Operational Risk Management in a Property/Casualty Insurance Company Mark Verheyen, FCAS, MAAA CAS Spring Meeting May 2005 A Carvill service Agenda Traditional (P/C) Insurance Company Risk Measures Operational Risk in an Insurance Company Operational Risk’s Impact on the Insurance Industry Quantification of Operational Risk in an Insurance Company Management of Operational Risk in an Insurance Company 2 A Carvill service What are the traditional measures of risk in a Property / Casualty insurance company? 3 A Carvill service Traditional Measures of Risk NAIC Risk Based Capital for Property / Casualty Insurers R0 – Subsidiaries and Affiliates R1 – Asset Risk – Fixed Income R2 – Asset Risk – Equity R3 – Credit Risk R4 – Underwriting Risk – Reserves R5 – Underwriting Risk – Premium 4 A Carvill service Traditional Measures of Risk Best’s B1 B2 B3 B4 B5 B6 B7 Capital Adequacy Ratio - Fixed Income Securities - Equity Securities - Interest Rate Risk - Credit Risk - Loss + LAE Reserve Risk - Premium Risk - Business Risk – Off-Balance Sheet Items 5 A Carvill service Traditional Measures of Risk Standard & Poor’s Capital Adequacy Ratio C1 – Asset Risk C2 – Credit Risk C3 – Premium Risk C4 – Loss + LAE Reserve Risk C5 – Business Risk 6 A Carvill service What is Operational Risk in an Insurance Company? 7 A Carvill service Operational Risk Underwriting Risk Reserving Risk Operational Risk Asset Risk Credit Risk 8 Operational Risk is not separate and distinct from the more traditional risk categories. Rather, it overlaps these categories. A Carvill service Operational Risk How does the banking industry define Operational Risk? “Operational Risk is defined as the risk of loss resulting from inadequate or failed internal processes, people, and systems or from external events. This definition includes legal risk, but excludes strategic and reputational risk.” Basel Committee on Banking Supervision “International Convergence of Capital Measurement and Capital Standards” 9 A Carvill service Operational Risk Banking (Basel) Insurance Corollary Mismarking Position (Intentional) Under-Reserving (Intentional) Model Errors / Misuse Under-Pricing, Under-Reserving (Unintentional) Outsourcing Delegation of Underwriting Authority Non-Client Counterparty Disputes Reinsurance Disputes Fiduciary Breaches Bad Faith Claims Fraud Fraud Anti-Trust Violations Anti-Trust Violations Natural Catastrophe / Terrorism Natural Catastrophe / Terrorism* * It is important to distinguish between the insurer’s operational exposure to natural catastrophe / terrorism and that exposure assumed from other parties as a covered insurance risk. Risks should be Serially Exclusive and Mutually Exhaustive (“SEME”). In other words, every risk falls in one and only one bucket. 10 A Carvill service How Has Operational Risk Impacted the Insurance Industry? 11 A Carvill service Operational Risk’s Impact “Failed Promises: Insurance Company Insolvencies” – a Congressional Report Failures attributed to: – – – – – – – Under-reserving Under-pricing Unsupervised Delegation of Underwriting Authority Rapid Expansion Reckless Management Abuse of Reinsurance Etc. Sounds like Operational Risk. 12 A Carvill service Operational Risk’s Impact “The Failure of HIH Insurance” – a corporate collapse and its lessons. Failure attributed to: – – – – – – – Under-reserving Under-pricing Lack of Internal Controls Expansion into Unfamiliar Markets Mismanagement Abuse of Reinsurance Etc. Sounds like Operational Risk. 13 A Carvill service Operational Risk’s Impact Primary Causes of P/C Impairments (1969 to 2002) Miscellaneous, 9.8% Im pairm ent of an Affiliate, 3.7% Deficient Loss Reserves, 37.2% Catastrophe Losses, 6.9% Reinsurance Failure, 3.7% Significant Change, 5.0% Overstated Assets, 7.8% Alleged Fraud, 8.5% “With the possible exception of insolvency due to catastrophe losses, in A. M. Best’s opinion, all the primary causes of insolvencies in this study were related to some form of mismanagement.” – Best’s Insolvency Study, Property Casualty U. S. Insurers, 1969-2002 Rapid Grow th, 17.3% Sounds like Operational Risk. Source: A.M. Best Company – by permission 14 A Carvill service Operational Risk’s Impact Annual Number of P/C Impairments 2002 2001 1999 1997 1995 1993 1991 1989 1987 1985 1983 1981 Average 25.6 21.9 32.5 1979 1977 1975 Total Im pairm ent Count 871 481 390 1973 1971 1969 to 2002: 1969 to 1990: 1991 to 2002: 1969 65 60 55 50 45 40 35 30 25 20 15 10 5 0 Source: A.M. Best Company - by permission Impairments increase following prolonged soft markets. Why is Operational Risk tied to the Underwriting Cycle? 15 A Carvill service How is Operational Risk Quantified in an Insurance Company? 16 A Carvill service Quantification of Operational Risk Standard Expenses Fraudulent Expenses Covered Losses Fraudulent Losses Total Expenses Total Losses Processing Errors The significant sources of operational risk are implicitly included in regulatory and rating agency capital models. Processing Errors Underwriting Errors Financial Statements Policy Premium Pricing Total Premium Regulatory / Rating Agency Capital Models Processing Errors 17 A Carvill service Quantification of Operational Risk NAIC RBC Model Premium Risk – Base capital charge is derived using industry worst-case loss ratio by line, adjusted for company experience Reserve Risk – Base capital charge is derived using industry average worst-case reserve development by line, adjusted for company experience Growth Charge – Based on a regression against industry data applied to company growth Significant sources of operational risk are implicitly included in the regulatory and rating agency capital models. 18 A Carvill service How is Operational Risk Managed in an Insurance Company? 19 A Carvill service Management of Operational Risk Communication and discipline are key. Pric in Plannin g g Underwriting Reserving Everyone needs to be aware of what is going on in the current underwriting environment and be realistic about what the results are. 20 A Carvill service Management of Operational Risk “For every clever person who goes to the trouble of creating an incentive scheme, there is an army of people, clever and otherwise, who will inevitably spend even more time trying to beat it.” – Levitt and Dubner, “Freakonomics” “Insurance companies create powerful incentives… for underwriters to sell as many policies as possible at whatever price the market will bear” – Sean M. Fitzpatrick, “Fear is the Key: A Behavioral Guide to Underwriting Cycles” Short-term incentives tend to be production based, while longterm incentives tend to be profitability based. Everyone needs to be aware of what the incentives are and how they impact behavior. 21 A Carvill service Management of Operational Risk What are the Key Risk Indicators of Operational Risk in an Insurance Company? Production – hit ratios, retention ratios, item count, pricing levels (renewal business and new business), rate per unit of exposure Internal controls – audit results, audit frequency Staffing – employee turnover, training budget, premium per employee, policies per employee Claims – frequency, severity, new classes of loss Outside data sources – rating agencies, regulators, industry trade organizations, data warehousing firms 22 A Carvill service Concluding Thoughts Operational risk isn’t a distinct class of risk that insurers are required to hold additional capital for. It is arguably the single largest threat to their solvency, though. Regulators and rating agencies implicitly include capital requirements for Operational Risk through the premium and reserve charges in their capital models. These risk-based capital models can serve as a framework for companyspecific models. Proactive communication and the monitoring of Key Risk Indicators can encourage changes in behavior in the underwriting cycle. 23 A Carvill service Mark Verheyen is a Vice President with ReAdvisory, the consulting arm of Carvill, one of the world's largest privately owned reinsurance intermediaries. He assists client companies in evaluating and structuring reinsurance programs, providing dynamic risk modelling and capital allocation services. Prior to joining ReAdvisory, he worked at both Ernst & Young and CNA Re. Mark is a member of both the CAS Enterprise Risk Management Research Committee and the Committee on Reinsurance Research. mverheyen@readvisory.com 24 A Carvill service