There was no ‘grandfathering’ of the existing Chief Actuary or Signing Actuary roles into the Head of Actuarial Function. Firms were advised not to assume that those performing these existing roles would automatically transition to the Head of Actuarial Function. Requirements of the Head of Actuarial Function role mean that this will represent more than just a change in job title.
One of the notable differences between the Head of Actuarial Function regime and the current Appointed Actuary / Signing Actuary roles is that there is no explicit requirement for the Head of Actuarial Function to be a qualified actuary. The Requirements do specify that the Head of Actuarial Function must be a member of a recognised actuarial association and appropriately experienced to fulfil the role. As the role is a Pre-Approval Controlled Function (PCF) position it is very likely that it will need to be fulfilled by a suitably experienced and qualified actuary in order to pass the fitness tests.
In the previous regime actuaries frequently occupied roles within the first and second line of defence and in a small number of cases occupy both e.g. fulfilling both Chief Actuary and Chief Risk Officer roles. While the new requirements do not impose restrictions on the Head of Actuarial Function fulfilling the role of Chief Risk Officer, firms now have an opportunity to clearly define duties and responsibilities of the respective roles.
The Society of Actuaries in Ireland has outlined the main responsibilities of the Head of Actuarial Function as follows: