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42<br />

The Talanx Group Strategy Enterprise<br />

managem<strong>en</strong>t<br />

Talanx Group. Annual Report <strong>2011</strong><br />

Research and<br />

developm<strong>en</strong>t<br />

The continuing low interest-rate <strong>en</strong>vironm<strong>en</strong>t is becoming an<br />

increasingly serious chall<strong>en</strong>ge for Germany’s life insurers. Whereas<br />

in <strong>2011</strong>, it was still possible for the industry to g<strong>en</strong>erate adequate net<br />

returns on its capital investm<strong>en</strong>ts, cross-sector announcem<strong>en</strong>ts on<br />

reducing shared profits suggest that the tr<strong>en</strong>d, should it continue, is<br />

likely to affect life insurance b<strong>en</strong>efits in the future.<br />

Legal and regulatory <strong>en</strong>vironm<strong>en</strong>t<br />

The business of the Talanx Group is subject to regulatory rules and<br />

requirem<strong>en</strong>ts that are both numerous and detailed. The supervisory<br />

authorities of the countries in which Talanx operates <strong>en</strong>joy<br />

far-reaching authorities and powers of interv<strong>en</strong>tion. Observing<br />

these regulations and requirem<strong>en</strong>ts, and continually adjusting its<br />

business and products to new laws, <strong>en</strong>tails a considerable financial<br />

outlay on the part of Talanx. Talanx curr<strong>en</strong>tly sees itself confronted<br />

by far-reaching changes in the regulatory <strong>en</strong>vironm<strong>en</strong>t in which it<br />

operates, particularly in the wake of rec<strong>en</strong>t national and international<br />

efforts aimed at avoiding another financial crisis.<br />

A global tr<strong>en</strong>d is now discernible towards tight<strong>en</strong>ing the regulatory<br />

and supervisory framework governing banks and insurance companies<br />

– including ev<strong>en</strong> stress tests, along with increased requirem<strong>en</strong>ts<br />

in terms of capital adequacy. A particular focal point is a<br />

financial institution’s “system relevance”. Companies whose collapse<br />

would have unforeseeable consequ<strong>en</strong>ces for the <strong>en</strong>tire financial<br />

and insurance industry will face much more string<strong>en</strong>t regulatory<br />

requirem<strong>en</strong>ts in the future, especially with regard to their capital<br />

base. This is in line with a resolution drawn up on 4 November <strong>2011</strong><br />

in Cannes, by the G-20 <strong>group</strong> of key industrialised and emerging nations,<br />

which named 29 banks deemed “too big to fail”. The International<br />

Association of Insurance Supervisors (IAIS) has be<strong>en</strong> giv<strong>en</strong> the<br />

task of verifying, by the G-20 summit in June 2012, whether certain<br />

conv<strong>en</strong>tional insurance companies – contrary to industry assessm<strong>en</strong>ts<br />

– should also be giv<strong>en</strong> the “globally system-relevant” stamp.<br />

It has also be<strong>en</strong> asked to develop appropriate test criteria, and,<br />

where necessary, id<strong>en</strong>tify these top global insurance players. The<br />

Talanx Group, too, is involved in this assessm<strong>en</strong>t process. The latest<br />

opinion of the administrative court in Frankfurt suggests, however,<br />

that the Group is not deemed system-relevant within the above<br />

meaning of the term. Other proposed reforms curr<strong>en</strong>tly under<br />

debate relate e.g. to the introduction of a financial transaction tax<br />

in the European Union.<br />

Markets and<br />

g<strong>en</strong>eral conditions<br />

Business developm<strong>en</strong>t<br />

Assets and<br />

financial position<br />

Rec<strong>en</strong>t times have also se<strong>en</strong> fundam<strong>en</strong>tal changes made to<br />

the structure of supervisory bodies, particularly at EU level. On<br />

1 January <strong>2011</strong>, the new Frankfurt-based European Insurance and<br />

Occupational P<strong>en</strong>sions Authority (EIOPA) replaced the former<br />

Committee of European Insurance and Occupational P<strong>en</strong>sions<br />

Supervisors (CEIOPS). The EIOPA’s main task is to draw up technical<br />

standards, recomm<strong>en</strong>dations and guidelines for coordinating<br />

the national supervisory authorities. Although the EIOPA has no<br />

authority per se over German insurance companies, it can request<br />

that a national supervisory authority justify any diverg<strong>en</strong>ce in its<br />

own supervisory practices from those set down by the EIOPA (what<br />

is known as the comply-or-explain principle). In exceptional cases,<br />

the EIOPA can also issue instructions to national authorities and, in<br />

the case of non-compliance, take action directly in the form of binding<br />

decisions applicable to the insurance companies in question.<br />

Furthermore, in accordance with the Treaty on the Functioning of<br />

the European Union, the EIOPA – in some cases with only limited<br />

control by the European Parliam<strong>en</strong>t – is set to play a key role in the<br />

rulemaking process for substantiating the Solv<strong>en</strong>cy II Directive that<br />

has yet to come into force. There is no doubt that the EIOPA’s work<br />

will have significant practical implications for Germany’s insurers;<br />

ev<strong>en</strong> in the curr<strong>en</strong>t preparatory stage, it has resulted in a barely<br />

manageable proliferation of supervisory rules and regulations<br />

across the whole sector.<br />

What is more, the so-called Omnibus Directive is curr<strong>en</strong>tly implem<strong>en</strong>ting<br />

changes to certain details of the Solv<strong>en</strong>cy II Directive.<br />

Although precise details of the Directive’s cont<strong>en</strong>t and how it is<br />

to be implem<strong>en</strong>ted and transposed into the national laws of EU<br />

member states are not yet known, it is certain to result in the<br />

wholesale harmonisation of supervisory legislation across the EU.<br />

The quantitative and qualitative tight<strong>en</strong>ing of supervision already<br />

incorporated in the Directive, together with requirem<strong>en</strong>ts for<br />

greater transpar<strong>en</strong>cy – in particular through more string<strong>en</strong>t capital<br />

adequacy requirem<strong>en</strong>ts and demands for in-house risk control<br />

systems, as well as <strong>report</strong>ing and docum<strong>en</strong>tation processes – is being<br />

addressed by German legislators in the form of a curr<strong>en</strong>t draft<br />

bill to am<strong>en</strong>d the country’s Insurance Supervisory Act (VAG). Against<br />

this backdrop, Talanx int<strong>en</strong>ds to submit an application for the approval<br />

of its own in-house risk model. Developed on a proprietary<br />

basis by Talanx, the risk model will be used instead of the alternative<br />

standard formula in the Solv<strong>en</strong>cy II Directive in order to <strong>en</strong>able<br />

solv<strong>en</strong>cy capital requirem<strong>en</strong>ts for the Talanx Group to be calculated<br />

with greater precision. Developed in constant dialog with the supervisory<br />

body, the in-house model aims to take maximum possible<br />

account of the Group’s individual business model, its legal structure<br />

and, above all, its risk structure. European and national supervisory<br />

bodies alike have expressed the wish that the major insurance<br />

<strong>group</strong>s develop in-house models as early as possible.

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