Statistical Quality Standards: Challenges in Internal Model Implementation
Markus Bellion, Christopher Lotz and Peter Müller
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
Statistical quality standards stand out among the internal model test and standards as they address the core of the matter, the internal model in the narrow sense.11 For a definition of an internal model in the narrow sense, see Chapter 1. They do not primarily take on the perspective of model purpose or model use (in contrast, for example, to the use test and the calibration standards).22 For further details about the use test and calibration standards, see Chapters 6 and 9. The regulatory requirements refer to a generally comprehensive methodology used by firms to calculate the probability distribution forecast (PDF). The internal model is thus not reduced to an instrument of arbitrary nature that already meets the requirements if all it does is, providing as output, a distribution of profits or losses with high forecast quality. Instead, besides the resulting PDF, the individual elements of the calculation methodology are subject to quality standards; these are mainly the underlying assumptions, the actuarial and statistical techniques used, and the data and information used as basis for model specification and parameterisation. This corresponds to the view that an internal
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