The United States RBC Standards, Solvency II and the Swiss Solvency Test: A Comparative Assessment

Cummins et al. (1994) provide a conceptual framework for policymakers to use in analysing risk-based capital systems. Based on their framework, this article provides an overview and critical analysis of risk-based capital requirements, with a focus on property/casualty insurance, as implemented in three regions of the world (the United States, the European Union and Switzerland). To integrate the dynamics of the insurance and capital markets and recent developments in regulation we add four new criteria to the original framework of Cummins et al. The analysis reveals various shortcomings of the standards used in the United States and indicates a need for reform in that country. In contrast, the Swiss standards and the framework planned for the European Union perform generally well. It is, however, not yet possible to identify which of these two systems is superior, as empirical evidence on their effectiveness in protecting policyholders is still lacking.