On 19 September 2013, the Central Bank of Ireland issued a consultation paper (CP73) on reserving and pricing for reinsurers (life, non-life and composite) and non-life insurers. CP73 proposes to place the obligation of the insurer/reinsurer to submit an annual statement of actuarial opinion (SAO) to the CBI, and related matters, on a statutory footing. The proposals include requirements as to the basis of the SAO and the governance arrangements to be in place in relation to reserving (these include specific obligations on boards of directors and the internal audit function). Notably, the role of a signing actuary will, if CP73 is implemented in its current form, be designated a Pre-Approval Controlled Function under the CBI's Fitness and Probity regime. Further, it will be necessary for the signing actuary of a high impact firm to be an employee of the firm. The closing date for submissions on CP73 is 10 December 2013 and the CBI intends entities subject to the proposed requirements to be in compliance for the financial year ending 31 December 2014.