Processing of consultation responses
DNB put out a draft version of its good practices document for consultation. The consultation round closed on 30 June 2018. The comments made by stakeholders were incorporated in this definitive version. Additions and improvements were made for the following items.
- The distinction between legislation and regulations and good practices was clarified. The fact remains that when giving an example of a good practice, repeating a part of the relevant legislation and regulations cannot always be prevented.
- Our example of materiality assessment uses additional assessment criteria that insurers use in performing materiality assessments. This assessment gauges with the help of legislative and regulatory criteria whether outsourcing of activitiess is important or critical.
- We clarified that the good practices document pertains to important and critical outsourcing. No good practices specifically aimed at outsourcing of critical functions and authorisations were included.
- We clarified that not all examples are applicable to all insurers. Insurance companies must make their own considerations as to which measures are fitting for the specific risk and the size of the company. Insures can include a proportionality test in their risk analyses.
- We also clarified our examples of good practices in subcontracting.
In addition to making adjustments to the above items, we clarified and added several examples.