Insurance Contracts Project Long-duration products March 3, 2014 Jennifer M. Weiner , Ernst & Young LLP | Partner | Professional Practice - Financial Services Michael M. Monahan, American Council of Life Insurers , Senior Director, Accounting Policy Content Key messages Existing guidance vs. proposed – are the changes improvements? Impact of the changes on the financial statements Appendix: recent meetings and decisions "The views expressed in this presentation are thoughts from the authors and do not necessarily represent the views of, and should not be attributed to, the American Council of Life Insurers or its members. Insurance Contracts Project Key messages FASB Project NOT dead Change in focus from convergence to improvements Unclear what “improvements” means Could get back to building block approach adjusted for constituent comments IASB Moving forward – focusing on: Other comprehensive income Unlocking the contractual service margin Participating contracts (probably biggest issue for Board to tackle) Insurance contract revenue Transition Plan on completing redeliberations in August and releasing final standard in first half of 2015 Expected cash flow assumptions Existing guidance FAS 60 products: Locked in assumptions at the initial contract recognition date and perform loss recognition test FAS 97 products: ▶ Record policyholder account balance plus the value of some guarantees ▶ Some guarantees and options not accounted for under existing guidance or accounted for using a glide path formula under existing guidance Potential Improvements? ► ► ► ► Update assumptions each reporting date Include expected: surrenders (and surrender charges); fees (cost of insurance mortality and expense charges and asset management fees); and, expenses (asset management expenses) Include expected value of all guarantees and options Recognize the change in those assumptions (other than the impact from the change in the discount rates) ► In the statement of comprehensive income ► In the balance sheet against an explicit margin Insurance Contracts Project Discount rate Existing guidance FAS 60 products: discount rate based on estimates of investment yields (net of related investment expenses) expected at the time insurance contracts are made consistent with circumstances, such as: ▶ Actual yields ▶ Trends in yields ▶ Portfolio mix and maturities, and ▶ The insurer’s general investment experience (typically includes defaults and reinvestment risks) FAS 97 products: a discount rate is not applied to the account value because the liability is recorded at the account value Potential Improvements? ► ► ► Use discount rates that reflect the characteristics of the liability ► Risk-free rate plus a liquidity adjustment ► A replicating portfolio ► Actual portfolio (adjusted for reinvestment risk) less items that are not related to the liability (i.e., expected and unexpected default, etc.). The impact from changes in the discount rates would be recorded to OCI Contractual participating features: ignore discount rate; record at corresponding asset value Insurance Contracts Project Margin Existing guidance Potential Improvements? ► FAS 60 products: ▶ Policyholder reserve includes implicit margin; earned over life of policies FAS 97 products: ▶ Margin is not typically recorded; recognized when fees are earned ▶ Margin recognized for unearned revenue liability (gross premium >net premium); recognized in constant relationship with inforce (life) or the amount of expected future benefit payments (annuity) ▶ EGP’s used to determine DAC amortization ► ► ► Recognize an explicit margin for the difference between the present value of the expected premiums and the measurement of the liability Recognize the margin as insurer satisfies its performance obligation and therefore is released from exposure to risk evidenced by a reduction in the variability (uncertainty) of cash outflows IASB: Recognize a risk adjustment for the compensation required for bearing the uncertainty about the amount and timing of future cash flows; where the entity is indifferent between fulfilling or selling the contract IASB: Recognize contractual service margin for remainder of difference between the present value of the expected premiums and the measurement of the liability; recognize as revenue over the coverage period based on services provided Insurance Contracts Project Premiums and benefit expense Existing guidance Potential Improvements? ► FAS 60 products: ▶ Recognize “premiums” and “benefit expense” when premiums are due ▶ Include all premium and benefit payments in income statement ► ► FAS 97 products: ▶ Recognize revenue when fees and charges are due ▶ Exclude from revenue and expenses account balances Recognize revenue in proportion to the value of coverage and any other services provided, including interest accretion on cash inflows Recognize claims and benefits expense as well as other fulfillment costs when incurred Exclude from revenue (and expenses) the amount of premium that the insurer is obligated to pay the policyholder or a beneficiary regardless of whether an insured event occurs Insurance Contracts Project What really changes if ED adopted Long-duration contracts Account Change in Statement of Financial Position Impact on Statement of Comprehensive Income Insurance contract liability / asset Measurement includes all features of the contract including options and guarantees not previously accounted for or accounted for at below present value Discount rates used may differ Assumptions are updated each reporting period Explicit margin is recognized and not offset for changes in expected cash flows Revenue recognition pattern will change from premiums due to an earned pattern for the portion attributable to the expected cash outflows and based on release from risk for the portion attributable to the margin Revenue may increase as a result of interest accretion on premiums Revenue may decrease for estimated returnable amounts Interest accretion recognized in investment income section rather than in underwriting section Impact on insurance liability as a result of changes in discount rates from initially determined discount rates recorded to OCI (unless contractually linked to assets recorded at fair value through P/L or contractual obligation is fair value) For contracts measured using FAS 60 Insurance Contracts Project What really changes if ED adopted Long-duration contracts Account Change in Statement of Financial Position Insurance contract liability / asset Liability is measured as the present value of the probability weighted expected cash flows rather than the policyholder account balance. In addition to the account balance accounted for today this will include: Expected surrenders (and surrender charges) Expected fees (cost of insurance mortality and expense charges and asset management fees) Expenses (asset management expenses) Expected guarantees and options not accounted for today or accounted for using a smoothing mechanism For contracts measured using FAS 97 Impact on Statement of Comprehensive Income Changes in expected gross profits transparent (rather than a mechanism for determining DAC amortization) Could recognize more premium (gross aggregate premiums less the amount that can be paid to the policyholder regardless of the insured event occurring) Recognize an explicit measurement of expected profit (i.e., the margin) Insurance Contracts Project Product Implications if ED adopted Products* Current GAAP Potential future GAAP Term life Future policy benefits and DAC (FAS 60 Long duration) ► PV of net fulfillment cash flows: mean of projections of cash inflows and outflows ► Current assumptions with changes in income (loss) ► Current discount rates for balance sheet ► Locked-in discount rates for income statement, except when expectations of crediting rates change and affect the measurement of the liability ► Changes in discount rates in OCI ► Unamortized margin (deferred gain), if any ► Probability-weighted Long-term care Future policy benefits and DAC (FAS 60 Long duration) Immediate annuities Future policy benefits and DAC (FAS 60 Long duration) Universal life Policyholder account balances and DAC (FAS 97) Deferred annuities Policyholder account balances and DAC (FAS 97) Closed blocks Future policy benefits and DAC (FAS 120) Guarantees w/ life contingency Future policy benefits (SOP 03-1) Guarantees w/o life contingencies Other liabilities (FAS 133 embedded derivatives) ► Accounted for under Financial Instruments standard (no significant change) Variable annuities and VUL Separate account assets and liabilities ► Segregated accounts (no significant change) Projection of base fees and benefits Stable Value Funds Policyholder account value with smoothed rate (FAS 97) ► Unclear Stable Value Wrap Fair valued as a derivative under FAS 133 ► – will depend on the types of guaranteed settlement options available. Unchanged Note * - “Products” are generic. Each individual product requires consideration under both current and future GAAP and does not indicate an EY view. Insurance Contracts Project Key performance indicators: long-duration contracts Current Significant KPI’s Available from proposed standard? Investment returns Benefit and expense ratio Premiums written/due Actual to expected experience measures for mortality, morbidity Disaggregation of information about the effect of experience adjustments and changes in estimates required in the notes or in the P&L Value of new business Information will be disclosed in the notes Value of existing book Balance sheet amount recognized using current assumptions; may not align to current definitions, which vary FASB ED proposal • Investment results highlighted separately from underwriting results on the face of the income statement • Interest accretion from unwinding of discount on liabilities included with investment income; interest accretion on cash inflows included in revenue • Investment income and expense for segregated fund accounts (i.e., separate accounts) presented with respective accounts instead of net • Premium recognition • Based on an “earned” concept which will change earnings pattern • Explicit margin earned based on release from risk offset by recognition of acquisition cost expense • Premiums written/due will be disclosed in the footnotes • Will recognize less premiums (and expense) for contracts where an amount could be paid to the policyholder regardless of the insured event occurring (e.g., whole life contracts and immediate annuities with term certain) • Could recognize more premiums for contracts with explicit account balances (i.e., universal life, variable annuities, etc.) for insurance component • Ceded/assumed premiums (and loss recoverables/payables) reported separately excluding returnable amounts not based on loss experience (i.e., ceding commissions, overrides, etc.) • Benefits and expense recognized when incurred; however; changes in assumptions recognized when made Insurance Contracts Project Timeline IASB plans to complete deliberations by August 2014 and issue final standard in first half of 2015 Effective date not yet discussed BUT IFRS 9 mandatory effective date for annual periods beginning on or after 1 January 2018 Opportunity to progress its insurance contracts project and potentially provide greater alignment between IFRS 9 and the new insurance contracts standard FASB directed the staff to analyze existing US GAAP guidance for insurance entities and identify potential areas for improvement for longduration contracts and potential disclosure improvements for shortduration contracts March 18-19 – joint meetings in Norwalk; FASB participation may be limited Insurance Contracts Project January 22, 2014 joint board meeting The FASB and the IASB discussed the feedback they received on their respective insurance contracts proposals. Some FASB members highlighted broad issues they would need to consider in redeliberations, including: Distinguishing between volatility, accounting mismatches and economic mismatch When the benefits of making the accounting more complex would outweigh the co Whether financial reporting comparability of insurers and other types of companies including financial institutions is important The IASB plans to address constituents’ concerns related to: Other comprehensive income Unlocking the contractual service margin Participating contracts Insurance contract revenue Transition The IASB will determine at a later date if any other issues will be redeliberated February 19, 2014 FASB Meeting February 19 Board decision All contracts that meet definition of insurance regardless of industry Scope Insurance entity; consider explicitly including other contracts later Changes to recognition, measurement and disclosures (premium allocation approach) Short-duration contracts Improvements to disclosures Long-duration contracts Improvements to existing US GAAP for recognition, measurement and disclosures Exposure Draft Changes to recognition, measurement and disclosures (building block approach) Insurance Contracts Project