Question ID: 50
Regulation Reference: Guidelines on the Forward looking assessment of own risks
Article: 45
Status: Final
Date of submission: 11 Mar 2014
Question
The first supervisory report on FLAOR, which needs to be submitted to the local supervisor in 2014, does it have to be done with the final reporting data of 2013 or with those data of 2014 (not necessarily the year end data of 2014)?
In the moment, when Solvency II is fully applicable, for example 2018, will the ORSA supervisory report to be done with the year-end data of 2017 (because this will be audited data) or with data (the SCR figures) of 2018?
EIOPA answer
Please have a look at the Final Report on the Forward Looking Assessment which can be found here
https://eiopa.europa.eu/fileadmin/tx_dam/files/consultations/consultationpapers/CP09-13/EIOPA-13-414_Final_Report_on_CP09.pdf
The feedback statement addresses your first question for the preparatory phase, please see page 12-13 “Timing and application issues”.
I would like to put your attention especially to point 3.60:
“Whilst the reference date for the forward looking assessment would under normal circumstances be the same as for a SCR calculation date, this does not necessarily have to be the SCR calculation for 31 December of a particular year but could be a SCR calculation at any time during that year. EIOPA would like to emphasise that it is for the undertaking to decide on the appropriate reference date for its FLAOR.”
EIOPA does not intend to diverge from this principle for the final Guidelines on ORSA. Meaning that here again it is the undertaking who needs to decide on the appropriate reference date for its ORSA.
In addition I would like to recall that the FLAOR (and later the ORSA) supervisory report needs to be submitted to your local supervisor within 2 weeks of the AMSB having reviewed and approved the assessments, see Guideline 10.