and controls;
  • provision of timely, complete and accurate information to the Central Bank;
  • appropriate governance and oversight of outsourced activities;
  • anti-money laundering / counter terrorism financing compliance; and
  • fitness and probity obligations.

It also identified its market-specific priority areas as:

  • MiFID conduct of business rules; and
  • client asset requirements.

Further, it identified its consumer protection enforcement priority areas as:

  • Code of Conduct on Mortgage Arrears;
  • suitability of sales; and
  • fair treatment of customers.

The Central Bank also stressed that its enforcement activities will not be confined solely to those identified areas, and that its enforcement work would be ongoing in the context of the changing regulatory environment throughout the year.

For the full text of the announcement, please click here.

Consumer Protection Outlook Report

The Central Bank has published its first Consumer Protection Outlook Report which sets out the Central Bank's assessment of both existing and emerging risks for consumers. The Central Bank indicated that it will shape its approach to consumer protection priorities and agenda over the next few years. It expects all firms to develop internal consumer protection frameworks, reflecting the nature, scale and complexity of their businesses and to provide the right support structure to generate positive outcomes for consumers.

The report itself sets out key consumer protection objectives for all regulated firms to ensure that they are treating their customers fairly and acting in their customers' best interests. It further highlights the risks arising in relation to those objectives. The Central Bank will be reviewing these risks and priority objectives over the coming years, and it indicated that these will be updated on an annual basis.

For the full text of the report, please click here.

Reserving Requirements for Non-Life Insurers and Non-Life and Life Reinsurers – FAQs

The Central Bank recently published a paper setting out a number of frequently asked questions ("FAQs") regarding the reserving requirements for Non-Life Insurers and Non-Life and Life Reinsurers (the "Requirements").

The FAQs reflect questions raised with the Central Bank and is intended to support the implementation of the Requirements. The Central Bank has stressed that the FAQs are for guidance purposes only.

To see the full text of the FAQ, please click here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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