Reinsurance—P&C COSO Component Cycle Transaction Process Control Objective Control Objective Control Type (CAVR) Control Objective Category (C/FR/O) Risk Point of Focus Point of Focus Control Type (CAVR) Control Activity Reinsurance Reinsurer selection The Company formulates a reinsurance program to meet business objectives including capacity, reduction of risk exposure and catastrophe protection. V O Management lacks the experience to place its own reinsurance cover, resulting in the selection of inappropriate reinsurers. Reinsurers and reinsurance intermediaries (including renewals) are selected and approved by a reinsurance committee comprising representatives from the underwriting, claims, actuarial, finance and legal functions. V Control Activity Reinsurance Reinsurer selection The Company formulates a reinsurance program to meet business objectives including capacity, reduction of risk exposure and catastrophe protection. V O Catastrophic events result in a high frequency and severity of claims which undermines the Company’s financial position. The reinsurance program includes a level of catastrophe cover commensurate with the nature and distribution of risks insured. V Control Activity Reinsurance Reinsurer selection Reinsurance needs for new products are evaluated and programs are V O The existing reinsurance program does not consistently address the risks insured across all product lines. Reinsurance needs are assessed for all new products on a timely basis based upon anticipated loss ratios, anticipated claims V 1 Reinsurance—P&C established timely. development patterns and cash flow forecasts. Control Activity Reinsurance Reinsurer selection Appropriate reinsurer selections enhances the Company’s financial position. V O The Company’s financial position is adversely affected by ceding business to reinsurers with poor credit ratings The Company assesses the impact of using a particular reinsurer on its own credit rating, by monitoring the assuming reinsurers’ credit ratings and financial performance. V Control Activity Reinsurance Reinsurer selection Senior management monitors the status of selected reinsurers to identify potential issues. V O Reinsurer selection or developments expose entity to unacceptable level of credit risk The reinsurance committee meets regularly to assess monitor the financial security and solvency of each reinsurer, and to monitor the Company’s credit risk exposure. V Control Activity Reinsurance Reinsurer selection Deterioration in the financial security of reinsures is identified on a timely basis. V O, FR Deterioration in the financial security of reinsurers is not identified on a timely basis. The company identifies reinsurers placed on credit watch by major rating agencies on a timely basis and scrutinise amounts due and payable accordingly. V Control Activity Reinsurance Contract Placement An enforceable contract exists between parties that effectively transfers insurance risk from the cedent to the assuming company. V O, FR Contracts do not exist to support reinsurance ceded Note: Generally the reinsurance contract is not signed by all parties until many months after the effective date. The documentation to evidence the binding agreement when coverage is first arranged is often minimal and records the basics of the agreement. The level of documentation V 2 Reinsurance—P&C increases to completeness at the signing of the contract. Reinsurance contracts and binding authorities are developed in accordance with Company guidelines and are authorized by senior underwriting management. Control Activity Reinsurance Contract Placement The Company records all reinsurance contracts entered into. C FR Incomplete record of contractual rights and obligations. A complete register of reinsurance contracts and intermediaries with binding authorities is maintained. C Control Activity Reinsurance Contract Placement The Company records all reinsurance contracts entered into. C FR Contract documentation may be altered, damaged or lost. Reinsurance contracts are stored in a secure location and accessible only by authorized personnel V Control Activity Reinsurance Contract Placement Reinsurance transactions are based upon current the reinsurance program. V FR New business is underwritten using outdated or based upon outdated contract terms or expired contracts. The approved reinsurance program and updates are communicated to all underwriters and intermediaries with binding authority. V Control Activity Reinsurance Contract Placement Reinsurance transactions are based upon current the reinsurance program. C, A FR Reinsurance transactions are processed based upon outdated contract terms or expired contracts. The policy administration system, reinsurance register, and commission register are updated to reflect reinsurance terms immediately upon inception of the contract. C, A 3 Reinsurance—P&C Control Activity Reinsurance Contract Placement Reinsurance contracts are approved by senior management V O, FR Contracts are amended without proper scrutiny and authorization. Amendments to existing contracts are approved by an appropriate officer and the policy administration system and commission register updated accordingly. V Control Activity Reinsurance Contract Placement Effective segregation of duties R FR Contracts are placed for the purpose of paying fraudulent ceded premiums to reinsurers’ Segregation of duties between approval of reinsurance and recording of reinsurance transactions. R Contract Placement Reinsurance Contract Placement The cedent owns or has appropriate rights to reinsurance ceded assets and incurs reinsurance ceded liabilities. C, A, V FR Internal control weaknesses at intermediaries result in the misstatement of reinsurance balances by the Company. Reinsurance contracts contain a clause permitting the inspection of intermediaries operations/records. C, A, V Contract Placement Reinsurance Contract Placement The cedent owns or has appropriate rights to reinsurance ceded assets and incurs reinsurance ceded liabilities. C, A, V FR The Company pays loss expenses that should have been settled by the reinsurer. Obligation for paying loss adjustment expenses is clearly defined as the responsibility of either the ceding or assuming company. C, A, V Contract Placement Contract Placement Contract Placement Reinsurance contracts demonstrate compliance with V C Taxation liabilities arise where reinsurance transactions to affiliates are deemed to be a means of Transfer pricing analysis is performed to ensure that reinsurance ceded to affiliates meets the V 4 Reinsurance—P&C transfer pricing requirements. extracting profits. definition of an arms-length transaction under transfer pricing requirements. Control Activity Reinsurance Contract Placement Reinsurance contracts comply with regulatory requirements. V C Failure to comply with regulatory requirements results in regulatory action Contract formation incorporates applicable domestic and overseas licensing requirements. V Control Activity Reinsurance Contract Performance Intermediaries and reinsurers fulfil their contractual obligations. V C Changes to reinsurance contract terms results in the retention of inappropriate insurance risks or increased insurance liabilities. Execution of the contract is reviewed periodically to ensure compliance with the contractual terms and of the agreement. V Control Activity Reinsurance Contract Performance Sufficient data to assess contract performance is gathered and recorded on a timely basis. C, A, V FR Inaccurate assessment of contract performance based upon inaccurate or incomplete data QR reviews are performed for each contract to ensure that sufficient documentation exists to support recorded ceded reinsurance transactions. C, A, V Control Activity Reinsurance Contract Performance The Company monitors the performance of individual reinsurance contracts. V FR Contracts fail to properly mitigate the insurance risk as expected. Financial performance of the contract is compared with anticipated results (including profitability and cash flows – see risk transfer analysis section). V Control Activity Reinsurance Contract Performance The Company monitors the performance of intermediaries placing reinsurance C, A, V FR The commission structure encourages inaccurate or fraudulent reporting of transactions by intermediaries. Periodic controls reviews are performed at reinsurers and intermediaries that are authorized to bind the insurance company without prior approval. C, A, V 5 Reinsurance—P&C business. Control Activity Reinsurance Contract Performance Management monitors changes to existing contract terms. V C Unauthorized amendments to existing contacts results adversely impacts the effectiveness of the overall reinsurance program. Changes to reinsurance contracts are reviewed and authorized by an appropriate officer. V Control Activity Reinsurance Contract Performance All amounts due to from reinsurers are collected in accordance with contract terms. C, A, V FR The Company fails to recover reinsurance recoverable balances An arbitration process exists to resolve disputed reinsurance recoveries. C, A, V Control Activity Reinsurance Contract Performance Reinstatements are utilized to provide cost effective reinsurance cover. A FR The Company pays reinstatement premiums where limits have not yet been exceeded. Reinstatement premiums are reviewed and approved by an appropriate official. A Control Activity Reinsurance Risk Transfer Analysis Contracts which pass the risk transfer test, cover future insurable events and are not multiple-year retrospectively rated are recognised under the prospective accounting method. V FR The Company has significant intercompany reinsurance agreements which may not meet risk transfer requirements Note: the following “red flags” are indicators of potential risk transfer issues: V 1. 2. Contracts where 3. 6 Unusually high premiums for value of coverage obtained Existence of contingent and sliding scale commission, profit commissions, retrospectively rated premiums, per claim deductibles Double triggers (e.g. Reinsurance—P&C the assuming reinsurer agrees to reimburse a ceding enterprise for liabilities incurred as a result of past insured events are recognised under the retroactive reinsurance accounting method. loss warranties) Accumulating retentions over multiple years 5. Experience account/fund balance 6. Significant coverage changes in multi-year contract 7. Commutation and termination provision allowing reinsurer to lock in payment pattern 8. Termination provisions limiting ability to cancel 9. Related party contracts 10. Multi-year retrospectively rated contracts 11. Retroactive reinsurance contracts 12. Contracts that do not on face value make business sense. 4. Contracts which pass the risk transfer test, qualify as short duration contracts and for which the premium expected to be paid or received are reasonably estimable and allocable in proportion to the reinsurance protection provided are recognised as multi-year restrospectively rated contracts. A full risk transfer analysis is prepared by underwriting and actuarial personnel to determine the appropriate accounting treatment as required by FAS 60, FAS 113 EITF 93-6 and SOP 987 7 Reinsurance—P&C Reinsurance contracts which do not meet risk transfer criteria are recognised under the deposit accounting method in accordance with SOP 98-7 Control Activity Reinsurance Risk Transfer Analysis Management maintains sufficient supporting documentation to support the risk transfer assessment. V O Management is unable to evidence compliance with the risk transfer test if challenged by third parties The risk transfer analysis is documented and reviewed by an official with appropriate underwriting experience. V Control Activity Reinsurance Risk Transfer Analysis Management continues to monitor risk transfer throughout the life of the contract. V O, FR Changes in contract terms mean that the contract no longer passes the risk transfer request and necessitates different accounting treatment. Risk transfer is reassessed by underwriting and actuarial personnel when there is any change or adjustment to the contractual terms of a reinsurance contract. This includes an assessment of whether any change causes all or a portion of the contract to be retroactive. V Control Activity Reinsurance Transactions Recording All premium and claims transactions are assessed for C, A, V FR Ceded reinsurance assets and liabilities do not reflect all applicable original events. The reinsurance system is updated to reflect the ceded portion of premiums written and claims recorded in the C, A, V 8 Reinsurance—P&C reinsurance, and accounted for in accordance with reinsurance contract terms. underlying policy and claims administration systems. Control Activity Reinsurance Transactions Recording All ceded reinsurance transactions are accurately recorded in the policy, claims and reinsurance and actuarial administration systems. C, A FR Inaccurate recording of policy data due to incorrect/invalid data entry Rejected reinsurance data is isolated, analysed and corrected on a timely basis through programmed controls, batch headers and suspense accounts. Management reviews resulting exception reports. C, A Control Activity Reinsurance Transactions Recording All ceded reinsurance transactions are accurately recorded in the policy, claims and reinsurance and actuarial administration systems. A, V FR The policy, claims and reinsurance administration systems overstate ceded premiums and reinsurance recoverables. System checks are in operation to prevent duplicate processing reinsurance transactions A, V Control Activity Reinsurance Transactions Recording All transactions are recorded on a timely basis. C, A FR Processing backlogs exist and are not cleared on a timely basis An appropriate level of review is in place to ensure that reinsurance data is entered on a timely basis and any backlogs addressed. C, A Control Reinsurance Transactions Facultative C, A FR Ceded premiums and claims Programmed systems C, A 9 Reinsurance—P&C Activity Recording reinsurance is clearly identifiable from Treaty reinsurance, and applicable transactions recorded in accordance with the appropriate contract terms. are inaccurately calculated. controls separately identify treaty and facultative reinsurance. Control Activity Reinsurance Transactions Recording The unearned premium reserve accurately reflects ceded reinsurance transactions. A FR Incorrect amounts of unearned premiums is recorded in the financial ledger. The calculation of ceded earned/unearned premium is performed by the reinsurance systems and reviewed by an appropriate official. A Control Activity Reinsurance Transactions Recording Management to ensure completeness and accuracy of data input. A, V FR Absence of effective monitoring controls by management. Management information critically analyses activity by contract and individual reinsurer: including current and historical ceded premiums and claims, loss and combined ratios, ceded unpaid case reserves and IBNR, the relationship between unearned to inforce ceded premium, profit commissions, contract pricing and cashflows. MI is periodically reviewed by an appropriate official. A, V Control Activity Reinsurance Transactions Recording Reinsurance transactions are C, A, V FR Inaccurate data input results in the misclassification of The financial subledgers are reconciled to the general C, A, V 10 Reinsurance—P&C accurately reflected and classified in the financial ledgers. financial records ledger. Reconciliations are reviewed and approved by financial management. Control Activity Reinsurance Transactions Recording Ceded reinsurance transactions are correctly calculated in accordance with contract terms. V FR Invalid or authorized reinsurance transactions are recorded in the Company’s records. Total reinsurance ceded assets and liabilities are reconciled to underlying individual reinsurers’ records on a timely basis and the reconciliation reviewed by an appropriate official. V Control Activity Reinsurance Transactions Recording Reinsurance amounts are accurately computed in accordance with contract terms. A FR Ceded reinsurance calculations are performed incorrectly. Ceded claims calculations are reviewed by an appropriate official and authorized by an appropriate official to ensure compliance with the terms of the contract A Control Activity Reinsurance Transactions Recording Reinsurance amounts are accurately computed in accordance with contract terms. A FR Ceded reinsurance calculations are performed incorrectly. Ceded premium calculations (including reinstatement premiums and contingent commissions) are reviewed by an appropriate official. A Control Activity Reinsurance Transactions Recording Deposit premiums are paid to the reinsurers as they fall due. A FR Incorrect amounts are paid to reinsurers on a periodic basis, adversely impacting the company’s cashflow and working capital requirements. The calculation of deposit premiums is reviewed by an appropriate official. A Control Reinsurance Transactions Prevention or C, A FR The financial ledger does Ceded premiums and claims C, A 11 Reinsurance—P&C Activity Recording detection of incorrect entries to premium and claims systems. not accurately reflect reinsurance activity. are reconciled to the policy and claims administration systems, actuarial system, commission register and the reinsurance subledgers Control Activity Reinsurance Transaction Recording The company maintains appropriate funds to reduce the statutory provision for unauthorized reinsurance. A R Misstatement of reinsurance liabilities The calculation of funds withheld is reviewed by an appropriate official. A Control Activity Reinsurance Transactions Recording Only valid transactions are recorded in the underlying records. A FR Incorrect amounts of gross and net written premium recorded in the financial statements. Suspense accounts are reconciled and reviewed by an appropriate official for unusual or aged items. A Control Activity Reinsurance Transactions Recording Effective segregation of duties. R FR Fraudulent data entry results in the misappropriation of cash receipts. Segregation of duties between those maintaining reinsurance premium and loss recoveries and those responsible for processing cash receipts and payments. R Control Activity Reinsurance Transaction Recording Reinsurance balances and transactions are correctly stated in the reporting currency. A FR Misstatement of reinsurance receivables, payables and activity. Translation of foreign currency written premiums is calculated using prevailing exchange rates at the date of policy inception. A Control Activity Reinsurance Transaction Recording Tax information derived from CA FR Erroneous data may be used in tax computations and Programmed subledger coding facilitates the C, A 12 Reinsurance—P&C premium activities is accurately and promptly reported. result in overpayments or underpayments of taxes. automated classification, summarization, and retrieval of required tax information. Control Activity Reinsurance Transaction Recording Tax information derived from premium activities is accurately and promptly reported. C, A FR Erroneous data may be used in tax computations and result in overpayments or underpayments of taxes. Review of major transactions or major classes of transactions by individuals who are knowledgeable about tax requirements. C, A Control Activity Reinsurance Transaction Recording Tax information derived from premium activities is accurately and promptly reported. CA FR Taxes are incorrectly calculated. Documented procedures for developing, summarizing, and reporting required tax information. C, A Control Activity Reinsurance Transaction Recording Relevant disclosure data is gathered completely, accurately and on a timely basis. C, A, V FR Required GAAP/ MD&A/ 10-K disclosures are incomplete or inaccurate for presentation in the financial statements Recorded transactions capture and aggregate required account disclosures including: - ceded written and earned premiums - ceded claims incurred - gross and net unpaid losses and loss expenses (current and prior year components) - A&E exposures - reinsurance recoverables and associated bad debt C, A, V 13 Reinsurance—P&C - - allowance funds withheld letters of credit reinsurance balances receivable/payable analysis of credit exposure by reinsurer appropriate segmental and geographical analysis associated cash flows material legal proceedings Control Activity Reinsurance Billings and collections Reinsurance amounts are accurately computed in accordance with contract terms. C, A FR Failure to bill and collect amounts due on a timely basis. Claims are received by the claims function are aggregated and passed to the reinsurance function for the purposes of assessing reinsurance recoveries on surplus or excess reinsurance contracts. C, A Control Activity Reinsurance Billings and collections Reinsurance amounts are accurately computed in accordance with contract terms. A FR Ceded reinsurance calculations are performed incorrectly. Ceded claims calculations are reviewed by an appropriate official and authorized by an appropriate official to ensure compliance with the terms of the contract A Control Activity Reinsurance Billings and collections Reinsurance recoveries are appropriately authorized. A, V FR Unauthorized reinsurance billings are issued to reinsurers. Individually significant reinsurer and intermediary billings are reviewed and authorized by an appropriate official prior to issuance. A, V 14 Reinsurance—P&C Control Activity Reinsurance Billings and collections Amounts billed accurately reflect adjustments permitted under the terms of the reinsurance contract. Effective segregation of duties. A, V FR Unauthorized reinsurance billings are issued to reinsurers. Billings are adjusted to reflect retrospective adjustments and contingent commissions. All such adjustments are reviewed by an appropriate official. A, V Control Activity Reinsurance Billings and collections R FR Fraudulent reinsurance transactions are recorded for the purpose of misappropriating assets. Segregation of duties exists between cash receipts processing and recording reinsurance recoverables R Control Activity Reinsurance Billings and collections Reinsurance recoverables are identified on a timely basis and communicated to intermediaries and reinsurers. C, A, V FR Failure to identify reinsurance recoverable balances receivable on a timely basis. Delays in collecting receivables Statements are issued to reinsurers on a timely basis detailing ceded premiums, claims, commissions, and applicable adjustments. C, A, V Control Activity Reinsurance Allowance for Uncollectible Reinsurance Recoveries recorded under reinsurance contracts represent collectible assets V FR Reinsurance recoverables represent collectible assets after making allowance for doubtful debts. Reinsurance personnel responsible for placing reinsurance business liase with credit controllers to monitor collectability of reinsurance recoverables. V Control Activity Reinsurance Allowance for Uncollectible Reinsurance Management monitors the recoverability of reinsurance assets C, A FR Unidentified delinquent accounts exist without any allowance for doubtful debts being established. Aging analysis of reinsurance recoverables is performed for each reinsurer to identify delinquent accounts. C, A Control Activity Reinsurance Allowance for Uncollectible Reinsurance Consistent methodology is applied to determine the C, A FR Bad debt allowance against reinsurance recoverables reflects the credit ratings of individual reinsurers (see The reinsurance committee meets regularly to assess monitor the financial security and solvency of C, A 15 Reinsurance—P&C allowance for bad debts on reinsurance recoverables. Reinsurer Selection). each reinsurer, and to monitor the Company’s credit risk exposure. Control Activity Reinsurance Allowance for Uncollectible Reinsurance Management approval is required to writeoff reinsurance recoverable balances. R FR Assets are written-off without pursuing recovery with sufficient rigour. Write-offs of amounts due from reinsurers and intermediaries are approved by authorized personnel only and supported by documentary evidence. R Control Activity Reinsurance Adjustments and Ledger Maintenance The financial statements accurately reflect the amount of premiums due expected to be recoverable. R FR Unauthorized adjustments are made to the financial ledger. Access to ledger journal entries is restricted to appropriate finance personal. R Control Activity Reinsurance Adjustments and Ledger Maintenance Effective segregation of duties R FR Unauthorized adjustments are made to the financial ledger Segregation of duties between recording of financial transactions and processing of receipts. R Control Activity Reinsurance Adjustments and Ledger Maintenance Polices and procedures exist for processing journal entries. A, V FR Incorrect/ inconsistent treatment of manual adjustments between subledgers. A chart of accounts is maintained and updated on a timely basis, establishing procedures and account mappings for processing journal entries to subledgers A, V Control Activity Reinsurance Adjustments and Ledger Maintenance Subledger journal entries represent valid adjustments to the Company’s V FR Incorrect or fraudulent journal entries are recorded All journal vouchers are approved by management and attached to supporting documentation. V 16 Reinsurance—P&C financial records. Control Activity Reinsurance Adjustments and Ledger Maintenance Ceded premiums are only paid in respect of inforce policies written. C, V FR Reinsurance premiums continue to be paid in respect of cancelled policies. Ceded premiums payments are cancelled once the direct policy is cancelled. C, V Control Activity Reinsurance Adjustments and Ledger Maintenance Prevention or detection of incorrect entries to reinsurance data. C, A FR The financial subledgers do not accurately reflect current policy data, reinsurance terms and billings. The financial subledgers are reconciled to the underlying policy administration, actuarial and reinsurance systems. Reconciliations are reviewed and approved by financial management. C, A Control Activity Reinsurance Adjustments and Ledger Maintenance Subledgers are reconciled to the policy and claims administration systems. V FR Unreconciled suspense accounts are not cleared on a timely basis. Suspense accounts are reconciled and reviewed by an appropriate official to identify and clear unusual or aged balances. C, A Control Activity Reinsurance Adjustments and Ledger Maintenance Subledger journal entries are recorded on a timely basiis. A FR Ledger maintenance activities are recorded in the correct financial period. Manual adjustments are reviewed by an appropriate official to ensure they are accurately recorded in the financial period. A 17