Teradata

For the past several months, Teradata Corporation has been researching Solvency II with the goals of (1) developing a better understanding of how the new legislation will impact the U.S. insurance industry at large and (2) developing a position on Solvency II that can be shared with its insurance partners. The companies most interested in the development of Solvency II are U.S.-domiciled companies with operations in the European Union (EU) today.

A group of North American-domiciled companies united in 2003 as the Group of North American Insurance Enterprises (GNAIE). Initially formed to review Draft Statement of Principles for Accounting (DSOP), GNAIE has added Solvency II to its agenda due to its presence in the EU and the impact it will have on its European operations. These companies have a vested interest in the legislation and have taken an active role through their Solvency II Committee to stay current with all developments. Its focus is on the impact of Solvency II on international standards, state regulators, and the international standards being proposed by the IAIS, or International Association of Insurance Supervisors. At its founding, the group consisted of twelve companies and now numbers eighteen:

• ACE Limited
• American International Group
• The Allstate Corporation
• AXIS Capital Holdings, Ltd.
• Genworth Financial, Inc.
• Hartford Financial Services Group, Inc.
• Lincoln Financial Corporation
• Manulife Financial Corporation
• MetLife, Inc.
• New York Life Insurance Company
• PartnerRe, Ltd.
• Principal Financial Group
• Prudential Financial, Inc.
• RenaissanceRe Holdings, Ltd.
• State Farm
• Sun Life Financial, Inc.
• Travelers Property Casualty Corporation
• XL Capital, Ltd.

The companies listed here have no official involvement with the groups in the EU that are drafting the new legislation. However, they do write abstracts to comment on issues that they disagree with. The Solvency II drafting groups (See Figure 1.) do not officially have to take U.S. views into consideration, but welcome GNAIE input.

GNAIE has broadly identified several areas of concern with the new legislation.

• Solvency II might be creating an uneven regulatory playing field leading to unfair competition (no regulatory equivalence).
• There is no clear definition for group structure and supervision. The U.S. does not have group supervision.
• Group capital equivalence – Capital has to be held by the entity in the EU so the assets of the parent company do not count.
• Non-European companies writing the same type of business want to be treated identically from a solvency standpoint, regardless of domicile.

It is interesting to note that during the writing of this document two member companies American International Group and the Hartford Insurance Group, have suffered failures due to either their counter- party swap practices or investment portfolio holdings, and others are beginning to seek additional funding through the sale of stock to strengthen their balance sheets. While the initial focus of this document is not to determine whether or not the evolving legislation could have averted the failures (i.e., via a market consistent valuation of assets and liabilities), this will certainly become the focus of the GNAIE organization, as well as U.S. regulators and rating agencies in the future.

Solvency I was developed for the EU countries in the 1960s to provide a standard for monitoring the economic capital to be held by an insurer. Inadequacies in the formula to calculate an insurer’s capital requirements caused insurers to go beyond the requirements of Solvency I with their own internal models. Solvency II, which is currently being developed, will provide a system that better matches the risks of insurers and is targeted for implementation in 2012. The drafting groups and insurance industry participating groups for the new legislation are listed in Figure 1.

The goals of Solvency II include a risk-based evaluation based upon market values, enhanced risk management requirements, and the creation of a level playing field in Europe between banks and insurers through the introduction of a comparable and transparent regulation. Modeled after Basel II, Solvency II uses a three-pillar structure. Pillar I, capital adequacy, has two tiers: a Solvency Capital Requirement (SCR) and a Minimum Capital Requirement (MCR). The SCR reflects a company’s target solvency requirement, and the MCR reflects a company’s minimal capital requirement, which if inadequate, invokes supervisory controls, which are defined in Pillar II. Pillar III represents the reporting and disclosure requirements to reinforce market discipline.

The Risk-Based Capital (RBC) standard used in the U.S. and the EU’s proposed Solvency II share the same goal of protecting policyholders and strengthening insurers through sound regulation. At the same time as the development of Solvency II in the EU, the RBC method in the U.S. is evolving into a more Principles-Based Approach (PBA). But, they differ in their focus – Solvency II is focused on an enterprise-wide view of risk while the RBC calculations used in the U.S. focus solely on the adequacy of capital. In contrast, Solvency II takes a top down approach based upon the identification of high-level principles and a clear structural framework which monitors risk across the enterprise, while U.S. insurers use a bottom up approach, setting the standards for one product group at a time. Time will tell whether U.S.-based companies’ risk management procedures will compare favorably with Solvency II or not.  

The ten key messages and objectives of the European Insurance Industry for Solvency II are outlined by the Comité Européen des Assurances (CEA):

1. To align capital requirements with the underlying risks of an insurance company.
2. To maintain strong, effective policyholder protection while achieving optimal capital allocation.
3. To develop a proportionate, risk-based approach to supervision with appropriate treatment both for small companies and large, cross-border groups.
4. To provide incentives to insurers to adopt more sophisticated risk monitoring and risk management tools – this would include developing full and partial internal capital models and increased use of risk mitigation and risk transfer tools.
5. To achieve a harmonized approach to supervision across all EU markets – this will help to ensure there is a level playing field for all insurers and should provide a common standard of protection to all consumers regardless of the insurers’ legal form, size, or location.
6. To increase competition within EU insurance markets and the global competitiveness of EU insurers – reducing or removing unnecessary regulatory constraints and adopting a coherent ‘lead supervisor’ approach for pan-European Groups. This will provide more choice and a better deal for EU consumers, and also enable EU insurers to compete more effectively in global insurance markets, in line with the Lisbon agenda.
7. We believe Solvency II must be built on a true risk-based economic approach if the objectives above are to be met. Assets and liabilities, including those with options and guarantees, must be measured and valued as closely as possible to their true economic value and should be reconcilable to the values provided in the accounts. The solvency capital requirement (SCR) must underpin a high level of confidence that insurers will meet their obligations even in adverse circumstances.
8. Solvency II should introduce a holistic approach to policyholder protection: risk measurement by the firm in Pillar I, qualitative review by supervisors in Pillar II, and improved disclosure to the market and other stakeholders enhancing economic discipline in Pillar III.
9. Pillar II is a cornerstone of the Framework, bringing the insurance industry and the supervisors closer to each other: Solvency II is a challenge to both parties who will need to work constructively as part of the supervisory review process and develop the necessary skills for the framework to be effective in assessing and encouraging robust internal controls and risk management. This qualitative review and any remediation measures proposed should be arrived at in a consistent manner across companies, jurisdictions, and over time.
10. Solvency II should reflect the way companies manage their businesses today and tomorrow. In a truly risk-based solvency system, due account should be paid to measures introduced to reduce and transfer risk, with full recognition of diversification effects.
    
    Shamieh, Charlie. “Solvency II – Understanding the Process.” CEA, Article 257, February 2007. 

Solvency II Legislation
Solvency II is was first scheduled for implementation in 2011. The quantitative impact studies – QIS1, QIS2, QIS3, and QIS4 – have delayed the implementation by one year to 2012. The implementation process with the major initiatives is depicted in Figure 2.

QIS1, 10/2005 to 03/2006, created the definition for the fair value of assets and liabilities. It was completed in March 2006, and it determined that insurers would need to:

• Implement advanced modeling techniques.
• Access more data than was currently captured.

QIS2, 06/2006 to 10/2006, reviewed alternatives for calculating the fair value of liabilities, including MCR and SCR. The study indicated that there was inconsistency in the calibration for MCR and SCR, and participating insurers requested more guidance. QIS3, 04/2007 to 06/2007, was a continuation of QIS2, and it provided additional tests for SCR and provided a new formula for the calculation of MCR. QIS4, 04/2008 to 06/2008, was a continuation of QIS3, and its goal was to encourage insurers to prepare for Solvency II and to further fine tune the calculation for the MCR formula. More than 1,400 insurers participated and, according to the study, the balance sheets of European insurers and reinsurers will not change dramatically under Solvency II. According to The Committee of European Insurance and Occupational Pensions Supervisors (CEIOPS), the vast majority of participants will meet the minimum and solvency capital requirements. There will be more studies coming after QIS4 that will be focused on the group as opposed to company level.

At the time of this writing, it is likely that the implementation of Solvency II will probably be delayed another year. A recent article by Richard Miller in Business Insurance indicates that an argument over capital allocation might mean a 2013 implementation. "To the dismay of the European insurance association, the draft Solvency II framework directive has hit a snag over the issue of group support, which in all likelihood will require the European Parliament and [European Economic and Financial Affairs] Council to work out a compromise early next year… The French government, which currently holds the rotating presidency of the European Union [and heads the Council], recently proposed that the directive’s group support section be deleted."

Group supervision represents one of the cornerstones (Pillar II) of Solvency II, so the outcome of this dispute is important to the implementation of the legislation.

Teradata had been working in the banking sector on Basel II during the 2004 through 2006 timeframe. The purpose of Basel II is to ensure that capital allocations are more risk sensitive, to separate operational risk from credit risk, and to align economic and regulatory capital.

We view Solvency II as an extension of the Basel legislation; both use a three-pillar concept to promote stability in the financial system. Pillar I defines a company’s minimum capital requirements. Pillar II defines the supervisory review process, and Pillar III outlines regulatory and reporting transparency. Over the past four years, Teradata has worked with its banking clients to enable them to leverage their data on a very granular basis to satisfy Basel II requirements. The Teradata® Financial Services Logical Data Model (FS-LDM) provides the foundation for the implementation of an Enterprise Risk Management (ERM) solution. As with the banking industry and Basel II, Teradata has made recent additions to its FS-LDM to support the insurance industry by adding the data attributes and entities required for ERM and Solvency II processing and reporting on an enterprise-wide level. Implementation of a data warehouse that provides a single view of the enterprise across all lines of business satisfies all of the data concerns identified in the next section.  

The Solvency II interviews, which were conducted in the July through August 2008 timeframe, resulted in feedback that fell into several categories, including organizational views about GNAIE, individual institutional views, actuarial, accounting/finance opinions, and data related implications. The following Solvency II-related questions were used in each of the interviews to provide consistency in the topics covered:

1. How will Solvency II facilitate the convergence of international risk management regulatory standards as well as others, for example, accounting standards?
2. How do you see the NAIC, as well as the state insurance regulatory bodies, viewing Solvency II? Do you see Solvency II being viewed as a proto- type for oversight in the U.S.?
3. What parallels do you see between the Basel II and the Solvency II regulatory standards?
4. Do you see the ultimate harmonization of capital requirements across the banking and insurance industries for similar products?
5. What are the major third-country (non-European) insurance issues?
   Level regulatory playing field causing competitive advantages for EU companies, for example diversification credit to determine solvency ratios for capital allocation.
• Supervisory Structure – no clear cut roles and responsibilities.
• Regulatory equivalence – How do you see, over time, non-EU regulatory structures evolving? If the capital standards evolve in different directions, how will this be addressed?
• Holding company concept – Is the formation of a new insurance entity composed of non-EU companies feasible?
6. How will the pressure from Solvency II compare with the pressure from rating agencies for improved risk management processes?
7. Do you see Solvency II as a catalyst for improved risk management practices as well as other standards, for example, accounting standards?
8. Do you envision that Solvency II will specifically upgrade the quality of risk management related to:
• Increased need for transparency?
• A structural framework to monitor risk across the enterprise?
• Broader scope of data/company information?
9. What do you believe will be the time frame for the introduction of Solvency II into U.S. operations? How much of the work for the EU will U.S. companies be able to leverage?
10. What impact do you see that Solvency II will have on the type of business in which insurance companies engage?

Our interviews covered life as well as property and casualty companies. The interviews, regardless of the individual’s focus, reflected many recurring themes and issues. These are listed in two categories – Common Themes and Data-Driven Issues.

• The implementation of Solvency II will be similar to the effort involved for Basel II compliance and expect that the IT spend will be similar.
• Solvency II is a reality and will impact not only those companies with operations in the EU (third countries), but also the U.S. industry at large.
• Even though Solvency II principles are in flux, all insurers need to understand the ramifications of the coming changes in advance of their adoption in 2012.
• Solvency II relies upon market consistent valuation of assets and liabilities and could demand additional capital be held for a risk even if there is no perceived threat to solvency (i.e., company may feel that a risk is properly hedged).
• Solvency II will contribute to the formation of separate holding companies in the EU to address capital holding requirements.
• Solvency II could contribute to a global standard for enterprise risk management, industry oversight, and accounting practices, particularly in the absence in the U.S. of a standard methodology for economic capital.
• Differences in capital allocation between a U.S. insurer and European insurer could result in decreased profitability for U.S. insurers for similar products.
• Solvency II through its supervisory review process (Pillar II), will provide a more holistic view of the enterprise.
• Solvency II will promote closer communication between the currently siloed risk environments common in U.S. insurance companies. 

• Solvency II promotes having data (life and non-life – diversification credit) on a single enterprise-wide risk platform – the data can be reused as opposed to using siloed data or creating new data marts, and companies showing diversified products on a single platform will be required to hold less capital than those showing siloed product results.
• The need for very granular data from across the enterprise as well as all subsidiaries to recreate transactions as needed, particularly for reinsurers who cede business internally.
• Lack of information for risk management (future state risk database with results from stochastic modeling).
• Lack of granularity, particularly required when recreating transactions – siloed environments capable of providing summary level data.
• Data availability – data that have not been routinely captured in the past may be required for Solvency II processing.
• Incomplete capture of risk attributes.
• Transparency with regulators and rating agencies.
• Increased level of information required by regulatory authorities.  

As a result of the data-driven issues discussed, insurers typically do not have good asset, liability, and accounting functionality on one platform. Risk is managed in product silos across the enterprise or not at all. This results in fragmented results, and also will not allow a company to participate in diversification credits for ERM in their capital position and ratings (particularly under Solvency II). In fact, insurers will be blind to diversification credits by not integrating life and non-life insurance on an integrated single platform. This could result in holding too much capital for existing business, and the profitability of a U.S. insurer’s products might suffer in comparison with identical products issued in the EU, where Solvency II will drive a single platform view of business.

This fragmented approach to risk management is not scalable enough to allow analysis of the entire enterprise and typically results in the use of poor quality source data and poor to non-existent data integration between platforms. Results take too long to obtain and are untrustworthy because there are multiple sources of information utilizing different assumptions in different areas of the business. To fully embrace a market-based view that is tempered by economic reality, an insurer will have to consider establishing an enterprise-wide view of their data across all business lines and install comprehensive modeling systems.

There was much focus on the convergence of accounting standards into one global standard, and there is evidence that this is already beginning to occur. One actuarial accountant stated that the Securities and Exchange Commission voted unanimously, on November 15, 2007, to approve rule amendments under which financial statements from foreign private issuers in the U.S. will be accepted without reconciliation to U.S. Generally Accepted Accounting Principles (US GAAP) if they are prepared using International Financial Reporting Standards (IFRS) as issued by the International Accounting Standards Board (IASB). As with Solvency II, GNAIE responds to issues with proposed accounting regulations in abstract format. GNAIE does get involved directly with the International Association of Insurance Supervisors (IAIS) group for the international meetings and have conversations with participants of these groups only at the CFO and CRO forums. “If we see something that we feel is wrong, we tell them, but usually in abstract form as there is no official involvement with the Solvency II groups. [We] interact via abstracts, but the Solvency II drafting groups do not have to take U.S. views into consideration.” The drafting bodies in the EU welcome the GNAIE comments, but they have no direct impact on their decisions. GNAIE has a consultant, based in France, who attends meetings and reports back on CEIOPS activities. The drafting bodies involved in Solvency II do not want any U.S. involvement in the drafting process.

That Solvency II is a reality and will have a significant impact on the U.S. insurance industry at large was readily admitted by all interviewed member companies. Even though Solvency II principles are in flux, companies need to understand the ramifications of the coming changes in advance of their adoption in 2012 because significant changes to processes and systems will be required to support its implementation. As a result, many of the member companies within GNAIE have initiated steps to segregate their holdings by creating new corporate identities. “Many are individually forming or contemplating forming holding companies in the EU, because no one really understands how the Solvency II calculations work or which subsidiaries are affected.”

Another reason for the creation of separate subsidiaries in the EU is due to the lack of recognition of a company’s capital holdings. Capital held by third countries, or non-European countries might be considered to be insufficient, because the capital held by the North American parent will not be recognized. The interviews pointed out that most companies are initiating this on their own. There are also concerns about benefits derived by EU countries when doing business abroad as they may be given diversification credit for their portfolios which their non-European counterparts are not. Solvency II might generate a capital requirement for a particular product that is not consistent with U.S. PBA capital formulas or NAIC risk-based formulas. In such a case, a U.S. company’s profit margin might suffer in comparison to its European counterparts. Other concerns include regulatory equivalence and supervisory review, as there is no clear definition of group structure of supervision. GNAIE believes that non-European companies writing the same type of business should be treated identically from a solvency standpoint regardless of domicile.

A major theme of the interviews was a concern that Solvency II could demand that more capital be held in reserve, even if there is no perceived threat to solvency. Some of the companies interviewed hope to be rewarded for the sound risk management practices they have implemented. According to one interviewee, his company “projects forward the value of the firm as well as the risk to that value through the use of a Monte Carlo Simulation [MCS] approach.” His company uses the MCS approach to evaluate the impact of alternate strategies on the value of the firm. “[The Company] performs a multi-year calculation of going forward values for their balance sheet, income statement, and cash flows, and then discounts those values back to the present to answer a variety of risk related questions. [The Company] is working hard to maintain their excellent risk program rating, as well as continue to work creatively to upgrade their risk management practices. A key goal has been to answer the question ‘Are we being compensated for the risk we are taking’?” The increasing attention paid to Solvency II, as well as the drive to improve their risk management program, has increasingly raised the importance of having an integrated data platform to do the calculations described previously.

Solvency II relies upon a market-consistent valuation of assets and liabilities and could require that more capital be held for a risk that a U.S. insurer feels is perfectly hedged or mitigated. This conversation came up in two contexts, variable annuities and mortgage backed securities. A number of companies feel that they might be penalized for what they consider to be perfectly hedged products. And one interviewee felt that a consistent market evaluation of mortgage backed securities would result in heavy write-downs. There is also concern about regulatory decisions from a supervisor in the EU. One interviewee is concerned with intervention and friction with foreign regulators: “Can you imagine a U.S. regulator giving up jurisdiction to a regulator from Ireland or France? Now, I can’t speak for them, but I don’t see how a global regulator from a different country can do it better than it’s done locally.”

With respect to data requirements, Solvency II will drive computing correlations at a granular level between transactions since correlations cannot be made at a portfolio level. There is also much concern with the accounting rules that are linked to Solvency II. The evolving accounting rules will drive increased need for granular data for such things as determining the degree to which balance sheet items are perfectly hedged. “Solvency II will drive computing correlations at a granular level between transactions since correlations cannot be made at a portfolio level. The evolving accounting rules will drive increased need for granular data for such things as determining the degree to which balance sheet items are perfectly hedged.” This granularity is also required for business that is ceded on an intercompany basis so capital can be matched to the appropriate liability. Also noted was the importance of harmonizing the difference between the regulatory, economic, and accounting views that will also require increased data scrutiny and granularity. One interviewee stated that “here is a significant challenge to pull together the data in order to make risk calculations.”

Another recurrent theme had to do with the comparison of the U.S. PBA and Solvency II. While Solvency II is gaining momentum in Europe, U.S. regulators and insurers are moving in a PBA direction for reserving and capital requirements. One interviewee pointed out that “The U.S. has officially kept itself out of the Solvency II initiatives and has not developed a suitable comprehensive alternative.” He went on to say, “The differences between the PBA proposed by Solvency II and the U.S. Principles-Based Approach is hard to compare and is covered by a recent paper by the Society of Actuaries. Solvency II starts higher up and views risk across all lines of business. While Solvency II is very well thought out, the PBA has a ways to go. The challenge with PBA is how to expand it to include credit, market, operational, and insurance risk. The U.S. has kept itself out of the Solvency II initiatives, and U.S. insurers have not developed a suitable alternative. The alternative has to be more than PBA models – it needs to be more comprehensive. There needs to be some consensus in the U.S. to determine if Solvency II will be workable. And, if it will not be workable, what do we agree upon?” He further pointed out that the challenge with a PBA is to ensure that calculations of credit, market, operational, and hazard risk are comparable across firms. While GNAIE companies are aligning themselves to the requirements of Solvency II, many other U.S.-based insurers are taking a passive approach and waiting for U.S. regulators to provide guidance. Even though U.S. regulators are currently revising principles-based valuation and capital requirements, the overriding differences between PBA and Solvency II are significant and will result in differences in the capital requirements for similar products issued by European insurers and U.S. insurers. This difference could impact the profitability of products offered by U.S. insurers in comparison with their European counterparts. There must be additional consensus in the U.S. to determine if Solvency II will be workable. In the absence of that consensus, Solvency II will probably be the leader in the likely global convergence of standards for capital allocation and accounting. 

A number of interviewees cited the positive effects of Solvency II. It was felt that Solvency II might enhance communication between the currently siloed environments in U.S. insurance companies. Most interviewees recognized that risk is calculated across numerous risk silos within the company. “The supervisory review process [Pillar II] should provide a more holistic view of the enterprise. Pillar III should help provide greater transparency to investors and analysts.” And, market analysis of the published data will help identify market, credit, operational, and hazard risks. Some of the responders do not see Solvency II as an imposition, but are concerned about how rating agencies will interpret it. Because Solvency II is very definitive, rating agencies will be more prone to say “show me,” using the Solvency II Use Test. This Use Test is one of the criteria that local regulators use (Pillar II) for solvency model approval.  

The sessions with participating companies have provided a wide range of responses to the standard set of questions used in each interview. Several conclusions can be drawn from these sessions which are readily apparent. First, Solvency II is going to raise the bar for ERM practices for all insurers whether or not they are participating in EU markets. As U.S. insurers move away from a risk-based capital process and embrace a PBA direction for risk management, they will in fact be aligning themselves with Solvency II. This transition will also reflect a change in attitude with respect to risk management, where instead of being viewed by insurers as a set of compulsory detailed rules that must be complied with, it will be viewed as an environment where principles refer to market consistency and economic market realities. This move from a compliance focus to a risk management focus is a cornerstone of Solvency II and is supported by Pillar II, where, again, detailed rules are not used to prescribe measurements for insurers, but rather a market-consistent approach is fostered. The Use Test prescribed in Pillar I will be used by insurers and integrated into the company’s daily approach to ERM. It reflects management’s risk management judgments when applying a PBA to risk management.

The emphasis on a market-consistent approach to ERM will probably require accessing data that have not been available or used in the past. Data that are captured from silos have a negative impact on the ability to make actionable, accurate, and timely decisions that impact a company’s operations and reflect the risk-based capital approach used in the past. An integrated source of data bridges the company’s disparate databases and provides a single version of the enterprise data by utilizing consistent data definitions, eliminating redundant data, and improving overall data accuracy. It also provides data on an integrated and highly granular basis. This granular segmentation capability is a key for determining if the historical and projected performance of risk-related activities is in proportion to the economic capital required to support each activity. The segmentation capability enables the calculation of risk-adjusted performance on a detail level basis and facilitates risk adjusted product pricing.

The same enterprise concept and approach applies to the risk model. There is little value in doing economic capital calculations across the enterprise if they are not done consistently. When fed a consolidated data source (the data warehouse), which represents a single view of the business, the modeling system applies common measurements across the enterprise to project how the business may be impacted in the future. Considerations for the risk model include utilizing a robust economic scenario generator, the modeling of assets and liabilities in the same model at the same time, and the ability to reflect management decisions in the model. The fundamental improvement is the ability to analyze the results and provide rating agencies and regulators an analysis of the risks and a plan with mitigation strategies.

The process must become an integral and frequently used part of the overall management of the company and be monitored constantly via the Use Test. If modeling is a process that is performed once per year to respond to external regulatory requirements, it will be of minimal value in the longer term view of the organization.

Understanding the current position of the enterprise, as well as the different ways an enterprise could be affected by enterprise grade modeling, is essential. What appears to be a requirement with Solvency II is actually an opportunity for insurers to transcend siloed systems and processes and to nurture capital growth, develop enterprise processes, and active decisioning. Companies that embrace an enterprise approach to risk management and implement the strategies and technologies required to manage it will not only exceed their compliance and regulatory requirements in both depth and breadth, but also establish a strong competitive advantage.

It is more than a mere aggregation of individual risk metrics – it truly needs to become an enterprise-wide approach to the discipline of risk management. Solvency II will be the catalyst that promotes the use of a PBA for risk management and rewards companies for using modern techniques to monitor their business.

The question to be asked after reviewing the goals of Solvency II and the results of the interviews is, “Could U.S. insurers satisfy the minimal and capital solvency requirements today and will they be able to in 2012/2013?”  

Clark, Matthew. “Solvency II – The U.S. Perspective.” Contingencies. March/April 2008.

Zolkos, Rodd. “The Song of Solvency.” Industry Focus. September 17, 2007.

Friedman, Elinor, Mueller, Hubert. “A Principles-Based Reserves and Capital Standard.” Emphasis. March, 2006.

Hunter, Lawrence A. “The Era of Re-regulation is Upon Us.” Insurance Journal. October 20, 2008.

Shamieh, Charlie. “Solvency II – Third Country Issues.” GNAIE. June, 2007.“Solvency II – Understanding the Process.” CEA, Article 257, February, 2007.“AIG knew of potential problems in valuing swaps.” Wall Street Journal. October 13, 2008.

Veysey, Sarah. “Solvency II amendments favor captives, stress proportionality.” Insurance Journal, October 20, 2008.

Miller, Richard. “E.U.’s Solvency II might be delayed.” Business Insurance. November 24, 2008.

European Web Sites:
European Commission
http://ec.europa.internal_market/insurance/solvency2/index_en.htm

EIOPC
http://ec.europa.eu/internal_market/insurance/committee_en.htm

CEIOPS – Committee of European Insurance and Occupational Pensions Supervisors http://www.ceiops.org  
CEA – Comité Européen des Assurances
http://www.cea.assur.org  

National Insurance Associations
Links can be found on the CEA website, click “Members”

CRO – Chief Risk Officer Forum
http://www.croforum.org   

Groupe Consultatif – Groupe Consultatif Actuariel Européen
http://www.gcactuaries.org

AISAM – Association Internationale des Societes d’Assurances Mutuelle
http://www.insurance-mutuals.org

ICISA – International Credit Insurance and Surety Association
http://www.icisa.org