摘要：The purpose of the Solvency II Directive is to strengthen the Single Market in insurance
and reinsurance services through a harmonised prudential framework which delivers a
high standard of policyholder protection. Within Solvency II the Commission¡¯s
proposals for group supervision, including the group support regime, can make a major
contribution to achieving this goal.
The Commission¡¯s proposals are innovative and have as a result attracted a great deal of
comment. They provide for a new model of group supervision which balances the
traditional regulatory view of an insurance group as a collection of separate legal entities
with an economic perspective which views the group as an integrated whole across
which risks are pooled and diversified.
These proposals will allow diversification effects at group level to be realised and lower
the costs of regulatory capital. This will support the objective of the Solvency II Directive
to strengthen the international competitiveness of EU insurers and reinsurers. The
potential for diversification effects at group level to provide greater financial stability is
outlined in this discussion paper.
Ultimately, the proposals should promote better regulation and encourage more
effective group supervision. This will be critical to achieving the high standards of
policyholder protection required by the Solvency II Directive. HM Treasury and the FSA
strongly support the Commission¡¯s proposals on group supervision. However, some
understandable concerns have been raised and this document seeks to addresses them.
It also puts forward some proposals to enhance the group support regime further.
Central to the proposals put forward is the establishment of colleges of supervisors for
groups operating on a cross-border basis. Colleges can benefit both the supervisory
authorities and insurance groups. They provide a platform for information sharing and
co-operation; the college structure can contribute to the overall coherence of group
supervision. Crucially, participation in the college enables supervisors to have oversight
of the group¡¯s activities as a whole, enhancing their capacity to supervise the entity
located in their jurisdiction.
It is critical that group supervision operates effectively for supervisors of
subsidiaries whose parent company is in another Member State or in a third country.
The size and openness of the UK¡¯s insurance markets means there are many such
subsidiaries operating in the UK, writing a large volume of business. It is vitally
important for policyholders that the requirements of the group support regime deliver a
regulatory framework which is robust and effective including in stressed conditions that
could affect the parent or subsidiaries within a group.
Solvency II provides an opportunity for the EU to set a global benchmark in prudential
regulation of insurance through an economically realistic, market consistent and highly
transparent approach. In essence the proposals on group supervision are the
application at group level of the sound general principles elaborated in the framework
Directive, especially the recognition of diversification effects at group level as well as at
solo level.
