Comments on Group Consulatif’s proposed guidelines for a “solvency report”

We regard this as an important project for promoting the role of the actuary within the solvency II context, and firmly support issuing this paper.

However we are concerned that these guidelines are interpreted in the correct way. The guidelines are very comprehensive and cover at least most (if not all) of the areas that an actuary should be considering. Naturally it is important to apply some form of “proportionality principle” when using these guidelines, as using the “full set” for a simple/small undertaking is definitely overkill. We believe that there should be some sort of text in the introduction to this effect; otherwise the reader might interpret the guidelines as something that must be applied in full for every company.

It might also be relevant to look at this document in relation to the recent issue paper published by CEIOPS regarding ORSA. Indeed this document emphasizes the importance of “proportionality” as well.

It is clear that the document will also need to be reviewed again, after the directive is finalized, but this can be done in due course.

Other than this we only have a few minor points to make (numbers refer to the appropriate section).

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