The Central Bank has published a prohibition notice that it issued to the former Chief and Signing Actuary at RSA Insurance Ireland (RSAII) and former Actuarial Manager at Euro Insurances DAC (EID) trading as LeasePlan Insurances, Martin Ryan.
Although it has only been published now, the bank said the notice became effective on August 30 of last year and prohibits Mr Ryan from carrying out any controlled functions in any regulated financial service providers for a period of five years.
The regulator said the notice was issued after Mr Ryan signed a statement accepting he had facilitated an undocumented practice while working at RSAII.
This resulted in a significant shortfall in the firm's reserves in 2013, it said.
Mr Ryan also failed to provide material information and gave false and/or misleading information during a fitness and probity assessment three years later when he was working for EID, the bank added.
"Regulated firms, and their management, have first line responsibility under the Fitness and Probity Regime, acting as a gatekeeper to the industry by ensuring people subject to the regime are fit and proper," said Seána Cunningham, Director of Enforcement and Anti-Money Laundering at the bank.
"Information provided by persons seeking to perform controlled functions during assessments of their fitness and probity must be complete and accurate."
Ms Cunningham added that those performing controlled functions must act with honesty and integrity, in accordance with the applicable standards of fitness and probity.
In circumstances where it is suspected that an individual has not met these standards, the regulator has the power under law to investigate.
"If warranted, the Central Bank will prohibit an individual from performing controlled functions in order to uphold public trust and confidence in the financial system and protect users of financial services," Ms Cunningham stated.
In 2013 RSA Insurance Group launched a probe called Project White which found certain individuals within RSAII were manipulating claim reserve estimates, the Central Bank said.
"They did this by recording estimates on the claims database that were significantly lower than claim handlers' recommendations and/or significantly delaying the recording of the claim reserve estimate increase recommended by the claims handlers in relation to certain large loss claims," the regulator said in the prohibition notice.
"Project White also found that there was a list…that detailed the existing claim reserve estimates for certain large loss claims recorded on RSAII’s claims database, as well as the claims handlers’ recommended claim reserve estimates for these claims which were not recorded."
As a result of the findings, between 2013 and 2015 RSA Insurance Group was forced to inject €423 million into the Irish arm of the business, when it emerged it had a hole in its balance sheet.
In 2015 Mr Ryan resigned from RSAII after he reached a settlement agreement with the company.
The same year the UK accounting watchdog, the Financial Reporting Council, commenced an investigation into Mr Ryan’s conduct while at RSAII.
In 2016, Mr Ryan agreed a settlement agreement, "Particular of Facts" and "Acts of Misconduct" with the Council, including that he was incompetent in submitting Statements of Actuarial Opinion to the Central Bank, based on inaccurate data due to under-reserving practice.
The statement also found that he failed to whistle-blow regarding the under-reserving or sufficiently challenge his colleagues in relation to it.
As part of the settlement, Mr Ryan agreed not to undertake the performance of any controlled functions.
However, he went on to work as an independent contractor providing services for EID, including some that were controlled functions, from December 2015 until April 2020.
In 2017 the Society of Actuaries in Ireland reprimanded Mr Ryan following an investigation and his acceptance that misconduct had occurred.
In 2018 the Central Bank fined RSAII €3.5m under its Administrative Sanctions Procedure after the company made admissions related to a failure to maintain technical reserves and to have sound and adequate administrative, accounting and robust governance procedures in place.
Following the conclusion of this probe the Central Bank began an investigation into Mr Ryan which ultimately led to his prohibition.
