May an insurer use a single ORSA (single ERB in 2015) for both the group and its insurance entities and how can an insurer apply for use of a single ORSA?
Under Solvency II, insurers have the option to submit one report (the "single" report) for both the group and all its insurance entities. The single report must be sufficiently transparent about both the group and the insurance entities. It should be noted that this application only concerns the report; the requirement under Article 45 remains in force.
As regards the Own Risk Assessment (Eigen Risico Beoordeling – ERB), an insurer may produce a "single ERB" for both the group and its insurance entities, already in 2015.
DNB informed you by letter of 18 June 2014 (reference number 2014/507815) about the legally required ERB for insurers. As indicated in the letter, an insurer may produce a single document from 2015 to report on both the group and its insurance entities (the "single ERB"), subject to prior approval by DNB. Insurers can apply for the single ERB using the "single ORSA" application form.
Who can apply?
In principle, every insurer (group) is entitled to apply for the use of a single ORSA. The option of producing a single document applies both to national and international insurance groups.
When can you apply?
DNB allows insurers to submit their applications from 1 April 2015.
We request that you use the attached application form (in Dutch) for this application. You may use this form for both the single ERB and the single ORSA. The form sets out the documentation required for our assessment. In addition, we request that you use DNB's e-Line to submit your application (see Applications - general).
How can you submit your application?
The required information can be submitted electronically using DNB's e-line application form (see Applications - general). Before submitting your application, please contact your examining officer.
If you wish to use the option, please send us a "prototype" group report setting out:
- the insurance entities included in the proposed set-up (scope);
- the treatment of the entities in the proposed group report and how transparency about them has been ensured;
- the interrelationships and considerations made for the group report for entities that are small in the context of the whole group, but that are or may be important to some supervisory authorities/countries;
- how the policymakers of the insurance entities within the scope of the report are involved in the ORSA process and ORSA approval;
- if applicable, the relevant language and any report translations needed.
You may also use a single ERB that you prepared at an earlier stage separately adding details on the above-mentioned questions.
The first step in the assessment procedure is verifying whether the application is complete. As soon as the package is considered complete, the substantive assessment commences. An assessment of an application for a single ORSA for international insurance groups may include the involvement of supervisory authorities from other countries. We point out that where a single ORSA is permitted and submitted, it will be shared with foreign supervisory authorities concerned in accordance with Article 246 of the Solvency II Directive.
Changeover from ERB to ORSA
By using the European guidelines to assess your application, DNB aims to make the changeover to Solvency II as smooth as possible. Given that approval of a single ORSA concerns legislation that is not yet effective, this can only be done through a pro forma decision. On the assumption that other relevant circumstances and insights will remain constant, DNB will convert the decision into a formal approval of the single ORSA, without any additional effort by the institution being required.
The decision on the use of a single ORSA must be taken by the supervisory authority, possibly in consultation with the College of Supervisors, within a six-month period.