Dear Alex, dear all,
Here are a couple of tentative comments on the “health” part of the
CAT template.
General comments
-
The general structure of the template supposes that the net capital
charge equals the gross capital charge + effects of risk mitigation. Although I
agree that this information is useful, I’m afraid that such labels might be
misleading, as the “net capital requirement” is generally understood as “net of
the LAC of TP and DT” (and not “net of risk mitigation”). Therefore I suggest
that the relevant columns are labeled “gross SCR before risk mitigation” and
“gross SCR after risk mitigation”, in order to avoid any
confusion.
-
Concerning the diversification effect between countries, may I
suggest that:
o
The total capital charge before diversification remains as it
is
o
The total capital charge after diversification is either filled in by
the undertaking, or calculated using the square root of sum of squares
formula
o
The diversification effect is calculated as the difference between
“capital charge after diversification” and “capital charge before
diversification”
Comments concerning the “mass accident” table
-
May I suggest to replace (in all relevant columns) “value of benefits
payable” by “total value of benefits payable” (just for
clarity)
Comments concerning the “pandemic” table
-
The separation between “income protection” and “medical expense”
could be made clearer. For instance, may I suggest that we
have:
o
two columns “income protection | number of insured people” and
“income protection | total pandemic exposure” on the one hand (same scheme as
for each risk of the “mass accident” scenario)
o
seven columns on the other hand for medical
expense
§
“medical expense | number of insured people”
§
“medical expense | unit claim cost
hospitalisation”
§
“medical expense | expected number of uses
hospitalisation”
§
“medical expense | unit claim cost medical
practitioner”
§
“medical expense | expected number of uses medical
practitioner”
§
“medical expense | unit claim cost no formal medical
care”
§
“medical expense | expected number of uses no formal medical
care”
-
In the last L2 text, no diversification is foreseen between countries
(the capital charge is a mere sum on all countries). Therefore I would suggest
to delete the lines on “diversification”.
Kind regards,
Aurélien
De :
Alexandros Ntelekos [mailto:Alexandros.Ntelekos@fsa.gov.uk]
Envoyé : lundi 26 mars 2012 18:26
À :
Sejal
Haria; Peter Ter Berg (DNB); Cook, Ian; Helen Bradley (Guy Carpenter); Anthony
Brown; COSMA Aurélien (UA 2774); BROWN, Geoff; alan_lockie@swissre.com; Maynard,
Trevor
Cc : Marjan Trobina; Daniel.Perez@eiopa.europa.eu; Romain
Labaune; Nikolaos Petalas; Zulfiya Samieva; H.J.G.Hendriks@DNB.NL; VOIGNAC
Laurent (UA 2776); Olaf Ermert
Objet : CATsg - Catastrophe
templates workgroup
Importance :
Haute
Dear CATsg
members,
I am contacting you
once more to ask for your contributions on an issue that EIOPA and the SCRsg has
requested that we have a look at: The catastrophe reporting templates. I have
already mentioned this at our last meeting but I now can be more concrete on
what is required from us.
The catastrophe
reporting template is effectively an excel spreadsheet along with an explanatory
document that undertakings will use to report their SF results to supervisors.
Harold (cc'd above,
H.J.G.Hendriks@DNB.NL) has already
done a magnificent job in putting this template together. The template has been
through public consultation with the industry and comments have been received.
The SGRsg has discussed these comments and is now asking the CATsg to have a
look at the template and at the comments and to provide feedback on the
template.
Following some
discussions with colleagues I have decided to put together a workgroup to have a
look at this issue with a view to discuss and close in the May meeting of the
CATsg in London. If you are in the to list of this email you are a member of
this group and I would like to ask for your
contribution.
This should be a
relatively straightforward exercise: All we need is for everyone to look at the
relevant part of the template (e.g. Ian at the nat-cats, Helen on liability,
Geoff-Alan-Aurelien at the health, etc) and the Log (see below), see
whether they are happy with the information requested (clarity, granularity etc)
and the relevant description in the log and then contrast with the high
level comments received from stakeholders. You should then send any
comments to Sejal who will be leading this group and will collect
the comments prior to the next meeting. I am keen on circulating any
comments of the workgroup and the templates to the wider group as soon as
possible so I would ask Sejal to pass these to me at least a coupe of
weeks prior to the next meeting.
I am attaching here
three documents:
1. The actual
catastrophe non-life template (spreadsheet)
2. The consultation
Log (a key for each cell mentioned under each sub-module in the
template)
3. The highlighted
issues from the public consultation process (high level comments from
stakeholders)
If you have any
questions about the template please feel free to contact Harold or
myself.
Kind
regards,
Alex
Alex
Ntelekos, Ph.D.
General Insurance
Department
Risk Specialists Division
The
Financial Services Authority
25 The
North Colonnade | Canary Wharf | London, E14 5HS
Tel: +44 20 7066
6338
Mob: +44 778 5950 818
alexandros.ntelekos@fsa.gov.uk
www.fsa.gov.uk
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