The CRO Forum welcomes the opportunity to comment this consultation paper on pre-application process for Internal Model. The timing for this paper is good as many supervisors are already starting a pre-application process and it will promote necessary harmonization. This paper is of high quality and the CRO Forum strongly supports CEIOPS in aiming for one unique pre-application process led by the lead/group supervisor in cooperation with the other supervisors concerned.
The CRO Forum welcomes the opportunity to contribute to the calibration of the standard formula through this paper on market risks. This document is a follow-up to our position papers published respectively last May: ‘Calibration Principles for the Solvency II Standard Formula”; and last December: ‘Calibration recommendation for the correlations in the Solvency II standard formula’.
CRO Forum's response to CEIOPS Consultation Paper no. 17: draft advice to the European Commission in the framework of the Solvency II project on Pillar 2 capital add-ons for solo and group undertakings We welcome this Consultation Paper from CEIOPS. The CRO Forum supports the inclusion of powers for a capital add-on in the Solvency II framework directive. However, we must emphasise that capital add-ons should be seen as a last resort as expressed, for example, in article 136(2) of the EU's Capital Requirements Directive.
While the exercise has highlighted a number of areas which require further consideration and discussion, the CRO Forum believes CEIOPS has achieved an important step in providing this new basis for discussion.
This presentation is based upon the consolidated responses of the Chief Risk Officer Forum and Comité Européen des Assurancesto CEIOPS-CP-03/06, "Draft Advice to the European Commission in the framework of the Solvency II project on subgroup supervisions, diversification effects, cooperation with third countries and issues related to the MCR and SCR in a group context."
The Chief Risk Officer Forum ('CRO Forum') comprises risk officers of the major European insurance companies and financial conglomerates, and was formed to address the key relevant risk issues. It is a technical group focused on developing and promoting industry best practices in risk management.
This presentation is based upon the consolidated responses of the Chief Risk Officer Forum to CEIOPS-CP-06/05, “Consultation Paper No. 9 - Draft Answers to the European Commission on the third wave of Calls for Advice in the framework of the Solvency II project.”