NAIC AS and IEE (2005) Detail Outline for Exam 7 – 2007 Part D NAIC AS and IEE – note this is from 2003. Page #s in 2006 can be different. AS – 2003 Signature Page (Page 1) Assets (Page 2) (IASA 2) Liabilities, Surplus, and Other Funds (Page 3) (IASA 5) Underwriting and Investment Exhibit (Page 4) Statement of Income: U/W-ing income; Investment Income; Other Income (IASA 10); Capital and Surplus Account: Gains and (Losses) in Surplus (IASA 10). Cash Flow (Page 5) Part 1 – Premiums Earned (Page 6) – pulls in 1A and 1B to calculate EP. Part 1A – Recapitulation of All Premiums (Page 7) – calculated UPRs. Part 1B – Premiums Written (Page 8) – Direct + Assumed – Ceded = Net. Part 2 – Losses Paid and Incurred (Page 9) Part 2A – Unpaid Losses and Loss Adjustment Expenses (Page 10) Part 3 – Expenses (Page 11) (LAE paid) Exhibit of Net Investment Income (Page 12) Exhibit of Capital Gains (Losses) – Realized gains only. Exhibit 1 – Analysis of Nonadmitted Assets and Related Items (Page 13) Notes (none given here) (Page 14) (Need to know Notes 23-27, 32, and 33 - 2004) 23. Reinsurance (Unsecured Reinsurance Recoverables; Reinsurance Recoverables in Dispute; Reinsurance Assumed and Ceded; Uncollectible Reinsurance; Commutation of Ceded Reinsurance; Retroactive Reinsurance; Reinsurance Accounted for as a Deposit). 24. Retrospectively Rated Contracts and Contracts Subject to Redetermination 25. Changes in Incurred Losses and Loss Adjustment Expenses 26. Intercompany Pooling Arrangements 27. Structured Settlements 32. Discounting of Liabilities for Unpaid Losses and Unpaid LAE 33. Asbestos/Environmental Reserves Don’t need to know Pages 15-27 (unless discussed in another paper) Schedule D Summary by Country (Page 28) – Long-Term Bonds and Stocks Verification Between Years Part 1A – Section 1 (Page 29-31) – Bonds – (NAIC) Quality & Maturity NAIC classes defined as follows: 1. Highest Quality 2. High Quality 3. Medium Quality 4. Low Quality 5. Lower Quality 6. Bonds in or near Default Part 1A – Section 2 (Page 32-34) – Bonds – Maturity by Type & Subtype Schedule DA – Part 2 (Page 35) (may not need to know these) NAIC AS and IEE (2005) Schedule DB (Page 36) (may not need to know these) Part A – Verification Between Years Part B – Verification Between Years Part C – Verification Between Years (Page 37) Part D – Verification Between Years Part E – Verification Part F – Section 1 (Page 38) Part F – Section 2 (Page 39) Schedule F Part 1 (Page 40) Part 2 (Page 41) Part 3 (Page 42) Part 4 (Page 43) Part 5 (Page 44) Part 6 (Page 45) Part 7 (Page 46) (May not need to know) Part 8 (Page 47) (May not need to know) Schedule H – Accident and Health Exhibit Part 1. Analysis of Underwriting Operations (Page 48) Part 2. Reserves and Liabilities (Page 49) Part 3. Test of Prior Year’s Claim Reserves and Liabilities Part 4. Reinsurance Part 5. Health Claims (Page 50) Schedule P – Analysis of Losses and Loss Expenses (Page 51) Part 1 – Summary (Page 51) Part 2 – Summary (Page 52) Part 3 – Summary Part 4 – Summary Part 1A – Homeowners/Farmowners (Page 53) Part 1B – Private Passenger Auto Liability/Medical (Page 54) Part 1C – Commercial Auto/Truck Liability/Medical (Page 55) Part 1D – Workers’ Compensation (Page 56) Part 1E – Commercial Multiple Peril (Page 57) Part 1F – Section 1 – Medical Malpractice – Occurrence (Page 58) Part 1F – Section 2 – Medical Malpractice – Claims-Made (Page 59) Part 1G – Special Liability (OM, Aircraft (All Perils), B&M) (Page 60) Part 1H – Section 1 – Other Liability – Occurrence (Page 61) Part 1H – Section 2 – Other Liability – Claims-Made (Page 62) Part 1I – Special Property (Fire, Allied Lines, IM, EQ, Burglary and Theft) (Page 63) Part 1J – Auto Physical Damage (Page 64) Part 1K – Fidelity/Surety (Page 65) Part 1L – Other (Including Credit, Accident and Health) (Page 66) Part 1M – International (Page 67) Part 1N – Reinsurance – Nonproportional Assumed Property (Page 68) Part 1O – Reinsurance – Nonproportional Assumed Liability (Page 69) NAIC AS and IEE (2005) Part 1P – Reinsurance – Nonproportional Assumed Financial Lines (Page 70) Part 1R – Section 1 – Products Liability – Occurrence (Page 71) Part 1R – Section 2 – Products Liability – Claims-Made (Page 72) Part 1S – Financial Guaranty/Mortgage Guaranty (Page 73) Parts 2A – 2S (Pages 74-78) Parts 3A – 3S (Pages 79-83) Parts 4A – 4S (Pages 84-88) Part 5A (HO/FO) (Page 89) Section 1 Section 2 Section 3 Parts 5B – 5R (Pages 90-99): missing 5G, 5I, 5J, 5K, 5L, 5M, 5N, 5O, 5P, 5S Part 6C (CAL/Medical) (Page 100) Section 1 Section 2 Parts 6D – 6S (Pages 100-104): missing 6A, 6B, 6F, 6G, 6I, 6J, 6K, 6L, 6P, 6S Part 7A – Primary Loss Sensitive Contracts (Page 105) Section 1 Section 2 Section 3 Section 4 (Page 106) Section 5 Part 7B – Reinsurance Loss Sensitive Contracts (Page 107) Section 1 Section 2 Section 3 Section 4 (Page 108) Section 5 Section 6 Section 7 Sch P Interrogatories (Page 109) (descriptions from Feldblum) #1: a 10-yr exhibit of extended loss and expense reserves on CM policies for med mal, other liability, and products liability by exposure years. #2: discloses whether or not company complied w/ 1998 ULAE definitions. #3: relates to the distribution of AAO expenses and reserves by AY. #4: discloses loss reserve discounting & the resulting difference between the U/W-ing and Investment Exhibit and Sch P. #5: Discloses net premiums in force for fidelity & surety business. #6: discloses whether claim counts are per claim or per claimant. #7: a general question about reserve adequacy. Don’t need to know Pages 110-114 Schedule D – (Pages E-08 – E-14) Part 1 (Bonds) (Page E-08) Part 2 – Section 1 (Preferred Stocks) (Page E-09) Part 2 – Section 2 (Common Stocks) (Page E-10) Part 3 (Acquired) (Page E-11) NAIC AS and IEE (2005) Part 4 (Sold, Redeemed, Disposed of) (Page E-12) Part 5 (Acquired then Disposed of during year) (Page E-13) Part 6 – Section 1 (Page E-14) Part 6 – Section 2 Pages included in Combined Annual Statement: Title Page; Assets; Liabilities/Surplus/Other Funds; Statement of Income; Cash Flow; U/W & Investment Parts 1 – 3; Exhibit of Net Investment Income; Exhibit of Capital Gains (Losses); Sch D: Summary by Country, 1A-1 and 2; Sch F: 1,2,3,4,5,6,7; Sch H: 1 through 4; Sch P except interrogatories; Sch T, Sch Z; Sch D: 1 & 2; IEE Insurance Expense Exhibit – 2003 Title (IEE-1) Interrogatories (IEE-2) Part I – Allocation to Expense Groups (IEE-3) Part II – Allocation to Lines of Business Net of Reinsurance (IEE-4 – IEE-5) Part III – Allocation to Lines of Direct Business Written (IEE-6 – IEE-7) Overflow Page for Write-ins (IEE-8) Feldblum (Sch F), "Reinsurance Accounting: Schedule F" – W Introduction Purposes of Schedule F Parts 1-3 provide supporting data for assumed and ceded accounting entries. Parts 4-7 develop the provision for reinsurance. Part 8 restates the statutory B/S from a net to a gross basis. Note: Unlike other schedules, Sch. F reports all lines combined. Part 1: Assumed Reinsurance Parts 1 and 3 do not contain retroactive reinsurance – which is handled in the special surplus entry in liabilities in the stat B/S (page 3). Four types of assumed reinsurance entries: Losses payable on paid losses and case reserves. Premiums assumed, the UE portions of premium, and assumed premiums uncollected. Contingent commissions receivable/payable. Security, funds deposited with reinsured company. Losses Payable Col 6 (paid losses & LAE) matches line 2 of page 3. Col 7 (known case losses and LAE) is similar to col 2 total on U/W&Investment Exh, Part 2A. But the U/W Exhibit doesn’t include LAE. IBNR losses are in col 6 on U/W&Investment Exh, but not in Sch F, Part 1. Also, reinsurance losses paid during the year are not in Sch F. Premiums and Commissions Col 9: Contingent Commissions. Positive means reporting company expects to pay contingent commissions to ceding company. Col 10: Assumed premiums receivable – net of regular commissions (which don’t appear in Col 9 either). Col 11: UEP. Feldblum (Sch F), "Reinsurance Accounting: Schedule F" – W Funds Withheld and Letters of Credit Unauthorized reinsurers cause ceding companies to post provision (unless secured). Even if reinsurer is authorized and not slow-paying, ceding company may still request a letter of credit. Col 12: funds held by or deposited with reinsured companies. These are owned by the reinsurer but held by ceding company. Col 13: Letters of credit – a letter from financial institution securing recoverables. It doesn’t affect reinsurer’s B/S, but it lowers the ceding company’s provision. Col 14: Assets pledged to secure letters of credit – bank may request the reinsurer hold a compensating balance to secure the letter of credit. Part 2: Portfolio Reinsurance Part 3: Ceded Reinsurance Fronting Companies – column 5 lists totals of contracts ceding 75% or more of direct premium. This business is not normal. Fronting arrangements are used by insurers who want to write business in states where they are not licensed. For example, ABC wants to write WC business in New York where they’re not licensed. ABC arranges for XYZ to write the business and cede it to ABC. In exchange, ABC provides a fronting fee to XYZ. Some regulators don’t like this because they don’t have access to unauthorized reinsurers, and distressed companies may not present a full and true statement. Exceptions – to column 5: Affiliated transactions: A, B, and C are affiliated companies. A and C cede 100% of business to B, while B cedes 1/3 of all business to A and 1/3 to C. This is often used when one company is used for preferred insureds, and another used for subprimes. Pools: involuntary pools and JUAs Small Amounts: less than 5% of P/H Surplus. Captives: insurance companies part of larger companies. Loss and LAE Commissions Illustration 1: Excess-of-Loss Reinsurance Treaty Illustration 2: Surplus Share with Provisional Commission Part 4: Aging of Ceded Reinsurance – Starting in 1989, there is a statutory penalty for 20% of loss recoverables more than 90 days past due and 20% of all recoverables from slow-paying authorized reinsurers; Also a payment schedule was added. The Due Date 1. If the original contract specifies when recoverables are due, then that is the due date. Example: loss occurs March 15. Loss paid by ceding company on Aug. 15. Ceding company bills reinsurer on Sept. 15. Contract says recoverables due within 30 days of time of notice. Thus due date = Oct. 15. 2. If a due date is not specified, but contract does specify a determination of a date at which claims are presented to reinsurer, then that is the due date. Example: contract says claims are presented to the reinsurer within 30 days of the date loss is paid by ceding company, then due date = Sept. 15. Feldblum (Sch F), "Reinsurance Accounting: Schedule F" – W 3. If due date nor presentation date not specified, and loss is >= $50k, then due date is the date losses were paid. For example, if dates not available in above example, and loss = $100k, then due date = Aug. 15. 4. If dates not available and loss is < $50k, then claims are to be considered current. Note: Reinsurance intermediary or broker is same as reinsurance cos here. The Aging Schedule – note the following columns in Part 4: Reinsurance Recoverable on Paid Losses and LAE 5 Overdue 10 = 6 7 8 9 Sum(6,7,8,9) 30 to 91 to Over 1 to 29 90 120 120 Total Current Days Days Days Days Overdue 12 13 11 = 5+10 = 10/11 Total Due %-age Overdue = 9/11 %-age More than 120 Days Overdue Column 13 isn’t used in statutory calculations. The Statutory Provisions for Reinsurance Provides penalties for: unsecured recoverables from unauthorized reinsurers unsecured recoverables from slow-paying (authorized) reinsurers overdue recoverables from authorized & unauthorized reinsurers recoverables in dispute from unauthorized & non-slow-paying authorized reinsurers. Provision appears page 3, line 16 of AS. Reinsurance recoverable on paid losses is an asset (page 2). Reinsurance recoverable on unpaid losses offsets gross unpaid losses and LAE; and Ceded UEPR offset gross UEPR (liabilities – page 3). Provision affects all 3 of these. Provision doesn’t affect loss reserves (which are net) included in losses on page 3; or in the Underwriting/Investment Exhibit, or in Sch P, where there is no distinction between authorized/unauthorized reinsurers and slow-paying/non-slow-paying. Provision must be >= uncollectible reinsurance. The change in provision directly affects surplus, but doesn’t affect statutory income statement. Reducing surplus also reduces RBC adjusted surplus and RBC ratio. GAAP statements have no provision. GAAP also shows all reinsurance recoverables as assets, and not liability-offsets. AM Best also removes provision when calculating adjusted leverage ratios. Note 22D. “Uncollectible Reinsurance” discloses uncollectible written off in four categories: (i) losses incurred, (ii) LAE incurred, (iii) premiums earned, (iv) other. A company with writeoffs greater than provision may be underestimating liabilities. Actuary must discuss collectibility on loss reserve adequacy in Statement of Actuarial Opinion. Relationships Prospective vs retrospective: Note 22 is a retro disclosure. Provision, GAAP offset for expected uncollectible, and actuary’s disclosure in Opinion are prospective estimates. Feldblum (Sch F), "Reinsurance Accounting: Schedule F" – W Basis of Estimate: Note 22 is fact. Sch F Provision is formula-driven. GAAP financial statements are management’s best estimate of future uncollectibility. Actuarial Opinion is Actuary’s estimate of future uncollectibility, which can differ from management’s. SAP-GAAP Accounting Philosophies GAAP – going concern; satisfies investors; usually estimated by management, and audited by an independent accountant. Statutory Accounting – seeks to ensure insurance obligations; satisfies P/Hs; relies heavily on conservative formulas; monitored by Regulators. GAAP Statutory Accounting Audience Served Investors P/Hs Focus (Topic) Future profitability Current obligations Focus (AS) Income statement B/S Nature of Estimate Unbiased Conservative Basis of Estimate Company management Statutory formula Users Sophisticated Unsophisticated Companies Targeted Going concern companies Distressed companies Decision Tree 1. If reinsurer is not authorized, provision for reinsurance = 100% of unsecured total recoverables + 20% of loss recoverables >90 days + 20% of amts in dispute. Security has no effect on the last two items. Provision is capped by total recoverables. 2. If reinsurer is authorized AND is slow-paying, then provision = greater of (i) 20% of unsecured total recoverables (including disputed amts) and (ii) 20% of loss recoverables >90 days. No capping is needed. 3. If reinsurer is authorized AND is non-slow-paying, then provision = 20% of loss recoverables >90 days + 20% of amts in dispute >90 days. Part 5: Unauthorized Reinsurers History: Before 1989, provision only applied to unsecured recoverables from unauthorized companies. In 1991, a provision for overdue recoverables from authorized reinsurers was added. Security reduces the provision for total recoverables from unauthorized, but not for overdue recoverables from authorized. If all recoverables are secured, then authorized felt this was too harsh. So the provision for overdue recoverables from unauthorized companies was applied as well. Recoverables in dispute are not overdue, so a ceding company could avoid penalties by classifying some overdues as “in dispute”. So in 1993, a provision for disputes was added. Penalty for Unsecured Recoverables Column 5: total recoverables = net UEP, loss recoverables, commissions (Part 3 Col 15) Columns 6-10 are funds securing recoverables: funds held by company (6), letters of credit (7), ceded balances payable (8), miscellaneous balances (9), other allowed offset items (10). Column 12 = Col 5 – sum(6-10), but must be >=0. Feldblum (Sch F), "Reinsurance Accounting: Schedule F" – W A letter of credit in statutory accounting must be evergreen (must renew as long as recoverables are outstanding) in order to offset provision. Overdue Recoverables – Columns 13-14. 20% recorded regardless of security. Capped at the securing funds (6-10). Amounts in Dispute – Column 16; included in total recoverables (5) and excluded from overdue recoverables (13). Dispute = litigation, arbitration, notification (formal written communication denying validity of coverage). Capped by securing funds (6-10). Illustrations Part 6: Overdue Authorized Reinsurance Column 7 shows slow-paying test = (loss recoverables >90 days) / (all recoverables on losses&LAE + amts received in last 90 days of statement year); if the ratio >= 20% then reinsurer is slow-paying. For these companies: provision = 20% (loss recoverables >90 days + Disputed amts). (Note that disputed amounts are excluded from >90.) Incentives – the amts received in last 90 days was added to the denominator to avoid discouraging claim settlements at the end of the year. Part 7: Slow-Paying Authorized Reinsurers – how do we know these are slow-paying? Provision is greater of 20% of unsecured total recoverables and 20% of overdue recoverables. Amounts in dispute aren’t considered (they are included – not excluded). The Provision for Reinsurance – calculation is done in the footnotes of Part 7. Other Estimates – company should hold greater of the provision and the estimated uncollectible recoverables; Residual Markets – all recoverables from mandatory pools should be reported as current. Part 8: Restatement of Balance Sheet – added in 1992 (comparable to SFAS 113) Liabilities on Pg 3 are net of reinsurance. Before 1992 GAAP offset ceded reserves against direct reserves (SFAS 60). Now separate entries for direct reserves and reinsurance recoverables are required unless a legal right of offset exists. Part 8 restates the B/S to be gross of reinsurance. Illustration A First Year: Policy issued 12/31/2001 with $10K premium. 40% quota share. UEPR = $10K gross and $6K net. Second Year: A $5K loss on 10/1/2002. Premium fully earned. UEPR = 0. Loss is unpaid at end of year. Loss reserve = $5K gross and $3K net. Third Year: Loss is paid, but not reimbursed by Reinsurer yet. Loss reserve = 0. The $2K recoverable is moved from a contra-liability to an asset (reinsurance recoverable on paid losses), even though there is no cash transaction. Fourth Year: Reinsurer pays recoverable. The asset is replaced with cash, with no effect on the income statement. Part 8 states helps to identify the net credit for reinsurance. Illustration B – Company pays $10M for quota share. Reinsurer pays $2M with recoverables of $1.5M on paid and $4.5M on unpaid. Surplus = $20M. Surplus was reduced $2M. Part 8 shows how much of surplus consists of recoverables ($6M). Illustration C – If reinsurer unauthorized with no security, provision = $6M. Surplus = $14M. Illustration D – If reinsurer provides $3.5M letter of credit, provision = $2.5M. Surplus = $17.5M. Of that, $3.5M arises from recoverables (Part 8). Feldblum (Sch F), "Reinsurance Accounting: Schedule F" – W Illustration E – If the security is funds withheld instead of letter of credit, provision = $2.5M. Surplus = $17.5M. The fund withheld is either an offset to reinsurance recoverable or to the cash held by ceding company owned by reinsurers. Part 8 doesn’t include cessions to involuntary pools/JUAs. Restatement of Balance Sheet to Identify Net Credit for Reinsurance- entries are as follows: Assets: 1. Cash & invested assets; 2. Agents’ balances or uncollected premiums; 3. Funds held by/deposited w/ reinsured companies; 4. Reins recoverables on loss & LAE payments; 5. Other assets; 6. Net amt recoverable from reinsurers; 7. Totals. Liabilities: 8. Losses & LAE; 9. Taxes, expenses, other obligations; 10. UEPs; 11. Advance premiums; 12. Dividends declared & unpaid; 13. Ceded premiums payable (net of commissions); 14. Funds held by company under reinsurance treaties; 15. Amts withheld/retained by company for account of others; 16. Provision for reinsurance; 17. Other Liabilities; 18. Total Liabilities excluding Protected Cell; 19. Protected Cell liabilities; 20. Total Liabilities; 21. P/H Surplus; 22. Totals. Restatement of Liabilities – Col 1 = net; Col 2 = needed adjustment; Col 3 = restated gross. Two types of adjustments: All reinsurance recoverables grouped as Line 6. Provision for reinsurance and funds held by company are offsets to Line 6. Line 8: Illustration A @ 2002: $3K net, $5 gross. Line 10: Ill. A @ 2001: $6K net, $10K gross. Line 11 would be similar with all advance premiums fully unearned before policy eff date. Line 13: a summary of Reinsurance Premiums Ceded UEPs Ceded advance premiums Reins. premiums payable Payment status Already paid Already paid Who holds cash Who owns funds Liability vs. contra-liab Sign of adjustment reinsurer Ceding co. Contra-liab positive reinsurer Ceding co. Contra-liab positive Not yet paid Ceding co. reinsurer liability negative Line 14 & 16 are liabilities. When reinsurance recoverables are grouped together, these liabilities become offsets to that asset. Line 14 is a liability in SAP and GAAP, while Line 16 only effects SAP. Line 15 are not related to reinsurance (unpaid FICA tax, uncashed checks to claimants) Line 17 could include P/H dividends declared and unpaid if the reinsurer contributes part of the dividend. Line 19 relates to securitization of insurance liabilities (an alternative to reinsurance). Line 21 (Note: doesn’t match 2003 AS): P/H Surplus cannot change. Line 6 (in assets) is the balancing item. Restatement of Assets Line 4: Is fully offset in Col 2, leaving 0 in Col. 3. This transfers to Line 6. Line 3: These funds are owned by reporting company, but held by reinsurers. This relates to assumed reinsurance. Reporting company will show 0 in Col 2. Feldblum (Sch F), "Reinsurance Accounting: Schedule F" – W Line 2: Left over from earlier AS’s. Note that in 2003, this line is replaced. Before 2001, agents’ balances were net or reinsurance premiums payable. Line 1 & 5: Used by some companies; others show 0s in Col 2. Line 6: Balances so that total assets = total liabilities & surplus. I. Illustrations: Restatement of Balance Sheet – Company has recoverables $160M on paid/unpaid, and $20M on UEPR. What are the adjustments? Assets Lines 1, 2, 3, 5: No adjustment. Line 4: Zeroed out completely. (-$40M in this case). Lines 6 & 7 determined later. Liabilities Line 8: Total recoverables on paid/unpaid are $160M. Recoverables on paid = $40M (from Line 4). Recoverables on unpaid = $120M. Adjustment = $120M. Lines 9, 11, 12, 15, 17: No adjustment Line 10: Adjustment = ceded UEPR = $20M. Line 13: ?? Ceded reinsurance premiums payable are fully offset: (-$5M in this case). Line 14: Fully offset: (-$20M in this case). Line 16: Fully offset: (-$15M in this case). Line 18: Total = +$100M (Note: This is inconsistent with Line #s above, but consistent with the 2003 AS – sloppy!!) Line 19: P/H Surplus remains same ($110M) Balancing Items Total Asset adjustment (Line 7) must be $100M, so Line 6 = $140M. II. Illustration: Provision for Unauthorized Reinsurance III. Overdue Reinsurance Aging Schedule IV. Slow-Paying Reinsurers V. Provision for Reinsurance by Type of Reinsurer Schedule F: Objectives and Evaluation Accounting Philosophies Supplement vs Replacement Unintended Consequences Accuracy Indicators of Uncollectibility The Reach of Regulation Prospective vs Retrospective Risks Conclusion Appendix A: Federal Income Taxes Appendix B: RBC Requirements Feldblum (Notes), "Notes to the Financial Statement," – W Feldblum (Notes), "Notes to the Financial Statement," – W Discounting of Liabilities for Unpaid Losses and Unpaid Loss Adjustment Expenses (32) Instructions – State whether any liabilities for unpaid losses or LAE are discounted. If so, then also respond to Sch P Interg. 4, and columns 32 and 33 of Part 1 in Sch P. a) if tabular basis used: Identify table used, rates used to discount, the amt of discounted liability in statements, and the amt of tabular discount by LOB and reserve category (case and IBNR). b) if non-tabular basis used: Identify rates used to discount and the basis for rates used, amt of non-tabular discount disclosed by LOB and reserve category (case, IBNR, ALAE, ULAE), amt of non-tabular discount in statement. c) if rates used to discount prior AY liabilities have changed from prior statement, or if there are changes in key discount assumptions (like payout patterns): Identify amt of discounted current liabilities at current rate (excluding current AY), amt of discounted current liabilities at previous rates (excluding current AY), change in discounted liability due to change in rates, amt of non-tabular discount by LOB and reserve category. Reserve Valuation Tabular discounts are allowed on WC Indemnity and on long term disability claims written on A&H policies. They are not allowed on medical payments and LAE. Reserve discounts allowed for some monoline med mal. Reserve discounts may be allowed by state insurance commissioner. Tabular Discounts and IBNR Claims – it is allowed on both case and IBNR. Dynamic Discount Rates Risk-Based Capital GAAP Disclosure Sch P: Columns 32 and 33 of Part 1. Statement of Actuarial Opinion: Actuary comments on how loss reserve discounts may affect reserve adequacy. Notes to the Financial Statements: See Instructions above. Changes in Discount Rates Change in Estimate Intercompany Pooling Arrangements (26) Instructions – if company is part of a group of affiliated companies participating in an intercompany pool, the following should be disclosed: 1) ID of lead company and of all affiliated companies and their respective pool %-ages. 2) Description of the lines and types of business subject to pooling agreement. 3) Description of cessions to non-affiliated reinsurers, and whether these cessions were prior to or after the cession of pooled business from the affiliated pooled members to the lead company. 4) ID of all pool members that are parties to non-affiliated reinsurance agreements that have a right of direct recovery from non-affiliated reinsurer. 5) Explanation of discrepancies between entities regarding pooled business on reinsurance schedules of lead company and corresponding entries on schedules of pool participants. Feldblum (Notes), "Notes to the Financial Statement," – W 6) Description of intercompany sharing of the Provision for Reinsurance and the writeoff of uncollectible reinsurance, if other than pool participation %-age. Intercompany Pooling Different reasons for intercompany pooling arrangements: - a parent company may retain management and structure of an acquired company (especially foreign subsidiaries). - an acquired company may have a different distribution system or book of business. - if a primary company acquires a reinsurer, they may wish to keep arms-length transactions, especially if reinsurer assume competitors’ business. - an affiliate may be designated to handle run-off business. - an insurer may gain regulatory/tax benefits from a company being in a different domicile (Bermuda). - an insurer may avoid onerous state regulation by designating one company to focus on one state’s business. - an insurer may have a multi-tiered rating structure, where each company handles certain different levels of risk (RSA did this). One management team may run all companies, where each entity cedes its business to the lead company, which then retrocedes a %-age to each legal entity. The pooling agreement covers premiums, losses, LAE. U/W expenses allocated according to state regulation. Assets, investment income, surplus are not affected. Cessions and assumptions from unaffiliated companies depends on whether or not they are classified as pool business. Pooled business is treated differently in Sch P than elsewhere, like Sch F. This Note helps to reconcile the differences. (In Sch P, history must be restated as if the current pooling was always in effect.) High Deductibles – (31) – disclose the amt of reserve credit that has been recorded for high deductibles on unpaid claims and the amts that have been billed and are recoverable. Similar to retrospective rating Insurer is liable for all claims, and is reimbursed by employer for losses below the deductible. Reimbursement is similar to a retro premium. Insurer assumes credit risk that employer won’t pay reimbursement (as in retros). In some states, reimbursement is treated like premium. Similar to excess insurance with a (claims handling) service contract Reserves on stat statements are net of expected reimbursements. RBC capital WP risk charge is levied on actual premium. In some states, the reimbursement is like service fees to a 3rd party administrator. Non-admitted asset charge levied on reimbursements for losses already paid, but not for reimbursements on unpaid losses. Regulatory Concerns – 10% non-admitted charge for uncollected reimbursements offsets the credit risk. The employer may not be able to pay an LDD assessment. Risk to employees is that insurer may not be able to handle claims because employer didn’t pay reimbursements, which is offset by stat rule that insurer is directly liable for WC claims. Feldblum (Notes), "Notes to the Financial Statement," – W Accounting for Unpaid Losses – these are net of expected reimbursements. (in retro rating, the entire loss reserve is a liability and the retro premium is an asset.) GAAP shows loss reserves gross of reinsurance recoverables and employer reimbursements. Non-Admitted Assets GAAP shows all receivables owed to the insurer. If a receivable is not receivable, it is written off through the income statement. Statutory accounting uses formulas to determine the non-admitted portion. If receivable is already due but not yet received, it’s not admitted if more than 90 days past due. If the receivable is not yet due, 10% of unsecured amount is not admitted (this is where large $ deductible reimbursements fall). If the receivable is secured it’s fully admitted. Paid Losses – these are net of reimbursements. Illustration: Accounting for Paid Losses – insurer sells high deductible WC w/ deductible = $500k on Jan 1. Claim on July 1 for benefits of $1K a week and expected disability of 1 yr. Insurer pays benefits through end of year, and intends to bill employer each July 1 for PY’s reimbursement. Employer hasn’t paid any reimbursement by Dec 31. B/S: (net of expected reimbursements): case reserve, incurred & paid loss = 0. $26K is credited from cash and debited to “reimbursements receivable under large dollar deductible policies”. 10% is non-admitted, so admitted = $23.4K. Income Statement: Future pmts are $26K, but should be fully reimbursed. Net reserve = incurred losses = 0. Cash flow shows $26K reduction in cash, and surplus decreases by $2.6K (non-admitted). Deferred Tax Asset: Income is $2.6K lower than the actual taxable income, and the difference will reverse over the coming year, so the stat deferred tax asset = $910. (which is 35% of 2.6K.) Illustration: Accounting for Loss Reserves and Reimbursements – insurer sells WC policy with $500K deductible on 7/1/2004. By 12/31, it has paid $350K in reimbursable benefits, and it has received $225K. It expects to pay $2.5M more in benefits, of which $2.2M is reimbursable. $300K is for expected payments above the deductible. Stat B/S shows loss reserves = $300K. GAAP shows $2.5M loss reserves and $2.2M expected reimbursements. Paid losses on cash flow are 0, and so are incurred losses. B/S entries are a net credit of $125K, of which $12.5k is non-admitted. Incidence of Loss Illustration: Accounting for Unidentified Losses Illustration: Accounting for Aggregate Deductibles Disclosures Note: Asbestos and Pollution (33) – these exposures are large, and it’s unclear who is liable for the damages or how one can estimate them. SSAP 65 states that the following should be disclosed: a) reserving method for case and IBNR reserves; b) amt paid and reserved for losses & LAE on gross and net basis; c) description of LOBs where there is potential environmental exposure, and the nature of the exposures; Feldblum (Notes), "Notes to the Financial Statement," – W d) the following for the five most current CYs gross and net, separately for asbestos and environmental losses: Beginning reserves, incurred losses and LAE, CY payments for losses & LAE, Ending reserves. Reserving methods Reinsurance Assumed and Ceded (23C) Instructions 1. Report max amt of return commission which would be due if they cancelled all reinsurance or if a receiver cancelled all of your assumed reinsurance…. 2. Report additional commission based on loss experience or profit sharing arrangement as a result of existing contractual arrangements Reinsurance Commissions Reinsurance has 2 functions: risk transfer and capital management (freeing capital embedded in loss or UPR). This note looks for possibilities of abuse of using commissions for surplus relief. Surplus relief can be misleading in two ways: If ceding company faces distress, reinsurer may not renew treaty, restoring the high premium-to-surplus ratio. A company may obtain an artificial relief by paying a higher reinsurance rate with a higher commission. Commission equity = UEPR * the reinsurance commission rate. The Note: Assumed Reinsurance Premium Commission Reserve Equity (1) (2) Ceded Reinsurance Premium Commission Reserve Equity (3) (4) Net Premium Commission Reserve Equity (5) (6) i. Affiliates ii. All Other iii. Total iv. Direct UEPR Illustration 1: Excess-of-Loss Reinsurance Treaty Contingent Commissions Part 2 of the Note: Reinsurance Direct Assumed Ceded Net i. Contingent Commission ii. Sliding Scale Adjustments iii. Other Profit Commissions iv. Total Illustration 2: Surplus Share with Provisional Commission Quota-share insurance is usually priced with a ceding commission, which becomes the effective reinsurance rate. Feldblum (Notes), "Notes to the Financial Statement," – W The treaty could use a contingent commission with high provisional rate to provide surplus relief. Retroactive Reinsurance (23F) Instructions 1. Provide info for retro reinsurance for losses already occurred: reserves transferred, consideration paid or received, paid losses reimbursed/recovered, special surplus from retro reinsurance, list of cedents/reinsurers included. 2. Disclose all contracts covering losses occurring prior to inception of contract not accounted for based on SSAP 62. Prospective vs. Retroactive Reinsurance Retroactive reinsurance can include reinsuring unpaid losses. Before 1992, outside of NY, most states treated retro reinsurance as ordinary. NY argued that companies used “loss portfolio transfers” to replace full value reserves with present values. Or reinsurer assumed no U/W risk. In 1992, NAIC adopted NY’s rules. Gain from retro reinsurance is set aside as special surplus and transferred to unassigned surplus after losses are paid. As a result, retro reinsurance cannot offset the reserves anymore. To get surplus relief from an undiscounted reserve, cede the reserves to a reinsurer at a discounted price (close to PV). Ceding company gets the difference in surplus relief and the reinsurer gets a profit. Accounting Procedures If reinsurance doesn’t satisfy FAS 113, then accounting entries are a reduction (credit) to cash and a debit to “deposit with reinsurance company.” No surplus relief. On GAAP, if reinsurance satisfies FAS 113, then recoverables are assets. Gains recognized over policy term for prospective and over lifetime of claims for retros. Stat Accounting: surplus relief is immediate, and additional surplus = “special surplus”. Feldblum (Notes), "Notes to the Financial Statement," – W Disclosure Requirements – aggregate of all retro insurance are reported in this format: (1) (2) Assumed Ceded A. Reserves Transferred: 1. Initial Reserves 2. Adjustments – Prior Year(s) 3. Adjustments – Current Year 4. Total B. Consideration Paid or Received: 1. Initial 2. Adjustments – Prior Year(s) 3. Adjustments – Current Year 4. Total C. Amounts Recovered/Paid (cumulative): 1. Prior Year(s) 2. Current Year 3. Total D. Special Surplus from Retroactive Reinsurance: 1. Initial 2. Adjustments – Prior Year(s) 3. Adjustments – Current Year 4. Closing Balance Additionally, retroactive insurance must be discussed by Actuary in the Opinion. Uncollectible Reinsurance (23D) Instructions – Describe uncollectible re written off including: losses incurred, LAE incurred, premiums earned, other. Four disclosures: GAAP statements: management’s prospective estimate – a non-ledger bad debt offset. Provision for reinsurance must be at least as large as uncollectible re. Appointed Actuary comments on it in Actuarial Opinion The Notes: uncollectible re written off – a retrospective disclosure. In most cases, the provision for reinsurance will be larger than uncollectible re because: Provision includes uncollectibles for all years, while the Note only reports one year. Provision should be at least as large as estimated uncollectible re. (Okay.) Structured Settlements (27) Annual Statement Instructions A. Disclose amt of reserves no longer carried by insurer because it has purchased annuities w/ claimant as the payee (one to whom money is paid) and the amt insurer is liable for if the annuities fail to perform. B. Disclose names and location of ins co and aggregate statement value of annuities due from any life insurer where the aggregate value => 1% of P/H Surplus. Include only Feldblum (Notes), "Notes to the Financial Statement," – W annuities where the company has not obtained release of liability from claimant. Also disclose if life insurers are licensed in the company’s state. Background – structured settlement is where one party (P&C) makes periodic payments (life annuity) to a 2nd party (accident victim) as compensation for damages incurred. Usually decided out-of-court. Structured Settlements and Retroactive Reinsurance Some insurers (usually WC carriers) will make the payments themselves, and the reserves they carry may be undiscounted or tabular discounted. Insurer may purchase a life annuity to make payments. The life insurance company will then use a discounted annuity reserve. Casualty insurer may purchase an annuity from its own life insurance subsidiary. Funding the settlement w/ an annuity is like retroactively reinsuring w/ a life insurance company. Stat accounting doesn’t allow a reduction in reserves for retroactive reinsurance, but this is not true for structured settlements. Rather, these settlements are seen to benefit the injured parties, so it’s not counted against the ceding company. Rationale for Structured Settlements Matching: Plaintiffs are entitled to lump sum payments, but jurors may disagree on the life expectancy of plaintiff or the discount rate to use. A structured settlement allows jurors to match compensation to damages suffered. Management of Assets: Lump sums can be squandered. Victims may be susceptible to fraudulent investment schemes. Structured settlements may be better. Minors: If injured is minor or incompetent, courts will probably suggest a structured settlement. Taxes: Money received in compensation for damages isn’t taxable. However, investment income on a lump sum is. If lump sum is awarded first and then exchanged for a structured settlement, it will be taxed. Statutory Accounting Treatment – four parties to consider in an annuity: The owner buys the annuity, who can then transfer ownership to someone else for compensation or as a gift. The annuity writer is usually a life insurance company. The measuring life determines the duration of benefits. ??? The payee receives the annuity payments. GAAP and Statutory Accounting Disclosures – this is necessary when the claimant is the payee and the insurer has not obtained a release of liability. Commutation of Ceded Reinsurance (23E) Instructions – describe commutations of ceded reinsurance during year by the following classes, including name of reinsurers: Losses incurred, LAE incurred, Premiums earned, other. Motivations for Commutations Reinsurance Recoverable in Dispute (23B) Instructions – Reinsurance recoverable on paid/unpaid (with IBNR) losses in dispute by notification (formal letter denying coverage), arbitration, litigation shall be identified if disputed amts for a reinsurer >= 5% P/H Surplus or if aggregate of all disputed items >= 10%. Feldblum (Notes), "Notes to the Financial Statement," – W Amounts in Dispute and Overdue Recoverables – Amounts in dispute do not enter the payment schedule in Part 4. (What?) Disclosure Requirements Feldblum (Surplus), "Statutory Surplus: Computation, Pricing and Valuation," – W Balance Sheets and Income Statements B/S: surplus = assets – liabilities. I/S: surplus = last year’s surplus + current year’s income. Example: Insurer begins year with $2000 surplus and $2000 cash. One policy for $1000 premium on Jan. 1. Incurs expenses of $250 and losses of $600 during year. Statutory acct on accrual basis, not cash basis. $200 paid by Dec 31, $400 in reserves. Then cash increases by + 1000 – 250 – 200 = + 550. Total cash = $2,550. Liabilities (0 at beginning) are $400 at end. Surplus = 2550 – 400 = $2,150. Net income = 1000 – 600 – 250 = $150 (the addition to surplus). In the following examples: Nonadmitted assets & statutory liabilities affect the B/S , but not the I/S, which is not affected. Non-Admitted Assets – in this example, $100 of premium is uncollected and >90 days due. No change to the I/S. Before adjustments, surplus = $2,150. In B/S, the non-admitted portion is reported in Col. 2 of Pg 2. Cash on hand = 2000 + 900 – 250 – 200 = $2,450. Surplus = $2,450 – $400 = $2,050. (Different from I/S.) The Asset Exhibit – Exhibit 1 on Pg 13 reconciles I/S surplus with B/S surplus. The Statutory Balance Sheet 4 columns on the B/S Assets page (Pg 2): 1) Assets; 2) Nonadmitted assets; 3) Net Admitted Assets; 4) Prior Year Net Admitted Assets. 3 columns on Exhibit 1 (Pg 13): 1) non-admitted assets at beginning; 2) non-admitted assets at end; 3) Change for year (col 2 minus col 1 – note this is backwards). Surplus Adjustments Exhibit 1 column 3 increases/decreases surplus on Pg 4 (line 26). Non-admitted assets in Exh 1 include regular N/A assets on B/S plus: bills receivable – past due – taken for premium; furniture & equipment; loans on personal security. Exhibit 1 does not include: non-admitted portions of assets lines 1-9; excess of book over market values (the change of which is unrealized capital gain/loss). Office Furniture Two methods for accounting for non-admitted assets: 1: Write off non-admitted asset as an expense on I/S. 2: Use GAAP entries for B/S and I/S, but classify asset as non-admitted with direct charge to surplus. Example: insurer buys office furniture with useful life of 10-yrs for $100K. GAAP entries are: Credit cash by $100K; debit office furniture asset by $100K. No change in GAAP equity. (All ledger entries.) On Stat financial statements – Method 1 has: credit cash by $100K, debit general expenses (I/S) by $100K. Stat surplus declines by $100K. Feldblum (Sch F), "Reinsurance Accounting: Schedule F" – W Method 2 has: Credit cash by $100K; debit furniture by $100K as non-admitted; change in nonadmitted assets is a charge to surplus. Year 2 GAAP non-ledger entries have: credit office furniture by $10K, debit depreciation expense by $10K. Stat – Method 1: no more accounting transactions. Stat – Method 2: credit office furniture asset by $10 (non-admitted) and debit depreciation expense by $10K. -$10 change in non-admitted assets will increase surplus. Accrued Retrospective Premiums Statutory Liabilities: Provision for Reinsurance Unrealized Capital Gains Audit Premiums Deferred Policy Acquisition Cost and Premium Deficiency Reserve Interest Due and Accrued Real Estate Stockholder Dividends and Capital Contributions Statutory Surplus, GAAP Equity, and Capital Invested In other industries, ROE is a proxy for the return on invested capital. For P&C insurance, GAAP equity <> invested capital. Invested capital = statutory surplus + capital embedded in gross UEPR and full value loss reserves. Double Taxation Valuation: Cost of Holding Capital: IASA 1, Chapter 2. Assets – L Admitted Assets Bonds – valued at amortized or the lesser of amortized and market (for low quality bonds). Stocks – explained below Mortgage Loans on Real Estate Real Estate – real estate owned by and more than 50% occupied is considered property. less than 50% occupied real estate is counted as property held for production of income or held for sale. Admitted Asset (properties occupied and held for production of income) = net book value (depreciated cost) minus related encumbrances. Admitted Asset (properties held to sell) = lower of (net book value or fair value) minus related encumbrances and estimated costs to sell the property. Cash and Short-Term Investments Cash includes savings accounts, CDs w/ maturity dates 1 year or less from acquisition date, cash equivalents such as short-term, high liquid investments. Short-Term Investments includes bonds w/ remaining maturities of 1 yr or less at time of acquisition, commercial paper, MM instruments, repurchase agreements. Reported in Schedule DA. Other Invested Assets Receivable for Securities Agents’ Balances or Uncollected Premiums – nonadmitted assets include uncollected premium over 90 days past due; uncollected ABs on policy by policy basis that exceed 90 days IASA 1, Chapter 2. Assets – L past due; and amt over 90 days due plus future installments for installment premiums over 90 days past due. If the reporting company is a direct writer, then premium balances include full amt due. If company uses an agent but bills P/Hs directly, the company may net out the commissions paid. If company writes through agents who collect premiums, the premium is usually recorded net of commissions. Funds Held By or Deposited With Reinsured Companies Bills Receivable Taken for Premiums Amounts Billed and Receivable Under Deductible and Service Only Plans Reinsurance Recoverable on Loss and LAE Payments Federal and Foreign Income Tax Recoverable and Interest Thereon Guaranty Funds Receivable or on Deposit – this refers to amts on deposit for receivables due from state guaranty funds and premium tax credits or P/H surcharges, etc. Electronic Data Processing Equipment and Software – capitalized and depreciated. Only other SAP asset to be treated this way is real estate. This is required to avoid fluctuating expense levels due to relatively high cost and irregularity of purchases. Operating system software counts as admitted since it creates the environment in which workers can work. (Individual application are not admitted.) EDP is also very quickly obsolete – further necessitating depreciation. Interest, Dividends, and Real Estate Income Due and Accrued Real Estate (Schedule A) Mortgages (Schedule B) and Other Invested Assets (Schedule BA) Bonds (Schedule D) Stocks (Schedule D) Interest on Bank Balances (Schedule E) Net Adjustments in Assets and Liabilities due to Foreign Exchange Rates Receivable from Parent, Subsidiaries, and Affiliates Amount Due from/to Protected Cells Equities and Deposits in Pools and Associations Amounts Receivable Relating to Uninsured Accident and Health Plans Details of Write-Ins Nonadmitted Assets Bills Receivable Not Taken for Premiums Furniture, Equipment, and Supplies – these are nonadmitted assets to be valued at the undepreciated amt after being capitalized and depreciated. SAP requires reporting the total cost of asset in year of acquisition and a portion of the cost as expense each year. Over the life of the asset, the entire cost will have been recorded as depreciation expense. Supplies such as pencils, stationery, paper are simply expensed and not counted as admitted assets. Leasehold Improvements Loans on Personal Security, Endorsed or Not Loans on Company’s Stock Aggregate Write-Ins for Other Than Invested Assets – includes: autos, airplanes, other vehicles; cash advanced to or in hands of officers/agents; travel advances; trade names & other intangible assets; deposits in suspended depositories; “non-bankable” checks. Summary IASA 1, Chapter 2. Assets – L IASA 1, Chapter 5: Other Liabilities, Capital & Surplus – L Other Liabilities – Found on AS Pg. 3. Accounts Payable and Accrued Liabilities Postretirement Benefits Other Than Pensions (SSAP No. 14) These benefits are those (other than retirement income) provided by employer to retirees, such as health care benefits, or life insurance benefits. Insurers must account for these on an accrual basis. The liability = the estimate actuarial PV of benefits. And is included in LAE (Ln 3) and Other Expense (Ln 5) based on the insurer’s allocation scheme. Commissions Payable, Contingent Commissions and Other Similar Charges – Ln 4 Agents and General Agents Reinsurance Commissions (as Reduction of Acquisition Expenses) Straight Profit Sliding Scale Guaranteed Profit Other Similar Charges – Ln 4. Company Officers or Management Other Expenses (Excluding Taxes, Licenses and Fees) – Ln 5. Payable to Parent, Subsidiaries, and Affiliates – Ln 19. Payable for Securities – Ln 20. Details of Write-ins – related to Ln 23. Banking Items Borrowed Money $........ and Interest Thereon – Ln 8. Debt Obligations of Employee Stock Ownership Plans (ESOP) – Ln ??? Drafts Outstanding – Ln 18. Reserves for Uncashed Checks – some companies may include this in Amts withheld/retained by company for account of others (Ln 14) or in Aggregate Write-ins (Line 23) Bank Overdrafts – recorded as a negative balance on Pg 2 Ln 5 (Cash). Reinsurance Items (SSAP 62) Funds Held by Company Under Reinsurance Treaties – Ln 13. Provision For Reinsurance – Ln 16. Ceded Reinsurance Premiums Payable (net of ceding commissions) – Ln 12. Dividends Declared and Unpaid – Ln 11 Stockholders – dividends usually paid as cash. Liability exists for dividends declared but not yet paid. Stock dividends are the capitalization of a portion of unassigned funds, so they are not a liability to be included here. Policyholders – paid as cash or as a credit against next premium. Undeclared dividends are not to be included. If shown, undeclared dividends are a segregation of surplus. Miscellaneous Items Amts Withheld or Retained by Company for Account of Others (SSAP 23) – Ln 14. Two parts to this line: deductions from employees for taxes, premiums, pensions, savings bonds, etc; and PH or claimant funds held by company. IASA 1, Chapter 5: Other Liabilities, Capital & Surplus – L Net Adjustments in Assets and Liabilities Due to Foreign Exchange Rates – Ln 17. Liability for Amounts Held Under Uninsured A&H Plans (SSAP 47) – Ln 21. Aggregate Write-ins for Liabilities Capital And Surplus: A Company’s P/H’s Surplus The Origin of P/H’s Surplus: Organizing an Insurer Initial Financing of Insurers Minimum Capital or Surplus – the min amt of P/H Surplus required depends on the type of organization being formed (stock, mutual, reciprocal) and the LOB to be written. Then state law stipulates the min. Stock – financed through stock (common or preferred – Lines 28 & 29 on Pg 3). If stock sold in excess of par, the excess is shown as contributed surplus (Ln 32). Stockholders own the company through a BOD. Mutual – organized and owned by P/Hs. No stock. Original net worth = surplus paid in by original P/Hs + funds from any interest party. Even after meeting original surplus requirements, they may be held to an ongoing surplus requirement to stay in business. Reciprocal Ongoing Financial Requirements Surplus for minimum ongoing requirements includes: paid-in/contributed surplus (stock); guaranty fund surplus (mutual); subordinated surplus debentures; certificates representing shares; deposit & escrow requirements; fractional shares; liability of subscribers and shareholders for unpaid shares; shareholders’ preemptive rights; organizational expenses & liability of incorporation; treasury stock (reduction to surplus); unassigned funds. Treasury Stock Guaranty Fund Certificates Capital or Surplus Impairment The Capital and Surplus Account Segregating and Replenishing Surplus Special Surplus Funds Subordinated Surplus Debentures (SSAP 41) Capital Notes Summary IASA 1, Chapter 8: Other Expenses – L Expense Accounting Classification of Expenses NAIC Operating Expense Classifications Management Expense Classifications Expense Allocation NAIC Reporting Management Reporting Direct and Indirect Expenses and Cost Pools Corporate Expenses Internal Accounting Controls Expense Information System (EIS) IASA 1, Chapter 8: Other Expenses – L Standards for Authorization and Payment Management Accountability Responsibility Accounting Benchmarking to Improve Performance Budgeting Variances Between the Plan and Results Controllable vs. Noncontrollable Expenses Flexible Budgets Expense Reporting National Association of Insurance Commissioners The Annual Statement The Insurance Expense Exhibit Ratemaking Management and External Reporting Summary IASA 1, Chapter 9: Investment Income – L Investment Instruments Short-term Investment Instruments Commercial Paper Certificates of Deposit Treasury Bills Repurchase Agreements, Reverse Repurchase Agreements and Dollar Repurchase Agreements Repurchase Agreement = one which reporting entity buys securities and agrees to resell the same securities at a stated price on a specific date (within 12 mths). The amt paid for the securities is a short-term investment. The difference between amt paid and amt sold is the interest income. The reporting entity should receive collateral having fair value at least = 102% of purchase price paid. Reverse repurchase agreement = one which a reporting entity sells securities and agrees to repurchase them at a stated price on a specific date (within 12 mths). These are collateralized borrowings. Proceeds from sale as a liability, and the difference between selling and buying price are an interest expense. The reporting entity should receive collateral at least = 95% of fair value of securities transferred. Dollar (reverse) repurchase agreements involve debt instruments collateralized w/ GNMA, FHLMC, FNMA. Money Market Mutual Funds Assets and Investment Income Accounting Long-Term Bonds – insurance company’s primary investment. In general, long-term bonds provide higher yields than money markets, with less risk. US Government Securities US Government Agency and Government-Sponsored Agency Securities Loan-Backed/Asset-Backed Securities Structured Securities Corporate Bonds Municipal Bonds IASA 1, Chapter 9: Investment Income – L Bond Mutual Funds Foreign and Eurodollar Bonds Surplus Notes Asset and Investment Income Accounting Sales and Exchanges Valuation – bonds at NAIC levels 3 through 6 must be valued at lower of amortized cost or market. For all bonds, the amortized cost = the amt paid plus premium or minus discount amortized to date (scientifically, not straight-line). Equities Common Stocks Preferred Stocks Warrants Mutual Funds Asset and Investment Income Accounting Sales and Exchanges Valuation Normally, equities are evaluated at SVO value (usually market value). Stocks from subsidiaries, controlled, or affiliated companies are valued either w/: 1) Statutory Equity Method (value of stat equity in company’s financial statement adjusted for unamortized goodwill); 2) Market Value Method. Preferred stocks valued at cost, amortized cost, lower of the two and market value depending on the SVO rating and sinking fund provisions. SVO ratings go from 1 to 6 (like bond ratings). They also rate “PSF” = preferred stock w/ mandatory sinking fund or “P” = no sinking fund. PSF 1 and PSF 2 get cost or amortized cost. PSF 3-6 get lowest of cost, amortized cost, and market value. P-1, P-2 get market value. P-3 through P-6 get lowest of cost or market. Mortgages Asset and Investment Income Accounting Sales and Exchanges Valuation Real Estate – unique to the insurance industry, an insurance company that owns its office space is required to pay rent to itself. This makes the cost visible on a basis comparable w/ the alternative of renting. Asset and Investment Income Accounting Sales Valuation Derivatives Options Caps – an agreement obligating the seller to effect cash settlement to buyer if underlying interest exceeds a predetermined level of performance (strike or cap rate price). Such an agreement could protect a company from falling long-term bond values due to rising interest rates. Floors – an agreement obligating seller to pay cash to buyer if underlying interest does not exceed a predetermined level of performance (strike or floor rate price). This could protect a company from having to invest a large amount of cash at lower yields. Collars IASA 1, Chapter 9: Investment Income – L Swaps Forwards Futures Assets and Capital Gain Accounting Other Investments Partnerships, Leases, Mineral Rights, Equipment Asset and Investment Income Accounting Sales Valuation NAIC Model Investment Laws (MIL) – insurance companies can choose between 2 different methods of analyzing investment holdings: 1) Defined Limits Version – defines guidelines for types and %-ages of invested assets that insurers are permitted to own. Only 5% of admitted assets (AA) can be invested in a single issuer. If SVO-3, then only 1% of AA. If SVO-4,5,6 then only .5% of AA. Exceptions: securities backed in full by US govt (no limit) and securities backed in full by Canadian govt (40% of AA). In aggregate, only 20% of AA invested in SVO 3-6; 10% of AA invested in SVO 4-6; 5% of AA in SVO 5-6, and 1% of AA in SVO 6. etc. 2) Prudent Person Version – relies on insurer to use prudent judgments to determine types and %-ages of assets acquired. Insurer can analyze their own experience based on how well investments meet company’s investment guidelines and how it enhances P/H Surplus. Criteria includes: historical rates of return by investment class; how well asset duration matches liability duration. Securities Lending Investment Performance Control Procedures Summary IASA 1, Chapter 10: Other Income and Direct Charges and Credits to Surplus – L Other Income – On Pg 4 in AS Net Gain or Loss from Agents’ or Premium Balances Charged Off – Ln 12 Finance and Service Charges Not Included in Premiums – Ln 13 Aggregate Write-ins for Miscellaneous Income – Ln 14 Premiums for Life Insurance on Employees Checks Canceled Because of Nonpresentation for Payment Gain or Loss on Sale of Equipment Retroactive Reinsurance Gain or Loss on Foreign Exchange Corporate Expense Fines and Penalties of Regulatory Authorities Miscellaneous Income or Expense Dividends to Policyholders – Ln 17 Dividends = dividends paid to P/Hs (Ln 8 Pg 5) + dividends declared and unpaid (Ln 11.2 Pg 3) – amt accrued at beginning of year. Federal and Foreign Income Taxes Incurred – Ln 19. Gains and Losses in Surplus – bottom of Pg 4 in AS Line 22: Net Income directly affects Surplus. IASA 1, Chapter 10: Other Income and Direct Charges and Credits to Surplus – L Net Unrealized Capital Gains or Losses – Line 23 With a few exceptions, stocks carried at market value, bonds at amortized cost, mortgages at unpaid principal, and real estate at cost less depreciation. Sources: Exhibit of Capital Gains (Losses), Sch. D Unrealized Capital Gain = change in difference between cost of stocks and their statement (market) value at beginning of year, and the cost and market difference at the end of the year. Bonds are usually carried at amortized cost for book and statement purposes. So, usually the unrealized gain = 0. If not eligible for amortized cost, then a difference can occur, affecting Unrealized Gains/Losses. Change in Net Unrealized Foreign Exchange Capital Gains (Losses) – Line 24 Differences in exchange rates can cause a change in net assets. Additional value from revaluing these assets is an asset on Pg 2 (Line 19). Any reductions are a liability on Pg 3 (Line 17). The change in this net gain/loss is charged to unassigned surplus on Line 24 here. Change in Net Deferred Income Tax – Line 25 Became effective in 2001. Change in Nonadmitted Assets – Line 26 Change in Provision for Reinsurance – Line 27 Change in Surplus Notes – Line 28 Surplus Note = any subordinated indebtedness, surplus debenture, debenture note, premium income note, bond, other used as a vehicle to increase surplus. Surplus (Contributed to) Withdrawn from Protected Cells – Line 29 Protected cell – similar to a Separate Account. This cell is held by company and is used to insulate proceeds of securities offering from the general business risks of the insurer, granting additional comfort for investors. Became effective 2002. Cumulative Effect of Changes in Accounting Principles – Line 30 Became effective 2001 with “codification”. Previously reported in Line 36 (aggregate write-ins). This is the difference between amt of capital & surplus at beginning of year and amt of capital & surplus that would have been reported if principle had been in effect for prior years. Anticipated Salvage and Subrogation – NAIC and state regulatory authorities now permit anticipated S&S to be included in dev ult inc and unpaid losses. Previously, reserves were gross of S&S. Postretirement Benefits Other Than Pensions Tabular Discounts – companies that used tabular discounts in the past, but are not now defined as tabular discounts, the restatement of prior years will result in a reduction of surplus. Capital Changes – Line 31 These can be: Paid In (the par/stated value of shares issued (+) and retired (-)); Transferred from Surplus (Stock Dividend); Transferred to surplus (reduction in capital when par value of stock reduced w/o offsetting reduction in # of shares O/S). IASA 1, Chapter 10: Other Income and Direct Charges and Credits to Surplus – L Surplus Adjustments – Line 32 Net Remittances from or (to) Home Office – Line 33 This is cash flow to a foreign home office. Dividends to Stockholders – Line 34 These may only be funded from retained earnings (unassigned surplus). Change in Treasury Stock – Line 35 Aggregate Write-ins for Gains and Losses in Surplus – Line 36 These can include: net proceeds from key-person life insurance on employees; unearned compensation due to stock purchase plans; special surplus funds – contingency reserves, catastrophe reserves, etc.; prior period adjustments. Summary IASA 1, Chapter 14: Generally Accepted Accounting Principles – L Sources of Accounting Principles Differences Between SAP and GAAP Assets – nonadmitted includes DPAC, furniture & equipment, uncollected premiums & reinsurance recoverables over 90 days due. Investments Bonds – under GAAP are valued at amortized cost if company has the positive intent and ability to hold the bonds until maturity and no decline in market value other than temporary (“held-to-maturity”). If the company buys and sells bonds without intending to hold them, they are valued at market value (“trading”). Other bonds are reported at market value (“available-for-sale”). Derivatives Transfers and Servicing of Financial Assets and Extinguishments of Liabilities Policy Acquisition Costs – commissions, premium taxes, and other U/W expenses. SAP: All costs are incurred immediately. GAAP: Some costs are deferred (capitalized and recognized) as an asset known as deferred PAC (DPAC). Accounting for the Impairment or Disposal of Long-Lived Assets Reinsurance FAS 113 review: reinsurance must meet the conditions: 9a) reinsurer assumes significant insurance risk; 9b) it’s reasonably possible that reinsurer may realize a significant loss. This section basically summarizes a lot of FAS 113. Unauthorized Reinsurance – SAP: liability established for amts receivable on paid & unpaid losses and UEPs from unauthorized reinsurers. This liability is reduced by funds held/securities. GAAP: no such liabilities except for amts deemed to be uncollectible. Policyholder Dividends – SAP: dividends to P/Hs not recorded as liabilities until declared by the BOD. GAAP: all undeclared P/H dividends are accrued at balance sheet date (estimating amt to be paid). Contingent Commissions – SAP: must use full accrual basis accounting for contingent commission to agents. GAAP: contingent commissions are accrued over same period in which the related U/W-ing results are recognized. Loss and Loss Expense Reserves – SAP: estimates for all losses unpaid are recorded as liabilities. Estimate are based on best estimate by LOB. The mid-point of the range is accrued. IASA 1, Chapter 14: Generally Accepted Accounting Principles – L Under GAAP, the lower end of the range would be recorded. SAP allows the discount of reserves for certain lines with fixed and reasonably determinable payments (WC, A&H). Under GAAP, these are usually non-discounted? (A little confusing wordings!) Salvage and Subrogation – SAP: company may recognize S&S either upon receipt or by accruing the estimated amt of S&S related to ult claim costs by reducing the related reserves. GAAP: anticipated S&S recoveries valued at estimated realizable values and applied as a reduction of claim liabilities at date of financial statements. Estimates of S&S recoverables are assets. Federal Income Taxes Temporary Differences – tax law requires to discount loss & LAE reserves and to recognize estimated S&S recoverables. Under SAP, discounting is only allowed for certain reserves with fixed and determinable payments. Also, tax law requires 20% of change in net UEP be included in taxable income. (These affect temporary items.) Permanent Differences – tax law requires a provision of 85% of tax-exempt interest income and dividends-received deduction (DRD) is exempt from taxation. (These will not reverse in the future.) GAAP vs SAP – GAAP allows for the deferral of certain taxes. SAP does not. Pensions Postretirement Benefits Other Than Pensions Guaranty Fund Assessments Foreign Exchange Business Combinations and Accounting for Goodwill and Other Intangibles Comprehensive Income GAAP Disclosures of Public Companies Earnings per Share Segment Reporting International Accounting Standard for Insurance Summary IASA 1, Chapter 15: SEC Reporting Requirements – L Three sources of reporting requirements: State govts, GAAP, and fed govt (SEC). Federal Regulations and Statutes Securities Act of 1933 – provides for the registration of securities to be offered or sold to the public. Form S-1 – when no other form is specified. Form S-2 – for insurers that have filed periodic reports for at least 3 yrs but don’t meet the voting stock requirements for S-3. Form S-3 – for insurers that have filed periodic reports for at 1 yr and have at least $75M of voting stock held by nonaffiliates. Form S-4 – used to register shares offered in connection w/ business combinations. Form S-8 – for insurer securities to be sold to employees/directors. Form S-11 – used for registering securities of certain real estate entities. Securities Exchange Act of 1934 – creation of the Securities and Exchange Commission (SEC) as an independent agency of US govt. Form 10-K – used to fulfill annual reporting requirements under the Act. IASA 1, Chapter 15: SEC Reporting Requirements – L Form 10-Q – filed w/ the SEC within 45 days after the end of each of the first three quarters. Form 8-K – a legal nature. It’s reported in narrative form and is required after any of: change in control; major acquisition or disposition of assets; bankruptcy or receivership; change of independent accountant; other events and Regulation FD disclosure; resignation of directors; financial statements and exhibits (included if filed as part of the report); change in fiscal year; Regulation FD disclosure. In Aug 2000, Regulation FD requires new disclosure requirements for issuers meant to promote timely communication of information to prospective investors. Regulation S-B: Integrated Disclosure System for Small Business Issuers- Aug 1992: simplified registration for certain qualified small business issuers. Regulation S-X: Form and Content of Financial Statements – whoa! Regulation S-K: Integrated Disclosure Rules – whoa! Other SEC Reporting Issues Staff Accounting Bulletin (SAB) Topic 5-N (SAB 62) – addresses two key issues. 1) the permissibility of discounting claim liabilities; 2) whether a change from a stat discount rate to an investment relate rate should be accounted for as a change in accounting or as a change in estimate. SEC answered: 1) discounting is permitted at the same rates company uses for reporting to authorities w/ respect to the same claims liabilities; 2) it is a change in accounting. SAB Topic 5-W – contingency disclosures: Specific uncertainties not normal and recurring should be disclosed, while some normal uncertainties (amt & timing of claims) do not need to be disclosed. SAB Topic 5-Y (SAB 92) – disclosures related to product & environmental liability. Legal definitions of liability and damage make estimating the potential ult exposure difficult. SEC requires comprehensive disclosures indicating: the existence of exposure, # of O/S claims, cost of settlements to date, accrued liabilities, availability of reinsurance, status of major litigation. Certification of Disclosure in Companies’ Quarterly & Annual Reports – Sarbox – Principle officers must certify the financial info contained in the issuer’s statements. Also, they must certify that: they are responsible for establishing, maintaining and regularly evaluating the effectiveness of issuer’s internal controls; they have made disclosures to the auditors and BOD about the internal controls; and they have included info in the reports about their evaluation. Electronic Data Gathering, Analysis, and Retrieval System (EDGAR) of the SEC Stock Exchanges Summary IASA 1, Chapter 18: Canadian Accounting – L Evolution and Regulation of the Industry Current Regulatory Developments Accounting Standards Actuarial Standards The Canadian Annual Return Main sections of the return: 10. General Information; 20. Financial Statements; IASA 1, Chapter 18: Canadian Accounting – L 30. Statutory Compliance; 40. Investments; 50. Miscellaneous Assets and Liabilities; 60. Premiums, Claims and Adj Expenses – Total; 67. Provincial & Territorial Summaries; 70. Reinsurance Ceded; 80. Commissions and Expenses – Total; 90. Out of Canada Exhibits. 7 Notable differences from NAIC in list of lines. 1) Fire, allied lines, FO multi peril, HO multi peril, commercial multi peril, IM, EQ, burglary and theft are combined into the property lines. 2) There is no WC which is conducted by provincial govts. 3) Med Mal is included with liability. 4) Auto no fault (BI, PD, direct compensation PD) is split out from “automobile, liability” into “automobile, personal accident”. And “automobile, other” is PhyD. 5) Separate lines for mortgage and title insurance (usual written by specialty insurers). 6) “Marine” refers to OM as IM is included in property line. 7) Personal/Commercial automobile are not shown separately. General Information Financial Statements Financial Instruments Measurement Uncertainty Balance Sheet – broken into 2 separate statements: “Statement of Assets” and “Statement of Liabilities, Capital, Surplus & Reserves”. Assets (Page 20.10) Receivables (Lines 20-27) Investments (Lines 4-10) Other Assets (Lines 40-44) Deferred Policy Acquisition Expenses (Line 43) Liabilities (Page 20.20) P/H Dividends and Rating Adjustments (Line 10) Unearned Premium (Line 12) Unpaid Claims and Adjustment Expenses (Line 13) – these cannot be separated by line. Unlike NAIC, S&S is recorded as an asset instead of as a deduction against unpaid claims. Premium Deficiency (Line 15) – exists when the sum of [expected loss costs on unearned exposure + expected policy maintenance costs of the unexpired policies (including CAT reinsurance costs & agent’s contingent profit sharing) + expected internal adjustment expenses associated w/ expected loss] > than sum of [UEP + investment income to be received on assets supporting UEP while unearned]. If the expected costs + DPAC are greater than UEP + II, then DPAC is reduced to offset the difference, and the remainder is premium deficiency. Other Liabilities Capital, Surplus and Reserves, (Page 20.20) Reserves Required (Line 40) Additional Policy Provisions IASA 1, Chapter 18: Canadian Accounting – L Income Statement (Page 20.30) – main source of confusion is how the change in net DPAC is treated as an actual adjustment to commissions, taxes, and general expenses. Income Expenses General Expenses Claims and Adjustment Expenses Minimum Capitalization Minimum Asset Test (Section 516 Test) – this test was used up to 12/31/02. Take assets from 20.10, add in Excess of Market Value over Book Value, and take out non-admitted assets, investment valuation reserve and reserve for foreign exchange fluctuations, non-admitted portions of investments in financial institutions, DPAC, recoverables from reinsurers, excess basket clause investments, and other recoverables on unpaid claims excluding SIR. This gives “(39) Assets available for test purposes.” Then take liabilities from 20.20, add in reserve for reinsurance ceded to unregistered insurers, additional policy provisions, required margins (more below), and take out recoverable from reinsurers, unearned commission adjustment, and other recoverables on unpaid claims excluding SIR. This gives “(69) Assets required for test purposes”. “(89) Excess of assets available over assets required for test purposes” = (39) – (69). And (90) is (89) as a % of (69). This is the ANSWER. Margins are calculated on 30.11. (09) Reinsurance ratio (excludes accident & sickness) = portion of incurred in respect of reinsurance ceded during preceding 12 mths divided by gross claims incurred during preceding 12 mths. This is capped at 50%. Margins: (a) Accident & Sickness Policies: (10) Margin on claims = 15% of net unpaid claims & LAE other than those in respect of installment claims. (11) Margin on UEP = 15% of net UEP other than those in respect of non-cancelable policies. (19) = (10) + (11). (b) Policies other than (a): (i) Unpaid Claims & UEP (Net): (20) Margin on claims = 15% of unpaid claims and LAE. (21) Margin on UEP = 15% of UEP. (22) Excess of “Required Coverage” over “Reserve” for reinsurance ceded to unregistered insurers. (28) 15% margin on self insured retentions. (29) = Total. (ii) Premiums Written: (30) Basic margin = 15% of gross WP during preceding 12 mths. (31) Supplementary margin on gross premiums = min(5% of gross WP during preceding 12 mths, $500K). (32) Gross Margin = (30) + (31). (33) Margin reduction for reinsurance = Gross Margin * Reinsurance Ratio. (39) Margin required for WP = (32) – (33). IASA 1, Chapter 18: Canadian Accounting – L (iii) Claims Incurred: (40) Basic margin = 22% of avg annual gross claims incurred during preceding 36 mths. (41) Supplementary margin = min(7% of avg annual gross claims incurred during preceding 36 mths, $500K). (42) Gross margin = (40) – (41). (43) Margin reduction for reinsurance = (42) * Reinsurance Ratio. (49) Margin required for Claims Incurred = (42) – (43). The greater of these three margins is added to liabilities. In 2003, this test is replaced by the MCT test. Minimum Capital Test (discussed in MCT below) Capital Available Capital Required Taxation Types of Taxes Taxes Based on Income Insurers Canadian Branches Tax on an Insurer’s Investments Tax on Insurer’s Capital Other Taxes by Provinces Premium Tax Capital Tax Sales Tax Goods and Services Tax Accounting for Income Taxes Summary IASA 2, Appendix D Canadian Annual Return (Selected Exhibits) – L Note: P&C-1 refers to the whole AR. Summary of Selected Financial Data for Five Years (10.60) (years across 5 columns) Operations 1) Assets 2) Liabilities 3) Reserves Required 4) Statutory capital and surplus = (1) – (2) – (3) 5) Gross WP 6) Net WP 7) Net EP 8) Gross claims incurred (excluding accident and sickness) Profitability Claims ratio 9) by year of account 10) by year of accident 11) Expense ratio 12) U/W-ing income 13) as a % of net EP IASA 2, Appendix D Canadian Annual Return (Selected Exhibits) – L 14) Net investment income 15) as a % of net EP 16) Investment Yield 17) Net income (loss) for the year 18) ROE Financial 19) Dividends to shareholders 20) Capital & surplus paid in during the year 21) Capital redeemed during the year Other Ratios 22) Stat capital and surplus as a % of liabilities & reserves required (4) / [(2) + (3)] 23) Gross risk ratio (5) / (4) 24) Net risk ratio (6) / (4) 25) Agents and brokers balances and amts due from subsidiaries and affiliates as a % of stat capital and surplus 26) Claims development as a % of stat capital and surplus Minimum Asset Test 27) Excess of assets available over assets required for test purposes ?? 28) as a % of assets required for test purposes. Assets (20.10) Liabilities, Capital, Surplus and Reserves (20.20) Minimum Asset Test (30.10 – 30.11) – covered in Chp. 18. Reserves Required (30.15) Deferred Policy Acquisition Expenses and Unearned Commission Adjustment (30.15) Investment Valuation Reserve (30.20) 4 Columns: (01) Book Values at Current Rates of Exchange (02) Market Values at Current Rates of Exchange (03) Market Excess = (02) – (01) (04) Market Deficiency = (01) – (02) Debt Securities (01) Short term Bonds and Debentures; A = Excess (02) Short term Mortgage Loans; D = Deficiency (03) Long term Bonds and Debentures (04) Long term Mortgage Loans (09) Total Debt Securities: total of (01) through (04) (10) Preferred and Common Shares; B = Excess; E = Deficiency (11) Real Estate (Investment and Own Use) (19) Total Debt Securities, Shares and Real Estate = (09) + (10) + (11); F = Deficiency. (29) Total Long Term Bonds and Debentures, Long Term Mortgage Loans and Real Estate; G = Deficiency (39) Total Debt Securities and Real Estate; C = Excess IASA 2, Appendix D Canadian Annual Return (Selected Exhibits) – L (49) Total Long Term Bonds and Debentures, Long Term Mortgage Loans, Shares and Real Estate; H = Deficiency Debt Securities: (50) I = Net deficiency for reserves purposes for long term Debt Securities and Real Estate = G – B if positive, else 0. Shares: (61) J = Net deficiency for Shares = E – C if positive, else 0. (62) K = J for previous year. (63) L = 2-yr avg of net deficiencies = 0.5 * (J + K). (64) M = Net deficiency for reserve purposes for Shares = min(J,L). IASA 2, Appendix D Canadian Annual Return (Selected Exhibits) – L Mortgage Loans: (70) N = Market deficiency for short term Mortgage Loans = D if book value of total Mortgage Loans exceeds 20% of book value of total assets, else 0. (71) P = D – A if positive and book value of total Mortgage Loans exceeds 20% of Book Value of Total Assets, else 0. Investment Valuation Reserve (80) Q = I + M + N. (81) R = F. (82) S = H + P. (89) Final answer = min(Q,R,S). Summary: (All-10) This can be explained by 4 principles: 1. Book vs. Market: IVR adjusts for the excess of book over market values. 2. Long-Term Assets: IVR is concerned w/ significant differences between book and market. Thus an insurer may only report differences in long-term securities. 3. Common Stocks: An insurer may use the 2-yr avg of excess of book over market instead of current year alone. 4. Mortgages: if mortgages constitute 20% or more of total assets, then all mortgages are considered to be long-term assets. Calculation of Required Margin on Net Unearned Premiums (30.30) IASA 3, Chapter 16: Financial Strength (Selected Pages) – L NAIC Insurance Regulatory Information System (IRIS) (Page 16-27) Phase 1: Statistical Phase – 12 tests, where 4+ unusual values will trigger additional analysis. All values are %-ages capped at -99% and 999% (Ratio 6 capped at 0%). IRIS Tests – (warning – 13 tests now – see IRIS paper) GROUP Ratio Description Leverage 1 Gross Premiums to PHS 2 Net Premiums to PHS 3 Change in Net Writings 4 Surplus Aid to PHS Profitability 5 2-yr Overall Operating Ratio 6 Investment Yield 7 Change in PHS Liquidity 8 Liabilities to Liquid Assets 9 Agents’ Balances to PHS Loss Reserving 10 1-yr Reserve Development to PHS 11 2-yr Reserve Development to PHS 12 Estimated Current Reserve Deficiency to PHS Unusual Values Over Under 900 -300 -33 -33 15 -100 -10.0 4.5 50 -10 105 -40 -20 -20 -25 -- Leverage ratios measure premium relative to surplus, but fail to distinguish between profitable/unprofitable business. Also, retros aren’t recognized. Ratio 4 fails to measure quality of reinsurance and recoverability issues. IASA 3, Chapter 16: Financial Strength (Selected Pages) – L If Ratio 5 produces result over 100%, must then consider results of Ratios 6 – 12. Ratio 7 is adjusted by DAC. Ratio 8: Liquid assets are reduced by affiliated investments and excess of real estate over 5% of liabilities. Also keep in mind the excess of market value of the bond portfolio over its amortized value. Phase 2: Analytical phase – when experienced financial examiners review the AS and ratios. They’ll identify insurers in need of regulatory attention, etc. GAAP Information GAAP Financial Information GAAP MD&A and Footnotes Industry Data Developing a Peer Group Use of Peer Group Information Security Issues Capital – includes RBC and Best’s Capital Adequacy Ratio (BCAR). Rating Agency Perspective OSFI MCT, "Guideline-Minimum Capital Test (MCT) for P&C Ins Cos," – SK (selected pages) Overview (2) – MCT Ratio = Capital Available / Capital Required. This is expected to be above 150%. The Minimum Capital Test (MCT) for Canadian Property and Casualty Insurers Risk-Based Capital Adequacy Framework – insurer is required to meet a “capital available to capital required” test. Capital Available = Equity (shares treated as equity under GAAP + contributed surplus + retained earnings + reserves + general/contingency reserves) + subordinated indebtedness & preferred shares whose redemption is subject to regulatory approval + Adjustment to Market (more later). Deduction/Adjustments (3) – the following are deducted: Investments in subsidiaries other than Regulated Financial Institution Subsidiaries. Investments in Affiliates. DPACs not eligible for either the 0% or 35% capital factors. Future Income Tax Debits not eligible for the 0% capital factor. Goodwill and Other Intangible Assets. Other Assets in excess of 1% of Total Assets. Capital Required = Capital for On-Balance Sheet Assets + Margins for UEP and Unpaid Claims + CAT reserves & additional policy provisions + an amt for reinsurance ceded to unregistered reinsurers + capital for Off-Balance Sheet Exposures. Minimum Requirements (4) – P&C insurers should meet the above minimum requirement. However, regulator may proscribe a higher capital requirement. Transitional Provisions Application – Canadian P&C insurers. Interpretation of Results OSFI MCT, "Guideline-Minimum Capital Test (MCT) for P&C Ins Cos," – SK Capital Required for On-Balance Sheet Assets (5) Definition of Capital (6) – 3 considerations for defining capital for purposes of measuring capital adequacy includes: its permanence; its being free of any obligation to make pmts from earnings; and its subordinated legal position to the rights of P/Hs and other creditors. Description of On-Balance Sheet Risks (7) Counterparty Risk (8) 1. Government Grade – includes securities issued by, loans made to, etc., from: fed govt or an agent of the Crown; a provincial or territorial govt; a municipality or school corporation in Canada; central govt of a foreign country where security is AAA, or if not rated – the long-term sovereign credit rating of that country is AAA. 2. Investment Grade – applies if a security’s rating meets or exceeds table below. Rating Agency Commercial Paper Bonds & Debentures Preferred Shares Moody’s P-1 A Aa S&P AA AA Dominion Bond Rating Service R-1 (low) A Pfd-2 Canadian Bond Rating Service A-1 (low) A P-2 3. Not-Investment Grade (9) – everything else not in 1 and 2. Includes any security that doesn’t have a rating. Capital Required for Policy Liabilities (17) Description of Risks for Policy Liabilities (18) – divides into 3 parts: variation in claims provisions (Unpaid Claims); possible inadequacy of provisions for UEPs; occurrence of CATs (EQ and Other). Margins for Unearned Premiums and Unpaid Claims – these are applied to the net amt at risk (net of reinsurance, S&S, and SIR) by class of insurance. The UEP margin is applied to max(net UEP, 50% of net WP in last 12 mths). Class of Insurance Margin on UEP Margin on Unpaid Claims Pers & Comm Property 8% 5% Auto – Liab & pers accident 8% 10% Auto – other 8% 5% Liability 8% 15% Accident & sickness Appendix A-1 Appendix A-1 Mortgage (federal companies only) Appendix B 15% All others 8% 15% Catastrophes (19) Earthquake Nuclear Mortgage Insurance OSFI MCT, "Guideline-Minimum Capital Test (MCT) for P&C Ins Cos," – SK Reinsurance Receivables and Recoverables (20) Registered Reinsurers – risk comes from credit risk and actuarial risk. credit risk = risk that reinsurer will fail to pay. actuarial risk = risk association w/ assessing amt of required provision. For registered Reinsurers, apply 2% capital factor to Unpaid Claims recoverable and 0.5% to UEPs recoverable. Unregistered Reinsurers – calculation for Unregistered Reinsurers will lead to Capital Required of up to 110% of applicable amts on the B/S. Capital Required for Off-Balance Sheet Exposures (21) Description of Risks for Off-Balance Sheet Items (22) Capital Required = (value of instrument at the reporting date – value of eligible collateral security or guarantees) * a factor reflecting nature and maturity of instrument * a factor reflecting the risk of default of the counterparty to a transaction. Feldblum (Loss Reserve Discounting), “IRS Loss Reserve Discounting,” – WN Introduction Investment Income and Amortization: Statutory vs Economic Income Illustration: Offsetting Discounting Principles Undiscounted Loss Reserves Discount Rate Loss Payment Pattern Incremental Percentages and Cumulative Differences Determination Year and Company Election Illustration A: No Extension of Payments Paid to Incurred Percentages Assumed Incremental Percentage Paid Discounting Computations Loss Reserve Discount Factors Illustration B: Long-Tailed Extension of Payments Two Year Lines Feldblum (Taxable Income), “Computing TI for P&C Insurance Companies,” – WN Introduction Proration Common Stock Dividends Revenue Offset Determining Tax Liabilities Alternative Minimum Income Tax Minimum Tax Credit Feldblum (Tax Strategy), “Federal Income Tax and Investment Strategy,” – WN Tax Rates: Investor Types Municipal Bonds Tax and Invested Capital Exercises Feldblum (Tax Strategy), “Federal Income Tax and Investment Strategy,” – WN Capital Gains Operating Income, Bond Portfolio, and Investment Strategy Blanchard, “Basic Insurance Accounting – Select Topics,” – WN Exam 7 – US GAAP vs Statutory Differences List of principal GAAP vs statutory differences 1. Deferred Acquisition Costs 2. Non-admitted Assets 3. Deferred Tax Assets (DTAs) 4. Invested Assets 5,6. Loss Reserves 5. Retroactive Reinsurance 6. Structured Settlements 7. Ceded Reinsurance 8. Acquisition Accounting, including “goodwill” Additional points Temporary vs permanent differences Permanent temporary differences Balance sheet versus income statement differences Gorvett, "Special Issues-Data Sources," Foundations of Casualty Actuarial Science – W Data Sources Insurance Industry Data NAIC Annual Statement Title page (page 1) Balance sheet (pages 2 and 3) Income statement (page 4) Statement of cash flows (page 5) Underwriting and Investment Exhibit Analysis and Reconciliation of Assets Five-Year Historical Data Schedule A Schedule D Schedule F Schedule P Schedule T Insurance Expense Exhibit A. M. Best Aggregates and Averages Insurance Reports Standard & Poor’s ISO and NCCI Reinsurance Association of America GAAP Financial Statements Other Sources of Information Wall Street Journal Gorvett, "Special Issues-Data Sources," Foundations of Casualty Actuarial Science – W Ibbotson Associates Commercial forecasting services Academic publications Internet-based sources Suggested Reading: ASOP 36, "Actuarial Standard of Practice, No. 36, Statements of Actuarial Opinion Regarding Property/Casualty Loss and Loss Adjustment Expense Reserves." – W Transmittal Memorandum Background Exposure Drafts and Public Hearing Standard of Practice Section 1. Purpose, Scope, Cross References, and Effective Date 1.1 Purpose 1.2 Scope 1.3 Cross References 1.4 Effective Date Section 2. Definitions 2.1 Actuarial Work Product 2.2 Appointed Actuary 2.3 Claim 2.4 Coverage 2.5 Data 2.6 Expected Value Estimate 2.7 Exposure 2.8 Loss 2.9 Loss Adjustment Expense 2.10 Present Value 2.11 Reinsurance Contract 2.12 Reserve 2.13 Risk Margin 2.14 Statement of Actuarial Opinion Section 3. Analysis of Issues and Recommended Practices 3.1 Professional Qualifications 3.1.1 Qualification Standards 3.1.2 Legal and Regulatory Requirements 3.1.3 Appointment as Appointed Actuary 3.2 Professional Guidance Concerning Reserve Opinions 3.2.1 Reserving Principles 3.2.2 Discounting of Reserves 3.3 Contents of a Statement of Actuarial Opinion 3.3.1 Items Covered by the Opinion 3.3.2 Types of Statements of Actuarial Opinion 3.3.3 Significant Risks and Uncertainties (Explanatory Paragraph) 3.4 Materiality 3.5 Reserve Analysis ASOP 36, "Statements of Actuarial Opinion Regarding Property/Casualty Loss and Loss Adjustment Expense Reserves." – W 3.5.1 Coverage Provisions 3.5.2 Changing Conditions 3.5.3 External Conditions 3.5.4 Data 3.5.5 Assumptions 3.5.6 Changes in Assumptions, Procedures, or Methods 3.6 Uncertainty 3.6.1 Sources of Uncertainty 3.6.2 Aggregation and External Data Sources 3.6.3 Expected Value Estimate 3.6.4 Range of Reasonable Reserve Estimates 3.6.5 Adverse Deviation 3.7 Reinsurance Ceded 3.7.1 Gross vs. Net Reserves 3.7.2 Collectibility 3.7.3 Uncollectible Reinsurance and Commutation 3.7.4 Risk Transfer Requirements 3.8 Review Opinion 3.8.1 Responsibilities of Reviewing Actuary 3.8.2 Responsibilities of Reviewed Actuary 3.9 Financial Reporting Items Affected by Loss and LAE Reserves 3.10 Adequacy of Assets Supporting Reserves Section 4. Communications and Disclosures 4.1 Form and Content of Statement 4.2 Documentation 4.3 Reliance on Others for Supporting Analysis 4.4 Reliance on Opinions of Other Actuaries 4.5 Changes in Opining Actuary’s Assumptions, Procedures, or Methods 4.6 Disclosure in the Opinion 4.7 Prescribed Statement of Actuarial Opinion 4.8 Deviation from Standard Appendixes Appendix 1 – Background and Current Practices Background Current Practices Appendix 2 – Comments on the 1999 Third Exposure Draft and Subcommittee Responses COPLFR P&C, “P&C Practice Note, Statements of Actuarial Opinion on P&C Loss Reserves as of December 31, 2006.” – W Introduction Organization Changes From 2005 Practice Note Advance Notification of Future Changes Electronic Filing COPLFR P&C, “P&C Practice Note, Statements of Actuarial Opinion on P&C Loss Reserves as of December 31, 2006.” – W #1 Appointment of Appointed Actuary – The Qualified Actuary must be appointed by the BOD (or committee). The Actuary must report to the BOD on the items within the scope of the Opinion. He must able make available the Opinion to the BOD. Discussion – the Appointed Actuary Illustrative Wording #1A Definitions – a qualified actuary is a person who is: a member of the CAS in good standing OR a member in good standing of the AAA who has been approved as qualified for signing casualty loss reserve opinions by the Casualty Practice Council of AAA. A long duration contract = when the contract term is >= 13 mths AND insurer can neither cancel nor increase the premium during the contract term. This excludes financial guaranty, mortgage guaranty and surety contracts. Discussion – Actuarial Report A few exemptions: Exemption for Small Companies: if an insurer has less than $1M direct + assumed WP during a CY and less than $1M direct + assumed loss & LAE reserves, then they may submit an affidavit under oath specifying those amounts. Exemption for Insurers under Supervision or Conservatorship: Exemption for Nature of Business Financial Hardship Exemption – such hardship exists when cost of producing an Actuarial Opinion would exceed lesser of: i) 1% of insurer’s capital & surplus reflected in the latest quarterly statement; ii) 3% of insurer’s direct + assumed WP during the CY. #1B Exemptions #2 Content – statement must consist of an ID paragraph, a scope paragraph, an opinion paragraph, plus one or more additional relevant comments paragraphs. #3 Identification Paragraph – should indicate the Appointed Actuary’s relationship to the company, qualifications for acting as an appointed actuary, date of appointment, and that the appt was made by the BOD, or by a committee of the Board. Discussions – Sections 2 and 3 #4 Scope Paragraph, Exhibits A and B, and Reliances – should include sentence such as: “I have examined the actuarial assumptions and methods used in determining reserves listed in Exhibit A, as shown in the AS …” Exhibit A should list items and amts with respect to which the Appointed Actuary is expressing an opinion. Then the Actuary should state that those items reflect the Loss Reserve Disclosure items (3 thru 8) in Exh B. It should also include: “In forming my opinion …, I relied upon data prepared by ____. I evaluated that data for reasonableness & consistency. I also reconciled that data to Sch P – Part 1… In other respects, my examination included such review of the actuarial assumptions and methods used and such tests of the calculations as I considered necessary.” Discussion – Data – see Appendix 1. Discussion – Methodology Illustrative Wording - Methodology #5 Opinion Paragraph Should include a sentence stating that the amounts carried in Exhibit A: meet the requirements of the insurance laws of the state of domicile. are computed according to accepted actuarial standards and principles. make a reasonable provision for all unpaid losses/LAE. COPLFR P&C, “P&C Practice Note, Statements of Actuarial Opinion on P&C Loss Reserves as of December 31, 2006.” – W (make a reasonable provision for the UPR for long duration contracts.) 5 categories a. Determination of Reasonable Provision. b. Determination of Deficient or Inadequate Provision. c. Determination of Redundant or Excessive Provision. d. Qualified Opinion. – when an item is in question because it can’t be reasonably estimated – actuary should state a reasonable provision except for these items. e. No Opinion – when the data isn’t sufficient to support a conclusion. Discussion – The Opinion – A reserve is reasonable if it is within the actuary’s range of reasonable reserve estimates. However, this range is often considerably narrower than the range of possible outcomes of the ult settlement value of the reserve. Discussion – Deficient or Redundant Provision Illustrative Wording – Deficient or Redundant Provision – The provision for unpaid losses and LAE is $X less (greater) than then min (max) amt I consider necessary to be within the range of reasonable estimates. #6 Relevant Comments Paragraph Discussion – Risk of Material Adverse Deviation Discussion – Additional Relevant Comments Discussion – Change in Methods and Assumptions – only material changes need to be discussed. Illustrative Wording – Change in Methods and Assumptions Discussion – Other Disclosures in Exh B – Discounting and Salvage/Subrogation Discussion – Other Disclosures in Exh B – Pools and Associations – three considerations: 1. Are pool reserves material? 2. Does the company book what the pool reports (w/ no analysis), perform an independent analysis and adjust the pool’s reported reserves, rely on the pool actuary’s opinion, or some combination of the above? 3. If there is a lag in booking of pool losses, does the company record this? Are premiums treated similarly? Are these items material? Illustrative Wording – Pools and Associations Discussion – Other Disclosures in Exh B – Mass Tort Exposure Either the Company has or has not provided enough coverage that could reasonably result in material levels of A&E liability claims activity. Actuary may comment on: whether there appears to be a material exposure; the aggregate $ amt of reserves held for this exposure; the significant variability and uncertainty inherent. Illustrative Wording – Asbestos and Environmental Liability Discussion – Retroactive Reinsurance/Financial Reinsurance – always required by AS instructions. Retroactive Reinsurance = loss-portfolio transfers Financial reinsurance = other reinsurance arrangements not meeting FASB 113 requirements for transfer of risk. Illustrative Wording – Retroactive Reinsurance/Financial Reinsurance Discussion – Reinsurance – always required by AS instructions. COPLFR P&C, “P&C Practice Note, Statements of Actuarial Opinion on P&C Loss Reserves as of December 31, 2006.” – W If ceded reinsurance is not material relative to stat net reserves & surplus, no more info is required. Illustrative Wording – Reinsurance – insurer may comment on the following: 1. Immaterial ceded reinsurance levels. 2. Material amts of ceded reinsurance, w/ none to troubled reinsurers. 3. Inadequate reserves for collectibility problems. 4. Miscellaneous – Public Information. Discussion – IRIS Ratios Illustrative Wording – IRIS Ratios #7 Actuarial Report and Underlying Work Papers Discussion – Actuarial Report #8 Signature of Actuary #9 Errors in Statement of Opinion Discussion – Sections 8 and 9 Discussion – Exhibit A: Scope Discussion – Retroactive Reinsurance Reserve Discussion – Premium Reserves Discussion – Disclosure Items Actuarial Opinion Summary Discussion – Filing the AOS: Discussion – Actuarial Opinion Summary: Discussion – Section 6: Appendices 1 Evaluation and Reconciliation of Data Note Discussion 2 Frequently Asked Questions 1. The term material is used several times in the practice note. How does an actuary assess materiality? 2. When is a carried reserve reasonable? 3. What if the net loss and loss expense reserves and the direct plus assumed loss and loss expense reserves make reasonable provisions for the unpaid loss and loss expense obligations of the company, but some of the amounts booked for certain subsets of the carried reserves do not in isolation make reasonable provisions for the associated portions of the company’s obligation? 4. Why would someone issue a qualified opinion? How exactly should an actuary indicate that an opinion is qualified? 5. How should an opining actuary treat a situation where there is a portion of reserves for which he or she did not perform an independent analysis? Does this necessarily mean that the opinion is qualified? Are there situations in which an unqualified opinion may be offered even though the actuary did not review all the reserves? If so, when should this be disclosed in the opinion? 6. How does the opining actuary usually treat pools where an opinion is provided by another actuary on behalf of the pool? 7. What is a clean opinion? COPLFR P&C, “P&C Practice Note, Statements of Actuarial Opinion on P&C Loss Reserves as of December 31, 2006.” – W 8. The NAIC Instructions for the Annual Audited Financial report, regarding the auditor’s review of data used by the Appointed Actuary, require the auditor to “…obtain an understanding of the data identified by the Appointed Actuary as significant…” to the decision regarding the reasonableness of reserves. Within this context, how should the actuary define the term “significant”? 3 NAIC Recommended Language for Actuarial Opinion for Pools/Associations NAIC Guidance for Actuarial Opinions for Pools and Associations 4 Statements of Actuarial Opinion on Title Loss Reserves Actuarial Opinion Discussion – Opinion Discussion – Salvage & Subrogation Discussion – Reconciliation of Data Discussion – Relevant Comments 5 Miscellaneous Illustrative Wordings in Common Use 6 Intercompany Pooling 7 Materiality – CAS VFIC 8 Unearned Premium for Long Duration Contracts Opinion Language Illustrative Wording 9a Regulatory Guidance Brief – Statements of Actuarial Opinion for year-end 2006 9b Regulatory Guidance Brief – Actuarial Opinion Summary for year-end 2006 10a 2006 Actuarial Opinion Instructions Exhibit A: Scope Loss Reserves: A. Reserve for Unpaid Losses B. Reserve for Unpaid LAE C. Reserve of Unpaid Losses – Direct & Assumed D. Reserve for Unpaid LAE – Direct & Assumed E. Retroactive Reinsurance Reserve Assumed F. Other Loss Reserve items on which the Appointed Actuary is expressing an Opinion. Premium Reserves: G. Reserve for Direct & Assumed UEPs for Long Duration Contracts H. Reserve for Net UEPs for Long Duration Contracts I. Other Premium Reserve items on which the Actuary is expressing an Opinion. Exhibit B: Disclosures 1. Materiality Standard expressed in $US. 2. Statutory Surplus 3. Anticipated net S&S included as a reduction to loss reserves as reported in Sch P. 4. Discount included as a reduction to loss reserves and LAE reserves as reported in Sch P. 4a. Nontabular Discount 4b. Tabular Discount COPLFR P&C, “P&C Practice Note, Statements of Actuarial Opinion on P&C Loss Reserves as of December 31, 2006.” – W 5. Net reserves for loss and LAE for the company’s share of voluntary & involuntary U/W-ing pools & associations’ unpaid losses & LAE included in reserves shown in AS. 6. Net reserves for losses & LAE that company carries for the following liabilities in AS: 6a. Asbestos, as disclosed in Notes. 6b. Environmental, as disclosed in Notes. Note: These reserves should exclude amts relating to contracts specifically written to cover A&E exposures. 7. Total claims made extended loss & LAE reserve (Sch P Interrogatories). 7a. amt reported as loss reserves. 7b. amt reported as UPRs. 8. Other items on which the Appointed Actuary is providing Relevant Comments. 10b 2006 Actuarial Opinion Summary Instructions 11 Guidance Regarding Data Testing Requirement Conger, "How Might the Presentation of Liabilities at Fair Value Have Affected the Reported Results of U.S. Property Casualty Insurers" – W – Chapter 3 (2004) 3.1 Definition of Fair Value 1999 IASB definition: the amt for which an asset could be exchanged or a liability settled between knowledgeable, willing parties in an arm’s length transaction. 1999 FASB definition: an estimate of the price an enterprise would have realized if it had sold an asset or paid if it had been relieved of a liability on the reporting date in an arm’s length exchange motivated by normal business considerations. That is, it is an estimate of an exit price determined by market interactions. 2003 FASB definition: the amt at which an asset or liability could be exchanged in a current transaction between knowledgeable unrelated willing parties when neither is acting under compulsion. Joint Working Group (JWG) of Standard Setters implies a 3-level hierarchy: Level 1: Estimate should be determined directly (by reference to current observable market prices of identical assets or liabilities). Level 2: If it can’t be determined directly, then estimate should be determined via proxies (by reference to market prices for similar assets or liabilities). Level 3: If it can’t be determined directly or via proxies, then the estimate should be determined via valuation methods (using generally accepted analytic approaches based on theoretical market pricing models). If valuation methods must be used, it can take several forms: market methods: valuations based on multiples drawn from transactions involving comparable assets or liabilities. income methods: PV techniques or option pricing models. Conger, "How Might the Presentation of Liabilities at Fair Value Have Affected the Reported Results of U.S. Property Casualty Insurers" – W – Chapter 3 (2004) cost methods: replacement or reproduction cost of an asset in comparable condition. A good test is to compare valuation method results with observable results. IASB has indicated that an undiscounted measure is inconsistent w/ fair value. And the measurement of fair value should include an adj for the premium market would demand. FASB refers to these as expected present value approaches. 3.2 Fair Value in a P&C Insurance Context 3.3 Estimating the Fair Value of Policy Benefit Liabilities 3.4 Status of IASB and FASB Deliberations Financial Accounting Standards Board International Accounting Standards Board 3.5 Considerations in Evaluating the Fair Value Proposal – in addition to the 3 listed below, one should also consider: neutrality of the measure and the cost of the measure. Reliability of the Measure – faithfulness, verifiability, not certainty. Relevance to Users Comparability and Consistency of the Measure Feldblum (RBC), “NAIC P/C Ins Company RBC Requirements," PCAS – W (exclude Sec. 11 and related Exhibits) 1. Introduction Instructions, Examples, and Analysis 2. Types of Risk 3. Asset Risks – these charges are largely adopted from the life insurance formula. These are more important to life insurance because: 1) Practice: capital-to-asset ratios: P&C companies tend to have assets 2 to 3 times its capital, and life insurance companies tend to have 10 times its capital. A 5% asset risk charge for life companies is about 50% of surplus, while for P&C it’s more like 10 – 15%. 2) Theory: asset risks are more important for life insurance companies, especial when investments are combined with life insurance products. P&C products are more for insurance protection only. Unaffiliated Fixed Income Securities – the charge reflects default risk, and the charge ranges from 0% for Treasury securities to 30% for bonds in Class 6. Preferred Stocks – the charge is set to the comparable bond charge + 2%. The charge is capped at 30%, so “class 6 preferred stock” charge is 30%. Also, there are no govt preferred stocks. Bond charges are included in R(1) while preferred stock charges are in R(2). Cash Risks – 0.3% charge (similar to the Class-1 bond charge) Bond Size Adjustment Factor – based on # of issuers. For the 1st 50 issuers, the charge is 250%. For 51-100 issuers, the charge is 130%. For 101-400 issuers, the charge is 100%. The remaining issuers get 90%. Take a weighted average of all the charges, subtract 100%, and add that charge to the “pre-size factor bond RBC charge” to get the “total bond RBD charge. For example: 500 issuers: [50 * 250% + 50 * 130% + 300 * 100% + 100 * 90%] / 500 = 116%. So, add 16% to get the total charge. Unaffiliated Common Stocks – originally 30% charge, but dropped to 15%. Three Perspectives Asset Concentration Factor Interest Rate Risk Insurance Affiliates Feldblum (RBC), “NAIC P/C Ins Company RBC Requirements," PCAS – W Domestic Insurance Subsidiary – RBC requirement is passed on to parent. Alien Insurance Subsidiary – charge = 50% of reported value of enterprise or of the securities it has issued, such as stocks or bonds. Investment Subsidiary – charge determined by “looking through” the subsidiary to its investments holdings. An investment subsidiary is any subsidiary engaged primarily in the ownership and management of investments for the insurer. Non-Insurance Subsidiaries – charge is 22.5% of its carrying value. Three Principles 1. RBC charge for a parent company is capped at the carrying value of the subsidiary. 2. If Parent Ins Co owns Non-Ins Holding Co, which owns Subsidiary Insurance Co, then Subsidiary Insurance Co is indirectly owned by Parent Ins Co. If Non-Ins Holding Co. has carrying value of $200M, and Subsidiary is at $100M with a RBC requirement of $50M, then the RBC charge to Parent for the investment in Non-Insurance Holding Co = RBC requirement of Subsidiary (capped at carrying value) + 22.5% of the difference between carrying values of the two subsidiaries. Charge = $50M + 22.5% * ($200 M - $100M) = $72.5M. 3. If Parent Ins Co owns preferred stock or bonds of Affiliated Ins Co, then the RBC charge to Parent is limited to the smaller of: the carrying value of preferred stock/bonds and amt of “excess RBC” above amts allocated to common stock investments in affiliated insurance companies. Investments in insurance affiliates/subsidiaries are included in R(0), while noninsurance subsidiaries are included in R(1) and R(2). Off Balance Sheet Risks – 1% charge. This includes: non-controlled assets, guarantees for affiliates, and contingent liabilities. 4. Credit Risk – a 10% charge for reinsurance recoverables Rationale for the Reinsurance Charge Reinsurance collectibility problems contributed to several major ins co insolvencies in the mid-1980s. Some financially troubled companies have used “sham” reinsurance transactions w/ affiliated companies to hide financial problems. Many reinsurance contracts don’t contain full risk transfer. Criticism of the Reinsurance Charge 1. Incentives: high charge for reinsurance is a disincentive to reinsure primary business. (NAIC responds: the 10% charge is lower than most reserving risk charges.) 2. Quality of Reinsurer: The charge doesn’t differentiate by type of reinsurer. (NAIC responds: this would serve as a rating agency for reinsurers – so no change made.) 3. Collateralization: The charge doesn’t consider secured recoverables. The RAA Study The Provision for Reinsurance Involuntary Market Pools Intercompany Pooling Agreements Miscellaneous Receivables – a 5% charge 5. Underwriting Risks Reserving Risks- this charge measures the susceptibility of loss reserves to adverse developments and is quantified separately by LOB using Sch P data for the past 10 yrs. Feldblum (RBC), “NAIC P/C Ins Company RBC Requirements," PCAS – W Industry Adverse Development – the charge begins w/ the calculation of adverse development ratios by Sch P LOB. NAIC calculated these in 1993 and these ratios are “frozen”. However, they can by updated by the NAIC as the need arises. Take each company’s adverse loss development ratios by Sch P LOB, where the numerator = the increase in est ult incurred losses between 2 statement dates (from Sch P, Part 2); and the denominator = the held loss reserves at the earlier statement date (subtracting paid losses [Part 3] from incurred losses [Part 2] in Sch P). Then company ratios are averaged to determine the base industry reserve charge. And these charges are used by everyone. “Worst Case Year” Some have argued that small insurers have greater random fluctuations in their ratios, and that simple averages were used instead of weighted averages. This led to an upward bias in the NAIC charge. NAIC responds: the simple avgs are not uniformly higher than the weighted avgs; and using weighted avgs would give undue influence to the results of the largest carriers. To determine the charge, for each LOB, consider the ratios for each year, and choose the largest ratio. Interest Discount Factor – this takes into account the reserve discounts not allowed by SAP. RBC formula uses a flat 5% interest rate in its calculations. The “Net” Industry Charge – an example: Private auto: 25.4% is the “worst case year” industry ratio. Use of a 5% interest rate deduction, the reserves are 92.1% the value of undiscounted. Thus the industry charge is 1.254 * 0.921 = 1.155 or 15.5%. Company Differences – the formula considers company’s own avg loss development by LOB over the past 9 yrs (from Sch P, Part 2) to that of the industry. Avg loss development = (current – initial) / initial incurred losses; where current incurred losses = sum(inc loss at current statement date for 9 AYs prior to current year) and initial incurred losses = sum(inc loss at initial statement dates). Above example continues. Take the company’s avg adverse development (1.04) and divide by the industry’s (1.065) to get 0.977. Multiply this by the worst year (25.4%) to get 0.248. Then take simple avg between this and the industry worst year: ½ * (.248 + .254) = 0.251. Finally multiply this by implicit interest margin: 1.251 * 0.921 = 1.152 or 15.2% of carried reserves. Note that the company’s worst-year is never used. Company Adverse Development Spreading Across Lines Written Premium Risk – one risk to consider is that the company’s future business will be unprofitable. The RBC formula uses a time horizon of 1 year. As a proxy, the formula uses the volume of business written during the most recent CY. This charge is determined similarly as the reserving risk charge. Interest Discount Factor – not same as above. This refers to investment income resulting from time lag between premium collection and loss payment. Take the “worst case year” loss ratio by an investment income factor (derived from IRS payment pattern and a 5% discount rate). The previous adjustment is for investment income from policy inception to final loss payment for a newly issued block of business. The latter adjustment reflects the expected Feldblum (RBC), “NAIC P/C Ins Company RBC Requirements," PCAS – W investment income on assets supporting loss reserves currently held by the company for all AYs combined. Company Experience Combined Ratios Unearned Premium Reserves – WP risk is the risk that U/W-ing results turn out to be worse than expected on the coming year’s U/W-ing activities. Reserving risk is the risk that U/W-ing results turn out to be worse on coverage that’s already been earned, but claims payments are not yet fully settled. Between these is an intermediate risk: that U/W-ing results turn out to be worse on coverage that has already been written, but not yet earned. Should we include a charge for this kind of risk? The Underwriting Risks Time Line UPR Risk Reserving Risk 1999 2000 WP Risk 2001 Equity in the Unearned Premium Reserves – originally there was a charge for this risk. If insurance companies held “net” UPRs (net of prepaid expenses), then the factors used to compute this charge would be about the same as those to compute the WP risk charge. But SAP requires UPR gross of prepaid expenses and does not allow for DPAC. For most companies, the gross UPR is about 20-25% greater than needed. This is “equity” in the UPR. The original formula contained an offset for prepaid acquisition expenses, resulting in a zero or insignificant charge. Thus this charge was completely deleted from the formula. Occurrence Policies versus Claims-Made Policies – some argue that since CM policies do not have IBNR development (though they do have development on reported claims), that CM policies have less adverse loss development. Though studies show this may be true, the difference wasn’t enough to yield meaningful conclusions. Quantification and Data – NAIC asked: how significant is the difference in adverse loss development between Occurrence and CM? And if different reserving risk charges are incorporated, how should the NAIC collect the data needed to quantify the offset? Implementation and Adoption – in response, the NAIC Blanks Task Force split Sch P into Occurrence and CM. Plus the current RBC formula reduces the reserving risk charge and the WP risk charge for Med Mal CM business by 20% compared to Occurrence. Offset for Loss-Sensitive Contracts – these will increase the reserving risk charge, due to the expected higher level of risk. It also affects the premium risk charge to guard against unexpected UW-ing results during the coming year. Risks in Retrospective Plans Magnitude of the Offset Definition of a Loss-Sensitive Contract Diversification by Line Feldblum (RBC), “NAIC P/C Ins Company RBC Requirements," PCAS – W loss concentration factor = reserves in largest LOB / total reserves for all lines. After adjusting for loss-sensitive business and for CM business, multiply the reserving risk charge by 70% + 30% * loss concentration factor. premium concentration factor = WP in largest LOB / total WP in all LOBs. Then multiply WP charge by 70% + 30% * premium concentration factor. Growth Charges Determination of the Growth Charge Adoption 6. The Covariance Adjustment When first introduced in 1991, Robert Butsic (of Fireman’s Fund) argued that simple summation is inappropriate since it assumes various risks occur simultaneously. He notes: 1. Non-insurance asset risk is independent of U/W-ing risk. 2. Historically, the correlation between stock & bond returns is only 14%. 3. Reserve and WP risk are not well correlated. Only 26%. 4. Based on judgment, reserve growth risk seems to be highly correlated w/ reserve risk. Risk Categories R(0): Investments in insurance affiliates; non-controlled assets; guarantees for affiliates; contingent liabilities. R(1): Fixed income securities (cash, bonds, bond size adj factor, mortgage loans); short term investments; collateral loans; asset concentration adj for fixed income securities. R(2): Equity investments (common stocks, preferred stocks, real estate); other invested assets; aggr write-ins for invested assets; asset concentration for equity investments. R(3): Credit risk (reinsurance recoverables, other receivables) R(4): Reserving risk (basic reserving risk charge, offset for loss-sensitive business, adj for CM business, loss concentration factor, growth charge for reserving risk) R(5): WP risk (BP risk charge, offset for loss-sensitive business, adj for CM business, premium concentration factor, growth charge for premium risk) Further notes: 1. After credit risk charge is calculated, ½ is removed from R(3) and added to R(4) to compensate for inconsistency between interdependence of (reserving risk and reinsurance collectibility risk) and the lack of a covariance term in the square root rule. 2. R(0) appears outside the square root rule, and all other terms are inside. 3. The asset concentration factor in R(1) considers all assets (R(1) and R(2)) combined and not separately. The Square Root Rule Total capital requirements = R0 R12 R22 R32 R42 R52 Remember, that R(3) is ½ the credit risk and R(4) is the reserving risk + ½ the credit risk. Also note the lack of covariance terms; the exclusion of R(0) charge from square root; and the marginal capital effects of each risk element. Covariance Terms The true total capital requirement depends on the meaning of “capital requirement”; the pdf of each risk element; and the interdependence of the risk elements. Feldblum (RBC), “NAIC P/C Ins Company RBC Requirements," PCAS – W Remember the complete square root rule on Risk A and Risk B: Total = A 2 2 * Cov( A, B) * A * B B 2 If there is perfect correlation, then the true total capital requirement is the straight sum of the individual risk elements. If there is no correlation, then the square root rule works. The true amt is probably in between the two. Butsic however argues: The square root rule overstates the true amt if the risk elements have normal or lognormal distributions; The correlation among the risk factors is weak, so any underestimation is small; The one important correlation is accounted for by moving ½ from R(3) to R(4). Conclusion: the 1st two arguments offset each other, and the unadjusted square root rule gives a reasonably accurate result. The Charge for Subsidiaries – this (R(0)) is placed outside the square root formula because it’s believed that any change in organizational structure of the company should not change the overall capital requirement. Marginal Effects Cj ; with TCR = total capital requirement; C(j) = individual capital TCR / C j 2 C i requirement. Risk categories w/ large pre-covariance charges (reserving risk) provide a high postcovariance contribution for each dollar of risk charge. Risk categories w/ low pre-covariance charges (default risk) provide opposite. Once covariance adjustment was used, it became clear that marginal effects of the asset risk charges were extremely small, which discouraged investment ploys as a way to reduce RBC requirements. RBC requirements are dominated by the U/W-ing risk charges (especially reserving risk), but the reserving risk do not adequately distinguish financially-troubled companies from sound companies, and the charges may give the wrong incentives that may actually raise insolvency risks. 7. Other Issues Quantifying the Capital Charge for Underwriting Risk – RBC formula balances 3 considerations as follows: 1. Accuracy: Capital charges must accurately reflect the risks faced by insurance companies. 2. Simplicity: rationale for charges should be understood by company executives and state regulators. 3. Incentives: The RBC formula should provide incentives for companies to strengthen their capital structures. Worst Case Year Statistical Quantification Credibility Feldblum (RBC), “NAIC P/C Ins Company RBC Requirements," PCAS – W Incentives – in practice, the adequacy of loss reserves may vary greatly from year to year. A reduction in reserve adequacy is an increase in stat surplus, and vice versa. Since bulk reserve requirements can’t be estimated precisely, troubled companies can choose an unreasonably low estimate to increase surplus and hide financial weakness. RBC may change this behavior. Reserve Strengthening and Weakening – however, RBC gives 3 incentives for companies to report inadequate reserves: 1. Reducing reserves increases stat surplus. Now even the financially strong companies will examine their RBC ratios to seek out the least costly ways to raise them. 2. Reducing reserves lowers the reserving risk charge. Since this charge is most dominant, its covariance adjustment is the greatest – giving an incentive for everyone to lower their reserves. 3. Reducing reported reserves also reduces the reported adverse development. One solution is to base the reserving risk charge on indicated reserves, not reported reserves. NAIC responds: alignment of reported reserves w/ indicated reserves is the task of the appointed actuary and state insurance department examiners, and not the responsibility of the RBC formula. Also consider that current requirement for the Opinion may help prevent deliberate reserve underestimations. Finally, reserve underestimations today would increase future development and the future reserving risk charge. WC and Tabular Discounts Duration and Volatility Criticisms Tabular Discounts Surplus Adjustments – RBC formula removes non-tabular discounts from P/H Surplus, but retains tabular discounts. This adjustment is phased in over a 5 yr period. However, the reserving risk charge is applied to reserves gross of non-tabular discount w/ no phase-in. Definition of Tabular Discounts 8. Implementation of RBC Requirements Minimum, Target, and Triple-A Standards – state statutes will define the minimum amt of surplus an insurance company must hold to obtain a license ($1M to $5M). However, the states make no attempt to define “optimal” or “target” amts a company should hold. The Actuarial Committee’s “White Paper” – this committee was tasked to study the parameters used in the RBC formula. The answer depends on the use of the formula. If the formula defined a minimum amt, then low parameters are appropriate. If used to define a target amt representing the “optimal” capital position for an insurer then higher parameters would be appropriate. If used to represent a “Triple-A” standard, or an amt of capital only the strongest companies would hold, then even higher parameters would be appropriate. The NAIC responded indirectly that the formula is meant to be a minimum level. 9. Regulatory Action Regulatory Hesitancy Levels of Action The ACL Level – authorized control level = a %-age of RBC standards. Has gone from 50% to 40% back to 50%. Feldblum (RBC), “NAIC P/C Ins Company RBC Requirements," PCAS – W Four Action Levels – RBC ratio = company’s actual (adj) surplus / RBC surplus. The actual surplus is adjusted for RBC purposes by removing the amt of non-tabular loss reserve discounts from surplus. Tabular discounts are not adjusted. ACL benchmark = 50%. Company Action Level – (75% to 100% of RBC standard), or 150% to 200% of ACL benchmark. No action required of state insurance department. However, the company must submit a plan of action to the insurance commissioner explaining how the company intends to obtain the needed capital or reduce operations/risks. Regulatory Action Level – (50% to 75% of RBC standard), or 100% to 150% of ACL benchmark. The company must submit a plan. The commissioner has the right to take corrective action (such as restricting new business). But such action is discretionary. Authorized Control Level – (35% to 50% of RBC standard), or 70% to 100% of ACL. Regulatory action is still discretionary, but commissioner is “authorized” to take control of the company. Mandatory Control Level – (Below 35% of RBC), or below 70% of ACL. The commission must rehabilitate or liquidate the company. Implementation – NAIC’s practice is to propose “model laws” that are enacted by each state’s legislature. This can lead to long delays and inconsistencies. Therefore, NAIC decided to do the following: 1) the proposed model law will not specify the RBC formula, since the state legislature could then change the formula. Rather, the model law requires RBC requirements. 2) in late 1990, NAIC adopted a “Solvency Policing Agenda” which says a state’s DOI will be accredited only if it passes the required model laws. Purposes of the RBC Standards – these are ranked from intended purposes to prohibited uses: 1) Minimum Capital Requirements: covered above. 2) Solvency Monitoring: RBC can be used in conjunction w/ more comprehensive financial examinations to determine solvency. 3) Legal Authority: RBC act gives the insurance commissioner a legal authority to intervene if a company appears to be financially troubled. 4) Rate-Making: PROHIBITED BY NAIC – RBC may be used to determine needed capital for a ROE rate filing. 5) Marketing: PROHIBITED BY NAIC – RBC might be used to identify “stronger” or “weaker” companies. The goals of NAIC’s RBC is to: Relate capital & surplus requirements to the risks inherent. Establish a universally recognized capital standard. Provide regulators w/ the authority to enforce compliance w/ more appropriate capital requirements. 10. Conclusion NAIC IRIS, “NAIC Insurance Regulatory Information System” – P/C Ratios – SKN Ratio Ranges Overall Ratios Ratio 1 – Gross WP to P/H Surplus = Gross WP / PHS * 100. NAIC IRIS, “NAIC Insurance Regulatory Information System” – P/C Ratios – SKN Gross WP = (Direct WP) + (Reinsurance Assumed-Affiliates) + (Reinsurance Assumed-Non-Affiliates). If PHS = 0 or negative, then ratio = 999. If PHS is positive and Gross WP is negative then ratio = 0. Range up to 900. If disparity between Ratio 1 and 2 is large, the insurer may be relying too much on reinsurance. Under pooling circumstances, this ratio may be skewed. Long-tail lines (WC) should maintain a lower Ratio 1. You should also consider %-age of assumed vs. direct to see if the insurer U/Ws its own business or not. Insurers with stable profits (see Ratio 5) can better handle a high Ratio 1. Ratio 2 – Net WP to P/H Surplus = Net WP / PHS * 100. If PHS = 0 or negative, then ratio = 999. If PHS is positive and Net WP is negative then ratio = 0. Range up to 300. If Ratio 2 is near 300%, you should also consider Ratio 4. If the insurer is an affiliate, look at Ratio 2 for the consolidated group. Insurers w/ stable profits (see Ratio 5) can better handle a high Ratio 2. Long-tail lines (WC) should maintain a lower Ratio 2. How adequate is the reinsurance protection against CATs? What is the general quality of the reinsurers? Ratio 3 – Change in Net Writings = Change in Net Writings / Net WP Prior Year * 100. Change in Net Writings = Net WP Current Yr – Net WP Prior Year. If Net WP Current and Prior are both 0 or negative, then result = 0. If Net WP Current is positive and Prior is 0 or negative, then result = 999. Large increase could signal abrupt entry into new LOBs or territories, or it could mean an increase in cash flow to meet current loss pmts. Large decrease could signal discontinuances of LOBs, loss of market share, or increased use of reinsurance. Range = -33 to 33. If unstable result, consider Ratio 9 to see if assets are properly valued and liquid enough to meet possible cash demands. Also, consider Ratios 11 – 13 to consider reserve adequacy. Increased writings not necessarily bad if accompanied by a low Ratio 2, adequate reserves (11 – 13), profitable operations (5) and stable product mix. Ratio 4 – Surplus Aid to P/H Surplus = Surplus Aid / PHS * 100. Surplus Aid = Ceding Commissions Ratio * (Ceded Reins UEP-Non-affiliates). Ceding Commissions Ratio = Reins Ceded Comms / Reins Ceded Premiums. NAIC IRIS, “NAIC Insurance Regulatory Information System” – P/C Ratios – SKN Reins Ceded Comms includes Reins Ceded Contingent Comms. Reins Ceded Premiums includes Affiliates + Non-Affiliates. Ceded Reins UEP – Non-affiliates includes “Total Auth & Unauth Other US Unaffiliated” and “Total Auth & Unauth Mandatory & Voluntary Pools” and “Total Auth & Unauth Other Non-US”. (Sch F – Pt 3.) If Reins Ceded Premiums or Surplus Aid is 0 or negative, then result = 0. If Surplus Aid positive and PHS is 0 or negative, then result = 999. Range up to 15%. High ratios may signal that PHS is inadequate, or that Surplus Aid is improving results in other ratios. If you get a high result, consider taking out Surplus Aid out of PHS and recalculate Ratios 1,2,7,10,13. You can do this easily by dividing each existing ratio by (1 – surplus aid ratio result). Profitability Ratios Ratio 5 – Two-Year Overall Operating Ratio = (2-Yr LR) + (2-Yr Exp Ratio) – (2-yr Investment Income Ratio). 2-yr LR = (Losses, LAE, & PH Divs Current & Prior Yr) / (EP Current & Prior Yr). 2-yr expense ratio = (Other U/W-ing Expenses – Other Income Current & Prior Yr) / (Net WP Current & Prior Yr). 2-yr investment income ratio = (Investment Income Earned Current & Prior Yr) / (EP Current & Prior Yr). If all the numerators added (minused) together is 0 or negative, then result = 0. If EP or Net WP is 0 or negative then result = 999. Range up to 100%. You may need to consider Ratios 11 and 13, since prior yr reserve development or current reserve deficiency may understate/overstate the true operating position. If Ratio 11 is outside the usual range, you should recalculate Ratio 5 by eliminating prior yr’s development to get a more accurate picture. Ratio 6 – Investment Yield = Net Investment Income Earned / (Avg Cash & Invested Assets Current & Prior Yr) * 200. The denominator = [Total Cash & Invested Assets + Investment Inc Due & Accrd – Borrowed Money Current & Prior Yr] – Net Investment Income Earned. Result capped at bottom by 0. Range from 3.0 to 6.5. Low yields could indicate: Speculative Investments; Large Investments in Affiliates, Home Office Facilities, or Tax-Exempt Bonds; Significant Interest Payments on Borrowed Money; Extraordinarily High Investment Expenses. High yields could indicate: Investments in High-risk Instruments; Extraordinary Dividend Pmts from Subsidiaries to the Parent. Ratio 7 – Gross Change in P/H Surplus = Gross Change in PHS / PHS Prior Yr * 100. Gross Change in PHS = PHS Current – PHS Prior. If PHS Current = 0 or negative, then result = -99. NAIC IRIS, “NAIC Insurance Regulatory Information System” – P/C Ratios – SKN If PHS Current is positive and PHS Prior = 0 or negative, then result = 999. Range from -10 to +50. A decrease in PHS is always a concern (thus range set at -10). High result causes concern as many companies had large PHS increases before they went insolvent. Be sure to also check: Ratio 5; unrealized capital gains/losses (large unrealized gains could mean the stock market is high – causing temporary increase in surplus); Ratio 8; S/H Dividends; Changes in non-admitted assets; Ratio 4; Accounting changes and corrections of errors; change in net deferred income tax; change in ownership. Ratio 8 – Net Change in Adjusted P/H Surplus = Adj PHS / PHS Prior Yr * 100. Adj PHS = PHS Current – Change in Surplus Notes – Capital Paid-in or Transferred – Surplus Paid-in or Transferred – PHS Prior Yr. If PHS Current = 0 or negative, result = -99. If PHS Current is positive and PHS Prior = 0 or negative, result = 999. Range from -10 to +25. Same as Ratio 7 except with adjustments to highlight insurer’s actual operations. Liquidity Ratios Ratio 9 – Liabilities to Liquid Assets = Adj Liabilities / Liquid Assets * 100. Adj Liabilities = Total Liabilities – Liabilities Equal to Deferred Agents’ Balances. Liquid Assets = Bonds + Stocks, Preferred & Common + Cash, Cash Equivalents & Short-Term Investments + Receivable for Securities + Inv Inc Due & Accrued – Invs in Parent, Sub, & Affiliates. If Liquid Assets = 0 or negative, then result = 999. Range up to 105. Many insolvent insurers showed increasing Ratio 9 results in their final years. Ratio 10 – Gross Agents’ Balances to P/H Surplus = Gross ABs in the Course of Collection / PHS * 100. If ABs = 0 or negative, then result = 0. If ABs is positive and PHS = 0 or negative, then result = 999. This ratio measures how much solvency depends on an asset that’s not easily converted to cash. Range up to 40. If high, check to see if AB more than 90 days was included in admitted assets. You can compare the ABs to ¼ the year’s gross WP and reins assumed net of commissions. Reserve Ratios Ratio 11 – 1-yr Reserve Development to P/H Surplus = 1-yr Loss Res Dev (from Sch P) / PHS Prior Year * 100. If 1-yr Dev is positive and PHS = 0 or negative, then result = 999. Range up to 20, which is most effective signal of troubled insurers. If the results show consistent adverse dev and/or Ratio 12 is consistently worse than Ratio 11, then the insurer may be intentionally understating its reserves. NAIC IRIS, “NAIC Insurance Regulatory Information System” – P/C Ratios – SKN Ratio 12 – 2-yr Reserve Development to P/H Surplus = 2-yr Loss Res Dev (from Sch P) / PHS 2nd Prior Year * 100. If 2-yr Dev is positive and PHS = 0 or negative, then result = 999. Range up to 20 … etc … same as Ratio 11. Ratio 13 – Estimated Current Reserve Deficiency to P/H Surplus = Est Loss & LAE Reserve Deficiency(Redundancy) / PHS * 100. Est Loss & LAE Reserves Deficiency = Est Loss & LAE Reserves Required – Loss & LAE Reserves Current. Est Loss & LAE Reserves Required = EP Current * Avg Ratio of Reserves to Premium. Avg Ratio of Reserves to Premium = Avg of Prior Yr and 2nd Prior Yr: Dev Loss & LAE Reserves to Premium Ratio Prior Yr. Prior Yr Dev Ratio = (Loss & LAE Reserves Prior + 1-yr Res Dev) / EP Prior. 2nd Prior Yr Dev Ratio = (Loss & LAE Reserves 2nd Prior + 2-yr Res Dev) / EP 2nd Prior. Range up to 25. Significant changes in premium volume can distort this ratio. Feldblum (Sch P), "Completing and Using Sch P" (Eighth Edition), CAS Study Note – W (2003) Introduction Purposes of the Schedule Other Purposes Experience Summary Exhibits The Schedule P Exhibits Prior Years Rows Data Types Part 1 – Current Valuation Premiums – recorded by CY and frozen. Loss and Loss Expense Payments Salvage and Subrogation Received Calendar Year Reconciliation Loss Adjustment Expenses DCC and AAO: Principles – adopted in 1998. DCC = Defense & Cost Containment for ALAE; AAO = Adjusting and Other for ULAE. Classification is by type of expense, regardless of whether it relates to specific claims. Classification is uniform for all companies. Expenses divided into two groups: expenses varying w/ amt of loss (DCC) and those varying w/ # of claims (AAO). (First 2 principles override this one.) DCC includes legal defense fees, costs of expert witnesses, fees to professionals working in defense of a claim. AAO includes adjustors’ fees, fees to other professionals working as adjustors, general claim department overhead. Declaratory Judgment Actions Feldblum (Sch P), "Completing and Using Sch P" (Eighth Edition), CAS Study Note – W Distribution of Adjusting and Other Expenses Previous Statutory Procedure – distribute AAO as follows: 1) 45% goes to most recent yr; 2) 5% to next yr; 3) the balance to all years (including most recent) in proportion to losses paid by AY during the most recent CY. 1) and 2) are to be capped at 10% of premiums earned in that year. For med mal, products liab, professional liab, non-proportional reinsurance, this method allots way too much ULAE to the most recent year, especially when claims in this line tend to settle much later. Illustration: Distribution of AAO Expenses Revised Method – Wendy Johnson’s method can be used. Illustration: Revised Method of AAO Distribution Relativities – the cost of maintaining an O/S claim = 1 unit. Closing a claim w/o payment = 2 units. Settling a claim w/ payment = 3 units. Cost of reporting a claim = 4 units. Claim History – Part 5 has 3 types of claim counts: 1) closed w/ pay; 2) O/S; 3) Reported. A triangle of closed w/o pay = reported – O/S at year end – closed w/ pay. Distribution Pooling and Reinsurance AAO Claim Counts Column 12: # of claims reported – direct & assumed. This contains cts for HO/FO, P Auto, C Auto, WC, CMP, Other Liability, Med Mal, Auto Phys Dam, Products Liability. Column 25: the lines listed above plus remaining primary LOBs show # of claims O/S (direct & assumed). Non-proportional reinsurance lines need not show any claim cts. Average Claim Severities = cumulative losses paid to date divided by cumulative claims closed w/ pay. Similar ratios: cumulative losses divided by sum of (claims closed w/ pay and O/S claims) shows avg incurred claim for non-frivolous claims. O/S case reserves divided by O/S claims shows avg size of case reserves. Claims may be counted per claim or per claimant (clarified in Interrogatory 6). Direct and Assumed vs Ceded – assumed includes proportional business, while ceded includes ceded non-proportional business. Intercompany pooling agreements split the claim cts among them. Since there is no simple way to determine # of claims ceded or assumed for non-proportional reinsurance, there are no claim cts for ceded or net, and no assumed on non-proportional reinsurance lines. Loss and Loss Expense Reserves Retroactive Reinsurance – retroactive reinsurance = the transfer of losses that have already occurred (not yet settled or not yet reported). Such retro reinsurance doesn’t effect Sch P. Rather, it’s coded as a write-in contra-liability on page 3, w/ an offsetting entry on line 24. Retroactive Reinsurance Accounting Illustration Feldblum (Sch P), "Completing and Using Sch P" (Eighth Edition), CAS Study Note – W Anticipated Salvage and Subrogation – this can offset either case losses unpaid or bulk losses unpaid. Distributing Unallocated Expense Reserves Claims Outstanding Illustration: Outstanding Claim Severity Loss Ratios Intercompany Pooling – if the pooling %-age changes, then past history must be restated at the new %-age level to avoid distortion in ldf patterns. For any AY, the Sch P entries divided by the pooling %-age should match previous statement’s entries divided by then-current %-ages. Occurrence and Claims-Made Business Tail Coverage Extended Tail Coverage RBC Underwriting Risk Charges Post Codification Tail Coverage Accounting Loss Date Excess Statutory Reserves Structured Settlements – though retroactive reinsurance doesn’t affect Sch P entries, structured settlements can actually distort Sch P ldf patterns – reducing reported loss factors and increasing paid loss factors. Auxiliary Exhibits Schedule P Triangles Derived Triangles Loss Adjustment Expenses Net vs Direct Experience Part 3 – Paid Losses The Prior Years Row – the upper left hand corner always contains 0. This row is meant to show development on the first listed year’s reserve. This development begins with payments made in the second listed year. (I think Feldblum has maybe miswrote something. No, it’s Sch P that’s messed up here.) Illustration: Completing the Prior Years Row – given the 2019 Schedule P. Take the prior years row and the 2009 row from 2018 Schedule P. Subtract out losses through 2010 and combine the two rows. Put 000 in the first entry in the 2019 Prior Years Row. Put in the rest of the entries. For the last entry, add in paid losses from 2019. Part 2 – Incurred Losses – net (skip IRIS sections) Updating the Part 2 Exhibits Updating the Two-Year Lines Part 4 – Bulk + IBNR Reserves Part 5 – Claim Counts – Section 1 shows cum claims closed w/ loss pmts. Section 2 shows claims O/S. Section 3 shows cum reported claims. Part 6 – Premium Development – separated by (direct + assumed) and (ceded). Principles – personal lines have premium fixed at inception; commercial policies have premium depending on activity of insured during policy period; WC premium depends on payroll; products liability depends on sales during term; retro premiums depend on losses which aren’t final until settled. Illustration: Retrospective Rating Feldblum (Sch P), "Completing and Using Sch P" (Eighth Edition), CAS Study Note – W Calendar Year, Exposure/Accident Year, and Policy Year Earned Premium Incurred Losses Audiences Illustration: Data Types Illustration Part A: Data Types – a retro WC policy issued on 10/1/2003 for a $10K, with a maximum premium = 150% of SP. One loss on 3/1/2004 with initial reserve of $8K. On 12/15/2004, payroll audit calls for an additional $1K premium. SP is now $11K with max prem = $16.5K. On 7/1/2005, 1st retro adjustment shows no additional or return premium. On 11/1/2005, case reserved revised to $25K. On 7/1/2006, 2nd retro adjustment calls for additional premium of $5.5K (to the max). On 8/1/2006, loss is settled for $20K. Calendar Year Accounting CY incurred losses: 2003 - $0; 2004 - $8K; 2005 - $17K; 2006 - (-$5K). CY EP = WP – change in UPRs + changes in EBUB PRs and accrued retrospective premium reserve. On 12/31/2003, ¼ of the policy has expired, so the year-end UPR is $7.5K. CY 2003 EP = $2.5K. Rest is earned in 2004. The audit premium of $1K is recorded as 2004 EP. The retro premium of $5.5K is recorded as 2006 EP. Policy Year Accounting PY incurred losses allocated to PY 2003 always. @2003 = $0; @2004 = $8K; @2005 = $25K; @2006 = $20K. PY 2003 EP: @2003 = $2.5K; @2004 = $11K; @2006 = $16.5K. Accident/Exposure Year Accounting AY 2003 incurred losses = 0. AY 2004 incurred losses: @2004 = $8K; @2005 = $25K; @2006 = $20K. Exposure year EP are similar. @2003: EY 2003 EP = $2.5K. @8/30/2004: EY 2003 EP = $2.5K; EY 2004 EP = $7.5K. @12/31/2004: audit is distributed over the policy term. (3/4 in 2004 and 1/4 in 2003). This results in: EY 2003 EP = $2750; EY 2004 EP = $8250. @12/31/2006: retro premiums are allocated in proportion to the coverage period. $1375 goes to EY 2003 and $4125 goes to 2004. Accounting for Exposure Year Premiums Individual exposure years (rows) show cumulative EPs, which include: collected premiums; billed but uncollected premiums; EBUB premiums; accrued retro premiums. The Prior Years row shows incremental CY changes to the EP for prior exposure years. The last column shows the distribution of current CY’s EP among exposure years. Last row shows CY EPs from Sch P Part 1. Illustration Part B: Actuarial Estimates – example A with premium reserves being used. In 2003, actuary estimates payroll audit will add $2K of premium. In 2004, bulk reserves = $6K and accrued retrospective premium reserve of $4K. Feldblum (Sch P), "Completing and Using Sch P" (Eighth Edition), CAS Study Note – W In 2005, accrued retrospective premium reserve changed to $12K. Note: these reserves are on a bulk basis, not per policy. Also, there is an original $10K deposit premium. Estimated Payroll Audit – At 2003, estimated EP for policy = $10K + 2K = $12K. So the EP for 2003 = $3K. The $9K is charged to 2004 in 2004. However, the payroll audit was -$1K lower than expected. Distribute this among 2003 and 2004. Estimated Retrospective Premiums CY: bulk reserves for losses and premiums assigned to 2004. PY: bulk reserves for both are assigned to 2003. AY: bulk reserves for losses assigned to 2004. Exposure Year: ¼ of premium reserves assigned to 2003 and ¾ to 2004. In 2005, the change in bulk reserve premiums is assigned to CY 2005, PY 2003, and for exposure year: ¼ to 2003 and ¾ to 2004. Same allotment for the reduction in 2006. Completing the Part 6 Exhibits Part 7 – Loss Sensitive Contracts RBC Underwriting Risk Charges Premium Sensitivity Loss Reserve Adequacy and RBC Offsets Definition of Loss-Sensitive Contracts Part 7 Historical Exhibits Illustration – Premium Sensitivity Part 7 Data Initial Deposits Quantifying the Sensitivity Reported Losses and Billed Premium Premium Billing Lags Prior Years Row Reinsurance Experience Prospective vs Retroactive Reinsurance Reinsurance and RBC Reinsurance and Surplus Relief Schedule P Interrogatories Reserve Margins Reserve Margin Controversy Statement of Actuarial Opinion Under-Reserving Actuarial Opinion Scope of the Statement Appendix A: Accounting for Audits and Retrospective Adjustments General Principles A. Accounting Methods B. Statutory vs Tax Accounting C. Financial Statement Reporting Procedures Illustration – Income Statement and Balance Sheet D. Non-admitted Asset Feldblum (Sch P), "Completing and Using Sch P" (Eighth Edition), CAS Study Note – W Accrued Retrospective Premium Reserves Statutory Accounting Principles Feldblum (IEE), "The Ins Expense Exhibit and the Allocation of Investment Income" – W (1997) Introduction The Structure of the Insurance Expense Exhibit Part I – Allocation to Expense Groups – divides expenses among: expense classification (rows) vs. expense groups (columns: loss supervision and collection expenses; acquisition & field expenses; general license and fees; taxes expenses; investment expenses). The middle 3 expense groups are “other U/W-ing expenses”. Part II – Allocation to LOB Net of Reinsurance Part III – Allocation to Lines of Direct Business Written – similar to Part II, except investment income is not included. IEE Part II: Allocation to Lines of Business Net of Reinsurance Allocation of Investment Income by Line of Business – starting in 1992, the IEE now allocates using the same allocation in the NAIC “Profitability by Line by State” report. Conceptual Level 1. Investment income is allocated to each LOB in proportion to the investable funds associated w/ each LOB. Investable funds are: funds attributable to insurance transactions and fund attributable to capital & surplus. 2. Funds attributable to insurance transactions are: loss reserves + UPRs – prepaid expenses – uncollected premiums. 3. Capital & surplus are allocated to LOB in proportion to total reserves + EP for the year. Component Level 1. The following balance sheet items use the average of the current year-end and the prior year-end: Net loss & LAE reserves; Net UPRs; Net ABs; P/H’s surplus. 2. Prepaid expenses = commission & brokerage expenses incurred + taxes, license, fees incurred + other acquisition, field supervision, and collection expenses incurred + ½ of general expenses incurred. 3. Net investment gain (loss) = net II earned and net realized capital gains (losses). It does not contain unrealized gains. The Allocation A. Allocate company’s mean surplus to LOB as described in illustration below. B. Determine the company’s overall “investment gain ratio” = net investment gain / [Mean net loss & LAE reserves + mean net UPRs – mean net ABs + mean P/H’s surplus]. C. The “investment gain on funds attributable to insurance transactions” = investment gain ratio times funds attributable to insurance transactions; where the latter term = mean net loss & LAE reserves + mean net UPRs * [1 – (prepaid expenses / WP)] – mean net ABs. D. The “investment attributable to capital & surplus” = the total investment gain for that LOB – the “investment gain on funds attributable to insurance transactions.” Where total investment gain = investment gain ratio * investable funds associated w/ that LOB; Feldblum (IEE), "The Ins Expense Exhibit and the Allocation of Investment Income" – W and the latter term = mean net loss & LAE reserves + mean net UPRs – mean net ABs + allocated P/H’s Surplus. Data Level The 1992 Revisions Profit or Loss – all columns are pre-federal income tax, regardless of caption. Pre-tax profit (loss) excluding all invest gain = EP + Other Income less Other Expenses – P/H dividends – Incurred Loss – DCC Incurred – AAO incurred – commissions/brokerage – taxes/fees – Other acquisitions – General expenses. Profit (Loss) excluding investment gain attributable to capital & surplus = Pre-tax profit (loss) … + Investment gain on funds attributable to insurance transactions. Total profit (loss) = last thing + Investment gain attributable to capital & surplus. Allocation Procedures: An Illustration – example features a commercial lines insurer that writes only WC and Other Liab. All amts are in millions. Allocation of Surplus to Lines of Business – stat surplus (page 3) = $500 at 1995 and $700 at 1996. The following data comes from 1995 and 1996 IEE: WC Other Liab 95 96 95 96 ABs 35 45 10 10 EP 350 450 200 200 Loss & LAE Reserves 1400 1700 600 600 UPRs 75 125 100 100 WP 400 500 200 200 Commission & brokerage 40 50 25 30 Taxes, licenses & fees 8 10 5 5 Other acquisition expenses 8 10 5 5 General expenses 40 60 20 20 IEE II allocation procedure requires that we allocate the mean surplus to LOB in proportion to: mean net loss (& LAE) reserves + mean net UPRs + EP for the year. You don’t adjust UPRs for ABs or for prepaid expenses. Mean surplus = $600. Mean loss reserves = 1550 for WC; 600 for Other. Mean UPRs = 100 for WC; 100 for Other. EP = 450 for WC; 200 for Other. Total = 2100 for WC; 900 for Other. This allocates $420 of surplus to WC and $180 to Other. Investment Gain Ratio – determined overall. Other info to consider: 95 96 Net investment income 250 250 Realized capital gains 100 50 Unrealized capital gains 100 150 P/Hs Surplus 500 700 Net investment gain = 250 + 50 = 300. Mean net ABs = 40 + 10 = 50. Investment gain ratio = 300 / [2150 + 200 – 50 + 600] = 10.34%. Feldblum (IEE), "The Ins Expense Exhibit and the Allocation of Investment Income" – W Prepaid (“Acquisition”) Expenses – determined by LOB. Prepaid expenses = [50 + 10 + 10 + ½ * 60] = $100 for WC; [30 + 5 + 5 + ½ * 20] = $50 for Other. Prepaid expense ratios = prepaid expenses / WP, not EP. Investment gain on funds attributable to insurance transactions – LOB – Column 18. Factor = 1 – (prepaid expenses / WP) = 80% for WC and 75% for Other. Funds attributable to insurance transactions = 1550 + 100 * 80% - 40 = $1590 for WC; 600 + 100 * 75% - 10 = $665 for Other. Investment gain …. = 10.34% times these amts = $165 for WC; $69 for Other. Investment gain attributable to capital and surplus – LOB – Column 20. Investable funds = 1550 + 100 – 40 + 420 = $2030 for WC; 600 + 100 – 10 + 180 = $870 for Other. Total investment gain = 10.34% of those amts = $210 for WC; and $90 for Other. Investment gain attributable to capital & surplus = 210 – 165 = $45 for WC; and 90 – 69 = $21 for Other. Part III – Allocation to Lines of Direct Business Written 2 differences between Part III and Part II: Most AS exhs show net experience, so there are few direct cross-checks from Part III. Since investment income relates to net experience, those columns are not in Part III. Profit or Loss The Measurement of Profitability Prospective versus Retrospective – pricing is mainly a prospective task, while the IEE is a retrospective measure of insurance profitability. Allocation of Surplus Reserve Run-Off versus New Business Insurance Returns and Investment Returns Perspectives on the IEE Procedures Appendix A: The Part II Entries Premiums Dividends Losses and LAE Agents’ Balances Underwriting Expenses Appendix B: The Part III Entries NAIC APPM, Preamble – SK I. Accounting Practices and Procedures Promulgated by the NAIC (1-5) II. Background (6-21) A. An Accounting Environment for Insurance Companies (6-7) B. Statutory Accounting Principles (SAP) (8-9) C. Comparison Of GAAP and SAP (10-11) D. Purpose of Codification (12-14) E. History of Codification (15-19) F. Scope of Project (20-21) III. Statutory Accounting Principles Statement of Concepts (22-38) NAIC SSAP 62, "Property and Casualty Reinsurance" – SK (paragraphs 1-71) Purpose of Statement of Concepts for Statutory Accounting Principles (22-26) Objectives of Statutory Financial Reporting (27-28) Concepts (29-36) Conservatism (29-30) Consistency (31) Recognition (32-36) Conclusion (37-38) IV. Statutory Hierarchy (39-40) V. Statements of Statutory Accounting Principles (41-43) VI. Materiality (44-49) VII. Relationship to GAAP (50) VIII. Relationship to Developments within NAIC (51-53) IX. Permitted Accounting Practices (54-57) X. Financial Statements (58-61) A. Annual Financial Statement (58-59) B. Interim Financial Statements (60-61) NAIC SSAP 53, "Property Casualty Contracts-Premiums" – SK Scope of Statement (1-2) Summary Conclusion (3-17) Earned but Unbilled Premium (9-12) Advance Premiums (13) Premium Deposits on Perpetual Fire Deposits (14) Premium Deficiency Reserve (15-16) Disclosures (17) NAIC SSAP 62, "Property and Casualty Reinsurance" – SK (paragraphs 1-71) Scope of Statement (1) Summary Conclusion (2-71) General (2-5) Characteristics of Reinsurance Agreements (6-7) Required Terms for Reinsurance Agreements (8) Reinsurance Contracts Must Include Transfer of Risk (9-16) Accounting for Reinsurance (17-24) Accounting for Prospective Reinsurance Agreements (25-26) Accounting for Retroactive Reinsurance Agreements (27-33) Deposit Accounting (34) Assumed Reinsurance (35-41) Ceded Reinsurance (42-46) Adjustable Features/Retrospective Rating (47-51) Commission Adjustments (48) Premium Adjustments (49) Adjustments in the Amount of Coverage (50) Impairment (51) NAIC SSAP 53, "Property Casualty Contracts-Premiums" – SK Commissions (52-53) Provision for Reinsurance (54-55) Disputed Items (56-57) Uncollectible Reinsurance (58) Commutations (59-62) National Flood Insurance Program (63-66) Disclosures (67-71 or 73?) NAIC SSAP 65, "Property and Casualty Contracts" – SK (paragraphs 1-45) Scope of Statement (1-2) Summary Conclusion (3-45) Claims Made Policies (4-9) Discounting (10-16) Structured Settlements (17-20) Policies with Coverage Periods Equal to or in Excess of Thirteen Months (21-33) High Deductible Policies (34-39) Asbestos and Environmental Exposures (40-43) Excess Statutory Reserve (44) Policyholder Dividends (45)