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Speaking at the Insurance Risk Europe conference, in London, Jarl Kure also expressed concerns about EIOPA's ability to ensure a consistent application of the interim guidelines, saying the regulator's tools were "not very strong".
In its final version of the interim guidelines published last week, EIOPA scrapped the quarterly report insurers would have to file at the end of December 2015 and lengthened the deadline for firms to make an annual dry-run as of December 31 2014 by two weeks to more than five months after year-end.
Insurers responded positively to the concessions to mitigate the burden of reporting on parallel running regulatory regimes during the preparation period. Initial proposals for the guidelines were criticised for being too burdenson and overly precriptive.
Tom Wilson, group chief risk officer at German insurer Allianz, said the interim measures were an opportunity for insurers to adjust to a new regulatory regime in a less pressured environment. But he urged EIOPA not to impose any additional measures on insurers between the passage of Omnibus II, the Directive that will amend Solvency II, and the full implementation of the rules in 2016.
But some claimed EIOPA should have gone further in reducing the burden on insurers. Olav Jones, insurance trade federation Insurance Europe's deputy director-general, said he was pleased that EIOPA had made clear that the guidelines should be applied in a proportionate way and that no quantitative reporting linked with Solvency II pillar I elements will be required before 2015. This, Jones said, should allow time for EIOPA to publish technical provisions on a number of items, including the valuation of assets and liabilities, and non-technical provisions, the calculation of the Solvency Capital Requirement (SCR) and guidance on the assumptions underlying the standard formula calculation. But EIOPA should have explained more clearly that the application of the guidelines by supervisors and insurers should be on a best-effort basis and deemed the requirement for narrative reporting inappropriate, Jones said.
There are also concerns about how consistent national supervisors will be in implementing the interim guidelines in 2014. National competent authorities have discretion to comply or explain why they do not intend to do so. In some cases, regulators lack the competence to enforce the rules by themselves and rely on new laws being passed.
The European Commission on Wednesday put forward a long-awaited second quick-fix Directive to push back the start date of Solvency II officially by two years. Solvency II will now officially apply from January 1, 2016. Member States will have to transpose the rules into national law before January 31, 2015.
In a statement, commissioner Michel Barnier said this was the last time Solvency II would be postponed. "We have done this only after obtaining assurance from the [EU] Council and the [European] Parliament that they would not further change this new application date of Solvency II."
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