Dopad Solvency II na produkty životního pojištění Seminář z aktuárských věd Praha 11. listopadu 2011 Agenda 1 Introduction Economic Balance Sheet Approach & QIS5 results Solvency Capital Requirement & QIS5 results 2 Impact of SII on Life Insurance Products Traditional Participating Life Insurance Products Unit-Linked Products Risk Products Annuities Life Products Summary 2 3 Impact of SII on Asset Liability Management 4 Conclusions Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Introduction What is Solvency II? • Solvency II is a new solvency regime for all EEA insurers and reinsurers • It is based on three guiding principles (pillars) which cut across market, credit, liquidity, operational and insurance risk Pillar 1 Quantitative Market Risk Market Risk Credit Risk Credit Risk Liquidity Risk Liquidity Risk Operational Risk Operational Risk Pillar 1 Quantitative Requirements Regulations on minimum capital Regulations on requirements minimum capital requirements Requirement (SCR) Solvency Capital Requirement (SCR) Technical provisions Technical provisions SOLVENCY II Pillar 2 SOLVENCY II Qualitative Pillar 2 Requirements & Rules onQualitative Supervision Requirements & Rules on Supervision Regulations on financial services supervision Regulations on financial services supervision Own Risk and Solvency Pillar 3 Supervisory Pillar 3 Reporting and Public Supervisory Disclosure Reporting and Public Disclosure Transparency Transparency Assessment (ORSA) Own Risk and Solvency Assessment (ORSA) Capabilities and powers Disclosure requirements of regulators, areas of Capabilities and powers activity of regulators, areas of activity Competition related elements Competition related elements Disclosure requirements Underwriting Risk Investment Rules Quantification 4 Dopad Solvency II na pojistné produkty Governance Disclosure © 2011 Deloitte Česká republika Solvency II timetable 2010 2009 QIS L1 L2 Nov 08 QIS4 results published Apr /May 09 SII Directive approved by European Parliament / by Council Mar 09, Jul 09, Nov 09 CEIOPS issued L2 consultation papers Mar 11 QIS5 report published Dec 09 SII Directive published Jan 11 Omnibus II Directive drafted Nov 09, Jan 10, Apr 10: CEIOPS Final L2 advice submitted to EC EC proposals for L2 measures Jan 12 Omnibus II adoption Commission Freeze Level 2 Delegated Acts Endorsement Apr-Dec 11: EIOPA drafts binding technical standards. End Dec 11: Final proposal for BTS to EC BTS Oct 10-Dec 11 EIOPA develops L3 guidelines Pre-consultation on L3 guidelines with selected stakeholders (not public) L3 5 Jul 10 CEIOPS published QIS5 spec 2012 2011 Dopad Solvency II na pojistné produkty Consultation and adoption © 2011 Deloitte Česká republika Economic Balance Sheet Approach & QIS5 results Economic Balance Sheet Approach • Capital requirement should be based on a total balance sheet approach based on economic valuation of all assets and liabilities. • An economic valuation of assets and liabilities implies that: • Assets should be valued at market value where this is both available and provides a reliable and appropriate valuation or mark-to-model value where this is not the case • Liabilities should be value on a best-estimate basis (economic value of liabilities) • Economic value of liabilities: • Expected present (based on risk free curves) value of future liability cash flows using best estimate assumptions i.e. not including prudence • Value of embedded financial obligations, including options and guarantees • Risk Margin (RM) for non-hedgeable financial and non-financial risks • Difference between economic value of assets and liabilities gives net asset value (NAV), also called own funds or available capital 7 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika From Solvency I to Solvency II Solvency I Solvency II Free Surplus Free Surplus Solvency I Capital Requirement Book value of Assets Statutory Technical Provisions Solvency II capital requirement (SCR) Revaluation of technical provisions Minimum capital requirement (MCR) Market Value of Assets Assets covering technical provisions, the MCR and the SCR • • 8 Risk margin Best estimate • Solvency II valuation rules Solvency II available capital (own funds) Technical provisions Both assets and liabilities are to be fair-valued (market value of assets and liabilities). Assets also contain the reinsurance recoverables (after correction for default risk of the reinsurer). An explicit risk margin (market value margin) is to be added to the fair value of the liabilities (Best Estimate) to give the technical provisions. This risk margin should be calculated using the Cost of Capital method. © 2011 Deloitte Česká republika Czech Republic (QIS5): Development of own funds CZK bn. 100 90 80 EPIFP 70 60 50 40 30 20 10 0 Source: Deloitte – QIS5 Results Consolidation for Czech Insurance Association (ČAP) Note: Data for all the insurance companies (life, non-life, composite) that submitted data to CAP (35 insurance companies, 23 participated in QIS 5, 18 submitted to CAP) 9 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Czech Republic (QIS5): Revaluation of technical provisions Source: Deloitte – QIS5 Results Consolidation for Czech Insurance Association (ČAP) Note: Based on submissions to CAP 10 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Revaluation of life technical provisions – comparison of CZ and EEA Source: Česká národní banka – Prezentace výsledků QIS5 11 Dopad Solvency II na pojistné produkty – dodatek © 2011 Deloitte Česká republika Solvency II and market consistent valuation Comparison of Own Funds and Embedded Value Adjusted Balance sheet & Embedded Value Solvency II Adjusted Statutory Equity (ANAV) Own funds CRNHR Risk margin Assets Assets Best estimate Embedded Value CE PVFP FCRC TVOG SII Technical provisions Statutory technical provisions • • Solvency II own funds and Embedded Value (EV) are closely related concepts The very same cash-flow projection can be used to calculate EV and SII technical provisions – projection of future profits (FP) under EV includes changes in statutory TP and investment income on statutory TP, the present value (PV) of these two items is equal to starting amount of statutory provisions if discounted by the consistent discount rate (RFR), thus: 𝑃𝑉 𝐹𝑃 = 𝑃𝑉 𝑝𝑟𝑒𝑚𝑖𝑢𝑚 − 𝑃𝑉 𝑜𝑢𝑡𝑔𝑜𝑒𝑠 𝐵𝐸 − 𝑃𝑉 𝑒𝑥𝑝𝑒𝑛𝑐𝑒𝑠 𝐵𝐸 − 𝑃𝑉 ∆𝑇𝑃 𝑠𝑡𝑎𝑡 + 𝑃𝑉 𝑖𝑛𝑣𝑒𝑠𝑡𝑚𝑒𝑛𝑡 𝑖𝑛𝑐𝑜𝑚𝑒 𝐶𝐸 𝑃𝑉𝐹𝑃 = −𝑇𝑃𝐵𝐸 + 𝑇𝑃 𝑠𝑡𝑎𝑡 12 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Solvency Capital Requirement & QIS5 results Solvency Capital Requirements Standard formula in QIS5 SCR BSCR Adj SCROp Correlation SCRNonLife SCRMarket Correlation Correlation Premium and reserve Lapse CAT SCRDefault Equity Spread Interest rate Concentration SCRHealth SCRLife Correlation Correlation Health SLT Lapse Mortality Health NonSLT Longevity Life Cat Health CAT Disability Morbidity Revision Life Expense Property Currency SCRIntang = included in the adjustment for the loss-absorbing capacity of technical provisions under the modular approach Illiquidity 14 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika SCR A d j Solvency Capital Requirement SCRNonLife Premiu m and reserve Life Underwriting Risk SCRMarket Spread Interest rate SCROp SCRDefault Equity Lapse CAT BSCR Con centratio n SCRHealth Mortality Longevity Disability Lapse SCRIntang Health SLT Lapse Mortalit y Health NonSLT Longevit y Life Cat Health CAT Disabilit y Revisio n Life Expens e Propert y SCRLife SCR Life FX Expense Revision Cat SCR for life underwriting risk • The capital charge for each life underwriting risk is first calculated and then a correlation matrix is used to determine the overall SCRlife Mortality Longevity Disability Lapse Expense Revision Mortality 1 Longevity -0.25 1 Disability 0.25 0 1 Lapse 0 0.25 0 1 Expense 0.25 0.25 0.5 0.5 1 Revision 0 0.25 0 0 0.5 1 Cat 0.25 0 0.25 0.25 0.25 0 15 Cat 1 © 2011 Deloitte Česká republika SCR A d j SCR Life Underwriting Risk Calibration SCRNonLife Premiu m and reserve SCRMarket Spread Interest rate Propert y SCROp SCRDefault Equity Lapse CAT BSCR Con centratio n SCRHealth SCR Life SCRIntang Health SLT Lapse Mortalit y Health NonSLT Longevit y Life Cat Health CAT Disabilit y Revisio n Life Expens e FX Approach • Aside from the lapse sub-module all capital requirements are determined by a single direction shock on the net value of assets minus liabilities • Example: Lifeexp = ΔNAV | expshock Risk QIS5 Draft TS Mortality Permanent increase mortality rates with 15% applicable to obligations contingent on mortality risk i.e. where the amount currently payable on death exceeds the technical provisions. Where (re)insurance obligations provide benefits both in case of death and survival and the death and survival benefits are contingent on the life of the same insured person(s), these obligations should not be unbundled (floor of 0 at contract level). Longevity Permanent decrease mortality rates with 20% applicable to obligations contingent on longevity risk i.e. there is no death benefit or where the amount currently payable on death is less than the technical provisions. Where (re)insurance obligations provide benefits both in case of death and survival and the death and survival benefits are contingent on the life of the same insured person(s), these obligations should not be unbundled (floor of zero at contract level). Disability A 35% increase in disability inception rates and a 25% increase for subsequent years. Plus, where applicable, a permanent decrease of 20% in recovery rates (combined stress). Applicable for obligations contingent on a definition of disability (compensation of losses or medical expenses due to illness, accident or disability / where morbidity acts as an acceleration of payments or obligations which fall due on death). Is likely to be applied only in cases where it is not appropriate to unbundle contracts (otherwise in health module instead of life module). 16 © 2011 Deloitte Česká republika SCR A d j SCR Life Underwriting Risk Calibration SCRNonLife Premiu m and reserve SCRMarket Spread Interest rate Propert y SCROp SCRDefault Equity Lapse CAT BSCR Con centratio n SCRHealth SCR Life SCRIntang Health SLT Lapse Mortalit y Health NonSLT Longevit y Life Cat Health CAT Disabilit y Revisio n Life Expens e FX Risk QIS5 Draft TS Lapse Shock up and down of 50% of lapse rates (but limited to a maximum change). Lapse mass shock of 30% of surrender strains for retail business and 70% for non-retail business. Expense Increase of 10% in future expenses compared to best estimate anticipations and increase by 1% per annum of the inflation rate compared to anticipations. Revision Increase of 3% in the annual amount payable for annuities exposed to revision risk. Only to be applied on annuities (or benefits that can be approximated by annuity) arising from non-life claims (excluding health SLT) where the amount of the annuity may be revised during the next year. Life Cat Absolute increase in the rate of policyholders dying of 1.5 per mille over the following year. Applicable to obligations which are contingent on mortality i.e. an increase in mortality increases technical provisions. 17 © 2011 Deloitte Česká republika Czech Republic (QIS5): Solvency ratio under SI and SII Source: Deloitte – QIS5 Results Consolidation for Czech Insurance Association (ČAP) 18 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Available and required capital Upper chart: • Comparison of capital requirements under Solvency I and Solvency II for Czech insurance companies participating in QIS5 (left column) • Comparison of available capital under Solvency I and Solvency II for Czech insurance companies participating in QIS5 (right column) Lower chart: • Solvency ratio under Solvency I (left column) and Solvency II (right column) • According to CNB, the average solvency ratio dropped from 376% (under SI) down to 222% (under SII) Source: Česká národní banka – Prezentace výsledků QIS5 19 Dopad Solvency II na pojistné produkty – dodatek © 2011 Deloitte Česká republika Solvency ratio – comparison under SI and SII S2 solvency ratio All insurers 7.5 The following charts points to issues with SI: 6.5 • Low correlation between SI solvency ratio and SII solvency ratio, somewhat higher if for L, NL and composite insurer segments • Available capital: accounting basis (statutory accounting versus fair value approach) • Required capital: ability to reflect risks the insurers are facing (limited under SI) 5.5 4.5 3.5 2.5 1.5 0.5 0.5 1.5 2.5 3.5 4.5 S1 solvency ratio 5.5 6.5 Composite insurers 7.5 3.5 6.5 S2 solvency ratio S2 solvency ratio Life insurers 4.0 3.0 2.5 2.0 1.5 1.0 5.5 4.5 3.5 2.5 1.5 0.5 0.5 0.5 1.5 2.5 3.5 4.5 S1 solvency ratio 5.5 6.5 0.5 1.5 2.5 3.5 4.5 S1 solvency ratio 5.5 6.5 Source: Deloitte – QIS5 Results Consolidation for Czech Insurance Association (ČAP) 20 Dopad Solvency II na pojistné produkty – dodatek © 2011 Deloitte Česká republika Czech Republic (QIS5): BSCR and life underwriting risk composition BSCR composition (composite companies) Intangible Health asset risk 0.28% underwriting risk 1.21% Counterpart y default risk 16.55% Other risks 8.56% Non-life underwriting risk 31.29% Market risk Life 25.25% underwriting risk 25.43% Market risk 30.12% Life underwriting risk (composite Longevity companies) risk 2.56% Revision risk 1.15% CAT risk 5.13% Mortality risk 6.23% BSCR composition (life companies) Life underwriting risk 61.32% Life underwriting risk (life companies) Longevity risk 0.02% Mortality risk 7.66% Revision risk 0.00% CAT risk 12.11% Expense risk 16.89% Lapse risk 50.35% Expense risk 18.82% Disability risk 17.69% Lapse risk 39.97% Disability risk 21.42% Source: Deloitte – QIS5 Results Consolidation for Czech Insurance Association (ČAP) 21 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika BSCR risk composition – comparison of CZ and EEA Source: Česká národní banka – Prezentace výsledků QIS5 22 Dopad Solvency II na pojistné produkty – dodatek © 2011 Deloitte Česká republika Life underwriting risk composition – comparison of CZ and EEA Source: Česká národní banka – Prezentace výsledků QIS5 23 Dopad Solvency II na pojistné produkty – dodatek © 2011 Deloitte Česká republika Impact of SII on Life Insurance Products Impact of SII on life products: Key considerations Profit testing and cost of capital Insurance companies use profit tests to set premium and evaluate profitability Cost of holding capital needs to be considered • Profit test: CF projection • Difference between regulatory and risk based capital • premiums • benefits (maturity, death, disability, surrender, claims, profit-sharing) • SI – does not reflect risks • SII – does reflect risks • expenses (acquisition, administration, claims, investment) • Introduces economic valuation and risk based capital requirement • taxes • Higher capital required implies lower return on capital, ceteris paribus • cost of capital • The change in SCR differs across products => the relative profitability of products will change • Prices are likely to change to reflect the real risk and cost to serve • Change in calculation of available capital – higher SCR mitigated by increase in available capital (lower TP) 25 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Impact of SII on life products: Further considerations The impact of changes in capital required introduced by SII on prices and design of insurance products will depend on a number of factors Competitive environment in the market (market structure - e.g. monopoly, oligopoly) Change in capital required Prices and design of insurance products Similarity between the current regulatory regime and SII Insurer operating models (nature of ownership, product and country diversification, customers, products) • Deloitte UK conducted study for EC to assess the potential impact of SII L2 measures on products • Generalization of the analysis is difficult due to differences across countries and insurance companies (existing regulation, tradition, product design, distribution channels, risk management, competition) 26 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Traditional Participating Life Insurance Products Traditional participating life insurance products Product Group Country Withprofits A AT,DK, FI, DE Withprofits B BE,CZ, EE, HU, IT, LT, LV, NL, PL, RO, SK, SI Withprofits C Withprofits D 28 Profit Sharing based on total firm earnings on a book value basis the spread of booked investment yields over the guaranteed rate CY, IE, MT, GB notional pool of investments known as “asset share” FR, NO, ES, SE experience relative to the assumptions in the technical provision; 70-90% of the margins achieved over the assumptions in the technical provisions are paid as bonuses Dopad Solvency II na pojistné produkty Typical Death Benefits Typical Surrender Benefits based on Options / Guarantees SI reserving basis Typical Asset Mix Includes accrued maturity bonus reservesincludes accrued regular & maturity bonus May be some GAOs / guaranteed interest rates 2.25-4% Pricing basis (at least at inception) Primarily supported with government and investment grade bonds Uncommon Between 90 – 110% of accrued maturity benefit reserves – includes accrued bonuses; possible surrender charge GAOs uncommon/very conservative guaranteed interest rate (specified in contracts) Net premium basis – very conservative with ass. usually fixed at inception Primarily supported with gov. bonds; little or no equity investment Can be significant Typically equal to the guarantee and benefits + applicable terminal bonuses Close to 100% of asset share; could be < than guaranteed benefits GAOs no longer commonly offered Gross premium basis – BE ass. with a margin for prudence set at valuation date Assets typically invested in corp. bonds and equity; property and gov. bonds also present May be based on a guaranteed sum assured reserves – a surrender charge may be applied GAOs uncommon/ guaranteed i.r. typically equal to invest. ass. in reserving basis Net premium basis – conservative Primarily supported with fixed interest investments Maturity/ Terminal Bonuses Can be significant Uncommon © 2011 Deloitte Česká republika Traditional participating life insurance products • Technical Provisions • • SCR • • • • Financial impact of SII Risk mitigation 29 Reduction due to move from a conservative to realistic basis (conservative discounting rates, mortality basis and no allowance for future lapses) Increase due to the impact of embedded options and guarantees (part of the discretionary payments to policyholders included in technical provisions) Significant increase in SCR due to market risk (≈ 50-70% of undiversified SCR) and underwriting risk (the remaining part) Market risk dominated by interest rate risk, UW risk by lapse and expense risk Surrender values are related to SI reserves => mismatch between SII reserves and surrender values and higher exposure to lapse risk Higher unit expenses (compared to developed markets) result in relatively higher SCR for expense risk Risk absorbing effect of deferred taxes and management actions • • Reduction in technical provisions offset by increase in SCR QIS5 results for the Czech market indicate an increase in capital needs for endowment products • Little reinsurance techniques currently in place and it is unlikely to change dramatically (limited contribution of mortality risk to SCR) Hedging exposure to interest rate risk not widely used but will become more rewarding under SII • Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Traditional participating life insurance products Product prices Prices likely to increase due to: • Increase in SCR compared to SI required capital (=> higher cost of capital); and • Increased variability of reserves due to embedded options and guarantees • Product innovation • • • 30 Consumer preferences unaffected by SII introduction (low attractiveness of endowment products) Costs and prices of endowment products likely to increase (also due to embedded options and guarantees) Under risk-based regime insurers have incentives either to increase prices for endowments or limit the extent of embedded options and guarantees Endowment products are likely to be even less attractive Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Unit-Linked Products Unit-linked products Product Group Country Premium Loading (Bid / Offer spread) UnitLinked A AT, DE 0-5% UnitLinked B BE, LU, NL, PT UnitLinked C CY, FI, IE, MT, GB UnitLinked D BG, CZ, EE, HU, LT, LV, PL, RO, SK, SI UnitLinked E UnitLinked F 32 DE, FR IT, ES, SE Annual Management Charges (p.a.) Typical Surrender Penalty Typical Death Benefits Typical asset Mix Maturity Guarantee Solvency I reserves Guaranteed Annuity Options (GAOs)? Approx. 0.5% 0% Greater of {110% of Fund Value; Fixed Amount} 50% equity, 50% fixed interest No MV of Units On some contracts 0.5-1.0% 0-5% in first year, reducing over early years of contract Greater of {Fund Value; Fixed amount or 100-130% of premium} 40% equity;, 60% fixed interest No MV of Units + small death benefits reserve No 1-5% 1-2% Initially close to 100%; decreasing to 0% over the first few years Close to 100% of Fund Value 60-80% equity, 2040% fixed interest No MV of Units + Sterling Reserves No longer commonly offered, may be sign. on mature portfolios 0% 1-2% + additional COI 100% in first year, reducing to 0 over first 5 years of contract One of {100-110% of Fund Value; Greater of Fund Value and Fixed amount} 20-40% equity, 6080% fixed interest No MV of Units No 0% Greater of {Fund Value;100% of premiums or Fixed amount} 40-60% equity, 4060% fixed interest 100-150% of premiums at a spec. date MV of Units + reserve for maturity and death guarantees No 0% 100-103% of Fund Value 40-60% equity, 4060% fixed interest No MV of Units + small death benefits reserve No 3-5% 0-3% 2.5-3% Dopad Solvency II na pojistné produkty 0.5-1.5% + COI 1.5-2.5% © 2011 Deloitte Česká republika Unit-linked products Technical Provisions Technical provisions are likely to be significantly reduced compared to SI: • Release of capital since currently UL reserves have a floor equal to the unit fund (and small reserve for death benefits) • Under SII reserves lower than the unit fund if the PV of future charges is higher than the PV of future expenses and costs (TP reduced by VIF) SCR SCR is likely to increase: • Application of stress scenarios for calculating capital requirements to the VIF as well as the value of the funds (flip side of allowing VIF to reduce TP) • Lapse risk tends to be the largest single component of the SCR (loss of VIF and surrender strain) accounting for approx. 80 – 85% of undiversified SCR • Surrender values are related to unit fund => mismatch between SII reserves and surrender values and higher exposure to lapse risk • Market risk less significant (≈ 20% of SCR), driven to larger extent by equity risk Financial impact of SII Release of moderate amount of capital: • Decrease in technical provisions • Increase in SCR unlikely to outweigh reduction in TP, risks inherent in the return and fund value are passed to PHs and only second round effects affect insurers Risk mitigation 33 • Little reinsurance techniques currently in place and it is unlikely to change dramatically (limited contribution of mortality risk to SCR) Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Unit-linked products Product prices Prices are unlikely to materially change: • Moderate scope for price reduction as a result of capital release • Insurers tempted to use release of capital to cross-subsidise other products • Competitive pressures (not only among insurers but also from funds of collective investments) may put downward pressure on prices • Product innovation • • 34 Consumer preferences unaffected by SII introduction (UL products gradually replace endowments) Demand could be stimulated by price reductions if consumers found to be sensitive to prices Riders will be promoted (see the next section on risk products) Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Risk Products Risk products (e.g. term assurance) SI reserving method Level of Prudence in Mortality Basis Country Product Type Typical Contract Duration Term A BG, PL, ES Annually renewable / Level 1-5 yrs Net Premium Large Term B CZ, FI, IT, RO, SK, ES Level 10-20 yrs Net Premium Large Term C CZ, ES Decreasing 20-30 yrs Net Premium Large Term D CY, IE, NO, SE, GB Level 10-20 yrs Gross Premium Moderate Term E CY, IE, GB Decreasing 20-30 yrs Gross Premium Moderate Product Group 36 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Risk products (e.g. term assurance) Technical Provisions Technical provisions are likely to be significantly reduced compared to SI: • Release of capital since these products are typically highly profitable (on a realistic valuation basis) • Under SII reserves can be even negative if the PV of future premium is higher than the PV of future expenses and death benefits (as compared to SI net premium reserves with a Zillmer adjustment) SCR SCR is likely to increase but the opposite impact is also possible (SI SaR effect): • Underwriting risk is by far the most important risk (≈ 95% of undiversified SCR) • Lapse risk (loss of VIF and surrender strain) tends to be the most important driver of the SCR (estimated to represent 85 – 95% of undiversified UW risk) • Mortality, catastrophe and expense risks considered less significant • Market risk is immaterial (low reserves and return-insensitive benefits) Financial impact of SII Release of significant amount of capital: • Decrease in technical provisions • Revaluation of assets (difference between book and market values) not expected to be significant • Increase in SCR unlikely to outweigh reduction in TP • Risk mitigation 37 • Reinsurance techniques reduce the SCR, under SII full credit for reduction of capital due to RI taken (unlike under SI, which imposes limit of 50% on RI) Different types of RI arrangements in place (different premium rates and profit sharing mechanisms) Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Risk products (e.g. term assurance) Product prices Prices are unlikely to materially change: • Scope for price reduction as a result of capital release • Price elasticity of demand is likely to be low, as well as competitive pressures • Release of capital likely to be used to cross-subsidise other products/ maintain profitability • Product innovation • • 38 Consumer preferences unaffected by SII introduction (higher demand for life protection products as consumers become more aware of risks) Risk products likely to be supported and developed by insurers (extending the scope of risks covered) Demand could be stimulated by price reductions if consumers found to be sensitive to prices Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Annuities Annuities Product Group Annuity A Annuity B Annuity C Annuity D Annuity E Country AT, DE Product Type Immediate Annuities CY, IE, GB Immediate Annuities NL Immediate and Deferred Annuities NO, SE ES Immediate Annuities Immediate Annuities SI basis Asset Mix Backing Liabilities Net Premium Conservative mortality and discount assumptions – generally locked-in at issue Primarily supported by gov. and investment grade corporate bonds denominated in local currency Non-profit Gross Premium BE assumptions for mortality and discounting with a margin for prudence set at the valuation date Primarily supported by gov. and investment grade corporate bonds denominated in local currency Non-profit Gross Premium Conservative assumptions locked-in at issue Primarily supported by gov. bonds denominated in local currency Gross Premium BE mortality assumptions, discount assumptions are locked-in at issue Primarily supported by investment grade corporate bonds. Between 80-90% of assets are denominated in local currency, the remainder in EUR. Net Premium Conservative assumptions, not locked-in at issue. When A and L are matched, TP are discounted using yields of the backing assets. Primarily supported by gov. and investment grade corporate bonds denominated in local currency WP / NP With-profits With-profits Non-profit SI reserving method Note: As annuities are rare in the Czech Republic, the Czech Republic is not covered in the Study. 40 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Immediate annuities Technical Provisions Small reduction in technical provisions expected: • Release of reserving margins (prudent discounting and mortality) due to move to best estimate liabilities and inclusion of a liquidity premium • Embedded options and guarantees unlikely to fully offset the release of margins SCR SCR is likely to be somewhat higher compared to SI: • Market risk (≈ 75% of undiversified SCR) driven by interest rate risk and spread risk • Underwriting risk driven by longevity risk Financial impact Total resource requirements under the QIS 5 remain more or less unchanged • Product prices 41 • Significant guarantees (in respect of longevity and interest rate) included. In the past guarantees were priced implicitly only by including margins in pricing bases combined with profit sharing SII will show the level of risk capital required to support these guarantees, which is likely to lead to a reduction of guarantees or increase in prices Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Life Products Summary Life products summary Traditional participating products Unit-linked products Risk products Annuities Technical provisions Solvency capital requirement Financial impact Increase Uncertain Decrease • Saving products (traditional with-profits products) and annuities – dominance of market risks • UL and risk products – underwriting risks more important (esp. lapse and expense) • Risk products also subject to mortality and disability/ morbidity risk, annuities to longevity risk • Products with fee-based income (UL and variable annuities) are generally less negatively affected than products with spread-based income and shareholder profit participation (traditional with-profits products) • A balanced risk profile implies higher diversification benefits 43 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Concluding remarks on life products Other considerations Product innovations – available experience • Immediate product innovations are hardly to be expected – introduction of risk-based regime in the UK (ICA – individual capital assessment) did not trigger product innovations Internal models • Firms using internal models will have competitive advantage (capital requirements lower by approx. 20%) esp. due to: • Correlations for market risk submodules and UW risk sub-modules • Capital requirements at sub-module level are comparable between internal model and standard formulae Harmonisation • SII will harmonize asset/ liability valuation approaches and capital requirements throughout the EU • However, differences in product design, consumer preferences and level of sophistication will remain 44 Dopad Solvency II na pojistné produkty Product prices & innovations Pricing considerations • Pricing is likely to better reflect the risks and the existence of embedded options and guarantees • There is a potential to allow for diversification benefits in pricing – well diversified firms could price more competitively • Change in the product mix (supply driven) to the extent to which risks are reflected in prices © 2011 Deloitte Česká republika Impact of SII on Asset Liability Management Closer ALM and changes in asset allocation • Solvency II implies a step change in the way market risks are assessed for solvency purposes 46 Solvency I Solvency II SCR based on fixed factors => the asset liability mismatch and market risk taken not reflected SCR reflects both asset liability duration mismatches and the market risk of different investment classes Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Asset structure – comparison of CZ and EEA Source: Česká národní banka – Prezentace výsledků QIS5 47 Dopad Solvency II na pojistné produkty – dodatek © 2011 Deloitte Česká republika Czech Republic (QIS5): Market risk composition Illiquidity premium risk 0.25% Market risk (life companies) Equity risk 14,43% Property risk 0.10% Currency risk 22,94% Concentration risk 19,29% Spread risk 8,35% Market risk (composite companies) Illiquidity premium risk 1.72% Currency risk 6.01% Property risk 6.66% Concentration risk 16.79% Interest rate risk 34,64% Interest rate risk 17.04% Equity risk 32.86% Spread risk 18.93% Source: Deloitte – QIS5 Results Consolidation for Czech Insurance Association (ČAP) 48 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Market risk composition – comparison of CZ and EEA Source: Česká národní banka – Prezentace výsledků QIS5 49 Dopad Solvency II na pojistné produkty – dodatek © 2011 Deloitte Česká republika Closer ALM and changes in asset allocation Possible responses of insurers to the change in the calculation of SCR Closer asset-liability matching – or at least a greater emphasis on monitoring this • Adjustment of interest rate position of insurers • Managing assets relative to the Solvency II liability profile • Adjustment of asset duration (by adjusting the duration of bonds and by entering fixed income derivatives positions) • Monitoring the asset liability mismatch position much more actively • Larger and more sophisticated ALM functions in insurance companies SII standard formulae seems to create an “unlevel” playing field in the risk-reward between different asset classes • Adjustment of the asset allocation to reflect the new capital requirements • Optimizing return on SII capital • Differences in expected return on the SCR between asset classes • Expected return on SCR similar for equity, other equity and property • Significant differences for credit investments of different durations • Invest in EEA gov. bonds (zero SCR for spread risk) to help manage asset-liability duration risks • Swaption programs to manage interest rate risks: insurers choose to hold assets too short in duration 50 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Risk-reward between different risk asset classes Example Standalone standard capital requirements by risk asset class 60.0% 49.0% 50.0% 39.0% 40.0% 30.0% 25.0% 20.0% 14.0% 10.0% 9.8% 7.0% 4.2% 0.0% Equity Other Property Credit A- Credit A- Credit A- Credit A(listed in equity rated rated rated rated EEA or (10y) (7y) (5y) (3y) OECD) • Equity – equity shock (30%) plus symmetric adjustment (9%) on the basis of QIS5 TS • Other equity – equity shock (40%) plus symmetric adjustment (9%) on the basis of QIS5 TS • Property – property shock (25%) on the basis of QIS5 TS • Credit – corporate credit for A-rated debtor obtained on the basis of spread risk factor Fup (1.4%) and by applying QIS5 formulae: 𝑢𝑝 Illustrative risk adjusted returns on capital • Obtained on the basis of standalone capital requirements (see above) and illustrative expected excess return • The following illustrative expected excess return over risk free rate were assumed: • • • • • • • 51 Equity: Other equity: Property: Credit 10y: Credit 7y: Credit 5y: Credit 3y: 3.3% 4.3% 1.9% 1.3% 1.2% 1.1% 0.9% Dopad Solvency II na pojistné produkty 𝑑𝑢𝑟𝑎𝑡𝑖𝑜𝑛𝑖 ∙ 𝐹 𝑟𝑎𝑡𝑖𝑛𝑔𝑖 20% 18% 16% 13% 12% 10% 8% 8% 9% 8% 8% 4% 0% Equity Other Property Credit A- Credit A- Credit A- Credit A(listed in equity rated rated rated rated EEA or (10y) (7y) (5y) (3y) OECD) © 2011 Deloitte Česká republika What are the likely asset allocation trends? Shift towards short-dated credit investments and a ‘divorce’ of the duration of the physical investment portfolio and liability duration Expected changes to insurers’ asset allocation Maintaining low allocations to equity and property Greater use of derivatives for risk management (esp. swaptions to manage interest rate and duration mismatch risk) Taking tactical risks where risk budgets allow (if high SII capital buffers exist) • Companies’ individual preferences for taking risk in their investment strategy vary with: • Their level of surplus capital under SII • The level of capital they wish to allocate towards market risk (“risk budget”) • Given the high expected returns on SCR for short-dated credit investment, the optimal portfolio for general account liabilities is dominated by short-dated credit investments 52 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Conclusions Conclusions • Solvency II results in a significant change in capital requirements • Solvency II will have an impact on insurance product costs, thus potentially on their pricing • Impact on life insurance products: • Traditional endowment products with guarantees are facing substantial increase in capital requirements • Unit-linked products and risk products seem to be the relative winners • The importance of ALM will increase reflecting the contribution of market risk to the total SCR 54 Dopad Solvency II na pojistné produkty © 2011 Deloitte Česká republika Děkuji za pozornost! Deloitte označuje jednu či více společností Deloitte Touche Tohmatsu Limited, britské privátní společnosti s ručením omezeným zárukou, a jejích členských firem. Každá z těchto firem představuje samostatný a nezávislý právní subjekt. Podrobný popis právní struktury společnosti Deloitte Touche Tohmatsu Limited a jejích členských firem je uveden na adrese www.deloitte.com/cz/onas. © 2011 Deloitte Česká republika