A PRESENTATION ON MODIFIED ACCOUNTING REGULATIONS FOR INSURANCE COMPANIES By: FARRUKH REHMAN Partner, A.F. Ferguson & Co. a member firm of the PwC network Date: 20 August 2013 Scope Draft Insurance Accounting Regulations, 2012 were issued by SECP on 19 November 2012 Therefore, this presentation covers the applicability and changes applied through these regulations. 2 Session to cover: • Developments in respect of Accounting Regulations for insurance companies in Pakistan • Some concerns in existing Accounting Regulations • Changes in presentation of Published Financial Statements • Presentation of Insurance Liabilities for life insurers • Applicability of IAS-27, IAS-39 & IAS-40 • Recognition of Cover Note in the books of accounts • Explanation of management and other expenses – non-life insurers • Change in premium deficiency requirement • Key issues identified in modified regulations PwC 3 Developments in respect of Accounting regulation for Insurance companies • • • Prior to the Insurance Ordinance, 2000 the concept of Accounting Regulations alongwith the prescribed format of financial statements was also given in Insurance Act, 1938. The Accounting Regulations were basic and the formats of financial statements were not keeping pace with the changes happening in the world with respect to the International Accounting standards. The Insurance Ordinance, 2000 brought about number of changes for the insurance industry and there under the new Accounting Regulations & formats of financial statements were introduced in 2002. The accounting regulations both for life and non life segments were detailed enough to address all aspects of the insurance transactions. The financial statements formats were also largely brought in line with International Accounting Standards. Some of the major changes included method of premium income, recognition of IBNR claims, creation of separate statutory funds for life business, introduction of premium deficiency etc. This was considered a major change at that time. 4 Developments in respect of Accounting regulation for Insurance companies – contd. • With the passage of almost 10 years now there have been further developments in the International Accounting Standards relating to insurance. • In 2004, the first Insurance specific IFRS-4 was issued and SECP made this applicable for insurance companies from period commencing from 1 January 2009. IFRS -4 did not change the existing accounting practices in any substantive way. It catered more of disclosure requirements than recognition and measurement. • Recently the IASB has issued exposure draft of IFRS-4 as part of its phase II for developing insurance specific standard. This is expected to change significantly the recognition and measurement requirements of insurance industry. 5 Some concerns in existing regulations • Difference in Financial Statements for Insurers and Other Sectors under the International Financial Reporting Standards (IFRS) • Total earnings of the Life Insurer not reflected completely • Consolidated financial statements are not required for investment by statutory funds • Applicability of IAS 39 and IAS 40 • Issues relating to calculation and classification of incurred but not reported claims – IBNR • Correct classification / allocation of Management Expenses • Recognition of Cover Note in the books of accounts • No basis of preparation for Statement of Exposures 6 Changes in presentation of Published Financial Statements The modified accounting regulations now prescribes format of Financial Statements in accordance with International Accounting Standards. A complete and detailed illustrative accounts have now been provided in Published Financial Statements format by SECP. This has been done to provide consistency across the insurance sector as done in banking sector. A comparison of existing and revised Statements comprising Financial Statements is given in the following slide. PwC 7 Changes in presentation of Published Financial Statements - contd . • Balance sheet • Statement of financial position • Profit and loss account • Statement of comprehensive income • Statement of cash flows • Statement of cash flows • Revenue account - • Statement of changes in equity • Notes to the accounts (for life insurers only) • Statement of premiums • Statement of claims • Statement of expenses • Statement of investment income PwC • Notes to the accounts 8 Comparison of balance sheet (Life insurers) Cash and Bank Deposits Cash and others Current and other accounts Deposits maturing within 12 months Fixed Deposits maturing after 12 months Loans Secured Against Life Insurance Policies Loans Secured Against other assets To employees To agents Others Unsecured Loans To employees or agents Others Investment Property Investment in subsidiaries and associates Fixed Income Securities Listed Equities Unlisted Equities Other Investments Government Securities Other Fixed Income Securities Listed Equities Unlisted Equities Mutual Funds Others (describe) Deferred Taxation Preliminary and Deferred Expenses Current Assets - Others Premiums due but unpaid Amounts due from other insurers/ reinsurers Investment Income Due but Outstanding Investment Income Accrued Taxation - payments less provision Prepayments Sundry receivables Others (please specify) Fixed Assets Tangible & Intangible Land and Builldings Furniture, Fixtures and Office Equipment Motor Vehicles Capital Work in Progress Intangibles (Please specify) TOTAL ASSETS Shareholders Aggregate Aggregate Fund Ordinary life Conventional Accident & current prior (investment business health year year linked) Note Assets Property and equipment Intangible assets Investment property Investments in subsidiaries and associates (applicable where equity accounting is followed) Investments Equity securities Government securities Debt securities Term deposits Mutual funds Others (please specifiy) Loans secured against life insurance policies Insurance / reinsurance receivables Other loans and receivables Deferred tax asset Taxation - payments less provision Prepayments Cash & Bank 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Total Assets Equity and Liabilities Capital and reserves attributable to Company's equity holders Ordinary share capital Share premium Reserves Unappropriated profit/(Accumulated loss) 19 20 Total Equity Surplus on Revaluation of Fixed Assets Liabilities Insurance Liabilities Liabilities under Investment Contracts Retirement benefit obligations Deferred taxation Borrowings Premium received in advance Insurance / reinsurance payables Other creditors and accruals Taxation - provision less payments Total Liabilities Total Equity and Liabilities Contingency(ies) and commitment(s) 21 Current Prior year year Rupees in thousand - - - - - - - - - - - - - - - - - - - - - - 22 23 16 24 25 26 27 Comparison of balance sheet (Life insurers) – contd. Share Capital and Reserves Authorised Share Capital Issued, subscribed and paid up Share Capital Accumulated Surplus/(Deficit) Other Reserves (describe) Less: Capital contributed by shareholders fund Net Shareholders' Equity Balance of statutory fund (including policyholder liabilities Rs. Prior year: Rs. ) Deferred Liabilities Deferred Taxation Staff Retirement Benefits Others Creditors and Accruals Outstanding claims (including IBNR) Premiums Received in Advance Amounts due to other insurers/reinsurers Amounts due to Agents Accrued Expenses Taxation - Provision less payments Other Creditors and Accruals (describe) Borrowings Short term running finance Loans received from banks Other loans Other debt security issued Other liabilities Other liabilities (please specify) TOTAL LIABILITIES TOTAL EQUITY AND LIABILITIES CONTINGENCIES AND COMMITMENTS (if applicable) Shareholders Aggregate Aggregate Fund Ordinary life Conventional Accident & current prior Assets (investment business health year year Property and equipment linked) Intangible assets Investment property Investments in subsidiaries and associates (applicable where equity accounting is followed) Investments Equity securities Government securities Debt securities Term deposits Mutual funds Others (please specifiy) Loans secured against life insurance policies Insurance / reinsurance receivables Other loans and receivables Deferred tax asset Taxation - payments less provision Prepayments Cash & Bank Note 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Total Assets Equity and Liabilities Capital and reserves attributable to Company's equity holders Ordinary share capital Share premium Reserves Unappropriated profit/(Accumulated loss) 19 20 Total Equity Surplus on Revaluation of Fixed Assets Liabilities Insurance Liabilities Liabilities under Investment Contracts Retirement benefit obligations Deferred taxation Borrowings Premium received in advance Insurance / reinsurance payables Other creditors and accruals Taxation - provision less payments Total Liabilities Total Equity and Liabilities Contingency(ies) and commitment(s) 21 Current Prior year year Rupees in thousand - - - - - - - - - - - - - - - - - - - - - - 22 23 16 24 25 26 27 Comparison of profit and loss (Life insurers) Current Year Prior Year Investment income not attributable to statutory funds Income from trading investments Gain/ loss on trading Dividend Income Others if any (please specify) Income from non-trading investments Held to maturity or Available for sale (classify as appropriate) Return on government securities Return on other fixed income securities and deposits Dividend income Others (please specify) Gain/(Loss) on Sale of Investments Available for sale Gain/(Loss) on revaluation of investments Trading investments Available for sale Provision for Impairment in Value of investments Provision for portfolio held to maturity Provision for portfolio available for sale Less: Investment Related Expenses Net Investment Income Rental income from investment property Other revenue (provide details) Less: Expenses not attributable to statutory funds (provide details) Add: Surplus transferred from statutory funds Profit/(Loss) before tax (and extraordinary items, if any) Extraordinary items (provide details) Profit/(Loss) before Tax and after extraordinary items Tax expense Profit/(Loss) after tax Profit and Loss appropriation account Balance at commencement of the year Profit for the year Prior year adjustment (provide details) Dividends paid Transfers to / (from) reserves PwC Other appropriations (provide details) Balance at end of year Note Premium Revenue Premium ceded to reinsurers Net premium revenue Fee income Net investment income Net rental Income Net realised gains / losses on investment property Net unrealised gains / losses on investment property Other income / loss 28 Current Year - Prior Year - 29 30 31 - - 32 - - Net income - - Insurance benefits Recoveries from reinsurers Claims related expenses Net claims - - 33 Acquisition expenses Marketing and administration expenses Other expenses Total Expenses 34 35 36 - - Finance costs 37 - - Excess of Income over Claims and Expenditure - - Add: Policyholder liabilities at beginning of year Less: Policyholder liabilities at end of year Results of operating activities Share of (loss)/profit of associates Profit before tax Income tax expense Profit for the year Other comprehensive income: - - Change in unrealised gains/(losses) on available-for-sale financial assets Currency translation differences (related to net investment in foreign currency) Other comprehensive income for the year, net of tax - - - - - - Total comprehensive income for the year Earnings (after tax) per share - Rupees - 38 39 11 - Comparison of balance sheet (Non - life insurers) Share Capital and Reserves Domestic companies Authorised Share Capital Paid-up share capital Retained earnings Reserves Other equity (please specify) Foreign companies Head office account Other equity (please specify) Current Prior year year Cash and Bank Deposits Cash and other equivalent Current and other accounts Deposits maturing within 12 months Deposits maturing after 12 months Loans (Secured or un-secured - classify as appropriate) To employees To agents Others Investments Investment Property Underwriting provisions Provision for outstanding claims (including IBNR) Provision for unearned premium Commission income unearned Total underwriting provisions Deferred Liabilities Deferred Taxation Staff Retirement Benefits Others (please specify) Creditors and Accruals Premiums Received in Advance Amounts due to other insurers/reinsurers Accrued Expenses Taxation - Provision less payments Other Creditors and Accruals (describe) Borrowings Short term running finance Loans received from banks Other loans Other debt security issued Deferred Taxation Preliminary and Deferred Expenses Current Assets - Others Premiums due but unpaid Amounts due from other insurers/ reinsurers Reinsurance recoveries due but unpaid Reinsurance recoveries against outstanding claims Salvage recoveries accrued Premium and claim reserves retained by cedants Accrued investment income Taxation - payments less provision Deferred commission expense Other deferred acquisition costs Prepayments Sundry receivables(provide details) Fixed Assets Tangible & Intangible Land and Builldings Furniture, Fixtures and Office Equipment Motor Vehicles Capital Work in Progress Intangibles (Please specify) Other liabilities Other liabilities (please specify) TOTAL LIABILITIES TOTAL EQUITY AND LIABILITIES CONTINGENCIES AND COMMITMENTS (if applicable) TOTAL ASSETS Current year Note Prior year Current Prior year year Rupees in thousand Assets Property and equipment Intangible assets Investment property Investments in subsidiary and associate Investments Equity securities Debt securities Term deposits Loans and other receivables Insurance / Reinsurance receivables Reinsurance recoveries against outstanding claims Salvage recoveries accrued Deferred Commission Expense / Acquisition cost Deferred taxation Taxation - payment less provisions Prepayments Cash & Bank Total Assets 5 6 7 8 - - 9 10 11 12 13 - - - - - - - - -- -- Total Equity - - Surplus on revaluation of fixed assets - - - - - - - - 29 15 16 17 Equity and Liabilities Capital and reserves attributable to Company's equity holders Ordinary share capital Share premium Reserves Unappropriated profit/(Accumulated loss) Liabilities Underwriting Provisions Outstanding claims including IBNR Unearned premium reserves Premium deficiency reserves Unearned commission income Retirement benefit obligations Deferred taxation Borrowings Premium received in advance Insurance / Reinsurance Payables Other Creditors and Accruals Taxation - provision less payment Total Liabilities Total Equity and Liabilities Contingency(ies) and commitment(s) 18 19 27 24 26 14 15 20 21 22 23 Comparison of profit and loss (Non - life insurers) Note Fire Marine, Motor Act Liability Others Treaty Current Prior & Aviation & Year Year Property Transport AggregateAggregate Net insurance premium Revenue Account Net Premium Revenue Net Claims Premium Deficiency Expenses Net Insurance Claims Premium Deficiency Net commission and other acquisition cost Note 24 25 26 Insurance claims and acquisition expenses Current Prior year year Rupees in thousand - - - - Expenses Net Commission Underwriting result Investment Income Rental Income Other Income (provide details) General and administration expenses Profit/(Loss) before tax Provision for Taxation Profit/(Loss) after tax Profit and Loss Appropriation Account Balance at commencement of year Profit/Loss after tax for the year Prior Year Adjustments (provide details) Proposed Dividend/Remittance to Head Office Transfers to/(from) reserves (provide details) Other appropriations (provide details) PwC Balance Unappropriated Profit/(Loss) at end of Year Management Expenses Underwriting results 27 - - Investment income Rental income 28 29 - - Other income Other expenses Results of operating activities 30 31 - - Finance costs Share of (loss)/profit of associates Profit before tax 32 - - Income tax expense 33 Profit after tax Other comprehensive income: Unrealised gains / (losses) on available-for-sale investments Others (please specify) Other comprehensive income for the year Total comprehensive income for the year Earnings (after tax) per share - Rupees 34 - - - - - - Change in presentation of Financial Statements - contd . Segmental information to be disclosed The segment information which at present is given on the face of the profit and loss account and the information in the statements of premiums, claims, investment income and expenses have now been presented in the note Segment Information. Revenue Account in the life insurers financial statements now also forms part of the Segment Information. Additionally Segmental results by line of business are now to be disclosed: o o an analysis between group life, group health, individual life distributed through direct sales force, individual life distributed through banks; an analysis between business written in Pakistan and business written outside Pakistan. PwC 14 Presentation of insurance liabilities One of the major changes in the modified accounting regulations for life insurers relates to the classification of insurance liabilities: 1. Balance of statutory funds Previously, retained earnings accounts A to D were part of balance of statutory funds which was disclosed after the Shareholders’ Equity. In the modified accounting regulations retained earnings accounts C and D, which are effectively arising out of surplus of the statutory funds attributable to the shareholders are therefore made part of shareholders’ equity. PwC 15 Presentation of insurance liabilities – contd. 2. Incurred But Not Reported Claims (IBNR) IBNRs were previously made part of Policyholder Liabilities on the basis that these are determined by actuaries and payable to policyholders. However, the nature of IBNR is different from policyholder liabilities in that IBNR is something where the claim event has actually happened but yet to be reported to the insurer. Whereas, policyholder liability is in respect of future event. The revised format of Financial Statements includes IBNR as insurance liabilities after outstanding claims. PwC 16 Presentation of insurance liabilities – contd. EXISTING BALANCE SHEET LINE ITEMS • Outstanding Claims • Balance of statutory fund Balance of statutory fund includes: o Policyholder liabilities (including IBNR) o Balance in ledger account A POST CHANGE BALANCE SHEET LINE ITEMS • Insurance Liabilities • Unappropriated Profit / (Loss) Insurance Liabilities include: o Outstanding claims o IBNR o Policyholder liabilities o Balance in ledger account A o Balance in ledger account B o Balance in ledger account B o Balance in ledger account C PwC o Balance in ledger account D 17 Applicability of IAS 27, IAS 39 and IAS 40 • As per existing regulations, insurers are given certain exemptions from IAS 27, IAS 39 and IAS 40. • However, revised regulations have encouraged compliance with IFRS, therefore these exemptions have been withdrawn. • These are presented in next slides. PwC 18 Applicability of IAS 27, IAS 39 and IAS 40 – contd. Applicability of IAS 27 As per existing regulations, consolidated published financial statements in respect of investments made through statutory funds is not required to be presented. However, this exemption has been withdrawn in modified regulations. PwC 19 Applicability of IAS 27, IAS 39 and IAS 40 – contd. Applicability of IAS 39 The existing regulations requires available for sale investments to be valued at lower of cost or market value. Now the accounting regulations adopts the requirements of IAS 39 completely and all investments requiring marked to market will be valued accordingly. PwC 20 Applicability of IAS 27, IAS 39 and IAS 40 – contd. Applicability of IAS 40 Under IAS 40 companies have the option to select accounting policy of valuing investment property either on cost or fair value basis. The existing regulations however provides restriction and do not allow the use of fair value option. The revised accounting regulation removes this restriction. PwC 21 Recognition of Cover Note in the books of accounts In non-life insurance business, particularly in Marine Insurance there is a practice of issuing cover notes for temporary period which remain in force until the insurance policy is issued. It was observed that the insurance companies start recognising the accounting for such transactions only when the insurance policy is issued. However, it was viewed that the company needs to record the transaction since its inception. The existing and revised requirements of the accounting regulations are in the next slide: PwC 22 Recognition of Cover Note in the books of accounts- contd. EXISTING Premium receivable under a policy shall be recognised as written from the date of attachment of the policy to which it relates. REVISED Premium receivable under a policy / cover note shall be recognised as written from the date of attachment of risk of the policy / cover note. PwC 23 Explanation of management and other expenses – non-life insurers Previously, there was no explanation of ‘expenses’ and ‘general and administrative expenses’ for non-life insurers. However, in modified accounting format ‘management expenses’ and ‘other expenses’ have been identified. Following are included in other expenses in modified format: o Legal and professional fee other than business related o Auditors’ remuneration o Subscription o Registration fee o Expenses of bonus issue o Donations o PwC Workers Welfare Fund 24 Change in premium deficiency requirement Existing Revised Where the unearned premium liability The provision for premium for any class of business is not adequate deficiency (liability adequacy test) to meet the expected future liability, after shall be recognised in accordance reinsurance, from claims and other with the requirements given in expenses, including reinsurance expense, International Financial Reporting commissions and other underwriting Standard 4 – Insurance Contracts. expenses, expected to be incurred after balance date in respect of policies in that class of business in force at balance date, a premium deficiency reserve shall be recognised to meet the deficit. PwC 25 Change in premium deficiency requirement– contd. Liability adequacy test IF Liability less related deferred acquisition cost and intangible assets Current estimates of future contractual cash flows then recognise deficiency in profit and loss If an insurer's liability adequacy test meets the minimum requirements as above, the test is applied at the level of aggregation specified in that test. PwC 26 Key issues highlighted in modified regulations – life insurance Possible adverse impact of taxation • The taxability of life insurers is computed as per the provisions of Fourth Schedule of Income Tax Ordinance, 2001. As per the Fourth Schedule only the amount of surplus transferred from revenue account to profit and loss account is subject to taxation. • The existing regulations present separate revenue account and profit and loss account in which the transfer of surplus from revenue account to profit and loss account is separately disclosed. PwC Page 27 27 Key issues highlighted in modified regulations – life insurance – contd. Possible adverse impact of taxation • In the modified accounting regulations there will be no revenue account and profit and loss account is prepared on a combined basis for all statutory funds and shareholders fund therefore, the transfer of surplus would not be separately identifiable on the face of profit and loss account. • The life insurance industry strongly feels that unless the requirements of Income Tax Ordinance are changed to reflect the new accounting regulations, taxation authorities may create huge demands on the insurance companies. PwC Page 28 28 n issues highlighted in modified regulations – life Key insurance – contd. The amount representing solvency margin in account D shall not be taken as equity. The surplus of any statutory fund which is not yet transferred to profit and loss account is disclosed as ledger account D relating to non participating business. This amount may be held in view of solvency margins. It is viewed that since there is a restriction on transfer such amount should be treated as liability. PwC Page 29 29 n Thank you PwC Page 30