ASSAL-IAIS Training Seminar: Overview of the Swiss Solvency Test 21st November 2012 Alex Summers Global Life Actuarial INTERNAL USE ONLY Important note The views expressed in this presentation are the presenter’s own and do not necessarily represent the views of either Zurich Insurance Group (Zurich), or FINMA I am very grateful to colleagues within Zurich and at FINMA for their assistance in preparation © Zurich Insurance Company Ltd. Further information from FINMA on the Swiss Solvency Test can be found on FINMA’s website at http://www.finma.ch INTERNAL USE ONLY 2 Agenda • Context and history • Key principles and conceptual framework • Groups & Capital and Risk Transfer Instruments • Experiences © Zurich Insurance Company Ltd. • Selected practical aspects INTERNAL USE ONLY 3 FINMA’s objectives* "FINMA's mandate is to protect creditors, investors and policy holders and ensure the smooth functioning of the financial markets. Through consistent supervision and predictable regulation, we make an important contribution to safeguarding the stability and good reputation of the Swiss financial centre, and consequently to enhancing its competitiveness.“ © Zurich Insurance Company Ltd. Prof. Anne Héritier Lachat, Chair of the Board of Directors, FINMA *: FINMA is the Swiss regulator for banking, insurance and other financial services INTERNAL USE ONLY 4 The SST protects policyholders by requiring a high probability of orderly run-off of business SST identifies insurers* at risk of being unable to honour their existing obligations A ladder of intervention allows appropriate actions to be taken when insurers run into difficulties SST ladder of intervention Risk 0 margin Total required capital © Zurich Insurance Company Ltd. SST sets capital requirements so that there is high probability of orderly run-off of business Internally Transfer of liabilities to a third party if necessary Both fulfilment and transfer value concepts are thus central to the SST Based on FINMA SST technical document p8 INTERNAL USE ONLY *: The term “Insurers” has been used throughout to indicate both insurance and reinsurance undertakings 5 The SST aims to be based more on principles than rules Liberty means responsibility. That is why most men dread it. George Bernard Shaw Principles encourage responsible management behaviour for good risk and capital management Principles are more challenging than rules both for the supervised and for the supervisors © Zurich Insurance Company Ltd. Principles must be powerful and general. Rules give less incentive for thoughtful risk management Innovation discouraged, reducing long term competitiveness Increased systemic risk INTERNAL USE ONLY 6 © Zurich Insurance Company Ltd. History of the SST: successful launch despite challenging conditions Developed 2003-2005 Field-tested in 2004 and 2005 In force since 1 January 2006 Larger companies first Results not binding initially As of 2008, all companies calculated SST 1.1.2011 SST capital requirements binding 2012 FINMA propose temporary lightening of SST in context of extreme financial markets and Solvency II uncertainty Internal model approval process is ongoing for many companies So far no requirement for public disclosure of results for individual insurers Source: FINMA, 2012 INTERNAL USE ONLY 7 Swiss Solvency Test and Solvency II are broadly equivalent FINMA has applied for recognition of the SST as equivalent to SII Defining principles of both risk-based framework are the same Based on a holistic market consistent balance sheet Requirements for good governance and transparent disclosure © Zurich Insurance Company Ltd. Uncertainty SII measures for Long Term Guarantees may cause differences FINMA has proposed temporary adjustments to SST in response EIOPA advice on Switzerland’s equivalence under Article 172, 227 and 260: Switzerland meets the criteria set out in EIOPA’s methodology for equivalence assessments under Solvency II… …but caveats around looser public disclosure requirements, captives and compliance / internal audit functions INTERNAL USE ONLY 8 Agenda • Context and history • Key principles and conceptual framework • Groups & Capital and Risk Transfer Instruments • Experiences © Zurich Insurance Company Ltd. • Selected practical aspects INTERNAL USE ONLY 9 The SST Principles in full 5. The market value margin is approximated by the cost of the present value of future required regulatory capital for the run-off of the portfolio of assets and liabilities 6. Under the SST, an insurer’s capital adequacy is defined if its target capital is less than its risk bearing capital © Zurich Insurance Company Ltd. 7. The scope of the SST is legal entity and group / conglomerate level domiciled in Switzerland 8. Scenarios defined by the regulator as well as company specific scenarios have to be evaluated and, if relevant, aggregated within the target capital calculation INTERNAL USE ONLY Source: FOPI, 2007 Defines How-to 4. Target capital is defined as the sum of the Expected Shortfall of change of risk-bearing capital within one year at the 99% confidence level plus the market value margin Transparency Defines Output 2. Risks considered are market, credit and insurance risks 3. Risk-bearing capital is defined as the difference of the market consistent value of assets less the market consistent value of liabilities, plus the market value margin 9. Governance 1. All assets and liabilities are valued market consistently All relevant probabilistic states have to be modeled probabilistically 10. Partial and full internal models can and should be used. If the SST standard model is not applicable, then a partial or full internal model has to be used 11. The internal model has to be integrated into the core processes within the company 12. SST Report to supervisor such that a knowledgeable 3rd party can understand the results 13. Regulatory disclosure of methodology of internal model such that a knowledgeable 3rd party can get a reasonably good impression on methodology and design decisions 14. Senior Management is responsible for the adherence to principles 10 SST principles aim for a sound, consistent and transparent framework • Risk based • Principles based • Holistic market consistent balance sheet giving economic view of both assets and liabilities • Available capital = market value of assets – best estimate liabilities • Required capital based on risk margin* + potential change in available © Zurich Insurance Company Ltd. capital over 1 year time horizon, using 1 in 100 expected shortfall as a risk measure, incorporating scenarios • Applies both to legal entities and groups *: For SST, also referred to as Market Value Margin (MVM) INTERNAL USE ONLY 11 Risk based framework for calculating SST Market Consistent Data and Best Estimate Assumptions Mix of predefined and company specific scenarios Standard Models or Internal Models Valuation Models Risk Models Market Risk Scenarios Market Value Assets Credit Risk Life P&C Best Estimate Liabilities Health Risk margin Output of analytical models (Distribution) © Zurich Insurance Company Ltd. Aggregation Method Target Capital INTERNAL USE ONLY SST Report Source: FOPI, 2007 12 Agenda • Context and history • Key principles and conceptual framework – BALANCE SHEET • Groups & Capital and Risk Transfer Instruments • Experiences © Zurich Insurance Company Ltd. • Selected practical aspects INTERNAL USE ONLY 13 SST Market Consistent Economic Balance Sheet The economic balance sheet gives a realistic picture of a company’s financial position at a given point in time Free capital Required capital for 1-year risk Available Capital Total required capital Risk Margin Best estimate of discounted liabilities © Zurich Insurance Company Ltd. Market value of assets Market consistent value of liabilities INTERNAL USE ONLY 14 Holistic market consistent balance sheet gives a complete and transparent view Consistent with transfer value concepts A little light dispels a lot of darkness. Rabbi Schneur Zalman SST ladder of intervention Valuation benchmark is price at which knowledgeable business partners would purchase or sell the positions in an arm’s length transaction Where these conditions are not satisfied in stressed markets, plausible methods and parameter estimates are to be selected. Risk 0 margin Total required capital © Zurich Insurance Company Ltd. Pro-cyclical effects need to be considered Not necessarily aligned to existing accounting standards Materiality concept vital INTERNAL USE ONLY Based on FINMA SST technical document p8 15 Overview of risk margin in the SST Risk margin is the extra amount needed above best estimate of liabilities to cover the risks the liabilities bring Non-hedgeable risks only Present value of opportunity cost of regulatory capital needed to support risks till the liabilities run off Relevant for both transfer and fulfilment value concepts SST risk margin is similar in nature to Solvency II risk margin Details differ slightly © Zurich Insurance Company Ltd. SST Treatment of risk margin aims to avoid circularity Simplifications are needed in practice INTERNAL USE ONLY 16 Agenda • Context and history • Key principles and conceptual framework – RISK CALCULATIONS • Groups & Capital and Risk Transfer Instruments • Experiences © Zurich Insurance Company Ltd. • Selected practical aspects INTERNAL USE ONLY 17 As a risk-based framework, SST aims for transparent view of insurers’ exposure to risk Nothing is easier than self-deceit. For what each man wishes, that he also believes to be true. Demosthenes Control and mitigation of risk are secondary objectives which are better achieved via transparency © Zurich Insurance Company Ltd. SST aims to avoid prudence, restrictions on eligibility of capital, investments and risk transfers These would reduce transparency and transfer responsibility for risk management to supervisor SST also aims for an appropriate parameterisation, considering all material, quantifiable risks Not seeking to perpetuate a given business model or distort transparent economic view for political aims INTERNAL USE ONLY 18 Risk as Change of Available Capital SST required capital covers the risk of adverse changes in the economic balance sheet over the next year The total capital requirement is set so that even after adverse experience, it should still be possible to transfer business to a third party Hypothetical balance sheets at t=1 © Zurich Insurance Company Ltd. Balance sheet at t=0 t=1 t=0 INTERNAL USE ONLY Source for illustration: FOPI, 2007 19 All material, quantifiable risks are covered in the SST Market risk Interest rates, spreads, foreign exchange, equity, alternative investments, volatilities © Zurich Insurance Company Ltd. Insurance risk Reflecting both parameter and random risk Non-life: settlement, new claims and accumulation risks Life: mortality, longevity, disability/morbidity, recovery, expenses, lapse and other options and accumulation risks Health insurance risks Impact of reinsurance has to be modelled separately (waiver possible) Credit risk Complete or partial default Migration: change in creditworthiness or rating For groups: changes in value of intra-group loans and other Capital and Risk Transfer Instruments INTERNAL USE ONLY 20 Other risks Risk concentrations are considered within SST scenarios Operational risk is currently not explicitly included in SST in the context of self-assessment by Swiss insurers Systematic quantitative assessment of operational risks considered for investigation by FINMA © Zurich Insurance Company Ltd. Liquidity risks have to be taken into account in insurers’ risk management outside of SST Model risks need to be taken into account in risk management Parameter risks incorporated into SST quantification Impact of other model shortcomings needs to be recognised FINMA can ask for explicit quantification in serious cases INTERNAL USE ONLY 21 One year time horizon consistent with transfer value concept One year time horizon allows for ladder of intervention while keeping calculation efforts reasonable for a given level of accuracy Choice of time horizon is a key decision which for SST then determines many areas of the framework © Zurich Insurance Company Ltd. SST volatilities are then set consistently with one year view Mean reversion does not play a role Treatment of business with long term guarantees remains consistent with one year time horizon INTERNAL USE ONLY 22 Risk measure is 99% expected shortfall Year 0: Year 1: uncertain known Available capital changes due to random events Available Capital Probability density of the change in available capital Revaluation of liabilities due to new information New business during one year Probability < 1% © Zurich Insurance Company Ltd. Claims Change in market Catastrophes value of assets Market value of assets Best estimate of liabilities Economic balance sheet at t=0 (deterministic) INTERNAL USE ONLY Average value of available capital in the 1% “bad” cases = Expected shortfall Economic balance sheet at t=1 (stochastic) 23 Expected shortfall risk measure prevents tail risks from being ignored Results for 99.5% Value at Risk as used for SII are typically not too different from 99% Expected Shortfall Expected shortfall requires more thought when extrapolating risks into extremes of the tail Probability density of the change in available capital Probability < 1% © Zurich Insurance Company Ltd. In practice ES is typically a more stable measure than Value at Risk Other useful mathematical properties such as coherence INTERNAL USE ONLY Average value of available capital in the 1% “bad” cases = Expected shortfall 24 SST requires use of Internal Models except where Standard Model is adequate The core of the SST framework are the underlying methodology and principles, not the standard models Valuation, risk measure, time horizon,… Methodology of the Solvency Test © Zurich Insurance Company Ltd. Company specific approach and simplifications Implicit and explicit prudence, limits, etc. to take into account the approximations used for the standard model Internal models are assessed with reference to the methodology of the SST framework Internal Models INTERNAL USE ONLY Standard Models 25 Standard Model and SST SST Standard Model Functional dependence of P&L on risk factors is linear Specified distributions (Normal except GI) Time 0 sensitivities Focus only on guaranteed cash flows gives disconnect with industry Embedded Value Realistic Internal Model based on SST Methodology Realistic dependence of P&L on risk factors Dependency between risk factors can be modeled more flexibly (e.g. tail dependency) Risks can be assessed via generation of scenarios of the economic state of the company in one year’s time Valuation and one year risk consistent Conceptually more consistent with EV © Zurich Insurance Company Ltd. Model can map better company’s internal view of business embedding of the model easier Standard model is adequate for “simple” companies with few optionalities and stable business Source: After FINMA 2007 INTERNAL USE ONLY Realistic model is adequate also for companies with optionalities in both assets and liabilities 26 Some SST Standard Model simplifications The following simplifications are applied consistently to both available and required capital in the SST Standard Model PRE (policyholders reasonable expectations) are fully risk bearing Future discretionary benefits are excluded from calculations with focus only on guaranteed cash flows © Zurich Insurance Company Ltd. Tax liabilities are fully risk bearing All calculations are done pre-tax INTERNAL USE ONLY 27 Agenda • Context and history • Key principles and conceptual framework – AGGREGATION • Groups & Capital and Risk Transfer Instruments • Experiences © Zurich Insurance Company Ltd. • Selected practical aspects INTERNAL USE ONLY 28 SST does not specify an approach to aggregation in calculating required capital SST standard model makes use of mixture of correlation matrices, convolutions and other simplifications for aggregation © Zurich Insurance Company Ltd. Copula approach can also work well for internal models, but is not a requirement INTERNAL USE ONLY 29 Agenda • Context and history • Key principles and conceptual framework – SCENARIOS • Groups & Capital and Risk Transfer Instruments • Experiences © Zurich Insurance Company Ltd. • Selected practical aspects INTERNAL USE ONLY 30 Scenarios are a key element of the SST to capture extreme risks and combinations of events Scenarios in the SST are events or combinations of events that cause a severe reduction in available capital but with low probability Help ensure model gives adequate weight to tail risks and tail dependencies Standard Model scenarios are defined by FINMA Insurers must provide additional specific scenarios relevant to their business © Zurich Insurance Company Ltd. Two types of scenarios in SST: Type 1: Scenarios to be aggregated into SST required capital Type 2: Scenarios to be evaluate but to avoid double counting, not aggregated into SST required capital Holistic impact must be considered, not only insured claims amount E.g. market risk impacts from a pandemic or terrorist attack For each scenario, expected effect must be quantified INTERNAL USE ONLY 31 Aggregation of scenarios into SST required capital is based on simplifying assumptions Assumed no more than one such extreme event each year, and they are independent Distribution in risk models assumed unchanged in event of extreme event © Zurich Insurance Company Ltd. Impact and probabilities define discrete point distributions which can then be summed together with continuous distribution resulting from nonscenario risk calculations Simple formula for Standard Model resulting from assumed Normal distribution for non-scenario risk calculations Monte Carlo simulation if using Internal Model INTERNAL USE ONLY 32 © Zurich Insurance Company Ltd. Scenarios in the SST Standard Model The historical market stress scenarios cover: Stock Market Crash 1987, Nikkei Crash 1989, European Currency Crisis 1992, US Interest Rates 1994, Russia / LTCM 1998, Stock Market Crash 2000 The list keeps growing and now includes additional synthetic market scenarios INTERNAL USE ONLY Source: FINMA SST Technical Document, 2006 33 Impact of Scenarios, SST 2009: Swiss life insurers prompted to further mitigate interest rate risk thanks to SST © Zurich Insurance Company Ltd. The crisis could have been much worse! INTERNAL USE ONLY Source: FINMA SST report 2009 34 Agenda • Context and history • Key principles and conceptual framework • Groups & Capital and Risk Transfer Instruments • Experiences © Zurich Insurance Company Ltd. • Selected practical aspects INTERNAL USE ONLY 35 Principles of Group Solvency Testing under SST Groups are defined by legal entities and the web of ownership relations and Capital and Risk Transfer Instruments (CRTIs) between them Therefore one number is not enough to assess a group’s risk: it is first necessary to analyze the solvency of the legal entities of the group Consolidated view can then offer useful additional insight © Zurich Insurance Company Ltd. Group supervisor needs to ensure consistent risk quantification across legal entities Review the web of CRTIs and ensure that quantitative and qualitative requirements on the CRTI are satisfied In case of a group’s financial distress The group supervisor should ensure capital mobility, and that capital flows according to the CRTI in such a way that all the group’s policyholders are protected optimally INTERNAL USE ONLY 36 Analysis of CRTIs allows understanding of how risks are spread within groups Intra-group retrocession, contingent capital issued and received, etc. Fungible capital Legal Entity 3 Parent Company Market Value Margin Legal Entity 1 Legal Entity 2 Group © Zurich Insurance Company Ltd. Intra Group Capital and Risk Transfer Instruments can only be considered if they are legally binding and accepted by the regulators involved A wide variety of CRTIs are possible, including intra-group reinsurance / retrocession, guarantees, participations, dividends, loans, issuance of surplus notes, securitization of future cash flows / earnings INTERNAL USE ONLY 37 Setting SST capital requirements for groups All (material) legal entities have to be modeled as per standalone SST but taking into account the web of CRTI Symmetric valuation of CRTI permissible Group’s required capital is then identical to that for parent company based on a economic, realistic framework © Zurich Insurance Company Ltd. The value of a subsidiary for the parent company is its economic value Independent of regulatory or accounting conventions the subsidiary is domiciled in SST allows economic value to be floored at zero The one-year risk of a subsidiary for the parent is defined as the potential change of the economic value of the subsidiary within a year In practice group modeling for SST requires very considerable effort INTERNAL USE ONLY 38 Group SST allows a consistent treatment and allocation of diversification © Zurich Insurance Company Ltd. Group Level Diversification A parent company benefits from group-level diversification since the random change of its assets and liabilities is not fully correlated to the changes of the economic value of its participations Restrictions on capital mobility have to be taken into account Group level diversification is effected via web of ownership ‘Down-streaming’ of Diversification A parent can down-stream group diversification to its subsidiaries via CRTIs e.g. legally binding parental guarantees A parental guarantee lowers the SCR of the subsidiary but increases the SCR of the guarantor Restrictions on capital mobility have to be taken into account INTERNAL USE ONLY 39 Agenda • Context and history • Key principles and conceptual framework • Groups & Capital and Risk Transfer Instruments • Experiences © Zurich Insurance Company Ltd. • Selected practical aspects INTERNAL USE ONLY 40 Introducing SST required a lot of effort on all sides… FINMA SST team consists almost of 20 quantitative specialists Each company is assigned a team out of these 20 people. Each internal model is assigned a team out of these 20 specialists. SST team evaluates approximately 130 annual SST reports, producing feedback to insurers regarding: Solvency ratio (SST ratio) Quality of calculations Quality of documentation © Zurich Insurance Company Ltd. SST team evaluates approximately 80 (partial) internal models INTERNAL USE ONLY 41 … but the effort was worthwhile When SST was field tested there was no meaningful correlation between SST results and those of the previously existing Solvency 1 framework © Zurich Insurance Company Ltd. This could indicate simple factor based Solvency 1 results gave little insight into economic reality indicated by risk based solvency testing INTERNAL USE ONLY 42 Agenda • Context and history • Key principles and conceptual framework • Groups & Capital and Risk Transfer Instruments • Experiences © Zurich Insurance Company Ltd. • Selected practical aspects INTERNAL USE ONLY 43 FINMA has been an enthusiastic supporter of equivalence between SST and Solvency II Equivalence should not compromise consistency of framework for regulation © Zurich Insurance Company Ltd. It brings many benefits Sharing of best practice Less wasted effort Less regulatory arbitrage Improved competitiveness of local market Improved appeal to multinationals, bringing capital and expertise Policyholders benefit in the end INTERNAL USE ONLY 44 Explicit concept of materiality is vital For regulation to be feasible to implement and enforce, a concept of materiality is needed In the SST, documented non-significant positions and non-relevant risks can be omitted or presented in a simplified manner if the overall impact of all simplifications is no more than either 10% of available capital 10% of required capital 10% of solvency ratio © Zurich Insurance Company Ltd. The lower the threshold, the higher the cost The key is being able to spot companies close to trouble FINMA can ask for more detailed calculations if solvency ratio close to or below 100% INTERNAL USE ONLY 45 Effort for internal model approval on all sides should not be underestimated High quality documentation helps Unlike SII, SST IMAP is not time bound No pre-approval phase © Zurich Insurance Company Ltd. Model changes during review period can be a challenge Special attention is needed for keeping decisions on models and calculations consistent over companies and over time INTERNAL USE ONLY By early 2012, FINMA had completed 27 model reviews Sector Unconditional acceptance Conditional acceptance Rejection Life General insurance Health Reinsurance Insurance groups 1 2 1 2 0 3 6 0 4 3 1 2 0 2 0 Total 6 13 8 Source: FINMA, 2012 46 Risk quantification is only one part of a successful framework for insurance regulation SST applies a Use Test and requires regular validation, thorough documentation and senior management responsibility for adherence to SST principles Clearly defined requirements for regular regulatory reporting, as well as reporting of losses or changes in risk-profile © Zurich Insurance Company Ltd. The Swiss Solvency Test is also complemented by the Swiss Quality Assessment (SQA) SQA considers Corporate Governance, Risk Management and Internal Control Systems for Swiss Insurers Restrictions on quality of “Tied Assets” backing liabilities INTERNAL USE ONLY 47 Overview of SST • Risk based • Principles based • Holistic market consistent balance sheet giving economic view of both assets and liabilities • Available capital = market value of assets – best estimate liabilities • Required capital based on risk margin + potential change in available © Zurich Insurance Company Ltd. capital over 1 year time horizon, using 1 in 100 expected shortfall as a risk measure, incorporating scenarios • Applies both to legal entities and groups INTERNAL USE ONLY 48 The SST has established itself as an essential supervisory tool for FINMA Introduction of SST motivated Swiss insurers to address their solvency situation Companies took necessary capital increasing and risk reducing measures Companies improved their risk management With the SST, FINMA has access to an effective solvency testing instrument Solvency problems are identified in a timely fashion © Zurich Insurance Company Ltd. Conservative measures can be taken based on a ladder of intervention INTERNAL USE ONLY Source: FINMA 2012 49 SST Solvency Position of Swiss Life Insurers, SST 2009-2012 SST Solvency Position of Swiss Non-Life Insurers, SST 2009-2012 100% 100% Excess Capital 98% 96% 94% 92% 90% 88% 86% 84% 82% 80% 2008 2009 2010 2011 2012 INTERNAL USE ONLY Expected shortfall SCR Market Value Margin Best estimate liabilities % Total market value of assets % Total market value of assets © Zurich Insurance Company Ltd. Despite a baptism of fire, the SST has given a clear and helpful view in tough times Excess Capital 98% 96% 94% 92% Expected shortfall SCR 90% 88% 86% 84% 82% 80% 2008 2009 2010 2011 2012 Market Value Margin Best estimate liabilities 50 Thank you for your attention © Zurich Insurance Company Ltd. Any further questions? INTERNAL USE ONLY 51 APPENDIX – Swiss Solvency Test compared against Solvency II © Zurich Insurance Company Ltd. Source: FINMA 2010 INTERNAL USE ONLY 52 Solvency II and SST Preamble Solvency II covers pillars I, II and III SST focuses on pillar I aspects including elements of pillar II. © Zurich Insurance Company Ltd. A full comparison of both supervisory regimes would consist in a comparison of Solvency II with the Swiss Insurance Supervision Act. For the following slides we focus on pillar I aspects of supervision and compare the SST with the pillar I aspects of Solvency II. INTERNAL USE ONLY 53 Solvency II and SST Defining principles Total balance sheet approach Market-consistent valuation Market-consistent valuation Risk based capital requirements • Insurance risks • Market risks • Credit risks • Operational risks Risk based capital requirements • Insurance risks • Market risks • Credit risks • Operational risks not modeled; capital add-ons considered. © Zurich Insurance Company Ltd. Total balance sheet approach INTERNAL USE ONLY 54 Solvency II and SST © Zurich Insurance Company Ltd. Calibration Value at risk of the change in available capital at 99.5% confidence level. Expected shortfall of the change in available capital at 99% confidence level. Time horizon: one year Time horizon: one year Yield curve based on swap rates and a Yield curve based on government liquidity premium depending on nature bonds. of liability. INTERNAL USE ONLY 55 Solvency II and SST Risk Model Standard model: formula. Standard model: stochastic model. Standard model is default choice. SST emphasizes principles and encourages the use of internal models. All companies may use the standard model. Internal models are mandatory for certain companies and groups. Similar requirements on internal models. Similar requirements on internal models. © Zurich Insurance Company Ltd. SST makes extensive use of scenarios (to reflect tail risk, tail dependencies, concentration risk, etc.). INTERNAL USE ONLY 56 Solvency II and SST Valuation: Market Consistency Market-consistent valuation is an autonomous principle. IFRS fair values are default choice for assets (QIS 4). IFRS fair values are acceptable if market-consistent. © Zurich Insurance Company Ltd. Directive stresses market-consistent valuation as an autonomous principle. INTERNAL USE ONLY 57 Solvency II and SST Scope “small” companies not subject to risk based capital requirements. All legal entities must satisfy risk based capital requirements. Use of a simplified model is acceptable depending on risk profile of entity. © Zurich Insurance Company Ltd. Most reinsurance captives may use a formula based approach. INTERNAL USE ONLY 58 Solvency II and SST Implementation Numerous field tests (impact assessments) before final roll out (field tests 2004 to 2007, tests 2008 to 2010), mandatory participation since 2006 for large insurers. Solvency II capital requirements will probably become binding in ….? SST capital requirements became fully binding in 2011. © Zurich Insurance Company Ltd. Numerous impact assessments before final roll out (QIS1,2,3,4,…). INTERNAL USE ONLY 59 Solvency II and SST © Zurich Insurance Company Ltd. Group Solvency Operational entity approach (reflects management view). Legal entity approach (reflects insured’s view). Based on the consolidated accounts . Based on the specific structure of the group. Assumes full diversification of risks within the group. Diversification effects depend on actual capital and risk transfer instruments. Capital is assumed to be fully transferable and fungible within group. Model takes into account • Restricted fungibility of capital and • Limited liability of shareholders. Focus: solvency of consolidated group. Focus • Solvency of each legal entity • Dependencies between legal entities INTERNAL USE ONLY 60