It must be well understood there have not been back to solvency I

1 Would it have been better wait to enact the text

Some, in France, were favourable to a report of Solvency II, on the grounds that the crisis would have acted as a revealer of weaknesses of a device copied that of banks (Basel II). In November, Jean Azéma, CEO of Groupama, publicly took position for a conditional sentence ("Les Echos" from November 23). "Solvency II is to remove the safety in the technical provisions of the insurers to put it in the own funds, on which several stakeholders (shareholders, State, or even leaders...). "feel of rights: this will undermine the insurance companies", says Jean-François Allard, CEO of mutual of French architects. II pro-Solvabilité see, a contrario, that the crisis has increased the need for an assessment of the needs capital risks and their management, and effective supervision of groups at European level. "Any delay would have been extremely damaging," indicated yesterday the European Insurance Committee, while regretting the abandonment of the group support regime.

2. Is there an alternative

For some, Solvency II would be a case of "the escalation of commitment syndrome": unable to stop the machine. "It is not a perfect system, there is still work," recognizes Romain Durand, a partner at Actuaris. But abandon en route back to the rustic solvency I capital requirements determined as a percentage of premiums (insurance non-life) and technical provisions (life insurance) was in fact not an option. "It must be well understood there have not been back to solvency I." "The risk would have been to legislate within the events and to adopt a highly regulated system," says Romain Durand.

In fact, the three pillars of Solvency II architecture is not challenged. The first pillar is intended to define the requirements quantitative both own funds (with two levels: a minimum, the RCM, and a the SCR target) and technical provisions. The second pillar deals with the control and the third of the information to pass to the market. "Regardless of the final format by the directive, the essential is that everyone prepares, because it is a real cultural change," warned Tuesday Thomas Behar, President of the Institute of the actuary, at a Conference in the salon Decid' Ashur.

Was 3 really learned the lessons of the crisis

The "caught original" Solvency II took the full extent with the crisis. They remain whole. First, the system is cyclical, as a result of a joint dangerous between the "fair value" accounting standards IFRS and the prudential requirements calibrated on the basis of a probability of ruin by 0.5 in a year. A little consistent horizon with the long duration of the insurance liabilities, which will lead the insurers to limit their investments in shares, and therefore in sub-optimal allocation of assets. In fine, this is likely to prevent them from fully play their role as "shock absorbers of crisis". Finally, the sacrosanct principle of diversification under which a group capital requirements are lower than the sum of the requirements of the entities comprising the took the lead in the wing. "In times of crisis, the risk to re - correlate", recently recalled Denis Kessler, CEO of SCOR. "Should have been completely take the system at the base, even if the same causes would have likely caused the same effects", slipping to Decid' Ashur Philippe Jurgensen, the President of the CMAA. Remains whether these defects may in part be corrected through enforcement of the directive, to be adopted by the European Commission in 2010. It is the debate now.