On 19 December 2016, the Central Bank of Ireland (the "Central Bank") published its final Insurance Quarterly Newsletter for 2016 covering regulatory developments on a domestic and European level since September 2016.
Amongst other items, the Central Bank reports on its recently-published 'Cross Industry Guidance in respect of Information Technology and Cybersecurity' and states that feedback on the related questionnaire completed by Medium High and Medium Low undertakings will be provided in Quarter 1, 2017. In addition, the Central Bank highlighted the need for auditors of High Impact undertakings to complete work in accordance with the Auditor Assurance framework and reminded that the auditors concerned must also submit an assurance report and a "review and recommend" report under section 27BA of the Central Bank Act 1997 by 30 June 2017.
The Central Bank also made a clarification regarding Collective Investment Undertakings (CIUs) in its related Information Note published in April 2016 noting that:
- (re)insurers should be fully compliant with the relevant Solvency II regulations regarding the CIU reporting template;
- the look-through approach should be performed until all asset categories, countries and currencies are identified; and
- the relevant EIOPA Guidelines advise that (re)insurers should perform a sufficient number of iterations of the look-through approach to capture all material risks.
The Central Bank also reports that although there is an improvement in the quality of data received through Solvency II reporting, (re)insurers are asked the following questions concerning their data governance:
- What controls are in place 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?
To view the Central Bank's Insurance Quarterly Newsletter in full, please click here.