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Requirements known no delays

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  1. Towards 2013 and beyond – the ILAG view (to 11 September 2012) Direction of travel Narrative Solvency II/ Omnibus II – Further delay announced on Omnibus II now forecast for 20 November with discussions focussing on discount rates. FSA website confirms they are tracking progress to see if it impacts the implementation plan for the UK. EU Commission have been asked to undertake impact assessment on 2014 implementation and benefits of delay until 2015. On 9 August FSA asked a sample of firms using the standard formula to calculate their capital requirements under the SII. Responses were requested by 28 September 2012. A Towers Watson survey of the risk calibrations applied to Solvency II internal models in development by UK life insurers has shown that many companies regard themselves as still having considerable work to do to validate and document risk measures. Specific market and non-market risks that are seen as presenting the biggest validation challenges include interest rates, credit spreads and mortality and lapse assumptions. Nil of note. ILAGs PPG is reviewing the simplified products proposals and responding. Summaries of IMD and PRIPs directives issued to ILAG members here. UCITs consultation on investment funds issued by EU Commission will be reviewed by ILAGs Regs PG and IPG A meeting has been held between representatives of ILAG, ABI, TISA, and other interested parties concerning the Government’s small pension pots activities. Further meetings are planned. FSA have reviewed sales practices in salaried environments, principally in Banks at present, where incentives are not felt to be in customers interests. Key Serious delays/ unknown outcomes Nil of note Delays/some unknowns A team from ILAGs PPG and ILAG Board EU sub group are meeting HMT on 27 September to discuss the possible extension of Test Achats to age and disability via the Discrimination Directive. The team will be ensuring Treasury officials are aware of the reasons why loss of either age or disability as an assessment factor would be catastrophicfor theUK Life and Longevity insurance industry and more importantly would severely restrict the affordability and availability of cover for consumers. EU pushing Ireland to advance Data Protection changes during its 6 month Presidency (from January) Requirements known no delays improving worsening No change French Trust Tax - some details are emerging although some of the practical implications remain unanswered. ILAG’s Tax PG is reviewing developments. HMRC consulting on bilateral agreement with US on FATCA. Response required by 23 November 2012.