I write to express a mixture of sorrow and anger at the dismal attempt by the IFoAs chief executive to justify the new TAS 100. He writes in his monthly column (The Actuary, September 2017, bit.ly/Actuarytransition): In raising the TAS requirements to a higher level of principle, it makes sense at the same time to broaden their scope.
I write to express a mixture of sorrow and anger at the dismal attempt by the IFoA's chief executive to justify the new TAS 100. He writes in his monthly column (The Actuary, September 2017, bit.ly/Actuarytransition): "In raising the TAS requirements to a higher level of principle, it makes sense at the same time to broaden their scope."
Really? Quite apart from the fact that the first part of the sentence does absolutely nothing to justify the second part, this assertion violates three of the five principles of good regulation which the IFoA and the FRC claim to subscribe to. Specifically, regulators should (1) intervene only when necessary; (2) focus on the problem so as to minimise side effects; and (3) be able to justify decisions.
Each of these three principles was breached by the FRC when it decided to expand the scope of TASs without identifying any new problem to be addressed, without minimising the manner in which the (unidentified) problem was dealt with and without giving any reason for the proposal.
I have written about this before in these pages (March 2014, bit.ly/Regsstillgoodforus). The FRC ploughed on, making no attempt to remedy the deficiency in its reasoning. It is a shame to see the IFoA's CEO now trying to plug the gap in the FRC's thinking in such a forlorn manner. One has to wonder why he felt the need.
Simon Carne
8 September, 2017
