Mar 2019 Summary RSR - Considerations
Insurance Undertakings are required to submit a ‘Regular Supervisory Report’ to the Central Bank of Ireland at least every 3 years. In the intervening years, unless required otherwise by the CBI, a ‘Summary Report’ must be submitted.
Article 312 of the Delegated Regulations provides advice on the content of this ‘Summary Report’ as follows:
“………. a report which sets out any material changes that have occurred in the undertaking's business and performance, system of governance, risk profile, valuation for solvency purposes and capital management over the given financial year, and provide a concise explanation about the causes and effects of such changes.”
Considerations for drafting:
- The structure should follow the five key headings included above, which are the same as for the full RSR report;
- Emphasis for inclusion is on ‘material changes’ since the last report;
- Content under each heading is guided by the requirement to provide concise explanation of the causes and effects of any material changes; and
- The RSR is a prospective document so determination of material for the summary RSR should look to current year and future year impacts of changes.
Most importantly, have regard to the words ‘Summary’ and ‘Concise’ – it is not a standalone document but relies on the contextual value of the last full RSR.