Most organisations advised by actuaries are regulated by both ASIC and APRA. AFCA also play an important role in difficult times like these.
The regulators will be much more active and potentially intrusive so that they can satisfy themselves as to the true state of affairs in each institution. APRA in particular will be pro-active and will likely interact with both senior management and boards – possibly regularly.
APRA will pay considerable attention to the capital position – both at present and under various scenarios for the future – and the operation of the ICAAP. It will also be keenly interested in how well risks have been identified and are being managed, and how effective the Risk Management Framework has been to date. It would be wise to review the various requirements in CPS/SPS 220, and assess how well they have been met to date in the COVID response.
Actuaries are likely to be heavily involved in responding to regulator interactions – in helping Board and management be well-prepared and in responding directly to queries. A thorough understanding of the situation, built on rigorous assessment and analysis, is critically important for this.
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