Why Spreadsheets can send the Pillars of Solvency II Crashing Down


Solvency II is now fast approaching and while it may provide added protection to policy holders, its impact on the insurance industry is not all a bed of roses. Expect insurance companies to restructure, increase manpower, and raise spending on actuarial operations and risk management initiatives. Those that cannot, will have to go. But what have spreadsheets got to do with all these?

Well, spreadsheets aren’t really the main casts in this blockbuster of a regulatory exercise but they certainly have a significant supporting role to play. Pillar I of Solvency II, which calls for improved supervision on internal control, risk management, and corporate governance, and Pillar II, which tackles supervisory reporting and public disclosure of financial and other relevant information, both affect systems that have high-reliance on spreadsheets.

A little background about spreadsheets might help.

Who needs an IT solution when you can have spreadsheets?

Everyone in any organisation just love spreadsheets; from the office clerk to the CEO. Because they’re so easy to use (not to mention they’re a staple in office computers), people employ them for processing numbers and as an all-around tool for planning, forecasting, reporting, complex modelling, market data analysis, and so on. They make such tasks faster and easier. Really?

You probably haven’t heard of spreadsheet hell

Unfortunately, spreadsheets do have certain shortcomings. Due to their inherent structure and lack of controls, it is so easy to commit simple errors like an accidental copy paste, an omission of a negative sign, an incorrect data input, or an unintentional deletion. Such shortcomings may seem harmless until your shareholders discover a multi-million discrepancy in your financial report.

And because spreadsheet errors can go undetected for a long time, they are constant targets of fraudsters. In other words, spreadsheets are high risk applications.

Solvency II Impact on Spreadsheet-based Financial and IT Systems

Regulations like Solvency II, are aimed at reducing risks to manageable levels. Basically, Solvency II is a risk-based system wherein a company?s capital requirements will depend on its measured riskiness. If companies want to avoid facing onerous capital requirements, they have to comply.

The three pillars of Solvency II have to be in place. Now, since spreadsheets (also known as User Developed Applications or UDAs) are high-risk applications with weak control features and prone to produce inaccurate reports, companies will have a lot of work to do to establish Pillars II and III.

There are at least 8 articles that impact spreadsheets in the directive. Article 82, for example, which requires firms to ensure a high level of data quality and accuracy, strikes at the very core of spreadsheets? weakness.

A whitepaper by Raymond Panko entitled ?Spreadsheets and Sarbanes-Oxley: Regulations, Risks, and Control Frameworks? mentioned that 94% of audited real world operational spreadsheets that were included in his study were found to have errors and that an average of 5.2% of all cells in the audited spreadsheets had errors.

Furthermore, many articles in the directive call for the enforcement of better documentation. This is one thing that’s very tedious and almost unrealistic to do with spreadsheets because just about anyone uses them. Besides, with different ‘versions? of the same data existing in different workstations throughout the organisation, it would be extremely difficult to keep track of them all.

Because of spreadsheets you now need an IT solution

It is clear that, with the growing number of regulations and the mounting complexity of tasks needed for compliance, spreadsheets no longer belong in this era. What you need is a server-based solution that allows for seamless collaboration, data reliability, data consistency, increased security, automatic consolidation, and all the other features that make regulation compliance more doable.

One important ingredient for achieving Solvency II compliance is sound data risk management. Sad to say, the ubiquitous spreadsheet will only expose your data to more risks.

More Spreadsheet Blogs


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Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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Is Change Management a Myth or a Possibility

The theory that it is possible to manage organisational change (Change Management) in a particular direction has done the rounds for quite some time, but is it true about Change Management. Was Barrack Obama correct when he said, ?Change will not come if we wait for some other person or some other time. We are the ones we have been waiting for. We are the change that we seek.?
Or, was business coach Kelly A Morgan more on the button when she commented, ?Changes are inevitable and not always controllable. What can be controlled is how you manage, react to, and work through the change process.? Let us consult the evidence and see what statisticians say.

What the Melcrum Report Tells Us

Melcrum are ?internal communication specialists who work alongside leaders and teams around the globe to build skills and best practice in internal communication.? They published a report after researching over 1,000 companies that attempted change management and advised:

? More than 50% report improved customer satisfaction

? 33% report higher productivity

? 28% report improvements in employee advocacy

? 27% improved status as a great place to work

? 27% report increased profitability

? 25% report improved absenteeism

Sounds great until we flip the mirror around and consider what the majority apparently said:

? 50% had no improvement in customer service

? 67% did not report increased productivity

? 72% did not note improvements in employee advocacy

? 73% had no improved status among job seekers

? 73% did not report increased profitability

? 75% did not report any reduction of employee absenteeism

This shows it is still a great idea to hear what all parties have to say before reaching a conclusion. You may be interested to know the Melcrum report gave rise to the legend that 70% of organisation change initiatives fail. This finding has repeated numerous times. Let’s hear what the psychologists have to say next.

There is a certain amount of truth in the old adage that says, ?You can lead a horse to water but you cannot make him drink.? Which of us has not said, ?Another flavour of the week ? better keep heads down until it passes? during a spell in the corporate world. You cannot change an organisation, but you can change an individual.

At the height of the Nazi occupation of 1942, French philosopher-writer Antoine de Saint-Exup?ry said, ?A rock pile ceases to be a rock pile the moment a single man contemplates it, bearing within him the image of a cathedral?. Psychology Today suggests five false assumptions change management rests upon, THAT ARE SIMPLY NOT TRUE.

1. The external world is orderly, stable, predictable and can be managed

2. Change managers are objective, and do not import their personal bias

3. The world is static and orderly and can be changed in linear steps

4. There is a neutral starting point where we can gather all participants

5. Change is worthy in itself, because all change is an improvement

Leo Tolstoy wrote, ?Everyone thinks of changing the world, but no one thinks of changing himself.? A prophet can work no miracles unless the people believe. From the foregoing, it is evident that change management of an organisation is a 70% impossibility, but encouraging an individual to grow is another matter.

A McKinsey Report titled Change Leader, Change Thyself fingers unbelieving managers as the most effective stumbling stones to change management. To change as individuals ? and perhaps collectively change as organisations ? we need to ?come to our own full richness?, and as shepherds lead our flock to their ?promised land?, whatever that may be. Conversely, herding our flock with a pack of sheepdogs extinguishes that most precious thing of all, human inspiration.

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Business Strategy

Knowing how and when to make the right strategic move is critical to your success in today?s dynamic environment. Our Strategic Management Consultants provide solutions for a tighter integration of your vision, values, and mission statements with the strategic management process.

The result is a stronger alignment of your operating activities with your goals, and also an improved internal infrastructure to support and manage the strategic management process.

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Can you do away with the Project Initiation Meeting?

Project initiation meetings are often skipped to fast-track projects. Once a sponsor is found, organisations go straight to project planning and execution. But based on our own experience, holding a project initiation meeting can actually eliminate many issues that may crop up in the future and hence may speed things up instead in the long run.

It is in the project initiation meeting where your project objectives and scope are clarified and all stakeholders are brought to the same page. Project sponsors and stakeholders will have to know in a nutshell what is needed from them, what the possible risks are, what different resources are required, and so on. So that, when it’s time to proceed to the next phase, everyone is already in-sync.

So what are taken up in such a meeting? Perhaps an actual example can help. Sometime in the past, we set out to work on an eCommerce website project. After conducting the project initiation meeting, these were some of the things we were able to accomplish:

  • Identified deliverables e.g. site design, interface to payment system, etc.
  • Come up with the project phases
  • Agreed what should be in and out of scope
  • Defined the acceptance test criteria
  • Identified possible risks
  • Identified the possible training and documentation work needed
  • Established whether any analysis was required, e.g. as with regards to payment interfaces
  • Formulated disaster recovery plans
  • Defined roles and responsibilities
  • Drafted timelines and due dates

Aren’t these covered in project planning? If the project is a big one, the answer is no. In a large project, project planning is a much more exhaustive activity. In a project initiation meeting, only the basic framework is defined.

Some questions may still remain unanswered after a project initiation meeting, but at least you already know what answers you need to look for. In the example we gave earlier, we left the meeting knowing that we needed:

  • a list of all necessary hardware to estimate the costs
  • to identify possible dependencies we might have with third parties
  • to identify what software had to be bought and what skills we needed to hire

When it was time to proceed to project planning, everyone involved already knew what direction we were taking. In effect, by not skipping the project initiation meeting, we were able to avoid many potential obstacles.

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