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88                                                              India Insurance Report - Series II



            In short, it can be stated that the Risk-Based Capital framework is significantly more comprehensive
        than the existing simple and broad-brush formula-based capital framework in India. It not only includes
        several additional risk factors for mathematical estimation of solvency capital required but also considers
        other qualitative aspects like risk management, corporate governance and disclosures.

            Some of the key attributes of Risk-Based Capital are as follows:

            1.  Economic and risk-based calibration of financial requirements under Pillar 1

                a.  Market consistent valuation of assets and liabilities
                b.  Capital charge to reflect all quantifiable risks associated with them under a pre-defined risk
                    measurement
                c.  Recognition of diversification and risk-mitigating mechanisms
                d.  Possible use of internal models for regulatory purposes

            2.  New supervisory relationship under Pillar 2

                a.  Ladder of intervention
                b.  Incentive to enhanced ERM and Corporate Governance
                c.  Enhanced group supervision

                d.  Risk-proportional application (meaning: supervisory response to be proportional to risk of
                    the insurers)

            3.  Opening up to the discipline of market scrutiny through detailed disclosure requirements under
                Pillar 3




        4. Solvency II vs. Risk-Based Capital

            One question that could arise in readers’ minds is “What is the difference between RBC and Solvency
        II?”. Risk-based capital is a very generic term and can be used for any capital framework that has some
        demonstrable relationship with risks to the insurer. It can be used where the relationship between risk
        and capital may or may not be very strong or even where all risk elements may or may not be considered
        for capital assessment. It is also possible for a capital framework to be called Risk-Based Capital in which
        qualitative aspects like risk management, corporate governance, and disclosures may or may not be
        considered. As against this, Solvency II is an initiative of European insurance supervisors and has clearly
        laid down guidelines which cannot be tampered with. Most of the discussion above about Risk Based
        Capital is in sync with the guidelines under Solvency II and broadly aligned with the RBC approach
        being followed by developed economies outside of the European Union.




        5. India’s Preparedness for Risk-Based Capital

            The  Indian insurance  industry  and the  Insurance regulator, IRDAI,  have been  discussing  the
        implementation of Risk-Based Capital for more than a decade now. Some of the major developments in
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