EFAMA KPMG Solvency II Report

4.2.2 Data Exchange Formats
4 WORKING GROUP FINDINGS | 29
Requirements
The Pillar 3 QRTs that insurers must submit to the regulator are still to be fi nalised
and current expectation is that final QRTs will be available in the autumn of 2012.
To date there has been no guidance on the format for data that need to be exchanged
across the industry in order that the templates can be completed by insurers. This is
particularly an issue with regard to template QRT AS D4, due to the requirement to
look-through.
While standardisation could well take place over time, it would be better to establish
this now and avoid the costs of creating costly processes which are subsequently
reengineered.
Challenges and Impacts
It would be operationally challenging for an asset manager to provide the QRT data in
numerous formats and templates. It would also be challenging for an insurer or asset
manager to receive QRT data in multiple formats and either scenario would be likely to
result in impacts on data quality, as it is harder to complete quality checks on numerous
bespoke requirements than a standard set of requirements.
Varied and numerous requests in different formats will also have knock on impacts on the
consistency of definition across the industry, as there will be no consistent data exchange
reference documentation.
Potential Solutions
An industry standard format for data exchange across the insurer and invested asset
industry would provide greater clarity for asset managers, TPAs, and insurers, as they
would know what format to produce data in, and expect to receive it in.
For aggregate data, a standard data exchange template at the aggregated CIC, country
and currency level would enable QRT AS D4 to be completed without the insurer
needing to collect data at the granular holdings level. The aggregation would be done
by the asset manager or TPA, and the data items would meet minimum Solvency II
requirements for QRT AS D4. This method would also resolve the issue relating to the
disclosure of granular holdings data.
Where firms require the individual holdings level data for Pillar 3 QRTs, a standard data
exchange template at the granular, pre-aggregated level would enable consistency of
definition and reporting of asset data across the industry.
Firms will also be collecting data for Pillar 1. Standardisation of data at this level would
focus on core data items required for Pillar 1, and minimise requests for all data or ‘nice
to have’ items.
The standard format would need to include standardised labelling to reflect the QRTs
and create consistency of definition, so a data directory should therefore accompany
the standard data exchange templates.
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