presented to CLRS by Scott Drab & Jim Christie
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Cross-border capital flows highlight the need for consistent, understandable financial information
The International Accounting Standards Board (“IASB”) is developing a single set of global accounting standards
Many countries committed to the objective of global “harmonisation”
Drivers for new approach
Historical cost accounting models lack relevance
Solvency-based approaches do not provide an accurate picture of financial performance
Convergence of banking and insurance
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There is now a phased approach to insurance contracts.
Phase I
– Implement by 2005
IAS
INSURANCE
PROJECT
Phase II
– Implement Fair
Value by 2007 / 8 (?)
The IASB’s objective for Phase I is to implement some components of the insurance project by 2005, without delay to Phase II
Key Phase I Issues
Defining Insurance
Accounting for insurance contracts
Disclosures
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A contract under which the insurer accepts significant insurance risk by agreeing to compensate the beneficiary if the insured event adversely affects the policyholder
(Insurance Contracts (Phase I) paraphrased with emphasis added)
Significant means at least one scenario with payment of commercial substance with an amount that is not trivial
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Financial risk is risk of possible future change in specified interest rate, security price, commodity price, foreign exchange rate, index of prices or rates, a credit rating or credit index or similar variable
Insurance risk is risk from contingent events other than financial risk
If both financial risk and significant insurance risk are present, contract classified as insurance
During Phase I, existing accounting policies apply with certain modifications
Prohibited – certain accounting policies are prohibited as they do not meet the
IFRS framework
Mandated
– certain accounting policies must be implemented if they are not already in the existing accounting policies
Allowed to continue, but not start – certain accounting policies that do not meet the IFRS framework can continue, but cannot be implemented.
Can be started
– certain accounting policies can be introduced.
Existing accounting policies are those in the primary financial statements
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The following accounting policies are prohibited
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The following accounting policies are mandated if they are not already present
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Current liability adequacy test applies if
Test at each reporting date using current estimates of future cash flows
If these are greater than current liability, liability is increased and deficiency flows through profit and loss
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Reinsurance asset is reduced and reduction flows through income statement if it is impaired
Reinsurance asset is impaired if:
Objective evidence of an event after initial inception that the cedant may not receive all amounts due to it
The impact of the event can be reliably measured
Impairment may be reversed
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The following existing practices may continue but companies may not switch to these where they are not already applied
Undiscounted liability basis
Deliberate overstatement of liabilities
Deferred acquisition costs approach
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The following accounting policies can be started subject to certain restrictions
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IFRS 4 Two high level principles:
Principle 1 – Explanation of recognised amounts
Principle 2 –Amount, timing and uncertainty of cash flows
Fair Value Disclosure for insurance contract assets and liabilities
Implementation guidance - runs to 61 paragraphs – but does not create additional requirements!
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Principle 1 - Explain
Accounting policies
Amounts
Assumptions
Changes in liabilities
Gain or loss on buying reinsurance
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Principle 2 – Cash Flows
Terms and conditions
Segment information
Risk management policies and objectives
Insurance risks covered
Run off triangles (loss reserve development)
Other risks
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Scope – all insurance contracts
Asset/liability model, rejecting deferral and matching
Where liabilities are independent of asset returns, unless
Policyholder benefits directly related to asset returns; e.g, linked products
Guidance needed for performance-related products
Intended to be consistent with IAS 39
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Accounting Basis
Proposal
Move to underwriting year accounting, thus no smoothing of results with
UPR and DAC
Liabilities Measured at Fair Value
Issues
Extra volatility of the insurance result
Potential changes to the IT systems
Loss ratios for new products to be estimated from day one
Re-engineering of reserving process
Reserves for expenses
Gain or loss at issue
Renewals/Future Premiums
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Discounting
Proposal
Discounting of reserves will become mandatory
Discounting at risk free rate, plus a spread for credit, and MVM’s
Valuing options and guarantees
Impact
Projection of expected cash flows
Selection of suitable economic assumptions consistent with market data
Need to consider all future events including legislation and technology
Re-engineering of the actuarial reserving process
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Market Value Margins
Proposal
Reserves will require a market value margin consistent with observed risk preferences of market
Margin incorporated either by adjusting discount rates or adjusting cashflows
Consider both diversifiable and non diversifiable risks
Impact
Need to develop suitable approach and discounting assumptions
Need for enhanced disclosures
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Future premiums only included where
Uncancelable continuation or renewal rights constraining insurer’s ability to re-price; and
Rights lapse if the policyholder ceases premiums
No net gain at inception (ignoring indirect costs) unless market evidence
Same derecognition rules as financial assets and liabilities will apply to insurance
Reflect all Guarantees and Options
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1) Model Risk
the risk that the wrong model was used to estimate the insurer’s liabilities
2) Parameter Risk
the risk of misestimating the parameters for the model used to estimate the insurer’s claim liabilities
3) Process Risk
the risk that remains due to random variation, even if the correct model and the correct parameters are used to estimate the insurer’s claim liabilities
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IAS Draft Statement of Principle 5.4: “The entityspecific value or fair value of an insurance liability or insurance asset should always reflect both diversifiable and non-diversifiable risk.”
This implies that model risk, parameter risk, and process risk should be modeled.
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IAS Draft Statement of Principle, Section 5.10: while it is “conceptually preferable” to reflect parameter risk and model risk, “it is appropriate to exclude such adjustments unless there is persuasive evidence that enables an insurer to [quantify] them by reference to observable market data.”
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The Fair Value of loss liabilities reflects the risk preferences of the insurance market.
What is the Insurance Market’s risk preference? The 75 th percentile of the loss reserve distribution? The 95 th percentile?
IAS Draft Standard of Principles: the risk preference is
“inevitably subjective” (Section 5.29)
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What are some practical techniques that could be used to model the MVM?
1) Canadian Provision for Adverse Deviation
Includes Parameter Risk & Model Risk
2) Initial Expected Profit Margin
Process Risk, Parameter Risk, & Model Risk
3) Poisson Frequency / Lognormal Severity Simulation
Process Risk
4) Mack’s Approach
Process Risk, Parameter Risk, & potentially Model Risk
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There are three parts of the Canadian Provision for Adverse
Deviation (PFAD) :
1.
Claims Development (2.5% to 15% of discounted gross liabilities)
2.
Reinsurance Recovery (0% to 15% of discounted ceded claim liabilities)
3.
Discount Rate (50 to 200 basis points on interest rate)
The MVM could be set equal to the claims development portion of the PFAD.
The PFAD does not attempt to model process risk (I.e. size of the company is not considered when determining the PFAD).
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If insurance markets are efficient, the DSOP suggests there should be no gain at issue
Consequently if a profit is indicated at issue, any theoretical MVM should be scaled so that the result is simply breakeven
Are P&C insurance markets efficient?
Are there situations where a gain at issue would be permitted?
Exhibit A in the appendix provides an example of this approach
Determine the distribution of loss reserves using a Monte Carlo approach
Frequency is assumed to be Poisson distributed
Severity is assumed to be lognormally distributed
Data requirements:
Pending counts (ultimate counts – closed counts); can be found in Schedule P
Loss Reserves (case + IBNR); can also be found in Schedule P
Coefficient of Variation for severity (can be based on historical or industry data)
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The data needed to calculate this method are readily available
The simulations could be run on Microsoft Excel or other readily available software
The method is already in use by some insurance entities to estimate process risk.
Parameters used in simulation are fairly easy to disclose and results can be replicated by outsiders.
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Actual insurer’s data may not fit the distributions prescribed by the actuary
The method only measures process risk.
All claims with payment may not have the same coefficient of variation parameters
The method is dependent on the insurer having adequate reserves.
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Exhibits 1-4 in the appendix provide an example of this approach
Mack Method could be applied to:
Paid Losses
Incurred Losses
Historical Recorded Ultimate Losses
Source: Measuring the Variability of Chain Ladder Estimates by Thomas Mack
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The data needed to calculate this method are readily available
This method can calculate process risk, parameter risk, and potentially model risk.
This method does not make any assumptions about the underlying distribution of the insurer’s losses.
This method can be readily calculated on a spreadsheet
An insurer that historically under-reserves will have a larger MVM than one that accurately estimates its reserves if the ultimate loss version of this approach is used.
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This method assumes that future losses will develop in the same way that losses have developed historically.
The Mack method relies on a number of implicit assumptions
For long tailed reserves, a number of years of experience are needed to estimate the variance in reserves.
This method can provide strange results for lines of business with sparse data.
This approach is not commonly used for valuing MVMs.
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More judgments by actuary required under proposed
IASB requirements:
1) Should the insurance company include parameter and model risk in their MVM?
2) How should the risk preference of the market be measured?
3) What approach should be used to model the MVM?
4) Given that you have selected your approach, how should you select your MVM?
Do the additional judgments help the world’s capital markets make sounder economic decisions?
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Jim.K.Christie @ca.ey.com
Scott.Drab@ey.com