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Business Requirement to Regulatory Requirement Mapping

Workstream ownership
Further description / comment

Gap Analysis Pillar 2 Deliverables Ma
1 2

BRP#

Workstream

BRP Name

BRP requirement description

Pillar 2 (Y/N) (refer P2 deliverables)

Other workstream delivery (name workstream/ function)

Other Workstream products

List the potential gap Process for identified. These will be updating key raised with the programme ERM for consideration. Also documents specify if the requirement no within Group longer relevant. and Regions

Life Insurance Risk Target Operating Model

People & Change BRP 057 Embedded Use Embedded Use Embedded Use Use Test Design Principles Evidence senior management understanding through training & reviewing the existing performance targets Training sessions are organised to improve senior management understanding on the functionality and limitations of the internal model and its applications in business. For the purpose of senior management training, the scope of internal model understanding should mean appropriate understanding of the calculation kernel and also appropriate understanding of the implications of internal model outputs for the decision making process. To meet the Use Test requirements in relation to Senior Management training, the Learning and Development Framework is adopted across Aviva to improve Senior Management understanding of the internal model and ORSA. Y People & Change Y People & Change N People & Change BRP 059 Embedded Use Senior Management Understanding / Training N People & Change

Board and Senior Management training

Covered within P&C work-stream. Falls under "3. Learning and Development " within the plan. Board Training plan modules 16. Need to check if this has been completed as latest version of plan has not been updated to confirm this

BBD?

BRP 057

Use Test Design Principles

Board & Senior Mgmt training Stage 2 training Board & Senior Mgmt training Stage 2 training

Covered within P&C work-stream. Falls under "3. Learning and Development " within the plan. Board Training plan modules 16. Need to check if this has been completed as latest version of plan has not been updated to confirm this Covered within P&C work-stream. Falls under "3. Learning and Development " within the plan. Board Training plan modules 16. Need to check if this has been completed as latest version of plan has not been updated to confirm this

BRP 059

Senior Management Understanding / Training

Board & Senior Mgmt training Stage 2 training

Covered within P&C work-stream. Falls under "3. Learning and Development " within the plan. Board Training plan modules 16. Need to check if this has been completed as latest version of plan has not been updated to confirm this

Is there any deliverables around Embedding of board training and stage 2 training?

Board & Senior Mgmt training Stage 2 training

Covered within P&C work-stream. Falls under "3. Learning and Development " within the plan. Board Training plan modules 16. Need to check if this has been completed as latest version of plan has not been updated to confirm this

BRP 059

Embedded Use

Senior Management Understanding / Training

BRP 059

Embedded Use

Senior Management Understanding / Training

L&D framework aligns with the CEIOPS requirement for Senior Management training and specifically outlines the category of individuals to whom the training will be provided. If there is further guidance from CEIOPS on the definition of Senior Management we recommend L&D to widen their scope to include these individuals. Training is provided to the Board and Executives of in-scope regulated legal entities. This training should cover all the areas outlined in the Learning & Development Framework, and in particular, in order to meet the Solvency II requirements, this training must cover the following areas as a minimum: • Overview of Solvency II and its impact on Aviva • Impact on decision making strategy due to new risk adjusted metrics, risk appetite and risk strategy • The 3 lines of defence model and roles and responsibilities • The risk framework, management and decision making for Executives in a Solvency II context • How the risk appetite is used as part of Internal model and how it links with the ORSA • Capital allocations process and use of economic capital • Scope of Internal model, limitations, future developments and methodology behind the internal model, how diversification arises and outputs produced by the internal model • ORSA / Use Test reporting and disclosures (SFCR, RTS, QRT) responsibilities and processes • New business and strategy planning framework • New capital and risk management MI used in business plans • New group-wide risk adjusted measure ‘Economic Gain’ and how this links to remuneration Training requirements for the Board members should also apply to the full membership of any committee which has direct delegated authority from the Board. Training is provided to the Senior Managers (Business Managers). This training should cover all the areas outlined in the Solvency II Learning & Development Framework, and in particular, in order to meet the Solvency II requirements, this training must cover the following areas as a minimum: • Sufficient understanding and necessary skills to interpret more complex risk information to include and evidence risk and capital considerations into their decision-making • Use of risk and capital projections to enhance business decision-making; Interpretation of new reports and analyses to achieve more efficient use of capital • The 3 lines of defence model and roles and responsibilities • The risk management Framework and decision making for Senior Managers in a Solvency II context • How risk appetite is used as part of IM and how it links with the ORSA • Scope of internal model, limitations, future developments and methodology behind the internal model, how diversification arises and outputs produced by the internal model • New business and strategy planning framework • Sufficient understanding and necessary skills to understand new risk adjusted metrics, internal model and ORSA to manage performance • Roles and responsiblities of internal model governance • Use of Economic Gain Regional HR functions consider Group training plans and ensure that they are appropriate for local use. Where additional local training requirements are identified, Regional HR should address these.

N

People & Change

Board & Senior Mgmt training Stage 2 training

Covered within P&C work-stream. Falls under "3. Learning and Development " within the plan. Board Training plan modules 16. Need to check if this has been completed as latest version of plan has not been updated to confirm this

N

BBD?

People & Change BRP 059 Embedded Use Senior Management Understanding / Training N People & Change

Board & Senior Mgmt training Stage 2 training

Covered within P&C work-stream. Falls under "3. Learning and Development " within the plan. Board Training plan modules 16. Need to check if this has been completed as latest version of plan has not been updated to confirm this

Board & Senior Mgmt training Stage 2 training

Covered within P&C work-stream. Falls under "3. Learning and Development " within the plan. Board Training plan modules 16. Need to check if this has been completed as latest version of plan has not been updated to confirm this

BRP 059

Embedded Use

Senior Management Understanding / Training

N

BBD?

People & Change BRP 059 Embedded Use Senior Management Understanding / Training N People & Change BRP 059 Embedded Use Senior Management Understanding / Training N Training requirements be applied to new Board members and Senior Managers as part of their induction People & Change BRP 70B Embedded Use Own Risk and Solvency Assessment (ORSA) updated with new Level 3 guidelines N

Board & Senior Mgmt training Stage 2 training

Referenced in plan but need to check

Embedding of board and snr mgt training

Need to check

Board training and senior management training

Covered within P&C work-stream. Falls under "3. Learning and Development " within the plan. Board Training plan modules 16. Need to check if this has been completed as latest version of plan has not been updated to confirm this

Group Executive Committee, Audit Committee, Risk Committee and Board be given appropriate training so that the management responsibilities in respect of ORSA are understood

Underwriting Underwriting management and Technical and Technical accountabiliti Pricing Pricing es and role Standard Standard profiles Document Life Insurance Policy DocumentGI components of the Target Operating Model DocumentGI Policy Tactical MI proposal Documented Document – revised revised Financial Risk Document – groupwide Credit. Development Development including Risk .iverables Mapping 2 3 3 3 4 4 4 5 5 6 6 7 9 Document – Top down risk assessment and reporting process (Group and Regional level) 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 Risk Life General Management Insurance Insurance Framework Product Product Policy. Target composite Liquidity Risk Market and Operating Operational management Liquidity Model Risk policy framework policies Operational Risk Target Operating Model Document – Document – Best practice Regulatory guidelines for Target responding Operating to regulatory Model development s Document – Planning to support 2011 Effectiveness Review (s166 expected Q3) Internal Model Validation Standard Asset and Liability Management Standard Customer Standard General Insurance Claims Handling Standard General Insurance ReInsurance Standard General Insurance technical provisions Standard Life Insurance Claims Handling Standard Life Insurance ReInsurance Standard Life Insurance technical provisions Standard ORSA Standard Purchasing and Outsourcing Standard Stress and Scenario Testing Standard Taxation Standard Asset Data Management Management Risk Policy Standard . Strategy. .

10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 Investment Model Management Development Standard Standard Asset Valuation Standard RCSA Standard Business Protection and IT Standard Capital Counterparty Communicati Management Rating ons Standard Standard Standard Internal Control Standard Document – Revised ToR’s Management reflecting the Asset Top Down Life In-force of Bad and agreed Management Remuneratio Risk Management Doubtful reorganisatio Product n Standard Assessment Standard Assets n of group Development Standard Standard level Standard management committees Brand Standard Collateral Management . Derivatives Management Distribution Environment CSR Standard and Funded Standard Standard Risk Mitigation Standard Errors and Breaches Standard External Auditor Standard Fees Standard Financial Crime Standard Financial Reporting Standard Foreign Exchange Standard Fund Management Standard Health & Safety Standard Internal Audit Standard Legal Standard Liquidity Standard P .

10 10 10 10 10 10 11 11 11 11 11 12 12 12 M&A Standard People Standard Regulatory Standard Securities Lending Standard Strategy Standard Document Document Framework Document showing showing Document – Document Documented defined for showing skills governance approach for Detailed Plan Final report showing 2nd line cascading / gap and approach to inclusion of to assess new on S2EC requirements review and monitoring Unit Pricing resource Appetite non S2 Internal (including for budget sign off of IM franchise Standard needs changes for measured Model review of for model approval and value to identified for dividend business 2010 ICA review adoption Regions and Risk function payment and units into risk results) completed process BU’s review plan appetite assumptions framework 12 Confirmation that risk appetite and economic capital frameworks and limits are being used in business decision making including 2012-14 business 13 14 15 Opera System (Phase 1) Document Definition of requirements for global standard (coverage and format) Documents showing an “end state” vision of suite of risk MI 16 16 16 17 17 Demonstrate how HR Documentati levers are Risk Risk on showing Updated aligned to Documented curriculum in curriculum in Risk Specific Documented reward Global Risk support the development place place Functional Risk KPI for objectives induction Fundamental measuremen strategy for outlined outlined training FY 2010 Dry FY2011 ORSA Exco incorporated programmes s . senior development development Stage 3 ORSA Report Report Bonusable into with Risk Training development business activity for activity for Training Objectives Director/Hof Fundamental Materials and leaders 1st and 2nd 1st and 2nd Materials performance s embedding line line management of a Risk Aware culture 16 16 16 16 16 16 17 18 Plan ORSA Statement IMAP P P P P P P P P P P P P P P P .Stage 1 t.

assessment – Phase 2 2014 plan template Enhancement Capital Stress and Allocation Scenario Framework Testing (includes Risk Framework Appetite) P P .20 21 22 23 24 Completion Self ALCO Report of EG in 2012 .