On 17 January 2011, the FSA updated the part of its website related to Solvency II to comment on the level 3 pre-consultation process. The FSA notes that, given CEIOPS is not able to conduct a public consultation on proposals for level 3 text until after the level 2 implementing measures have been published by the European Commission, CEIOPS has agreed that it can conduct some pre-consultations.
The pre-consultation will only be provided to a small number of entities, including the European Insurance and Reinsurance Federation (“CEA”), CRO Forum, Amice and Groupe Consultatif. The pre-consultation on reporting and disclosure will also be sent to CFO Forum and the Fédération des Experts Comptables Européens. Firms should get the level 3 pre-consultations from their trade bodies. For example, the Association of British Insurers will receive these from the CEA and plans to make them available to members. If an insurer is not a member of a trade body, it can also request the papers from its usual supervisory contact. The website states the following pre-consultations, which commenced in December 2010 and are currently open, will end on 11 February 2011:
- use test;
- profit and loss attribution; and
It also notes that the following pre-consultations will end on 18 March 2011:
- system of governance; and
- guidelines on the own risk and solvency assessment.