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De Nederlandsche Bank (DNB) has asked insurers to develop an ORSA by the end of 2012 as part of its voluntary pilot test. It expects to receive 70 reports and is planning to provide feedback in the first quarter of 2013
Boke de Pater, senior consultant at Towers Watson in the Netherlands, said despite the expected delay to Solvency II, all insurers and the DNB are sticking to their Solvency II programme schedules.
According to Pater, the development of Solvency II in the Netherlands is a particular challenge for subsidiaries of companies based outside the country. "There has been a lot of discussion between head offices based in a country where the progress is slowing down and Dutch subsidiaries. The head offices don't understand the effort in pillar 2 and feel forced by their subsidiaries because there is further development in the Netherlands", he said.
Only a handful of Dutch insurers are implementing a partial internal model for Solvency II and Pater expects those to be approved in 2013. "The gap between countries that are more prepared for Solvency II, such as the UK and the Netherlands, and other countries that are less prepared will only increase now because of the delay rumours. Dutch insurers are pushing ahead with pillar 2, while other countries are slowing down", he added.