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EMEA Captive


Concerns, confusion and commercial carriers


Guenter Droese of ECIROA talks with EMEA Captive about the ongoing discussions surrounding Solvency II.


of Europe’s leading captive association he is concerned about the treatment captives face under current Solvency II proposals outlined by the European Commission (EC) and the European Insurance and Occupational Pensions Authority (EIOPA). As Droese was at pains to make clear, captives appear—for the time being at least—to be being given a low priority in the Solvency II discussion process that is helping to shape the scope and interpretation of the regime.


G “The Solvency II discussion process is meant to have been a


democratic one, but it has so far proven to be far from that,” Droese said. “Instead the process has been very much focused on legal concerns and technicalities, with discussions dominated by those who can afford to invest time, money and manpower to voice to the EC their own particular concerns.”


Smaller and medium-sized players such as captives, mutuals and


niche insurers are struggling to get their voice heard in the process, he said, and have had limited chances to discuss with the regulator their comments on the impending regime. Droese added that there was concern among those within the captive community that while they are being invited to comment, there was no certainty that their


“Our main target here at ECIROA is to get proportionality accepted within the Solvency II framework, which will help to differentiate captives from commercial carriers,” Droese said. “While the EC has accepted in principle that proportionality needs to be applied within the Solvency II framework, they are yet to define exactly what it means and how it will be applied.” Such uncertainty has left captives in a quandary as they consider the likely ramifications of the impending regulatory measures.


Droese said that although captives accept the need for Solvency


II, there is concern regarding the level of sophistication being applied group-wide. He said that there was a hope that regulation would “allow deviation from the highest level of sophistication


uenter Droese, chairman of the European Captive Insurance and Reinsurance Owners Association (ECIROA), is in a combative mood when discussing Solvency II. It is evidently an issue close to his heart: in his role as head


views were being given sufficient consideration. “It seems that there are some high-level people discussing Solvency II with the regulators, but the rest of the community—captives included—are not being given the same opportunities.”


There are concerns over Solvency II’s final make-up, and the possible application of differentiation and proportionality—key issues with a bearing on the captive sector. Will captives be treated in the same way as commercial carriers? Is differentiation a likely outcome from the ongoing discussions, and does EIOPA understand the specific demands of captives, are all questions that Droese and the wider captive community have raised.


emea captive 2012


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