Wednesday 1 August 2012

FSA's Pillar 2 site - updates on ORSA

So the Wharfsiders have released some material to their Pillar 2 microsite around ORSA, rolling off the back of EIOPA's releases earlier in July. Bearing in mind the ORSA training stats assembled by KPMG on my previous post, I dare say any guidance is good guidance, so I haven't been too precious when making notes on it!

In the Q&A section, they throw few punches (and pull most of those anyway!) when answering on subjective elements such as proportionality, ORSA Report length, Group ORSA scopes and potential use of ORSA report content by the fledgeling FCA. They are however clear that they will expect to see evidence of ORSA Processes in working order in the IMAP package, and that ORSA's are not expected to be generic across the industry.

Meanwhile in the Expert Group presentation (my invite clearly lost in the post!), the slides reiterate the fundamentals (i.e. it's a process that happens to produce a report, not a reporting process), but doesn't shed much more light - I guess you had to be there!

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