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FEE overall supports the proposed EIOPA guidelines on the System of Governance, on Forward Looking assessment of the undertaking’s own risks (based on the ORSA principles), on the submission of information to National Competent Authorities (NCAs) and on the Pre-application for Internal Models. Furthermore, FEE agrees with the results of the Impact Assessments performed on each of the four aforementioned areas.
The implementation proposals remain consistent with previous EIOPA consultations therefore previous FEE comments submitted in this respect remain valid.
Finally, FEE would like to reiterate the importance of addressing the users’ expectations by recommending harmonisation of the requirements for independent assurance on regulatory disclosures for insurance undertakings in the European Union under the Solvency II framework. The role of auditors includes increasing confidence in information by providing independent assurance. One of the objectives of Solvency II, through Pillar 3, is that market discipline can play an important role in regulating behaviour. In order for the market to impose discipline, it needs good quality, reliable information.
The assurance process provides independent challenge to the judgements involved. It can also increase the attention placed upon that judgemental information by senior management and ensure that the processes involved in generating that information are more robust.