Casualty Actuarial Society Insurance Accounting for Actuaries May 17, 2005 Presented by: Kevin Wick, FCAS, MAAA PwC Financial Reporting Context “The most appropriate reserve within a range of actuarially sound estimates depends on … the financial reporting context in which the reserve will be presented.” • Current Loss Reserving Principles Page 2 PricewaterhouseCoopers Financial Reporting Context “The most appropriate reserve within a range of actuarially sound estimates depends on … the financial reporting context in which the reserve will be presented.” • Current Loss Reserving Principles “Loss reserves are utilized for a variety of purposes, including financial reporting, valuation, commutation and ratemaking.” “The context in which loss reserves are presented may indicate elements to be reflected in the loss reserves.” • Proposed Loss Reserving Principles PricewaterhouseCoopers Page 3 Financial Statements • Purpose is to communicate financial information to the users • Standards established on how to account for various items • Objective is to account for various items in accordance with standards - reaction of users not relevant • A good financial statement is one that accounts for all the items appropriately - results may be good or bad Page 4 PricewaterhouseCoopers Current Accounting Standards for Loss Reserves • “Best estimate” of the unpaid claim costs • Basic consistency between GAAP and Statutory • Conceptual framework for current guidance - SFAS 5: Accounting for Contingencies (March 1975) Page 5 PricewaterhouseCoopers Key issues confronted when accounting guidance (SFAS 5) established • • Overall issue - “Accounting Accruals” versus “Financial Decisions” Specific contentions 1. Financial “protection” provided by accruals 2. Income fluctuation 3. Comparability of financial statements Page 6 PricewaterhouseCoopers “Accounting Accruals” versus “Financial Decisions” “Accounting Accruals” “Financial Decisions” • Simply a method of allocating • Choosing how to financially deal costs among accounting periods with a contingency • No effect on an enterprise’s cash • Example includes “to buy first flow dollar insurance coverage or be self-insured” • FASB “…the presence or absence of an accrued credit on the balance sheet will have no effect on the consequences of that decision” Page 7 PricewaterhouseCoopers Contention 1: Financial “protection” provided by accruals Contention • Accruals provide financial “protection” similar to reinsurance • Without reserve margins, enterprises will be forced to purchase insurance or reinsurance because they will not have the protection provided by the reserve margin Page 8 PricewaterhouseCoopers Contention 1: Financial “protection” provided by accruals FASB Response Contention • “accruals … in no way protect the • Accruals provide financial assets available ... to pay claims” “protection” similar to reinsurance • “Accrual, in and of itself, provides • Without reserve margins, no financial protection that is not enterprises will be forced to available in the absence of accrual” purchase insurance or reinsurance because they will not have the protection provided by the reserve margin Page 9 PricewaterhouseCoopers Contention 2: Income fluctuation Contention • It is important to set aside reserves to avoid reporting net income that fluctuates widely from period to period Page 10 PricewaterhouseCoopers Contention 2: Income fluctuation FASB Response Contention • “Financial statement users have • It is important to set aside indicated that information about reserves to avoid reporting net earnings variability is important to income that fluctuates widely from them” period to period - Consider both “expected” return and “variability” • “If the nature of the business is such that there are variations in periodic net income, that fact should not be obscured” Page 11 PricewaterhouseCoopers Contention 3: Comparability of financial statements Contention • Regular periodic accrual of losses, whether or not they have occurred, is justified on the grounds of comparability of financial statements - Self-insurance costs versus insurance costs - Various amounts of reinsurance purchased Page 12 PricewaterhouseCoopers Contention 3: Comparability of financial statements Contention • Regular periodic accrual of losses, whether or not they have occurred, is justified on the grounds of comparability of financial statements - Self-insurance costs versus insurance costs - Various amounts of reinsurance purchased FASB Response • “to report activity when there has been none would obscure a fundamental difference in circumstances between enterprises that transfer risks and others that do not” Page 13 PricewaterhouseCoopers Principles/Quotes underlying SFAS 5 • “The sole result of accrual, for financial accounting and reporting purposes, is allocation of costs among accounting periods” • “The use of an accounting reserve does not reduce or eliminate risk” • “Earnings fluctuations are inherent in risk retention, and they should be reported as they occur” • “The Board cannot sanction the use of an accounting procedure to create the illusion of protection from risk when, in fact, protection does not exist” Page 14 PricewaterhouseCoopers What is the Financial Reporting Perspective? “The consulting actuary continues to feel that conservative reserve margins are necessary because of the uncertainty in original reserve estimates due to the limited experience base, large potential swings in ultimate liabilities, and the Company’s relatively small total capital position” Page 15 PricewaterhouseCoopers What is the Financial Reporting Perspective? Financial Reporting Perspective “The consulting actuary continues to feel that conservative reserve margins • Translation “The consulting actuary are necessary because of the seems to be having trouble uncertainty in original reserve distinguishing between funding for estimates due to the limited uncertain reserves versus financial experience base, large potential reporting of uncertain reserves.” swings in ultimate liabilities, and the Company’s relatively small total capital position” Page 16 PricewaterhouseCoopers What is the Financial Reporting Perspective? “I know my reserve point estimate is well above all the indications from my methods. The 2004 loss year looks extremely favorable but the 2005 year is much worse. Lowering the reserves will just create large swings in their claim costs” Page 17 PricewaterhouseCoopers What is the Financial Reporting Perspective? Financial Reporting Perspective “I know my reserve point estimate is well above all the indications from my • Translation “It is imperative that the methods. The 2004 loss year looks users of the financial statements be extremely favorable but the 2005 year kept unaware of the risks this is much worse. Lowering the reserves company is involved with” will just create large swings in their claim costs” Page 18 PricewaterhouseCoopers What is the Financial Reporting Perspective? “I have some concerns regarding the various changes at the Company … I believe it is appropriate to be conservative at this time” Page 19 PricewaterhouseCoopers What is the Financial Reporting Perspective? “I have some concerns regarding the various changes at the Company … I believe it is appropriate to be conservative at this time” Financial Reporting Perspective • Is what this actuary “believes” relevant? • Translation “I am ignorant of the financial reporting standards my work is being used for” Page 20 PricewaterhouseCoopers What is the Financial Reporting Perspective? “The reserves are presented both reasonably and conservatively…it is much more likely than not they will develop favorably…my actuarial judgment calls (used for deriving my BEST estimate) tended to be conservative…I can see your concern regarding the bias…my preference is to bring the estimates down over the next few years.” Page 21 PricewaterhouseCoopers What is the Financial Reporting Perspective? “The reserves are presented both reasonably and conservatively…it is much more likely than not they will develop favorably…my actuarial judgment calls (used for deriving my BEST estimate) tended to be conservative…I can see your concern regarding the bias…my preference is to bring the estimates down over the next few years.” Financial Reporting Perspective • Translation “I am going to help this company misrepresent their financial statements, but mind you only for a few years. An added bonus on this approach is the company will be able to take advantage of tax deductions they are not entitled to” Page 22 PricewaterhouseCoopers What is the Financial Reporting Perspective? “As long as a company maintains the same level of conservatism in their reserves, the income is not distorted” Page 23 PricewaterhouseCoopers What is the Financial Reporting Perspective? “As long as a company maintains the same level of conservatism in their reserves, the income is not distorted” Financial Reporting Perspective • Translation “it is okay to misrepresent financial statements as long as you do it consistently” • Why would you do this? Page 24 PricewaterhouseCoopers What is the Financial Reporting Perspective? “Accounting tells the story, it does not write the story” Page 25 PricewaterhouseCoopers What is the Financial Reporting Perspective? “Accounting tells the story, it does not write the story” Financial Reporting Perspective • Translation “I can distinguish between my role in financial reporting versus my role in making financial decisions” Page 26 PricewaterhouseCoopers