On 19 December, the Central Bank published its Insurance Quarterly Newsletter. This edition of the newsletter covers regulatory developments at a European and domestic level since September 2016. Many of these issues are covered in this or previous editions of the Arthur Cox Insurance Regulatory Update.
Following on from the issuance of Cross Industry Guidance in respect of Information Technology and Cybersecurity, auditors of high impact undertakings are reminded that they are required to submit an assurance report and a "review and recommend" report under section 27BA of the Central Bank (Supervision & Enforcement) Act 2013 by 30 June 2017.
The Central Bank also made clarifications in relation to an information note in April 2016 regarding the look through of Collective Investment Undertakings (CIUs). Undertakings should be fully compliant with the relevant Solvency II regulations on CIU reporting, the look-through approach should be performed until all asset categories, countries and currencies are identified and undertakings should perform a sufficient number of iterations of the look-through approach to capture all material risks.
The Central Bank conducted an assessment of the quality of the data it has received through Solvency II reporting. Although an improvement in the quality of data has been made, (re)insurers are asked the following questions in relation to their data governance: what controls are in place in your undertaking to mitigate risks to the quality of reporting; to what extent has the review and governance process within your undertaking been either validated or shown to be ineffective; to what extent is there certainty of the integrity of the data from its origin to final reporting?
A link to the newsletter is here.