In the UK, one demon that will not be roaming the streets is a hard Brexit following the extension. This has paved the way to a General Election in the festive season. One demon in the UK that has been stalking the European and USA markets will be in the financial news. The opposition party is resurrecting the alchemy of financial taxation, and this could blast an icy chill into the Christmas season if an upset at the polls occurs.
With the Rugby World Cup in full swing and moving to the decisive knock out stages, we have been treated to a feast of the oval ball game. Some great matches and a fairy tale unfolding as the ‘Brave Blossoms’ cause more than one upset. The host nation has won hearts and minds during their continuing progress. Elsewhere in the competition, and as usual, the scrum set pieces have garnered a certain amount of controversy!
When it’s time to review systems and processes how do you best go about that? Chat to your peers in similar organisations to identify what they’re using? Search the internet? Employ the services of a consultancy firm to do the research for you? They’re all familiar options widely used, and the outcome of each can actually be quite different.
I have always been a fan of the concept of a shared platform across banks. Looking at some of the big examples such as SWIFT and CLS, and the shared ownership/consortium concept such as EBS and FXall, you can see how the utility aspect can be put to good use. As the increased automation of FX trading evolves, customers now have a wide range of choices when it comes to execution of trades. Central Limit Order Books (CLOBs) such as Reuters Matching and EBS have spawned single dealer platforms (SDP) and multi-bank platforms (MBPs) alongside anonymous ECN’s, so a wide choice of platforms have become available, suiting all types of market participant’s preferred execution choices. Technology has allowed for aggregation in what remains a fragmented market place and algorithmic techniques are a growing component across a wide spectrum of the market.
The Women’s World Cup (WWC) has been in full swing and finally we entered the knock out phases after 36 games, 106 goals and plenty of technological controversy, 24 teams became 16 after many dramatic twists and turns. With the climax approaching this weekend, the semi-finals have so far followed suit. Like football, with a team’s coaches, goalkeeper, defence, midfield and strikers with a communicated strategy, a treasury has similar requirements of its technology. As the knockout stages progress we have again seen technology (VAR) continuing to make a difference in key games!
In November last year we held a Breakfast Briefing entitled “New Horizons for Treasury Regulation”, two of the topics we covered were IBOR reforms especially from the legal aspects and the Fundamental Review of the Trading Book and predicted these would come centre stage in 2019.
Delving beyond the world of algo’s/AI, the drive for ever faster speeds and platform consolidation is potentially the return of the utility platform were a shared platform offers efficiencies to a group of participants. For example, the concept of a Regulatory Reporting utility for an association of banks could well lead to better transparency in reporting, higher quality/more accurate data, and lower costs. The benefit of a shared platform would bring efficiencies to the changing reporting requirements and probably lead to a faster deployment.
Following two high profile fines for regulatory reporting failures, totalling nearly £62 million by the UK’s FCA, the fines prompted an interesting observation by the Director of Enforcement and Market Oversight at the FCA.
Here we are … always following new market developments to inform our product development teams … and one item caught my eye in the last week:– Digital Regulatory Reporting (DRR) starring the FCA and a host of collaborative partners! As Ronald Reagan noted having seen the film Back to the Future “Never has there been a more exciting time to be alive, a time of rousing wonder and heroic achievement.”
This week I have been dusting off the Q&A release from ESMA in September 2018 regarding the reporting of FX Swaps to ensure we have successfully planned for the impending changes. The aforementioned Q&A included reference data and transaction reporting scenarios where an FX Swap is reported as a single stand-alone financial instrument. This Q&A implementation period was six months and to ensure a consistent approach across reporting requirements, ESMA also published a Q&A on FX Swaps reporting under EMIR, which should be implemented 12 months after its publication, as it is more difficult to implement, but the two are harmonised to ensure consistency.
Last week we looked at the recent GFXC note on Disclosures and today we take a deep dive into the accompanying report. As will be seen, it continues the theme of the importance of disclosures.
Not if - it’s the clarity of content that counts for FX Disclosures!
The Global FX Committee released the minutes of their last meeting, papers on Cover & Deal, Disclosures and a survey on Valentine’s Day. It makes for interesting reading for the FX market and luckily, on the 90th anniversary of the Valentine’s Day Massacre no bullets were fired!
LIBOR, which stands for ‘London Interbank Offered Rate’ is a benchmark interest rate that is currently used across a wide range of financial contracts both on and off balance sheet. Currently contracts in excess $370 trillion are reliant on LIBOR benchmark rates. As things currently stand, the LIBOR rate that appears on pages of a Reuters (or other) screen could go blank on 1st January 2022.
LIBOR is going nowhere fast. With $370 trillion of outstanding notional swaps tied to it, the desire to wean markets off this popular fix is going to be a long hard slog. The reasons for removing LIBOR are well rehearsed and the underlying intellectual rigour behind the arguments were compelling before the deluge of rate rigging allegations appeared.
The UK’s Cryptoassets Taskforce is comprised of HM Treasury, the FCA and the Bank of England. Not to be likened to the three witches from Macbeth who are often thought about at this time of year!! Just in time for Halloween, they have published a Final Report that sets the scene for the Cryptoassets, Blockchain and Distributed Ledger Technology (DLT) sector in the UK from a policy and regulatory perspective.
The European Union (EU) Securities Financing Transaction Regulation (SFTR) is part of Europe’s continuing clampdown on potential risks in the banking & financial services sectors. Scheduled for introduction in Q3 2019, it requires firms to report details of their Securities Financing Transactions (SFT’s) to trade repositories. This includes a range of instruments including; Repos, Securities and Commodities Lending, Buy/Sell Backs, Margin Lending and Total Return Swaps.
With FX volatility now rising rapidly our three fintech entrepreneurs were planning how to disrupt the Foreign Exchange market (the only financial market that runs for 24 hours per day) with a revolutionary ‘follow-the-sun’ app. They were planning to set up a global, low-cost, transparent, real-time, digital, blockchain exchange staffed by robots.
One thing that often comes up, whether we are talking informally to market contacts, or engaged with clients and prospects, is the level of uncertainty around technology strategy.
The American Foreign Exchange Committee (FXC) has issued one of its letters last week addressed to all “Market Participants”. The FXC is an FX industry group that has been providing guidance to the market since 1978.
The 2018 Payment Services Directive (PSD2) opens up payments markets to new, radical service providers in an aim to create a cheaper, more efficient European payments market. It provides new opportunities for third parties to access banks’ internal data in real-time to improve customer service.
Insurance managers and captive owners will recognise that building strategic partnerships is an essential part of their business, none more so than with chosen technology provider.
Football is a game of two halves but last night for English fans that added 4 minutes felt like another half! For the “football’s coming home” brigade it was a decent start. The debate around VAR was well and truly stoked following the game and the pundits debate on the efficiency of VAR continues! We “was robbed” a phrase that comes to mind! It is uncanny how this translates into parallels with current debate in the financial markets.
Eurobase has just given me a reusable coffee/tea mug in support of World Environment Day. This should arrest the use of plastic in the office and help our seas and oceans, albeit in a very small way, but every little helps! Cycling into work, I heard on the radio about the tremendous amount inspired teachers do to educate our children on environmental matters. I can personally attest to the “nag factor” our teenagers bring to correct the ways of their elders! Overall, it is about doing the “right thing”.
Some corporate banks have recently been losing clients to non-traditional providers of payment services. Others are wondering how best to tap into this important revenue opportunity during a period of rapid evolution. Either way there are some fundamental concepts that need to be incorporated when designing an extended online service. Disruptors have demonstrated the importance of creating digital solutions that make it easy for customers to conduct their payments fast and with full transparency. Fortunately, there is no exclusivity on functional excellence and more conventional banking providers are now benefiting from the lessons learnt.
Electronic devices consume our lives. The extension of wifi-enabled "smartness" into all manner of devices has turned even a basic doorbell into a legacy system. These rapid advances in technology often put domestic and professional lives out of sync. Many of us will recognise greater utilisation of technology in our personal lives. Landlines, printers and the humble computer mouse are all a regular part of our office lives, but obsolete in our own homes.
Following the release of the new Banking collateral, our Director of Business Consulting reflected on the development of siena in the context of the market defining events over the past 25 years or so. From the early days of the expansion of computing power through the electronification of trading and the dot com bubble to the Financial Crisis. David Woolcock reflects on how these momentous events have shaped our product development. At the end of the article is the challenge of what lies ahead in the next phase of continual enhancement and improvement of our flagship treasury solution.
We were recently asked – what 3 things do you think are affecting/will affect the reinsurance industry from a technology perspective?
In my last blog The week that was the MiFID II deadline I highlighted the issue with LEI’s. This time it seems it is the turn of ISINs that are causing some turbulence below the surface of what otherwise has been a great industry effort to get the good ship (MiFID II) launched and implemented without any sharp squalls driving us onto the rocks.
So the 3rd of January came to pass and the City was not plunged into meltdown by the implementation of MiFID II/MiFIR. Some confusion reigned due to the late announcement of 6-month smoothing exercise to the implementation of LEI’s. The summary statement was –
In conversation with clients, one topic that comes up time and again is PSD2. When I ask "So, what are you doing on PSD2" there are broadly two responses, "We have it under control" or "We have a team looking at it" swiftly followed by “it can't be much different to PSD". Can it? The answer is quite simply Yes! How much different PSD2 is to PSD is another story altogether and something that deserves a little more time.
Halloween got me thinking as to what demons the European markets might expect on a spooky night like tonight. What could come knocking at our doors and will they be a trick or a treat?
From a technological perspective, we decided to delve into the realms of Innovation and Efficiency. I mean, who doesn’t want their business to run more innovatively and efficiently? Do technology solutions really have the ability to drive innovation and efficiency, reduce operational costs and improve return on capital.
As the 61st Monte Carlo Rendezvous comes to a close and the principality which the (Re)Insurance industry, for a few days claims as home, bids farewell for another year, it is an opportunity to reflect on why the Rendez-vous (RVS) after all this time is still relevant and an important event in the (re)insurance calendar.
Recent news reports suggest parents, teachers and employers are unhappy about the new GCSE grading system that was used for the first time in pupil results announced two weeks ago. A lack of clarity of the new scoring system has been blamed for the confusion.
You would be mistaken if you thought enforcement notices were just the preserve of big banks and individuals. Many smaller regulated banks fall foul of the FCA’s and other authorities’ scrutiny. For FCA regulated firms this is mainly around two important principles of business (Principle 3 & Principle 11). Principle 11 deals with relations with the regulator but the most important one is number three (and in terms of fines a costly one!).
Big data is still big news. For the insurance industry, it’s not just a lot more data although that is part of it; it is data that permits an unprecedented degree of analysis. Only now have we reached a point where data and technology are capable of making use of information we can gather.
It's customary in any discussion of Blockchain to assert that there will definitely be a change to the insurance industry. We then go on to state a number of use cases unrelated or tangential to insurance (Land Title Registry, Fine Arts Ownership and Imogen Heap are the usual suspects). But the B3i initiative and other similar ventures are, at last, giving the insurance industry real examples to consider.
Do you have systems in place to enable adherence to the Global Code for FX?
The Global Code of Conduct for FX (the Code) was released on the 25th of May 2017, to a good reception from diverse market participants and brought the curtain down on two years of work.
I can remember clearly, in one of the first English lessons after moving school, we were taught certain rules. The rule that sticks in my mind today is "Never use the word 'Thing'". Using the word 'thing' in your written work will result in an instant de-merit. For some of my fellow students, this became a challenge, to try and use 'thing' and get away with it.
Here we are now - a year has passed since the Referendum and Article 50 was triggered in March by Mrs May. It took some time but we got there eventually – a recurrent statement, used by many throughout the process, was the phrase “We have to respect the will of the people.” In this case, democracy means Brexit, and whichever side you sit on this: Patriotic or Pro EU; the show must go on!
As computers have taken over the workplace, the insurance industry, along with others, now relies upon them for the basic day to day business functions. Initially, organisations began to build new systems upon existing legacy systems as processes and software evolved, but now it seems that these legacy systems may not be up to the job.
One of the takeaways I had from numerous conversations at the ACI Congress in Dublin, where Eurobase participated, was the question “how do we continue to offer voice trading, which is what customers want, and be compliant with MiFID II?”
The recent Cyber-attack involving digital criminals asking for a ransom is proof that Cyber-crime can no longer be referred to as just a "Threat" or as a topical subject that we mention on the agenda of a boardroom meeting. It is here and it’s spreading like the plague...for all those that are less prepared.
In the FT today comes the news that UK branches of foreign banks will have to adhere to whistleblowing rules that allow staff to voice concerns to City watchdogs without having to tell their employers.
It is no secret that the traditional (re)insurance firms have a reputation of reluctance to adopt and adapt to new technologies. However, here we are, in the 21st century and technology is shaping as well as transforming our whole world and fast, and it does not intend to slow down for anyone.
I have the privilege to serve on the BIS FXWG Market Participants Group (MPG) that is crafting the Global Code of Conduct for FX.Interest in the Code is being expressed by market participates of all shapes and sizes alongside those being engaged in multiple roles across the Foreign Exchange industry.
2016 was a challenging year for captives with much attention being placed on Solvency II, BEP’s and Employee Benefits (EB). Now 2017 is in full swing, it is clear to see that last year’s three hot topics are going to continue as trends in the market for the foreseeable future.
“MiFID II and MiFIR will change the way banks around the world do business —particularly with respect to the scope of data, communications formats and records that must be maintained.” -Bloomberg
Responding efficiently to the dramatic changes that MiFID II will bring in January 2018 is key to ensuring your organisation continues to succeed and remains profitable. As a bank or branch/subsidiary regulated by a European regulatory authority and operating in the EU, your bank is subject to MiFID II in general terms. MiFID II covers nearly all instruments (e.g. including Forward FX) except for most Spot FX. The confusion regarding the definition and whether spot FX is in or out has been clarified to some extent and relies mainly on the T+2 (smaller currencies up to T+5) and “physically settled” definitions.
I had the pleasure of listening to a couple of gentlemen on one of my train journeys home this week. They were discussing Blockchain - with one of the individuals portraying himself as a Blockchain expert. However, I soon realised this was another example of someone picking up on the hype around this topic without actually understanding how it works or can be adopted.
In today’s banking industry many organisations are finding it increasingly challenging to meet the transparency requirements imposed on them. It arguably feels like a fusillade of bullets coming from all sides. Central banks, regulators, internal requirements, auditors, and others, are all imposing their own compliance and risk practices, to which banks must adhere or face the consequences and potentially pay a hefty price in regulatory fines.
How can technology support the principle of ‘fair and effective markets’?
In my last blog on cross border payments I was mulling the concept of “fair and effective” markets and musing how that would apply to the current landscape of high bank charges in this area. The original blog was inspired by a newspaper article that was expressing outrage that a bank was discriminating against smaller corporates (SME’s) on a systematic basis.
The concept of having one or multiple global insurance programmes in place has continued to be attractive to multinational corporations. The benefits are well understood and include contract certainty and regulatory compliance and, having agreed coverage terms, conditions then apply on a blanket basis to all of the international operations within the programme.
It is heartening to see at last some good news on the regulatory front in Europe. It is now widely expected that the European Parliament and Commission will move to postpone the entry in force of the PRIIPs Regulation by 12 months. This will bring the timing in line with MiFID II. If all goes well the “cunning plan” will move the date of application to 31 December 2017.
Continuing on from our last blog which highlighted the background to the emergence of the Building Society market, we are looking in more detail at the regulatory journey the sector has been on. In our next blog we will be taking a more detailed view on how regulation is impacting the market now and in the future. We will look at how the current situation and future impacts on the sector.
With another 3 months still to go, 2016 has already been quite an eventful year. The renewal season was kicked off with the pre-Rendezvous AM Best Reinsurance outlook. Some of the issues covered were woven like a red thread throughout the Monte Carlo Rendezvous, the Guernsey ILS roundtable and will certainly be discussed during other events such as the ECF in Luxembourg in November this year.
The OECD BEPS (Base Erosion and Profit Shifting) strategy 2015 is currently being rolled out globally. With many corporations in a preparation phase, the impact on the captive insurance market is starting to cause concern.
I remember vividly watching a BBC TV programme when I was a boy, it was a production regarding the challenge of cycling the entire length of Great Britain. Stretching over 1000 miles from Land's End in Cornwall to the remote town of John O'Groats on the windy northern coast of the Scottish Highlands. It caught my enthusiasm instantly, a physical challenge which seemed way beyond my ability and the opportunity to thoroughly explore the land I call home. Despite the intervening years, the aspiration of one day completing it has not only stayed with me, but grown.
Two recent articles in the Guardian, both covering the post Brexit situation, got me thinking about the impact so far of the referendum vote.
One of the authors represented the view that “the FTSE has shrugged off a quick post referendum dip” and is now stronger than ever and that the drop in the value of the British pound represents an opportunity for more exports.
In a previous blog “One Code to bind them all…”, it was noted that the Global Code covers all participants in the Foreign Exchange market – “Banks, Financial Institutions, Corporates, Alternative Liquidity Providers and Platforms”. Indeed one code to bind us all!
Man-made disasters, NAT-CAT, Reinsurance, ILS and Collateralised Reinsurance – how does all of this fit together?
There is no denying a constantly increasing trend of man-made disasters and NAT-CAT events both in frequency and severity. This can be seen in the charts taken from Swiss Re’s SIGMA 01/2016 publication for the year end 2015.
Eurobase prides itself on being an organisation that provides a reliable, mindful and personal approach to business. This includes our products and services alike.
Successful sales people will tell you that whatever is being sold, the ‘softer’ aspect of the sale is as important as the process and the product.
When we are recruiting, it is easy to focus on the process and the product (the role), and sometimes the softer aspects can get side-lined, but this is where hirers can take a leaf out of the sales book. If we treat our candidates in the same way as we treat our customers we stand a much better chance of a successful outcome.
Not a day goes by without another expression of strongly held views in the media. With engagement from people on both sides of the debate, this will intensify as we grow closer to the day of the vote, June 23rd 2016.
There are a lot of potential areas which may be troubled by the UK’s exit from the EU and all of them are widely discussed with the opponents fiercely trying to eviscerate each other’s arguments.
The areas of potential concern range from consumer affairs (pricing, safety testing, TCF), global role and defence, policing and security (cross border policing and security), immigration, sovereignty and laws, work and pay, travel and living abroad to the important area of trade and the economy.
On the 26th of May part 1 of the Global Code of Conduct will be published. This will be the high level principles to govern in a single code the unregulated over the counter (OTC) wholesale FX market. Part 2 will be published in exactly one years’ time. This will be the last part though, so not quite as long a saga as the Lord of the Rings!
“Customer satisfaction is worthless. Customer loyalty is priceless.”
Very few companies would not include ‘great customer service’ on their list of key ingredients that are essential for success. Great customer service builds strong and lasting relationships, demonstrates a greater understanding of modern customer needs, adds a personal human touch and infuses positivity within the business and its customers. It’s critical for attracting repeat customers and building positive word of mouth and a respected brand.
The aptly named (by Eurobase) C Day, or Complaints Day, was June 30th 2016.
I’m sure you are already fully aware that the FCA and the Lloyd’s code for handling complaints have set a deadline for having an operational complaints management solution. Of course, this is not the only day that people will complain, but it is the date in which Managing Agents in the London Market will be required to have a fully auditable complaints handling solution in place for anyone including (but not limited to) Policy holders, TPA’s, Coverholders, Brokers, Lloyd’s and the FOS, who may raise a complaint or query. The solution must be able to manage complaints in compliance with the regulation and reporting requirements of the FCA.
The round table discussion hosted by Business Insurance recently at the RIMS conference in San Diego reflects the current uncertainty around the soft insurance market and if and when that may change.
One of the speakers indicated that “the insurance market had the feeling of the start of a hard market” but added that “this is not what is going on”. Some experts believe there is so much anxious capital in the market now, that not even a major catastrophic event would change the willingness to invest in the insurance market. There is a promise of profit on investments and a reasonable degree of safety for the investment.
It looks like the insurance premium cycle is now looping in the soft market phase and the next premium rate increase is not even to be seen on the horizon.
With ILS (insurance-linked securities) heading into the London Market, every effort is being made to push the corporation tax legislation through in 2016. UK companies will then be able to make the most of the business opportunities on offer.
So, what is this ILS regulation and what makes it different from traditional (re)insurance?
Having the right people in the right place at the right time is essential for any successful business. Equally deciding which recruitment agency can best enable you to achieve this is invaluable. Your time is precious to your business, hence reducing your time spent on candidate selection is important.
After the draft of MiFID II technical standards in December 2014, financial institutions began to get a flavour of the profound changes ahead. Scandals were propelling the drive to enact legislation that would boost market integrity through the introduction of more transparent markets. This transparency, unless adequately planned for, can require significant changes to a vast panoply of IT systems.
''The greatest technology in the world hasn’t replaced the ultimate relationship building tool between a customer and a business; the human touch''
Three days in Qatar in March, high 20’s and a room full of insurance experts – what could possibly take the edge off that? How about tigers on the loose on the streets and all the Brits in the room bringing inclement weather with them… the locals were not impressed on either front!
No matter how long you have been looking for a new job or whether the job you have just been offered is the perfect job for you, it can still be an unnerving experience to receive a counter offer. Knowing how to handle the situation can make the transition from one role to another much smoother. If you are unprepared it can cause you to question your decision making, so we have carefully selected three key things to remember when handling a counter offer:
Last month, Eurobase spoke at the London Market Technology Exchange forum (www.lmte.london). The focus was on TOM (the Target Operating Model for the London Market). Joe Dainty, Global Head of Operations at Lloyd’s, was the keynote speaker and a hard act to follow. So, in order to give the audience something new to think about, we thought we would share some insights and similarities we recognise through our experiences of working in the Banking sector over the last 20 years.
The worlds banks are currently looking at finding new ways to exploit blockchain technology. If you haven’t heard of it (hard to believe), Kate Knibbs says "it’s a simple digital platform for recording and verifying transactions so that other people can’t erase them later."
It has long been a source of headlines that UK PLC will soon be facing its biggest workforce challenge yet, as people are generally living longer. Based on figures from the Office for National Statistics, the number of people aged over 60 in the UK keeps rising and is expected to have increased by 13% between 2013 and 2020.
Companies wishing to manage their insurance risks have long looked towards captives as a viable alternative to self-insurance. The captive market continues to flourish both domestically and abroad with small captives emerging as valuable players in their own right and growth being seen in new and emerging markets such as Latin America.
Congratulations! You’ve finally found the perfect candidate for that key role in your organisation. But now you have to wait to see if they are going to accept. So how do you make sure they answer with a resounding ‘yes’?
There are two key factors which now come into play: offering the right package and ensuring you follow an effective process:
You’re ready for your next move. How do you get noticed by your future employer? Do you go online and start searching the job boards? Or do you pick up the phone and speak to that recruitment agency you’ve heard about? We’ve compiled this list of five practical tips – and key questions to ask yourself – to help you understand what they both have to offer, so you can effectively decide what to use to find your next challenge, a job board or a recruitment agency:
Halloween is approaching, and with ‘19,823 recruitment agencies registered with HMRC in the UK’*, we understand one of the most daunting tasks clients face is to manage their increasingly growing recruitment Preferred Supplier List (PSL). However, here we share with you ‘5 easy steps to help you manage that scary PSL’:
Bermuda’s enduring position as the pre-eminent domicile for captive insurance was confirmed once again at this year’s Bermuda Captive Conference. The three day conference saw a record attendance, a record number of sponsors and a record number of exhibitors. To further evidence the territory’s dominance, the conference launched the Captive Hall of Fame.
Paul Buckle, of Eurobase, discusses what effective data management can do for the captive business.
Increasing pressure from regulatory bodies, in addition to the need for stronger MIS and balance sheet control is driving a demand for Treasury Management solutions.
At Eurobase, we have invested millions of pounds in our synergy2 end-to-end policy administration system and framework for the global market.
The outlook for the MENA insurance market is extremely positive for 2013, with projected double digit growth. However, as insurance organisations grow and diversify through cross-border trading, many are finding their incumbent software is limiting their growth or unnecessarily increasing their operational costs.
“While achieving growth, operational excellence and innovation in such a difficult economic and competitive environment might be easier said than done, opportunities are available for insurers that can seize the moment.”
One of the emerging trends in the e-FX market sector is that a growing number of banks are setting their sights on providing services to smaller customers via their e-FX platforms. Significantly, many are indicating that, partly as a result of under-estimating the volume of customers at this tier, the rewards for providing services in this way are greater than envisaged.
Financial markets and regulatory bodies continue to assert pressure on organisations in the face of growing demand to control risk and re-structure balance sheets. No organisation can afford to be ill-equipped to trade in the market. Nowadays the ability to hedge positions efficiently and transparently is an absolute necessity.
In our previous blog, we discussed some of the Solvency II challenges to regulators and carriers. Following on from this entry, we have looked at the implications for Enterprise Risk Management strategies as part of Solvency II.