1: Overview
1.1 The Insurance Practitioner Panel (IPP) is a statutory body representing the interests of insurance practitioners established in October 2023 by the Prudential Regulation Authority (PRA) in accordance with sections 2L and 2MA of the Financial Services and Markets Act 2000 (FSMA). The members of the IPP act in an individual capacity, not as representatives of their firms or the trade associations that nominate them. Upon the establishment of the IPP, the Insurance Sub-committee (ISC) of the Practitioner Panel was dissolved. In previous years, the ISC reported on its activities as part of the PRA Practitioner Panel Annual Report. To reflect that the IPP was established within the reporting period, and for ease of reference given the similar functions of IPP and ISC, this report covers the activities of both the ISC until its dissolution in October 2023 and the IPP from its establishment in October 2023 to the end of the reporting period.
1.2 In 2023/24, the ISC and then the IPP have effectively represented the interests of insurance practitioners by considering and providing appropriate scrutiny on significant PRA policy and regulatory developments relating to the insurance sector which benefit from members’ input. This has been achieved through discussions at ISC/IPP meetings with relevant PRA and wider Bank of England (‘the Bank’) policy leads, senior management, and Prudential Regulatory Committee (PRC) members. Relevant information has continued to be shared between the ISC/IPP and the PRA Practitioner Panel.
1.3 The ISC and the IPP have followed the established approach of early engagement in order to add value to the PRA’s approach to policymaking. The IPP is committed to continuing to provide challenge and advice to the PRA, ensuring that practitioners’ views are appropriately considered.
IPP membership – as at 29 February 2024
- Charlotte Jones, Group Chief Financial Officer, Aviva – Association of British Insurers
- Andrew Chamberlain, Chair of the Actuarial Standards Committee of the International Actuarial Association – Institute and Faculty of Actuaries
- Andrew Stoker – Association of British Insurers
- David Sansom, Chief Risk Officer, Lloyd’s – Lloyd’s
- Helen Pickford, UK Chief Financial Officer, Zurich Insurance Group – Association of British Insurers
- Kevin Gill, Partner, Ernst & Young – Insurance & Reinsurance Legacy Association International
- Neil Brothers, Ark Syndicate Management Limited – Lloyd’s Market Association
- Patrick Nolan, Regional Chief Risk Officer, EMEA, Chubb – International Underwriting Association
- Peter Green, Chief Executive, Healthy Investment – Association of Financial Mutuals
- Rakesh Thakrar, Chief Financial Officer, Phoenix Group – Association of British Insurers
1.4 As outlined in the IPP’s Terms of Reference, members serve for a three-year term with the opportunity to extend for an additional term. Over the reporting period there were changes to the ISC and IPP’s respective memberships, which are detailed below.
1.5 During the reporting period two members completed their terms on the ISC and were succeeded following nominations from their respective trade associations. Once Neil Griffiths’ term came to an end, Lloyd’s Market Association nominated Neil Brothers as his replacement on the IPP. Paul Corver’s second term on the ISC ended within the reporting period, with the Insurance and Reinsurance Legacy Association International nominating Kevin Gill as his replacement.
1.6 Upon the establishment of the IPP in October 2023, the PRA’s Prudential Regulation Committee appointed the incumbent members of the ISC to become members of the IPP. The members were appointed on terms corresponding to their remaining term on the ISC in order to ensure that members’ terms remain staggered.
1.8 Andrew Stoker served as the Chair of the ISC until the establishment of the IPP. He acted as the interim Chair of the IPP for its first meeting. Going forward, Charlotte Jones will be the permanent Chair.
2: Panel engagement with the PRA
2.1 As planned, there were three meetings of the ISC/IPP. The ISC met twice within the reporting period and the IPP met once. Meetings of both the ISC and IPP were attended by PRA senior executives, as well as the PRA Chief Executive Officer (CEO) when possible. Key outcomes and insights from these meetings continue to be fed back to relevant decision-makers and policy leads, contributing to the transparency of the policy making process.
2.2 The PRA CEO will hold bilateral meetings with the IPP chair to discuss the Panel’s views and other relevant issues.
Examples of items considered by the Panel and impact on the PRA
2.3 The following items are examples from the reporting period of subjects on which ISC/IPP views were sought and the added value these insights provided to the policy process.
Issue |
Description |
|
Insurance Ease of exit (ISC) |
The ISC’s views were sought on the rules and expectations for solvent exit planning of insurers. The ISC expressed views on the scoping principles, the most significant barriers to solvent exit and what could improve the likelihood of a successful solvent exit. |
|
Solvency UK (ISC) |
The ISC considered matters related to reforms to the Solvency II regime. In relation to the engagement plan for the Solvency II reform consultation papers, the ISC discussed various formats and the importance of appropriate timing for this engagement. The ISC’s views were also sought on proposals for the Matching Adjustment consultation (CP 19/23). Members assessed the key elements of the regime’s proposals, including providing their views on the limit for highly predictable assets within MA portfolios. |
|
Liquidity risk (ISC) |
The ISC provided views on the issue of managing and supervising liquidity risk for insurers. Members provided helpful insight on the liquidity risk frameworks and the importance of developing multiple appropriate metrics. |
|
Solvency II Transfer (IPP) |
Following consideration of Solvency II in previous years, this topic returned to the Panel. The IPP was consulted on the details of transferring the remaining firm-facing Solvency II requirements from assimilated law into the PRA Rulebook and other policy materials. The members provided their views on the policy and the PRA’s approach. |
|
Stress Testing (IPP) |
The IPP considered two papers relating to the PRA’s stress testing for the insurance sector. Members expressed views on the design and approach for life insurance stress testing (LIST) in 2025. In addition, the panel also commented on the high-level design features, calibration, communication strategy and industry engagement for the next dynamic general insurance sector-wide stress test (DyGIST). |
2.4 The Sub-Committee/IPP’s views continued to be fully considered by the PRA and reflected in its approach, as appropriate. Members views have been impactful and represent a key component of the PRA’s consultation process.
3: IPP forward agenda
3.1 The IPP is scheduled to meet three times in the 2024/25 reporting period. The forward agenda will be shaped by IPP members, and the PRA Executive and senior management team. The focus of the agenda will continue to include items prior to their wider consultation paper publication. However, some topics discussed during the course of the reporting period are expected to return to the IPP as they continue to develop. The agenda will also include any emerging and urgent issues that would benefit from a panel discussion, as determined by the IPP or at the request of the PRA.