Guidance · GFSC · 23 Nov 2020
The Guernsey Financial Services Commission mandates strict pricing controls and equitable valuation standards for licensed insurers managing Life Assurance Unit Linked Funds. Insurers must implement robust reconciliation procedures, ensure actuarial oversight of discretionary pricing elements, and maintain annual reviews of delegated or third-party pricing systems. The guidance establishes a 0.5% de minimis threshold, requiring mandatory reporting and policyholder compensation for pricing errors exceeding this limit while exempting smaller discrepancies from restitution.
GUERNSEY FINANCIAL SERVICES COMMISSION
GUIDANCE NOTE FOR LICENCED INSURERS ON UNIT
LINKED PRICING
licensed insurer’s responsibilities in this respect. c) Where the pricing function is delegated, the licensed insurer must satisfy itself that the delegate’s system will produce accurate results. The licensed insurer should review the outputs from the system at least annually and on any significant system change. d) Unless the valuation and record keeping systems are integrated, the valuation output should be agreed with the licensed insurer’s records of the fund at each valuation point. In addition, the licensed insurer’s records, including debtors and creditors, should be agreed with the Custodian’s record of stocks, capital and income cash at least monthly. Any reconciling items should be followed up promptly and debtors reviewed for recoverability. e) Systems should be in place whereby deals in securities are confirmed in writing as quickly as possible to the licensed insurer (or delegate). All deals to which the fund is committed must be included in the valuation. A cut-off procedure should be in place to guard against omissions or duplications. f) Where prices are obtained other than from the main pricing source (e.g. unquoted, suspended or illiquid stocks), the licensed insurer should maintain a record of the source and basis for the value placed on the stock. This should be frequently reviewed and approved by the Actuary. g) A system should be in place to ensure that investment and borrowing powers are not breached and that, if breaches occur, they are identified and rectified promptly. h) A system should be in place to ensure that dividends are accounted for as soon as stocks are quoted ex-dividend unless (as with some stocks) it is more prudent to account for them on receipt. Unless a longer interval is more appropriate for reasons of materiality, fixed interest dividends and interest should be accrued at each valuation point. Similar considerations apply to the expenses of the fund. i) A justification for the figures included for dealing expenses and commissions included in the price should be reviewed at least quarterly for each market. In addition, adjustments should be made when substantive changes in a market’s costs occur (e.g. changes in the rate of stamp duty). j) Licensed insurers should fix a limit for certain key elements of a valuation such that any movement beyond that limit is investigated and the investigation and evidence of the outcome should be evidenced by signature of the Actuary. Such key elements include:
share/unit price; stock prices; exchange rates; income accruals and expenses. If a price has remained unchanged for a fixed period, it should be investigated to ensure that movement in the price has not been overlooked. k) Cash should be reconciled to the bank account at every valuation point. Outstanding items should be followed up. l) Controls should be in place to ensure the correct number of units in issue is recorded at each valuation point. m) A copy of the valuation should be sent to any external investment adviser/manager at least monthly. They should check that the correct securities are recorded.
Note from RegAlert. AI assistants can read this document in full, and search 70,000+ more, through the RegAlert MCP connector (https://mcp.regalert.today/mcp). Free with an account. How to connect ChatGPT, Claude or Cursor.
More like this from GFSC
We email you every new GFSC publication the day it's published.
Source: Guernsey Financial Services Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
In RegAlert: added · updated