The Internal Model Approval Process
Stefano Pasqualini
Foreword
Introduction
Balance Sheet, Capital Requirements and Internal Models
Partial Internal Models
The Internal Model Approval Process
Policy for Model Changes
Internal Models to Calculate the Group Solvency Requirement: The Perspective of the Home and Host Supervisor
Use Test: Challenges and Opportunities
Statistical Quality Standards: Challenges in Internal Model Implementation
Representation, Reality and the Solvency II Data Challenge
The Calibration Standards
Profit and Loss Attribution
Internal Model Validation: The Regulatory Perspective
Model Validation: An Industry Perspective
Solvency II Internal Model Documentation Requirements
How to Review External Models and Data Embedded in the Modelling Framework
The Limitations of Internal Models and the Supervisory Review Process
The internal model approval process aims to assess if (re)insurance firms’ internal modelling framework can be used to calculate the solvency capital requirement (SCR). This process requires firms to demonstrate compliance with several mandated tests and requirements. For example, among other things, (re)insurance firms need to provide evidence that:
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the internal model is able to calculate the SCR;
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the systems concerned for identifying, measuring, monitoring, managing and reporting risk are adequate;
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the use test, statistical quality, calibration and profit and loss (P&L) attribution, validation, documentation, external models and data standards have been met; and
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any potential interrelation between these requirements has been properly considered.
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Moreover, if the application refers to a partial internal model, the (re)insurance firm also needs to:
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justify the limited scope of the model (ie, provide evidence that there is no cherry-picking);
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demonstrate that the resulting SCR reflects more appropriately the risk profile of the (re)insurance firm; and
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provide evidence
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