Social impact Solvency II

Insurers are actively implementing the Solvency II guidelines, managing them alongside their capital and risk management. The repercussions of decisions in this context will extend beyond the boardroom, affecting the relationships between both individual and corporate policyholders and insurers. These potential consequences have been explored and documented in a report by The Economist Intelligence Unit, involving 254 EU organisations, including insurers, financial institutions, and non-financial institutions.

While the Solvency II guidelines aim to provide better protection for policyholders, various parties are questioning who will ultimately bear the cost of the solvency regime. Simultaneously, there are concerns that insurers will be limited in their role as investors, compelled towards ‘safer’ investments and fewer non-investment loans. This could potentially lead to challenges for capital-seeking organisations, as balance sheet constraints might result in banks ceasing to make investments.

With these questions in mind, The Economist Intelligence Unit commenced its investigation into the potential impact of Solvency II on consumers, the insurance industry, and society, where insurers act as investors.

The key findings and conclusions of this research are:

• The requirements of Solvency II are seen as excessive. Respondents believe that the balance is lost and the demands are too stringent.
• Policyholders will ultimately bear the cost of Solvency II, as insurers will pass these costs on to them.
• Insurers expect to take fewer risks in their investment strategies.
• There is ambiguity among organisations about the consequences for debt issuance.
• Legislators will need to reconsider the capital charges.
• The unintended consequences are yet to be fully understood, causing concern among various organisations.

Although a revision of the current legislation is deemed necessary, the potential consequences and timing of Solvency II are causing apprehension. The current political and economic climate leads many to believe that insurers, policyholders, and other stakeholders will be adversely affected by Solvency II. It is expected that premiums will increase and that investments will be impacted. Whatever the exact outcomes may be, it suggests that insurers seek absolute certainty about the application of the rules and their implementation in these uncertain times.

What is the Relationship

Between SOC 2 and SOC 3?

Guidance for accountants reporting on controls of a service organization relevant to the financial reporting of user organizations was primarily included in SAS 70. This regulation focused on risks related to financial reporting. However, it was often misused for reporting on operations or compliance. The SSAE 16 and ISAE 3402 regulations were established to address these issues.

The AICPA identifies three types of Service Organization Control Reports (SOC): SOC 1 (ISAE 3402 and SSAE 16), SOC 2 (Security, Availability, Processing Integrity, Confidentiality, and Privacy), and SOC 3 (a SysTrust for Service Organizations).

For SOC 3, the AICPA has developed a standard logo.
By offering three types of reports that better meet market needs, the AICPA has effectively addressed several issues that existed with SAS 70.

EIOPA – ComFrame

Gabriel Bernardino, president of EIOPA, expressed his desire for an international insurance market supervisory and legislative body in a speech early this month.

´The insurance market is spreading globally, creating new opportunities, challenges but also risks,´ said Bernardino. Creating a healthy and stable insurance market requires such international cooperation. The best way to ensure financial stability and proper consumer protection is through the development of a global regulatory and supervisory standard.

ComFrame

Efficiency of supervision could improve under ComFrame: Common Framework for the Supervision of Internationally Active Insurance Groups (IAIGs). ComFrame is an integrated, multilateral and multidisciplinary framework for group-wide supervision of international insurance companies, particularly in the area of Solvency II.

To ensure consumer protection at the international level, it is necessary to also improve regulatory capital requirements (Solvency II). This of course takes into account different perspectives and developments worldwide.

Cooperation with regulators at universities would be essential to the IAIG’s approach. Information sharing and cooperation between supervisors would be a defining element of effective supervision.

Mr Bernardino’s plans will require the insurance market to be open to even more structural changes. Besides the changes currently being implemented, the question is whether ComFrame is timely.

In addition, are the possible benefits of an international supervisory and legislative body especially for the DNB and other supervisory bodies (not only in implementing European and International laws and regulations, but also in monitoring them. After all, the capacity problems at the DNB were already present since the advent of Solvency II) or are the benefits also for the insurer and ultimately the policyholder?

Register ISAE 3402

The Corporate Governance Foundation is the driving force behind the ISAE 3402 register. The ISAE 3402 register is a publicly accessible database that lists organisations that have been certified to ISAE 3402. The ISAE 3402 register focuses on reliable partners, provides a platform for companies to showcase their ISAE 3402 certification, and promotes knowledge sharing and development in the field of ISAE 3402.