Ireland: Insurance Regulatory Update, October 2017

Last Updated: 9 November 2017
Article by Elizabeth Bothwell and Jennifer McCarthy

OCTOBER 2017 – THIS MONTH'S NEWS

CENTRAL BANK'S ANNUAL INSURANCE BRIEFING

On 24 October, the Central Bank held its annual insurance briefing event. The topics discussed at the event focused on Brexit, Solvency II annual reporting, the challenges that technology poses for the

consistent supervision across the single market. She also addressed the need for UK insurers to consider the implications on their business model of a loss of their passporting rights in the wake of Brexit. According to Ms. Cronin, the Insurance Directorate of the Central Bank has scaled up its authorisation unit and is prepared to deal with an increase in the volume of applications for insurance authorisation arising from the Britain's exit from the EU. In terms of the substance, the Central Bank expects to see evidence of strong local governance supported by a sound risk management framework. The Central Bank must be satisfied that the outsourcing of critical functions such as underwriting, claims or distribution channels would be subject to frequent monitoring and review, to ensure adequate control. Reinsurance, is also a key area, as a high degree of reinsurance may indicate a lack of substance in the local entity, or exposure to concentration risk and counterparty risk.

The Director of Insurance Supervision's speech is here.

NEWLY APPOINTED DEPUTY GOVERNOR, ED SIBLEY DELIVERS SPEECH ON PRUDENTIAL REGULATION AND BREXIT

In his first speech as Deputy Governor, Mr. Sibley shared his perspective on a number of different topics including the approach of the Central Bank to prudential regulation in light of recent regulatory developments, financial conduct and Brexit. On Brexit, he warned that it is "entirely plausible" that there will be a 'hard' Brexit, with no transition period and that much needed to be done to prepare for this scenario, particularly in the insurance sector.

The Deputy Governor's speech is here.

DIRECTOR OF INSURANCE SUPERVISION, SYLVIA CRONIN, DELIVERS SPEECH ON DIGITAL TECHNOLOGY, CYBER RISK AS A DISRUPTER AND THE IMPORTANCE OF CULTURE

Sylvia Cronin, Director of Insurance Supervision delivered a speech on the Central Bank's supervisory approach to digital technology, cyber risk and culture. She acknowledged the challenges that digital technologies have meant for its supervisory approach, and

insurance industry and the Central Bank's supervisory priorities for 2018. In relation to Solvency II supervision, capital monitoring and outsourcing were cited as two key areas of focus for the Insurance Directorate. Director of Insurance Supervision, Ms. Sylvia Cronin noted that internal models will continue to be rigorously assessed by the Central Bank. On outsourcing, the Central Bank anticipates there being a change in the distribution channels used by insurers as a result of Brexit, which may lead to an outsourcing of core insurance activities such as underwriting and claims management. The Central Bank plans to carry out a number of supervisory initiatives to understand the risks posed by companies that will heavily avail of outsourced services post-Brexit. In addition, Ms. Cronin cautioned that the Central Bank will approach the assessment of these arrangements diligently and rigorously.

The Insurance Directorate's supervisory priorities for 2018 will focus on branch inspections, Brexit preparedness and cross sectoral review outcomes. In terms of actuarial focus, the Insurance Directorate's 2018 priorities are pricing discipline, reserve adequacy monitoring and assessment of internal models.

The Insurance Directorate's briefing notes are here.

The Director of Insurance Supervision's opening speech is here.

MEDIATION ACT 2017

On 2 October, the Mediation Act 2017 (the Act) was enacted and it is expected to be commenced in a number of weeks. The Act, which applies to all litigation disputes apart from arbitration, employment disputes and certain disputes under tax and customs legislation, is designed to encourage the use of mediation as an alternative means of dispute resolution. Section 7 of the Act provides for an 'agreement to mediate' to be put in place between the parties and the mediator, it also deals with the manner in which the mediation will be conducted, how the fees and costs of the mediation will be paid, the place and time of the mediation, confidentiality and termination. Under

the Act, the outcome of the mediation must be the determination of the parties and not the mediator and Section 9 provides for introduction of codes of practice for mediators to set standards for the conduct of mediation. The Act also introduces an obligation on solicitors and barristers to advise their clients to consider using mediation as a means of resolving disputes.

The Mediation Act 2017 is here.

COST OF INSURANCE WORKING GROUP PROGRESS UPDATE

On 23 October, the Department of Finance's Cost Insurance Working Group released its third quarterly progress report for 2017. According to the progress report, work on the legislative framework for the National Claims Information Database, which is to be run by the Central Bank, is at an advanced stage and it is expect that the draft heads of the legislation will be forwarded to the Government in the coming weeks. In parallel with this process, the Central Bank has been leading the development of the technical specification of the Database and has held a number of workshop sessions to determine these precise specifications. In a speech given earlier this month to the Joint Committee on Finance, Public Expenditure and Reform, and Taoiseach, Governor of the Central Bank, Phillip Lane also indicated that as part of its work on the cost of insurance, the Central Bank intends to issue a public consultation on the extension of notice periods and information that must be provided by insurers to policyholders regarding the renewal of policies.

The Department of Finance's progress report is here.

The Governor's speech is here.

DIRECTOR OF INSURANCE SUPERVISION, SYLVIA CRONIN DELIVERS SPEECH ON BREXIT AND SUPERVISORY CONVERGENCE

In a speech delivered to the IDA on 13 October, Director of Insurance Supervision, Sylvia Cronin discussed the importance of supervisory convergence – there must be a common understanding and interpretation of the Solvency II regulations to ensure outlined what the Central Bank expects to see regarding the features of sound governance in respect of cyber security and IT; including considering the need for a digitally focused culture. Ms. Cronin discussed the difficulties the Central Bank's has encountered in achieving a balance at the point of authorisation between ensuring firms meet regulatory expectations, while at the same time encouraging innovation and new concepts. She also acknowledged that new technology and increased digitisation represent significant risks in the areas of data protection, reputation and business interruption. The Insurance Directorate has undertaken a number of new initiatives to combat some of these risks including; issuing cyber security questionnaires to certain undertakings; training supervisors and utilising the auditor assurance framework mandated by legislation to seek assurances on cybersecurity governance for high impact undertakings.

The Director of Insurance Supervision's speech is here.

LLOYD'S MARKET ASSOCIATION RELEASES BRIEFING NOTE ON INSURANCE CONTRACTS POST BREXIT

On 19 October, the Lloyd's Market Association released a briefing note on applicable law and jurisdiction for insurance contracts post-brexit. The note, discusses the current legal regime in place across the EU concerning jurisdiction and the enforcement of judgements in relation to insurance contracts. The note goes on to speculate on the possible post-brexit environment and advocates the merits of arbitration clauses in contracts of insurance to overcome some of the legal uncertainty during Britain's withdrawal from the EU.

Separately, on 11 October, the British Parliament published a letter from Philip Hammond, Chancellor of the Exchequer on the impact of Brexit on cross-border insurance contracts. The Chancellor states that the British government is aware of the risk Brexit represented to the financial services industry and in particular the legal uncertainty as to the status of existing cross-border insurance, pension and other financial services contracts sold under passporting arrangements. He made it clear that the British government would endeavour to secure a transition period to avoid a cliff-edge for businesses trading in the single market.

The Lloyd's Market Association note is here.

The Chancellor's letter is here.

IN EUROPEAN AND INTERNATIONAL NEWS...

THE ECONOMIC AND MONETARY AFFAIRS COMMITTEE OF THE EU PARLIMENT RECOMMENDS DELAYING APPLICATION OF IDD

The Economic and Monetary Affairs Committee (ECON) has recommended to the European Commission that the application of the Insurance Distribution Directive (IDD) be delayed until 1 October 2018. A draft European Parliament decision on its website dated 11 October was presented at a meeting of ECON on 16 October. The draft decision states that the current proposed timeline does not allow sufficient time for industry to implement the necessary technical and organisational changes required. It recommends keeping the transposition deadline of the IDD as 23 February 2018 but asks the European Commission to assess whether the application date can be extended to 1 October 2018.

On 17 October, Insurance Europe issued a press release welcoming the recommendation. Michaela Koller, Director General of Insurance Europe is quoted as saying "Insurance distribution processes will be heavily impacted by the new conduct of business requirements in the IDD. For the benefit of consumers, insurers need an appropriate amount of time to properly implement these requirements. Therefore, Insurance Europe calls on all of the European institutions to recognise the importance of delaying the application of the IDD and to take appropriate action".

Insurance Europe's press release is here and the ECON website is here.

EIOPA PUBLISHES FINAL REPORT ON GUIDELINES UNDER IDD ON IBIPS

On 11 October, EIOPA published its final report on guidelines under the Insurance Distribution Directive (IDD) on insurance-based investment products (IBIPs). The guidelines relate to "execution-only" sales, which tend to be IBIPs sold online or over the phone where the insurance distributor neither provides advice nor verifies the customer's knowledge of the product and the risks involved. The guidelines aim to mitigate the risk of detriment to consumers due to mis-selling of IBIPs. They include criteria for identifying product features that customer find difficult to understand, such as the ability of the customer to determine the maturity or surrender value of a product.

The report includes: the final text of the guidelines; an impact assessment, which presents the key policy questions and the associated policy options considered in developing the guidelines; a feedback statement with a summary of the main conclusions of the public consultation that ended in April 2017; the final explanatory text to the guidelines; and a table setting out the comments received and how they were resolved.

The guidelines are to be translated into all official EU languages and, within two months of their publication, competent authorities must confirm whether they comply or intend to comply with the guidelines.

EIOPA's report is here and press release is here.

EIOPA PUBLISHES ITS SINGLE PROGRAMME DOCUMENT (SPD)

The SPD consists of two parts, the first sets out the direction for the development of EIOPA and the business strategic objectives for the period 2017-2019. The second part of the SPD contains the EIOPA annual work programme 2018 (AWP). The AWP

discusses a number of different priorities and actions for EIOPA for the year ahead including: strengthening consumer protection, improving the functioning of the internal market in the field of pensions and insurance, strengthening the financial stability of the insurance and occupational pensions sector and EIOPA as a responsible, competent and professional organisational. EIOPA has also included InsurTech as a cross-cutting theme in the AWP with the objectives of promoting supervisory convergence, facilitating a level playing field throughout Europe based on the principles of proportionality and pursuing a technology neutral approach to financial innovation. A cross-departmental taskforce has been established to assist EIOPA in this regard.

EIOPA's work programme for 2018 is here.

EIOPA RECOMMENDS SIMPLIFICATIONS TO THE CALCULATION OF CAPITAL REQUIREMENTS

On 30 October 2017, EIOPA submitted its first set of advice to the European Commission in relation to specific items in the Solvency II Delegated Regulations. The advice covers: simplification of calculations of the capital requirements in the solvency capital requirement standard formula in relation to risks such as lapse and mortality; reduction of reliance on external credit ratings in the standard formula; treatment of guarantees, exposure guaranteed by a third-party and exposures to regional governments and local authorities; recognition of risk-mitigation techniques to hedge financial risks where the exposure is changing frequently; applying the look-through approach to undertakings that invest on behalf of insurers; the use of specific parameters for reinsurance stop-loss treaties; and the loss-absorbing capacity of deferred taxes.

EIOPA's advice and press release are here and here.

EUROPEAN COMMISSION PUBLISHES STUDY ON CONSUMERS' DECISION MAKING IN INSURANCE SERVICES

On 27 October, the European Commission published a behavioural study on consumers' decision-making in insurance services. The study considers the way non-life insurance products are currently sold, tests the effectiveness of remedies intended to improve consumer-decision making and analyses the willingness of consumers to purchase these products domestically and on a cross-border basis.

The study makes a number of notable policy recommendations, including:

  • Information provision: National regulators and industry associations should regularly assess standards for the provision of information to ensure that the information is friendly and salient. Information provided to consumers should not only help them to understand the insurance contract but should also aim to enhance their understanding of the interaction between premium and excess.
  • Price comparison websites (PCWs): National authorities should ensure that PCWs are transparent, comprehensive, show costs clearly and enable complex comparisons.
  • Pressure Selling: A code of conduct could be established for car rental and add-on insurance to reduce the risk of pressure at the point of sale.

Cross-border insurance: The study releveled that latent demand exists for cross-border insurance products and it suggests that EIOPA could promote an EU standardised claim forms for different types of insurance products in order to increase cross-border purchases.

The European Commission's press release and report is here.

EUROPEAN COMMISSION REQUESTS REPORT ON COST AND PAST PERFORMANCE OF RETAIL INVESTMENT INSURANCE PRODUCTS

On 17 October 2017, the European Commission published a request to the European Supervisory Authorities (ESAs) to issue recurrent reports on the cost and past performance of the main categories of retail investment, insurance and pension products. The reporting is to be based on data and information originating from disclosures and reporting required under EU law such as the Insurance Distribution Directive and the Packaged Retail and Insurance-Based Investment Products (PRIIPs) Regulation. The purpose of the report is to provide retail investors with a broad overview of the performance and cost of retail investment products, which should allow retail investors to compare investment products and better interpret the information available to them at product level. It is also intended that the recurrent reports would enhance competition and drive pricing discipline in these markets.

The European Commission's request is here.

EIOPA'S CHAIRMAN ADDRESSES THE ECONOMIC AND MONETARY AFFAIRS COMMITTEE OF THE EU PARLIMENT

EIOPA Chairman, Gabriel Bernardino delivered his annual statement to ECON on 9 October 2017, in which he discussed the challenges of enhancing supervisory convergence, better consumer protection and financial stability. He applauded the successful implementation of the Solvency II Directive but warns that more work needs to be done to guard against the risks of regulatory arbitrage. He also believes EIOPA's mandate should be strengthened to intervene earlier in potential cross-border failures. On the topic of consumer protection, while he was satisfied with the Commission's endorsement of the majority of EIOPA's technical advice on the Insurance Distribution Directive, he was disappointed to see that third party payments have not been included in the list of typical conflict of interests. Mr. Bernardino also welcomed the Commission's proposals to reform the EU's supervisory architecture and sees it as a significant step forward in the completion of the Capital Markets Union.

The Chairman speech is here.

INSURANCE EUROPE PUBLISHES DATA BREACH NOTIFICATION TEMPLATE

On 6 October 2017, Insurance Europe published a template for breach notifications under the General Data Protection Regulation (GDPR). Insurance Europe has uploaded the template to a new section of its website entitled 'Cyber Insurance'. In addition to the data breach notification template, the new page covers the development of the cyber insurance market, including the barriers to the development of the market, as well as providing a list of national insurance association initiatives.

The template has been shared with the EU Working Party on the Protection of Individuals with regard to the processing of personal data, which is developing guidelines for data breach notification templates under the GDPR.

EIOPA's press release and the template are here and here.

INSURANCE EUROPE PUBLISHES UPDATED PRIIPS INFORMATION EXCHANGE TEMPLATES

On 6 October, Insurance Europe and the European Fund and Asset Management Association (EFAMA) published updated packaged retail and insurance-based investment products (PRIIPs) exchange templates, which are intended to provide a functional description of the set of data to be exchanged from asset managers and banks to insurers to assist them in fulfilling their PRIIPs regulatory obligations. The European PRIIPs Template (EPT) has been amended by an additional data field relevant only to funds/structured products offered in the German market and now contains data fields related to structured products, which were not catered for under the initial template. The Comfort EPT (CEPT) now provides for two possible methods for the VEV calculation for regular premium.

Insurance Europe and EFAMA's updated EPT and CEPT are here.

INSURANCE EUROPE RESPONDS TO EC CONSULTATION ON THE MOTOR INSURANCE DIRECTIVE

On 24 October 2017, Insurance Europe published on its website its response to the European Commission's Regulatory Fitness and Performance (REFIT) review of the Motor Insurance Directive (MID) (2009/103/EC). The MID abolished border checks on motor insurance within the EU and obliges all motor vehicles in the EU to be covered by compulsory third party insurance. The REFIT programme reviews legislation with the aim of simplifying EU law and reducing regulatory burdens without undermining policy objectives.

Insurance Europe views the MID as an essential tool in the protection of road traffic accident victims and any amendment to the MID should not reduce the high level of protection it provides. According to Insurance Europe, the MID is already fit for purpose for connected and autonomous vehicles and these should not be excluded from its scope.

Insurance Europe also opposes the standardisation of claims history statements on the grounds that it would complicate third party liability insurers' business without bringing real added value to drivers. It also supports rules to ensure that access to in-vehicle data is independent from vehicle manufacturers, as this is becoming increasingly important due to the increasing connectivity of vehicles.

Insurance Europe's response and press release are here and here.

INSURANCE EUROPE WELCOMES THE GEAR 2030 REPORT ON THE EU AUTOMOTIVE INDUSTRY

Insurance Europe has welcomed the recommendations made by the European Commission in the recently published "Gear 2030" report on the future of the EU automotive industry. In particular, Insurance Europe welcomed the report's conclusion that the Motor Insurance Directive will continue to play a key role in the protection of victims of road traffic accidents, but notes that more work will need to be done in the regard. The report's conclusions on automated and connected vehicles in respect of data storage and access in circumstances surrounding accidents was also welcomed by Insurance Europe. However, they expressed disappointment that the report does not recognise more explicitly the need for EU action to ensure consumers are in a position to decide who can access their in-vehicle data and for what purposes.

The "Gear 2030" report is here.

Insurance Europe's statement is here.

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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