Practical approaches to the Own Risk and Solvency Assessment Casualty Actuaries in Europe (CAE) Spring meeting May 31st 2013 Caspar Richter, CEO, Actuary M.Sc. Caspar.Richter@SolvencyTool.com Agenda Title: Practical approaches to ORSA Duration: 50 minutes Examples of tables of contents Brush up on legislation Risk identification Planning for the future 2 Stress test and scenarios Copyright SolvencyTool ORSA A few questions How many have read the ORSA guidelines from EIOPA? How many have participated in doing an ORSA? How many have done it several years? …I hope at least to give you some inspiration! 3 Copyright SolvencyTool ORSA Initial thoughts Personal statement A personal point of view: Establish your governance system and risk management setup Get your processes and reporting for this up and running Now ORSA should be a short document summarizing all this at the end of the year 4 Copyright SolvencyTool ORSA Reporting structure Example of contents 1. Executive summary 2. General setup a) Company structure and ORSA approach b) Strategy and business model (main products, distribution channels, growth plans etc.) c) Risk identification and risk management 3. New and expired risks and incidents during the year 4. Own Risk and Solvency Assessment a) Basic own funds and solvency capital requirement as at 31st Dec 2012 b) Stress tests and scenario analyses c) Reverse stress tests 5. Performance of ORSA related processes during the year a) Compliance with predefined risk limits b) Compliance with other risk management setup 6. Expectations for the future (3-5 years) a) Capital target b) Capital and risk planning (projections of BOF, SCR and MCR) c) Contingency planning 7. Conclusion and actions 5 Copyright SolvencyTool Agenda Title: Practical approaches to ORSA Duration left: 45 minutes Examples of tables of contents Brush up on legislation Risk identification Planning for the future 6 Stress test and scenarios Copyright SolvencyTool Risk identification Typically used to provide documentation for the risk management process. Strengthens the forward-looking perspective Typical process to update the risk register and get support for ORSA Step 1 Identify Step 2 Select Step 3 Assess Step 4 Approve Bottom-up Top-down Bottom-up Top-down Risk owners identify emerging risks and expired risks Risk owners evaluate risks about to expire 7 AMSB chooses important risks for the company / group Risk owners assess the important risks (qualitative assessment and possible quantitative as well) Chief Risk Officer selects final assessment of all risks Copyright SolvencyTool AMSB approves important risks and their assessment Risk identification Typically used to provide documentation about the risk management process. Strengthens the forward-looking perspective Some risk managers establish links for each risk to Solvency II model, organisation, risk owners etc. Risk register In internal risk committees risk owner decide on a common understanding of the risk matrix (likelihood and severity) 8 Copyright SolvencyTool Risk identification Typically used to provide documentation about the risk management process. Strengthens the forward-looking perspective Discussion in risk committees can be very important to get the full picture Basis: Risk identification spring 2012 (01-02-2012 - 28-02-2012) (Published) Risk: Too many manual processes Risk description: In the financial division there are several manual processes without automatic and independent control. Control procedures should be improved to minimize the risk of human errors. CRO responsible Risk owner Risk owner John Doe Christian Armstrong David Schulz Likely Unlikely Possible Small Medium Medium Impact amount (Gross) 0 0 0 Impact amount (Net) 0 0 0 Medium Medium Medium Responsible Probability Probability percent Impact Rating Priority Module for model Operational Involve risk owners Listen to opinions Discuss aspects on probability and severity Get consensus Reevaluate existing risks Identify emerging risks Sub model Risk accepted Risk significant for board Risk reduction necessary Risk reduction implemented Implementation date Description of risk reduction action 9 Copyright SolvencyTool Risk identification Typically used to provide documentation about the risk management process. Strengthens the forward-looking perspective Demonstrate that new risks are identified and necessary action is taken 10 Copyright SolvencyTool ORSA Reporting structure Example of contents 1. Executive summary 2. General setup a) Company structure and ORSA approach b) Strategy and business model (main products, distribution channels, growth plans etc.) c) Risk identification and risk management 3. New and expired risks and incidents during the year 4. Own Risk and Solvency Assessment a) Basic own funds and solvency capital requirement as at 31st Dec 2012 b) Stress tests and scenario analyses c) Reverse stress tests 5. Performance of ORSA related processes during the year a) Compliance with predefined risk limits b) Compliance with other risk management setup 6. Expectations for the future (3-5 years) a) Capital target b) Capital and risk planning (projections of BOF, SCR and MCR) c) Contingency planning 7. Conclusion and actions 11 Copyright SolvencyTool Agenda Title: Practical approaches to ORSA Duration left: 30 minutes Examples of tables of contents Brush up on legislation Risk identification Planning for the future 12 Stress test and scenarios Copyright SolvencyTool Stress test and scenarios A short list of possibilities Further explanations on slides to come Example of approaches Sensitivity of parameters or assumptions Taylor series of the SCR Historical incidents and losses Use of market data Stress tests Scenarios as simple aggregation Combination 1 of stress tests Combination 2 of stress tests … Stress test 1 Stress test 2 Stress test 3 … What are the implications? Or reverse stress testing • • • • • • 13 BOF below capital target BOF below SCR BOF below MCR What can cause insolvency? Certain combinations? Certain events? Copyright SolvencyTool Stress test and scenarios Sensitivity of parameters or assumptions Simple lists Risk Event Claim frequency increased Loss = 10% of earned premiums Run-off losses Loss = 5% of tech. provisions 56 mEUR Large losses Loss = 3% of earned premiums 40 mEUR Nat. CAT Basis: Market loss of 1,338 mEUR 23 mEUR … Comments • • • 14 Involve AMSB in this Take historical experience into consideration Use partial internal model if relevant Copyright SolvencyTool Impact 133 mEUR Stress test and scenarios Taylor series of the SCR Simple explanation of changes Level 1 Risk BSCR SCRop Adj SCR Amount 1.531.652 100.000 -250 1.631.402 Factor 100,0% 100,0% 100,0% Amount 150.001 100.000 500.000 1.300.000 25.000 -518.349 1.531.652 Factor 41,5% 60,6% 12,4% 37,3% 92,1% 100,0% Solvency Capital Requirement: 𝑆𝐶𝑅 = 𝐵𝑆𝐶𝑅 + 𝑆𝐶𝑅𝑂𝑝 + 𝐴𝑑𝑗 Taylor series: Changes in SCROp and Adj have 100% effect on SCR Level 2 Risk SCRmkt SCRdef SCRlife SCRhealth SCRnl SCRint Diversification BSCR SCRmkt SCRdef SCRlife SCRhealth SCRnl 100% 25% 25% 25% 25% 25% 100% 25% 25% 50% 25% 25% 100% 25% 0% 25% 25% 25% 100% 0% 25% 50% 0% 0% 100% Basic Solvency Capital Requirement: 𝐵𝑆𝐶𝑅 = 𝑖,𝑗 𝐶𝑜𝑟𝑟𝑖 , 𝑗 × 𝑆𝐶𝑅𝑖 × 𝑆𝐶𝑅𝑗 + 𝑆𝐶𝑅𝐼𝑛𝑡 Taylor series: 𝐹𝑎𝑐𝑡𝑜𝑟𝑖 = 𝑗 15 Copyright SolvencyTool 𝐶𝑜𝑟𝑟𝑖, 𝑗 × 𝑆𝐶𝑅𝑗 (𝐵𝑆𝐶𝑅 − 𝑆𝐶𝑅𝐼𝑛𝑡) Stress test and scenarios Taylor series of the SCR Simple explanation of changes Further remarks: The SCR calculation is hierarchical Factors are relative to a parent Factors could be multiplied up through the modules Thereby changes could be explained directly by e.g. variations in claim provisions, premiums etc. And contributions are additive! Example of use of Taylor series for market risk Market risks Interest Equity Q1 2013 Q2 2013 Change % Effect on SCR 68.687 52.215 -16.472 33% -5.436 6.592 6.421 -172 9% -15 Property 4.694 4.688 -6 22% -1 Spread 37.169 34.323 -2.846 23% -655 0 0 0 0% 0 13.506 14.218 711 16% 114 0 0 0 0% Concentration Currency Counter-cyclical premium Total 16 0 -5.993 Copyright SolvencyTool Stress test and scenarios Historical losses or near misses Link them to the solvency II modules and risk identification Results of SCR calculation should be compared with historical data Loss identification Loss identification spring 2012 (01-02-2012 - 28-02-2012) (Published) CRO responsible Loss Loss description John Doe Mass accident On a small commercial business there w as an accident with a machine. 7 people w ere involved. 03-02-2011 800.000 John Doe Industrial fire Fire on a big pow erplant causing huge property damage and loss of profit claims. 14-06-2010 11.000.000 John Doe Windstorm There w as a minor w indstorm in 2010 causing losses across the country. 15-01-2010 7.500.000 Increase in thefts The number of burglaries in private homes have increased over the past years and reached a maximum in 2009. 01-07-2009 6.000.000 Reinsurer bankrupt Utopia Re w ent bankrupt and the company had to clean cut a few treaties. 01-02-2009 250.000 John Doe Loss on equities Financial crisis in 2008 / 2009 caused a severe decrease in the value of equities. 01-03-2009 8.000.000 John Doe Loss on CDO's Financial crisis in 2008 / 2009 caused a severe decrease in the value of CDO's. 01-03-2009 100.000 Date of loss Estim ate of total gross loss Was loss an Description of loss reduction action Loss was identified risk reduced Large claims Reinsurance programme covered the claim. The loss w as covered by reinsurance. Increased claim frequency John Doe Premiums increased Reinsurers John Doe Assets losing value 17 Copyright SolvencyTool Limit in total amount of equities. Change of investment guidelines. No more uncommon investment types w ill be used in the future. ORSA Reporting structure Example of contents 1. Executive summary 2. General setup a) Company structure and ORSA approach b) Strategy and business model (main products, distribution channels, growth plans etc.) c) Risk identification and risk management 3. New and expired risks and incidents during the year 4. Own Risk and Solvency Assessment a) Basic own funds and solvency capital requirement as at 31st Dec 2012 b) Stress tests and scenario analyses c) Reverse stress tests 5. Performance of ORSA related processes during the year a) Compliance with predefined risk limits b) Compliance with other risk management setup 6. Expectations for the future (3-5 years) a) Capital target b) Capital and risk planning (projections of BOF, SCR and MCR) c) Contingency planning 7. Conclusion and actions 18 Copyright SolvencyTool Agenda Title: Practical approaches to ORSA Duration left: 15 minutes Examples of tables of contents Brush up on legislation Risk identification Planning for the future 19 Stress test and scenarios Copyright SolvencyTool Planning for the future Capital and risk planning Contingency plans Current year Year + 1 Year + 2 Year + 3 Year + 4 BOF before dividends Dividends Basic own funds Capital target SCR Green SCR limit Yellow SCR limit Comments: A few examples of capital target: (1 + loading) * SCR SCR + buffer Factor * Earned premiums Capital target should reflect the risk appetite defined by AMSB and the stress and scenario testing Projections could be made by simple scaling or by use of expected development in most important risk drivers Red SCR limit MCR 20 Copyright SolvencyTool Year + 5 Planning for the future Risk appetite from top level to bottom Establish key risk indicators Simple approach to risk appetite and key risk indicators • Risk appetite: Create 3 limits on top level • Green, yellow and red limit for SCR • Apply limits for all modules by use of factor • Simple way to construct indicators that single risks are increasing more than accepted • Specific actions can be initiated if respectively green, yellow or red limit is exceeded • Contingency plans are hereby made concrete and far more practical on a detailed level Key risk indicator for each of the modules: Green: Below low limit Yellow: Between low and middle limit Red: Between middle and high limit Black: High limit is exceeded 21 Copyright SolvencyTool ORSA Reporting structure Example of contents 1. Executive summary 2. General setup a) Company structure and ORSA approach b) Strategy and business model (main products, distribution channels, growth plans etc.) c) Risk identification and risk management 3. New and expired risks and incidents during the year 4. Own Risk and Solvency Assessment a) Basic own funds and solvency capital requirement as at 31st Dec 2012 b) Stress tests and scenario analyses c) Reverse stress tests 5. Performance of ORSA related processes during the year a) Compliance with predefined risk limits b) Compliance with other risk management setup 6. Expectations for the future (3-5 years) a) Capital target b) Capital and risk planning (projections of BOF, SCR and MCR) c) Contingency planning 7. Conclusion and actions 22 Copyright SolvencyTool Agenda Title: Practical approaches to ORSA Duration left: 5 minutes Examples of tables of contents Brush up on legislation Risk identification Planning for the future 23 Stress test and scenarios Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment General considerations • Guideline 1: Principle of proportionality • Guideline 2: Role of the administrative, management or supervisory body (top-down approach) • Guideline 3: Documentation – – – – 24 ORSA policy; Record of each ORSA; Internal report on ORSA; and ORSA supervisory report. Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment Observations • Adapt ORSA according to the complexity of your company • Involve the senior management and the board • Secure audit trails and internal procedures and write a report 25 Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment ORSA policy • Guideline 4: ORSA policy includes at least – a description of the processes and procedures in place to conduct the ORSA including how the forward-looking perspective is addressed; – consideration of the link between the risk profile, the approved risk tolerance limits and the overall solvency needs; – information on: • • • 26 (i) how stress tests, sensitivity analyses or reverse stress testing are to be performed and how often they are to be performed; (ii) data quality requirements; and (iii) the frequency and timing for the performance of the (regular) ORSA and the circumstances which would trigger the need for an ORSA outside the regular timescales. Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment Observations • Explain how ORSA is forwardlooking • Risk tolerance limits should be included • Explain what triggers an ORSA outside the regular timescale 27 Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment Record of ORSA • Guideline 5: Appropriately evidenced and documented internally Internal report • Guideline 6: Make sure that relevant people receive information on ORSA results 28 Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment Observations • Remember to inform internally about the results of ORSA 29 Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment Performance of ORSA • • • • • • Guideline 7: Valuation and recognition Guideline 8: Assessment of the overall solvency needs Guideline 9: Forward-looking perspective Guideline 10: Regulatory capital requirements Guideline 11: Technical provisions Guideline 12: Deviations from the assumptions underlying the SCR calculation • Guideline 13: Link to the strategic management process and decision making framework • Guideline 14: Frequency of ORSA 30 Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment Observations • Consider how the overall solvency needs should be assessed • Check for deviations from assumptions underlying the SCR • Be sure to link business strategy and ORSA 31 Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment Group specificities of the ORSA • • • • • Guideline 15: Scope of the group ORSA Guideline 16: Reporting to the supervisory authorities Guideline 17: Assessment of overall solvency needs Guideline 18: General rule for group ORSA Guideline 19: Specific requirements for a single ORSA document covering the participating insurance or reinsurance undertaking or the insurance holding company and any subsidiary in the group • Guideline 20: Internal model users • Guideline 21: Integration of related third-country insurance and reinsurance undertakings 32 Copyright SolvencyTool Brush up on legislation EIOPA Final Report on Public Consultation No. 11/008 On the Proposal for Guidelines On Own Risk and Solvency Assessment Observations • Consider if separate ORSA reports should be written for each company in the group or if one could do the job • Make sure to take into consideration the actual ability to move basic own funds from one company to another in the group • Use internal model results 33 Copyright SolvencyTool End of presentation Title: Practical approaches to ORSA Questions are welcome Contact details: Caspar Richter, CEO, Actuary M.Sc. Caspar.Richter@SolvencyTool.com +45 6086 3604 34 Copyright SolvencyTool