Risk Nexus Long-term investments, risks and regulation: an insurance perspective November 2014 Contents 1.Introduction 1 2. 3 4 5 5 Insurers as long-term investors 2.1 Linking investments to liabilities 2.2In search of optimal long-term exposures 2.3Factors that might limit insurers’ long-term investments 3. Beyond long-term investments: the specific insurance perspective 4. The accounting and regulatory treatment of insurers’ long-term investments 4.1 Challenges associated with Solvency II 4.2Assessing the reform proposals… 4.2.1 …with respect to fair-value accounting… 4.2.2 …and with respect to capital requirements 7 9 10 12 12 14 5. Policy recommendations 5.1 Improve the stability of regulatory regimes and limit the scope for arbitrage 5.2Further deepen and strengthen the capital market 5.3Ensure a functioning insurance market 16 17 18 6.Conclusions 19 7. Appendix: Definitions and issues related to long-term investments 7.1 Definition of long-term investments 7.2 Definition of long-term funding 7.3 What challenges do long-term investors face? 7.3.1 Availability of savings 7.3.2 Transformation of savings into investments 7.3.3 Private sector incentives to invest in long-term assets 21 22 23 24 24 25 25 Cover: Investment in basic infrastructure will help to stimulate global economic growth. About Risk Nexus Risk Nexus is a series of reports and other communications about risk-related topics from Zurich. © Zurich Insurance Company Ltd. 2014. All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means without permission in writing from Zurich, except in the case of brief quotations in news articles, critical articles, or reviews. 15 1. Introduction The financial crisis that began in 2008, and the ensuing Great Recession, have weakened the fiscal position of many countries, induced financial institutions to deleverage their balance sheets and led to reduced bank lending. As a result, there has been an appreciable reduction in investment funding, in particular for long-term infrastructure investments. According to McKinsey,1 between 2013 and 2030 infrastructure investments of the order of USD 57 trillion or an equivalent to an annual 2.5 percent of global GDP will be needed – 60 percent more than in the previous 18 years. Given the public sector’s fiscal constraints and the reluctance of banks to commit to long-term investments (LTIs), it is not clear where the funding for these investments will come from. That’s why policymakers are interested in tapping new funding sources, with insurers and pension funds appearing to be the most likely candidates to fill the gap. No one would dispute that insurers, with assets of more than USD 24 trillion,2 have a significant capacity to engage in LTI funding. But there appear to be barriers to the contribution of insurers. Observers have deplored a lack of suitable funding vehicles with an acceptable risk/ return profile, and they have identified regulatory hurdles. Recent policy proposals aim therefore to make funding LTIs more attractive to insurers. They call specifically for adjustments to the accounting treatment of long-term assets and the risk weights relevant for solvency requirements, and they look for ways to overcome the pro-cyclical nature of accounting and regulatory rules. McKinsey (2013), ‘Infrastructure Productivity.’ (http://www.mckinsey.com/insights/engineering_ construction/infrastructure_productivity) 1 This paper takes a different tack. While acknowledging that insurers have been, and will continue to be, holders of infrastructure investments, it emphasizes the importance of maintaining appropriate risk-reward incentives when it comes to assessing the prospects of LTIs. It argues that the regulatory treatment of LTIs, as for example proposed under Solvency II, is by and large in line with the risks related to these investments. Setting low capital requirements for certain long-term assets would distort the economic risk-reward calculus of LTIs. Regulatory measures alone will not make LTI risks disappear, and they will likely backfire if risks that were downplayed artificially by regulatory fiat do, in fact, materialize. Moreover, politicallymotivated preferences for one specific class of investments over another may crowd out other investments with the potential to increase an economy’s productive capacity. This paper also emphasizes the dual role of insurers in support of LTIs. The focus on investment funding is only one side of the equation. The reduction to the funding contribution neglects the equally important economic role of insurers. By taking risk out of the entrepreneurial equation, insurance contributes – in often-unacknowledged ways – to the growth of businesses, and thus to the long-term prosperity of society as a whole. Insurance not only facilitates risk transfer by charging risk-sensitive premiums and therefore incentivizing rational risk-taking, it also serves as a mechanism to allocate scarce funds efficiently to the economy. If for no other reason than this specific economic role, we hope this study will foster a better understanding of how the insurance industry contributes to economic growth now and in the future. Our policy recommendations follow from the dual role of insurers. We acknowledge the need to better promote LTIs. But rather than focusing on the funding role of insurers and creating artificial regulatory incentives to promote this, policymakers should enable the industry to add value in a sustainable way. Measures could include the provision of a stable and consistent regulatory environment across the whole Raffaele Della Croce and Juan Yermo (2013), ‘Institutional Investors and Infrastructure Financing,’ OECD Working Papers on Finance, Insurance and Private Pensions No. 36, Paris. 2 Closing the long-term investment gap: the dual role of the insurance sector 1 financial sector, thus creating a level playing field for all LTI investors. They should further ensure that insurers can mitigate the economic, political and legal risks associated with LTIs by facilitating a fully functioning insurance market. This requires inter alia the acceptance of risk-based pricing and international risk diversification through access to reinsurance or other forms of cross-border capital pooling. This paper examines first in section 2 how insurers support LTIs by providing long-term funding, which is followed in section 3 by a discussion of the specific role insurers play in providing protection for these investments. Section 4 summarizes the accounting and regulatory treatment of long-term funding by insurers as well as current policy proposals to promote LTIs. In Section 5 we present policy recommendations. Section 6 offers concluding remarks. Readers interested in the specific nature of LTIs and their contribution to economic growth are referred to the appendix in section 7. This is a joint paper drafted by Zurich’s Government and Industry Affairs, Investment Management, and Group Risk Management. Contributors were Jérôme Berset (Head of Risk Governance and Reporting); Michael Christen (Strategy Development, Investment Management); Hansjörg Germann (Head of Strategy Development, Investment Management); Daniel M. Hofmann (Senior Advisor); Christian Hott (Economic Advisor, Government and Industry Affairs); Benno Keller (Head Research and Policy Development, Government and Industry Affairs); and Katja K. Müller (Risk Governance and Reporting Specialist). 2 Closing the long-term investment gap: the dual role of the insurance sector Section 2 Insurers as long-term investors Closing the long-term investment gap: the dual role of the insurance sector 3 2.1 Linking investments to liabilities Achieving the optimal balance between risk and return remains the key challenge in the insurance industry.” Insurers hold substantial assets to back their promises to policyholders. Globally, insurers have investable funds in excess of USD 24 trillion, of which roughly USD 20 trillion are with life insurers. Insurers hold reserves for two reasons: (i) in many lines of business, and especially in long-tailed liability insurance, the full amount of losses or claim payments becomes known only years after a loss event has occurred. To meet their obligations, insurers must hold assets that generate future cash flows sufficient to meet expected payouts to policyholders; (ii)in life insurance, savings product payouts are usually made many years after customers have paid premiums for these products. In addition to reserves that are needed to cover expected payouts, insurers have to hold sufficient equity capital and an adequately liquid investment portfolio to cover unexpected payouts. These unexpected payouts result from the fact that risk pooling is not always perfect and in some lines of business, losses can be large and unpredictable. The maturity of an insurer’s liabilities varies with its business model. The maturity may range from a few months for some ‘non-life’ or general insurance products (liability insurance is typically an exception) to 30 years or more for certain life insurance products. An insurer’s investment strategy needs to take not only the maturity but also the liquidity of liabilities into consideration. Due to the nature of their liabilities, life insurers in particular have a capacity to hold certain amounts of less liquid, longer-term assets. They are thus seen to be in a much better position than banks to provide long-term funding for infrastructure projects and other LTIs. 4 Closing the long-term investment gap: the dual role of the insurance sector However, insurers need to be careful not to hold an excessive amount of less-liquid assets: in times of crisis, such assets may need to be sold at large discounts to find buyers. Less-liquid asset holdings on the balance sheet of an insurer that exceed the true amount of long-term liabilities can therefore create ‘price discount risk’ or ‘haircut risk,’ which would require insurers to hold additional capital. If the amount of investments in an insurer’s less-liquid assets does not exceed this type of capacity constraint, the liquidity risk is largely mitigated: The long duration of liabilities enables the insurer to hold investments through a cycle without facing a forced sale at discount prices (fire sale). This promotes stability in financial markets, something often observed in previous crises. For example, when the financial crisis erupted in 2008, banks in particular were forced to sell risky assets at large losses to mitigate the threat of insolvency, while other investors – especially insurers – with sufficient capital, appropriate risk management practices and no appreciable asset-liability mismatches, were able to withstand the downturn, hold on and benefit when markets recovered. One key point is that insurers’ investment strategies differ in significant ways from those pursued by asset managers. Insurers strive to manage potential asset-liability mismatches and ensure that mismatches do not endanger the company or risk their ability to make good on promises to policyholders, while at the same time maximizing the expected return spreads between assets and liabilities. By contrast, asset managers often seek to achieve superior investment returns relative to agreed benchmarks, such as equity or bond market indices. Insurers’ investment strategies must meet two objectives: They must allow insurers to hold a sufficient amount of assets traded in liquid markets to cover not only expected payouts but also unexpected larger payouts; and they must provide sufficient equity capital to absorb adverse results from asset-liability mismatches. It follows that insurers wishing to hold riskier assets must also hold more lossabsorbing capital. That is the only way to ensure that obligations to policyholders will continue to be honored if these assets lose value relative to an insurer’s liabilities. 2.2 In search of optimal long-term exposures Achieving the optimal balance between risk and return remains the key challenge in the insurance industry. Seeking higher returns has a downside, however: capital markets will only offer a higher expected return when higher risks are included in the equation. Assets that are not traded in liquid markets tend to benefit from a liquidity risk premium. Liquidity risk in this context is defined as the potential loss on assets that have to be sold at a discount in order to meet liability outflows (forced sales or fire sales). The liquidity premium has a term structure. Longer-term investments need to offer higher returns and are optimal assets to match long-dated liabilities. The ability and willingness to seek returns and tolerate the resulting risks varies from investor to investor. The funding provided by an insurer’s liabilities must be understood before investing in less-liquid assets. Assessing the optimal exposure to these types of assets requires a structured process. Insurers differ from banks in that while banks are typically funded with shortterm wholesale borrowing and deposits that are callable on demand, insurers – even in economic downturns – are funded by stable premium flows. It is nevertheless crucial that insurers diligently monitor their capacity to invest in less-liquid assets as an integral part of their asset-liability management. This capacity is primarily dependent on the ‘stickiness’ of the liabilities, i.e., the availability of continued access to funding in liquidity crises. Investment and actuarial functions must work together to determine the insurer’s capacity to invest in less-liquid assets, comparing the liquidity profile of assets against the liquidity profile of liabilities for many years into the future. The matching principle is the defining characteristic of the insurance sector’s investment behavior. This liability-driven investment approach differs in significant ways from the conservative buy-and-hold strategy that often – and somewhat erroneously – is typically associated with insurers. 2.3 Factors that might limit insurers’ long-term investments A number of impediments could limit an insurer’s appetite for infrastructure investments. Three of the more prominent are: • Lack of expertise. Risks associated with infrastructure projects are varied and may well exceed conventional expertise. Specifically, these risks may include failures in construction and technical design, and lack of comprehensive and reliable performance data about infrastructure investments, a point that the European Insurance and Occupational Pensions Authority (EIOPA) also made in its analysis of certain long-term investments.3 • Unstable cash flows. To match their long-term liabilities, insurers prefer predictable and stable cash flows. Greenfield projects, which comprise more than two-thirds of all infrastructure investments and carry a considerable construction risk, may not meet this requirement. Moreover, project loans are typically not traded in secondary markets, a characteristic that may conflict with an insurer’s liquidity preference. See EIOPA (2013), ‘Discussion Paper on Standard Formula Design and Calibration for Certain Long-Term Investments.’ 3 Closing the long-term investment gap: the dual role of the insurance sector 5 • Regulatory and legal uncertainty. Given the long tenor of infrastructure investments, the political environment in which a project loan is signed off may change repeatedly over time, adding a considerable degree of regulatory and legal risk. This point is illustrated by the Norwegian government’s recent decision to reduce gas pipeline tariffs, a measure that is likely to have an impact on the expected cash flows of pipeline investments. These reservations notwithstanding, what counts in the end is a comprehensive view of the investment process and how it is embedded in the asset-liability management process. This consideration is also reflected in rating agencies’ commentaries. According to a recent paper by Standard & Poor’s (S&P), Standard & Poor’s Ratings Services (2014), ‘Investing in Infrastructure: Are Insurers Ready to Fill the Funding Gap?’ 4 6 Closing the long-term investment gap: the dual role of the insurance sector an insurer’s investments in infrastructure would be assessed on how those investments affect “its capital and earnings and the quality, diversification and liquidity of its investment portfolio. We (S&P) also assess how these investments affect the insurer’s asset and liability management, investment and overall risk tolerances, and ability to operate within clear limits, supported by effective control systems.”4 In light of such a comprehensive assessment, and in considerable contrast to what many believe, S&P analysts conclude that “infrastructure development can potentially meet insurers’ appetite for long-tenor, higher-yielding assets that provide a good match with their longterm illiquid liabilities.” Section 3 Beyond long-term investments: the specific insurance perspective Closing the long-term investment gap: the dual role of the insurance sector 7 There is considerable potential to enhance the role of insurance in enabling LTIs, particularly in emerging economies.” A central function of insurance is to protect against the financial consequences of adverse events. By providing such protection, insurers make investments more attractive to risk-averse investors and therefore enable investments, which in turn enhance the productive capacity of entrepreneurs and thus the growth potential of the entire economy.5 private sector, for which insurance is even more important, is likely to increase its share of total infrastructure investments. As, on a global level, only about a third of all losses from natural disasters are insured (and in emerging economies only 10 to 20 percent), there is considerable potential to enhance the role of insurance in enabling LTIs, particularly in emerging economies. Insurance can also be seen as a form of contingent capital: The insured pays a premium today to receive cash (or capital) later in compensation for the financial consequences of a pre-defined adverse event. Because the risk is passed to the insurer, the customer does not actually have to hold capital to absorb the financial loss caused by an adverse event.6 This contingent capital has two interesting features: it becomes capital only after an idiosyncratic (or insured) event and, unlike bank credit or access to the capital market, it is available independent of economic and financial cycles. This makes the availability of contingent capital provided by an insurance contract wholly independent of other sources of capital. To facilitate the beneficial role of insurance, it is important to allow insurers to charge risk-sensitive prices or rates. Risk-sensitive (or risk-commensurate) rates serve a number of purposes. They are instrumental for reducing, if not eliminating, the problem of adverse selection.10 By assigning a price to risk, insurance also provides an economic incentive to appropriately manage the trade-off between risk and return, and avoid or reduce excessive risk-taking activities. In addition, riskcommensurate rates (in other words rates that are not politically prescribed) enable an appropriate return to be generated on the equity capital allocated to insurance, thus preventing economically inefficient or wasteful allocation of capital. In meeting these three objectives, private insurance based on risk-commensurate rates plays an important and often under-appreciated economic role. Yet many countries limit insurers’ freedom to charge risk-sensitive rates, particularly for risks covered by flood insurance. In 2012, property insurance globally covered losses in excess of USD 200 billion.7 Of this total, USD 81 billion covered natural catastrophes and man-made disasters.8 Thus, insurance coverage made a substantial contribution to taking idiosyncratic risks out of LTIs. The importance of this contribution is likely to grow in future as economic losses caused by natural catastrophes are expected to increase. See also Zurich Government and Industry Affairs (2012), ‘The Social and Economic Value of Insurance: A Primer.’ https:// www.zurich.com/internet/main/SiteCollectionDocuments/ insight/social-and-economic-value.pdf. 5 See also Shimpi, P. (2004), ‘Leverage and the Cost of Capital in the Insurative Model.’ Mimeo. 6 7 Source: Axco Global Statistics Source: SwissRe (2014)‚ ‘Natural catastrophes and man-made disasters in 2013,’ sigma 1. 8 See von Peter, G., S. von Dahlen, and S. Saxena (2012‚ Unmitigated disasters? New evidence on the macroeconomic cost of natural catastrophes,’ BIS Working Papers No 394. See also Geneva Association (2013), ‘Insurers’ contributions to disaster reduction – a series of case studies.’ 9 10 Adverse selection may result because information (about a pre-existing condition, for example) is known only to the insured (asymmetric information) or because regulation prevents the insurer from charging an appropriate, risk-commensurate rate (regulatory adverse selection). Insurance can significantly reduce the long-term macroeconomic consequences of disasters by supporting necessary investments and financing reconstruction in the wake of natural catastrophes.9 In a more recent development, insurers and reinsurers have also begun to provide catastrophe coverage for emerging market governments. This allows these governments to react quickly to catastrophes. Governments that would otherwise struggle to raise sufficient funds can provide relief to victims and fund reconstruction. In the future, the Examples are Argentina and Brazil, but also the Neal Bill in the United States. 11 8 Closing the long-term investment gap: the dual role of the insurance sector Insuring large-scale risks of the kind associated with infrastructure or caused by natural catastrophes requires international risk diversification, access to reinsurance and a global capital market. On a national or regional level, losses arising from these risks occur too infrequently to make them suitable for pooling. To some extent, only large and internationally-diversified insurers and reinsurers are in a position to provide protection for such large-scale risks that escape pooling. However, a number of countries have recently introduced barriers to international re-insurance of such risks, making protection potentially more costly or putting it entirely out of reach of domestic policyholders.11 Section 4 The accounting and regulatory treatment of insurers’ long-term investments Closing the long-term investment gap: the dual role of the insurance sector 9 Solvency II is likely to create a number of challenges for insurers, particularly with regard to investments in long-term assets.” Ever since G20 leaders stated that “long term financing for investment, including infrastructure, is a key contributor to economic growth and job creation in all countries”12, accounting and regulatory treatment of long-term investments has been very high on the political agenda and has influenced discussions with accounting standard setters and prudential regulators. Regulations will soon be introduced in the European Union (EU) which, according to critics, could induce institutional investors to at least partially retreat from long-term investments and, in most cases, less-liquid segments of the credit market. Implicit in these concerns is the view that the proposed changes do not adequately take into account insurers’ ability to ride out short-term market volatility.13 4.1 Challenges associated with Solvency II See G20 Finance Ministers’ Communique, Moscow 2013 (https://www.g20.org/sites/default/files/g20_resources/ library/Final_Communique_FM_July_ENG.pdf). 12 Representative for such views is a report by the World Economic Forum (2011), ‘The Future of Long-term Investing,’ Geneva: World Economic Forum. 13 14 Solvency II is only one variant of risk-based insurance regulations. In 2011, Switzerland introduced its version, known as Swiss Solvency Test (SST), which in large parts anticipates, and corresponds with, the solvency regime to become effective in the EU in 2016. In the interest of brevity, this text refers to Solvency II in a generic manner, as a proxy for all risk-based regulatory regimes. Solvency II will soon be at the heart of the new European prudential regulatory framework for insurance companies.14 In a notable departure from the current Solvency I framework, the amount of capital that insurers are required to hold in the future will no longer be determined solely by the volume of premiums, but rather on the risks insurers assume through their underwriting and investment activities. The new regime has thus been accurately described as an economic risk-based system of financial regulation. Its salient features are the integrated and consistent view of risks associated not only with the liability side of the insurance balance sheet, but also with the asset side and the mark-to-market valuation of the entire balance sheet. The greater the risks associated with assets and liabilities and the mismatch between them, the more capital must be available on the insurer’s balance sheet to carry those risks. The new regime also promises to abolish quantitative restrictions on specific asset classes, as is the case under Solvency I.15 Under Solvency I there are no specific capital requirements on investments, instead the regime imposes asset admissibility limits. 15 10 Closing the long-term investment gap: the dual role of the insurance sector Although the comprehensive risk-based framework and an end to restrictions on investment are significant improvements over Solvency I, as well as other statutory frameworks, Solvency II is likely to create a number of challenges for insurers, particularly with regard to investments in long-term assets. The three main concerns typically raised in this debate relate to (i) the valuation of assets and liabilities under the fair value or mark-to-market accounting principles introduced with the new regime; (ii) the calibration of risk models, and specifically the risk weights assigned to various asset classes; and (iii) the pro-cyclicality introduced by the capital requirements and fair value principles. These three challenges can be summarized as follows: • Fair value, or mark-to-market accounting principles, will be the basis for the valuation of insurance balance sheets under Solvency II. As long as there are liquid markets that allow for transparent and homogenous price-building, an asset’s fair value is given by its market price. If this does not apply – as can be the case for long-term investments (such as infrastructure) for which there is no liquid market – the valuation must build on models that include market information deemed to be as relevant as possible. While these principles are readily understood, in practice their implementation is fraught with obstacles. Changes in risk assessment and/or observable market information (e.g., interest rates) may have a much greater impact on the values of longterm assets than on short-term assets. Additionally, given the heterogeneity and low liquidity of many LTI markets, valuation models must rely on very limited data. As a result, the valuation of long-term investments is associated with a considerable degree of uncertainty. Treatment of long-term assets and corresponding capital requirements under Solvency II In a manner similar to the framework governing banking regulation (as codified in Basel II and Basel III), Solvency II consists of three pillars, with capital requirements in Pillar 1. There are no specific capital requirements tailored to infrastructure investments. Insurance companies, like banks, can choose to either calculate the required solvency capital and minimum capital by applying a standard formula, or by using an approved internal model. Either way, the calculations are based on a broadly economic total balance sheet approach; fair values are the starting point for the valuation of the balance sheet. Only through the use of an internal model can a company capture the specific risks of long-term investments; calibration must be backed up with appropriate statistics and validated. Under the current version of the standard formula, investments in long-term assets are not specifically segregated as a specific risk module. Investments in infrastructure would be captured in different ways, depending on the type of investment: • Infrastructure project equity: Investments in project equity are captured by the equity risk sub-module of the standard formula and due to their characteristics are most likely to be classified as ‘type 2 equity.’ This implies calculating the required capital based on a 49-percent shock, plus or minus any ‘symmetric’ adjustments. A symmetric adjustment that reduces the capital requirements after a market crash by up to 10 percentage points is designed to mitigate unwanted pro-cyclicality. • Project bonds: Project bonds will be treated under the bond sub-category of the spread risk sub-module in the standard formula. The calibration according to the duration is not linear, resulting in incentives for investing in longer-term project bonds. • Project loans: Loans are subject to the same capital requirements as bonds. Hence, the risk charge is dependent on the duration as well as the external rating of the instrument. • Infrastructure investment funds – listed and unlisted funds: Assuming the relevant information is available, the look-through principle would apply when evaluating the capital requirements for listed infrastructure investment funds. This means that the risk charges would be the same as those that would be applied if the insurance company had invested directly in the underlying asset. Risk-based frameworks for determining capital requirements make the link between the risks on an insurer’s balance sheet and the amount of capital it must hold. As individual asset classes carry different risks, capital requirements (or risk weights) are adjusted accordingly. In each asset class, weights increase with increasing duration, and the question arises whether the risk weights used in the standard formula adequately reflect the characteristics of LTIs. Consequently, if not appropriately compensated with higher returns, the capital requirements on long-term investments are perceived as burdensome, making the investments less attractive relative to investments in the same asset class that have shorter durations. Given this line of reasoning, capital requirements proposed under the Solvency II standard formula would likely deter insurers from financing LTIs. On the other hand, Solvency II requires and rewards sound asset-liability management, which will motivate insurers to invest in longterm assets that match the corresponding liability profile. Closing the long-term investment gap: the dual role of the insurance sector 11 Fair-value accounting principles and the capital requirements proposed under Solvency II are perceived to lead to ‘pro-cyclical’ investment behavior. Capital requirements that are largely independent of market cycles could potentially trigger such behavior, leading insurers to buy assets in market upswings and sell assets during downturns. Such behavior could amplify market cycles and contribute to financial instability. In other words, the proposed regime could impair the insurance sector’s ability to ride out market volatility. 4.2 Assessing the reform proposals… Given the economic importance attributed to LTIs, policymakers and other stakeholders have advanced a number of proposals to mitigate some of the challenges discussed in the previous section.16 Examples include (i) matching and volatility-adjustment mechanisms, (ii) changes to the extrapolation methodology used to determine the adjustment speed to the very long-term discount rate (the ultimate forward rate, ‘UFR’), and (iii) counter-cyclical premiums (CCP). In late 2013, EU policymakers agreed on pragmatic modifications to the proposed Solvency II regime, including a more detailed treatment of securitized instruments and a 16-year transition period for the valuation of insurance liabilities. At the same time, the EIOPA refused to grant specific exemptions that would favor infrastructure investments on the grounds that this body lacks “comprehensive, reliable and publicly available performance data” to justify lower capital requirements.17 16 The European Commission’s (2013) ‘Green Paper Long-Term Financing of the European Economy,’ explicitly asks, for example, “To what extent do you consider that the use of fair value accounting principles has led to short-termism in investor behaviour? What alternatives or other ways to compensate for such effects could be suggested?” EIOPA (2013), ‘Discussion Paper on Standard Formula Design and Calibration for Certain Long-Term Investments’ and EIOPA’s letter to the European Commission on this issue; available at https://eiopa.europa.eu/en/consultations/ consultation-papers/2013-closed-consultations/april-2013/ discussion-paper-on-standard-formula-design-andcalibration-for-certain-long-term-investments/index.html. 17 12 In principle, all of the proposals advanced so far endeavor to take the bite out of fair value accounting principles and capital requirements that are seen by some to be incompatible with the business model of insurers and specifically with the long-term nature of many insurance investments. One could indeed argue that fair value is not always the same as the investment value, i.e., the subjective value an investor may attribute to a certain asset. In particular, Closing the long-term investment gap: the dual role of the insurance sector investors with longer time horizons may value an asset based on the discounted value of cash flows through to maturity and, for a bond, its redemption value. Both cash flows through to maturity and the redemption value in the distant future may not be affected even during times of market stress, when the fair value of an asset can fall significantly below its investment value as liquidity risk premiums increase. Even though insurers are able to hold assets, including less-liquid assets, through severe market dislocations, the potentially significant discrepancies between fair value and investment value still need to be reconciled. One way to address the diverging valuation metrics during crises could be to adjust the discount rate applied to the value of liabilities by an appropriate liquidity premium calibrated to the liquidity premiums observed in the financial markets. 4.2.1 …with respect to fair-value accounting… Given the economic importance of LTIs, policymakers and academics are seeking to address these issues and to facilitate conditions for insurers to provide longterm funding. The current low-yield environment combined with substantial market uncertainties can be especially challenging for certain insurers. A number of proposals have been made to better deal with this situation. Examples include matching and volatility adjustment mechanisms to the relevant risk-free interest rates used to value an insurer’s liabilities. Another example is an extrapolation mechanism for the UFR to contain the so-called ‘artificial volatility’ embedded in the fair-value principles for long-term liabilities. But these mechanisms would only buy time. If the environment does not improve in due course, economic losses would eventually be revealed. Such mechanisms are implicitly linked to expectations that governments would step in if the environment deteriorates or losses are realized at policyholders’ expense (through reduced benefits). Recent empirical studies have documented the ability of fair value to predict failure due to poor asset and credit quality.” CFA Institute (2013), ‘Fair Value Accounting and Longterm Investing in Europe: Investor Perspective and Policy Implications.’ The CFA Institute represents nearly 110,000 chartered financial analysts and 138 member societies. The study is available at: http://www.cfainstitute.org/ ethics/Documents/fair_value_and_long_term_investing_ in_europe.pdf. 18 Blankespoor, E., T. J. Linsmeier, K. R. Petroni, and C. Shakespeare (2012), ‘Fair Value Accounting for Financial Instruments: Does It Improve the Association Between Bank Leverage and Credit Risk?’ The Accounting Review, Vol. 88 (4), pp. 1143-1177. 19 20 The crisis literature is, by default, focused on the banking sector since few insurance groups failed during the recent financial crisis. The notable exception was, of course, one large American insurance group, with a substantial financial market division. While no one claims that the fair-value approach provides a perfect outcome when applied to accounting and reporting, critics tend to downplay the important arguments in support of fair-value principles. The following summarizes four insights published in a recent study by the CFA Institute:18 • Fair value is an indispensable signaling device; it provides the foundation for the purchase, sale and holding of financial assets, and it is an early warning indicator of financial trouble. The financial crisis has underscored the importance of always having an up-to-date view of the true value of the assets and liabilities underlying an economic transaction. As the CFA Institute notes, “The absence of such information simply leads to moral hazard by originators of securities and sub-optimal allocation of capital by investors.” Moreover, recent empirical studies have documented the ability of fair value to predict failure due to poor asset and credit quality. Blankespoor et al (2013) found that “both two and three years prior to failure, fair-value leverage dominates the other two leverage measures in predicting failure,” which in their view “… demonstrates that leverage based on fair value provides the earliest signal of financial trouble.”19 • Fair value reduces agency conflicts. Inherent in many investment decisions are conflicts between principals (or investors) and agents (management). Under conventional cost accounting, management has considerable leeway in the recognition of gains and losses. This can drive a wedge between the reported value of assets and their fair value, providing a short-term incentive for management to inflate reported gains and thus inflate its own bonuses and incentive payments. Fair value will reduce such information asymmetry and take out the short-termism often associated with cost accounting. • The validity of fair value is independent of the investment horizon. Both shortterm and long-term investors must continually reassess the quality of their holdings. This implies that the “relevance of fair value information does not change with the holding period of financial instruments.” Holding periods may be subject to (i) changes in economic conditions or (ii) abrupt and unforeseeable structural breaks. In both cases, fair value will provide relevant information when it comes to deciding whether to either hold or shed an investment. In light of these considerations, policymakers would be ill-advised to endorse the ‘business-model-based’ accounting schemes, despite occasional demands for such an approach among LTIs’ stakeholder groups. Long-term investors are no different from other investors. They, too, must continually monitor the value of their investments, even when they choose to hold their assets for very long periods. • Concerns that fair value increases pro-cyclical investment behavior are likely exaggerated. There appears to be little empirical evidence to support the fear that requiring financial institutions to write down their assets to depressed market values could trigger fire sales, turning what might have been a modest market setback into a full-fledged implosion.20 In fact, one study found no “clear link between fair value accounting, regulatory capital rules, pro-cyclicality and financial contagion” among U.S. banks at the time of the recent financial crisis. It concluded that there must have been other, more significant factors, putting stress on bank regulatory capital.21 Moreover, as the CFA study points out, a number of German institutions that failed or were bailed out at that time had not applied fair-value accounting on financial instruments prior to the financial crisis. Shaffer, S. (2010), ‘Fair Value Measurement: Villain or Innocent Victim? Exploring the Links between Fair Value Accounting, Bank Regulatory Capital and the Recent Financial Crisis. Federal Reserve Bank of Boston,’ Working Paper No. QAU10-01, available at http://www.bostonfed.org/bankinfo/ qau/wp/2010/qau1001.htm. 21 Closing the long-term investment gap: the dual role of the insurance sector 13 In light of these considerations, it is fair to conclude that mark-to-market accounting and reporting principles are better than their reputation would suggest, and that it would be unwise to weaken them in the alleged interests of long-term investor concerns. During the recent crisis, financial institutions did not fail because fair-value accounting forced them to reveal unsustainable asset positions. They failed because they mismanaged a toxic brew of risk, leverage and opacity. That said, it is important to acknowledge that fair value – although it provides a very important set of information – will provide only one set of information for the valuation of assets and liabilities. In order to provide transparency and make sound decisions, there is scope to augment this information using other accounting principles as reference point. To create an environment that is favorable to long-term investments, policymakers’ objective should be to promote disclosure of the valuation models used, and the level of uncertainty embedded in the valuations, rather than seek to rig or skew accounting rules. 4.2.2 …and with respect to capital requirements Considered in isolation, the capital adequacy requirements for different asset classes imposed by Solvency II appear to be considerable, particularly when compared with the non-differentiating regime of Solvency I. However, the conclusion that Solvency II’s capital requirements would be punitive with respect to long-term investments does not necessarily follow. 22 Laas, D. and Siegel, C. (2013), ‘Basel Accords versus Sovlency Solvency II: Regulatory Adequacy and Consistency under the Postcrisis Capital Standards,‘ Working Paper, Universität St. Gallen. 14 Closing the long-term investment gap: the dual role of the insurance sector Setting the right risk weights for capital regulation is a challenging exercise, especially when it comes to illiquid and heterogeneous assets, including many long-term investments. Further research is needed to assess and measure the interaction between the opportunities related to the investment in LTIs and the corresponding risks. This is especially important because risk weights have the potential to have a direct impact on asset allocation.22 Providing artificial incentives to encourage investments in specific types of assets, however, may lead to bubbles that increase risk, thus threatening market stability. Investors will only be in a position to make sound (risk-based) investment decisions and evaluate whether expected yields are proportionate to the risk if true economic and risk-based capital requirements are used. Besides taking the risk weights for long-term assets into consideration, it is important to note that (i) insurance investments are to a large extent liability-driven, (ii) insurers will always seek to optimize the risk-return profile of the investment portfolio, and that (iii) diversification may significantly lower the capital requirements of a well-balanced portfolio. This leaves room for engagements in a broad portfolio of assets, including infrastructure investments, so long as the risks are commensurate with expected returns, and providing the risky assets are part of a diversified portfolio. Section 5 Policy recommendations Closing the long-term investment gap: the dual role of the insurance sector 15 Each new regulatory initiative gives rise to another set of challenges with additional costs and potentially unintended consequences.” Although the EIOPA has thus far refrained from granting regulatory relief for infrastructure investments, it is fair to assume that EU policymakers will continue to look to insurers to fill the LTI funding gap. They are likely to exert pressure on regulators to relax regulatory requirements for these activities. It is hardly surprising that parts of the industry welcome these political pressures, as evidenced by a number of proposals for regulatory adjustments that would make funding of infrastructure investments more attractive. However, any attempt to adjust current and proposed regulation should take at least two fundamental guiding principles into account: Regulation should not distort incentives and therefore should not interfere with an efficient allocation of financial resources; and capital adequacy requirements must reflect a comprehensive view of the risks on the insurance balance sheet to promote a sustainable and stable insurance business. With these principles in mind, we offer our policy proposals relating to (i) regulation and accounting; (ii) the governance of the European capital market; and (iii) the functioning of the insurance market. 5.1 Improve the stability of regulatory regimes and limit the scope for arbitrage • Maintain fair-value valuation, as it provides the necessary transparency for insurers to make appropriate decisions. Introducing matching adjustments or an extrapolation mechanism would only temporarily hide losses and could distort markets. Instead, insurers should remain transparent about their valuation model and the level of uncertainty embedded in the valuation. 23 Centre for the Study of Financial Innovation (2013), ‘Insurance Banana Skins 2013 – The CSFI survey of the risks facing insurers.’ • Capital requirements must capture all underlying risks. In particular, they should avoid setting artificial incentives 24 Swiss Re (2013), ‘Strengthening the role of longterm investors.’ Laas, D. and Siegel, C. (2013), ‘Basel Accords versus Solvency II: Regulatory Adequacy and Consistency under the Postcrisis Capital Standards,’ Working Paper, University of St. Gallen. 25 26 Basel Committee on Banking Supervision (2010), ‘Review of the Differentiated Nature and Scope of Financial Regulation, Key Issues and Recommendations.’ Basel: Bank for International Settlements. 16 Closing the long-term investment gap: the dual role of the insurance sector to promote investments in specific asset classes. Only truly risk-based capital requirements will provide incentives to investors to make risk-based investment decisions that are in line with appropriate risk-reward considerations. • Ensure a stable regulatory environment. The stability of regulatory and legal frameworks has a significant impact on the insurance industry because of its long-term time horizon. In addition to creating compliance burdens, each new regulatory initiative gives rise to another set of challenges with additional costs and potentially unintended consequences.23 With respect to investment strategies, regulatory reforms may already have resulted in unwanted shifts in the global asset allocation of insurance investment portfolios.24 • Establish a consistent regulatory framework across the whole financial sector. When investing in the same asset classes, the same types and amounts of risk have to be assigned equivalent capital charges, regardless of the type of financial institution, in order to maintain a level playing field within the insurance industry and across the financial sector.25 The Basel Committee on Banking Supervision recommends that the banking, securities and insurance sectors “work together to develop common cross-sectional standards where appropriate so that similar rules and standards are applied to similar activities, thereby reducing opportunities for regulatory arbitrage and contributing to a more stable financial system.”26 It goes without saying that this should also include pension funds. Without a strong joint effort by regulators, standard setters and industry participants, opportunities for regulatory arbitrage will remain, with negative consequences for the risk profile of the whole financial sector. 5.2 Further deepen and strengthen the capital market • Complete the European capital market. While insurers are well-positioned to provide long-term LTI funding, the availability of appropriate funding vehicles continues to be a hurdle. Deepening and completing the European capital markets would address these challenges. One way to facilitate the provision of long-term finance by insurers is to increase the share of bond issues, especially by corporates. To improve financing for SMEs, banks could securitize loans and sell them on the market.27 As the financial crisis revealed, this could result in principalagent problems, which in turn could adversely affect the quality of the securitized loans. Encouraging covered bond issues, or requiring the bond originator to hold equity tranches, could mitigate this problem. Defining new guidelines and structures, as well as standards for the rating of financing vehicles,28 are additional measures that are worthy of consideration. • Complete the longer end of the bond market by issuing more long-term government bonds. As part of broadening the European bond market, governments should start issuing more long-dated bonds. This would allow insurers to better match (‘unrewarded’) asset-liability interest rate risk exposure and free up capital for (‘rewarded’) risk-taking, such as risks associated with long-term infrastructure investments. • Strengthen insurers’ expertise in infrastructure investments. Historically dominated by banks, infrastructure debt markets are now opening to institutional investors. They see these assets as an opportunity to diversify away from government and covered bonds. But professionalism and experience are key factors for an appropriate understanding of infrastructure investments. As most insurers have neither the scale nor the skill to be professional and experienced infrastructure investors, the use of third-party specialist asset managers will likely be essential for insurers. • Further promote retirement savings. In macroeconomic terms, the lack of savings may constrain investments. Since the flow of savings may be limited in the future for a number of reasons (see also page 25), European governments may wish to encourage individuals and households to increase their savings. To meet this objective, measures could include compulsory auto-enrolled savings programs to fund future retirement income.29 • Provide a stable macroeconomic, political and regulatory environment. All investments – long-term investments in particular – are prone to risks arising from changes in the macroeconomic, regulatory and legal environment. Inflation erodes the confidence of savers and creditors, while rapidly increasing government debt may call the stability of current tax regimes into question. These factors add considerable uncertainty and can discourage investors. A stable macroeconomic environment, long-term price stability and balanced budgets will go a long way towards supporting a favorable environment for investment. Economic stability is also likely to promote a stable regulatory and legal environment, which is instrumental in maintaining both investor confidence and the insurance industry’s ability to offer long-term risk protection. In this context we refer to the recent joint proposal by the Bank of England and the European Central Bank on how to reform the impaired securitization market in Europe. The joint paper is available at https://www.ecb.europa.eu/pub/pdf/ other/ecb-boe_impaired_eu_securitisation_marketen.pdf. 27 28 See also Group of Thirty (2013), ‘Long-term Finance and Economic Growth.’ 29 See also Group of Thirty (2013), ‘Long-term Finance and Economic Growth.’ Closing the long-term investment gap: the dual role of the insurance sector 17 5.3 Ensure a functioning insurance market Risks associated with infrastructure investments are likely to be large scale and highly concentrated.” To fill the long-term investment gap, it is important to address all challenges. There is no point in promoting long-term investment funding if businesses continue to face unmitigated economic, political and legal risks because they cannot access insurance services that would allow them to manage these risks, or at least reduce their financial consequences. Ensuring a functioning insurance market requires that at least two principles be upheld: • Insurance must reflect risks. Risk-sensitive prices help insurers to address the problem of ‘adverse selection.’ They provide an economic incentive to reduce risk-taking activities and promote an economically-efficient 18 Closing the long-term investment gap: the dual role of the insurance sector allocation of capital. In meeting these objectives, private insurance based on prices commensurate with risk fills an important economic role. • Risk diversification should not be constrained. Risks associated with infrastructure investments are likely to be large scale and highly concentrated. Losses arising from them occur too infrequently to allow for an efficient pooling of risk; mitigation through international risk diversification and access to reinsurance will be essential. Policymakers should therefore allow for international risk diversification and refrain from artificially constraining access to reinsurance or other forms of cross-border capital pooling. Section 6 Conclusions Closing the long-term investment gap: the dual role of the insurance sector 19 The current post-crisis environment of sub-par growth in many corners of the global economy provides a strong case for the promotion of LTIs. And in light of the huge need in particular for infrastructure investments, stimulating LTIs is a sound policy lever to support growth. However, there appears to be a funding gap, given the constrained conditions of public finances and the banking sector’s understandable reluctance to engage more actively in long-term lending. Insurers are prepared to close at least part of this LTI funding gap. Given the stable long-term nature of their liabilities, they have the capacity to hold risky and less liquid long-term assets. However, it is important that insurers fill this role in a prudent and sustainable way. An exclusive focus on the funding side of LTIs is incomplete. It neglects the reality that insurers have a dual role to play when it comes to supporting LTIs. Equally important is the industry’s capacity to absorb risks, thereby facilitating the growth of businesses and thus the long-term prosperity of society as a whole. For that reason, strengthening the insurance sector’s core function – risk transfer – should be high on policymakers’ agendas – also in the interest of promoting LTIs. 20 Closing the long-term investment gap: the dual role of the insurance sector A strong risk-based regulatory framework contributes to a stable insurance sector and increases trust in insurance products. It is important that regulation does not hinder the beneficial contribution of insurers, for example, by hampering international risk diversification. Such diversification is essential for insuring large-scale risks, such as infrastructure projects, or providing coverage to protect against natural catastrophes. However, regulation should also avoid using the insurance industry to support often parochial political objectives. Insurers are not risk-absorbers of the last resort and their balance sheets should not be deployed to correct policy mistakes or make up for regulatory inconsistencies. Accounting rules and capital adequacy requirements that do not properly reflect risks can lead to serious market distortions and possibly even sow the seeds of the next crisis. In order to support long-term investments, policymakers would be well advised to promote a functioning market for insurance services, rather than encouraging institutional investors to take risks by selectively changing the incentives for holding long-term assets. Section 7 Appendix: Definitions and issues related to long-term investments Closing the long-term investment gap: the dual role of the insurance sector 21 7.1 Definition of long-term investments LTIs are commonly defined as investments in productive assets that have a long life span.30 LTIs enhance the productive capacity of individual enterprises and the entire economy over the long term, providing a foundation for sustainable growth and employment. ‘Long-term’ in this case has no commonly-agreed definition but, as the Financial Stability Board (2013) states, the life span of LTIs is usually assumed to be longer than a business cycle. On a global level, LTIs fluctuate over time between 25 percent and 30 percent of gross domestic product (GDP).31 Based on IMF global output projections, this implies that annual LTIs should be between USD 24 trillion and USD 29 trillion by 2018. But there are substantial differences between countries, depending on the economic growth trajectory and the capital intensity of production. China, for example, invests more than 50 percent of its GDP in long-term assets, in particular in real estate, equipment and infrastructure. By contrast, in advanced economies, investments in infrastructure are comparatively small; in these countries, equipment and software, and education account for the largest portion of LTIs (see Chart 1). Chart 1: Long-term investments in percent of GDP 60 Residential real estate CRE and other structures 50 Infrastructure Equipment and software 40 Education R&D 30 20 10 0 USA GBR GER FRA JPN CHN IND BRA MEX Data from 2011 and 2010. Source: Group of Thirty (2012) LTIs are mainly carried out by corporations (e.g., equipment and R&D), governments (e.g., infrastructure and education) and households (e.g., residential real estate). In most countries corporations are the largest contributors (about 45 percent of all LTIs), especially when it comes to funds for equipment and software, as well as commercial real estate.32 30 See, for example, European Commission (2013), ‘Green Paper – Long-Term Financing of the European Economy’ (http://eur-lex.europa.eu/resource.html?uri=cellar:9df9914f6c89-48da-9c53-d9d6be7099fb.0009.03/ DOC_1&format=PDF); Financial Stability Board (2013), ‘Financial regulatory factors affecting the availability of long-term investment finance’ (http://www. financialstabilityboard.org/publications/r_130216a.pdf); and Group of Thirty (2013), ‘Long-term Finance and Economic Growth.’ (http://www.group30.org/images/PDF/ Long-term_Finance_lo-res.pdf) 31 Source: Group of Thirty (2013), ‘Long-term Finance and Economic Growth.’ 32 Source: Group of Thirty (2013), ‘Long-term Finance and Economic Growth.’ 22 Closing the long-term investment gap: the dual role of the insurance sector 7.2 Definition of long-term funding An individual household, company or government can fund its LTIs by using internal sources (savings or, in the case of governments, tax revenues that are not used for other expenses) or external sources, i.e., the excess savings of others. These excess savings are usually channeled to investments via banks that collect deposits and provide loans, or via the market, where companies can raise funds by issuing bonds or equity. Savers invest in these financial assets either directly or indirectly, for example via insurers or pension funds. On the aggregated macroeconomic level, however, investments are equal to savings, regardless of how much of the investment is funded internally or externally (see Chart 2). In order to avoid maturity mismatches and related refinancing risks, LTIs require long-term funding, i.e., loans and bonds with long maturities. Chart 2: Simplified overview of long-term investment funding in a closed economy Public ‘savings’ Funding by public ‘savings’ (taxes – noninvestment expenses Public investments Bonds Private sector investments Insurers Premiums Bonds Other institutional investors «Investments» Loans Banks Deposits Private savings Equity Direct holdings of equity and bonds Funding by internal sources Source: Zurich Insurance Company Ltd33 Governments finance their LTIs with tax revenues and by issuing bonds. They fund about 30 percent of all LTIs (see Chart 3), and are the single largest funding source for infrastructure investments and education. Almost half of private LTIs, or about 30 percent of total LTIs, are funded by internal sources (i.e., household wealth and income or retained income of corporations). Loans dominate the external funding of private LTIs and are used to finance roughly 30 percent of all LTIs. The remaining 10 percent of total LTIs are funded through the market by equity (8 percent) and bonds (2 percent). 33 Other institutional investors are, for example, pension funds and investment funds. Closing the long-term investment gap: the dual role of the insurance sector 23 Chart 3: Financing long-term investments (in percent) Total R&D Education Infrastructure Equipment and software Commercial real estate Residential real estate 0 Internal financing 20 Government 40 60 Equity 80 Loans 100 Bonds Source: Group of Thirty (2012) 7.3 What challenges do long-term investors face? A private household may decide to build a new home, or a company might plan to make capital expenditures, but challenges could deter them from their objective. As noted, on the macro level, investments must equal savings. Challenges for LTIs can therefore emanate from three different angles: sufficient savings need to be available to fund LTIs, these savings must be transformed into investments, and investors require incentives to engage in LTIs. These challenges are discussed in more detail here. 7.3.1 Availability of savings • In many countries, high public indebtedness and adverse market conditions have led governments to adopt fiscal austerity. As a result, many governments have cut back on their LTIs. This has particularly affected investments in infrastructure and education, for which, as mentioned already, governments are the main funding source. According to a McKinsey report,34 between 2013 and 2030 infrastructure investments on the order of USD 57 trillion are needed – 60 percent more than in the previous 18 years. Given fiscal constraints, most governments will be hard-pressed to fund these investment needs. To lessen the impact of austerity measures on long-term economic growth, countries need to shift from entitlement spending to more discretionary long-term spending. Limits should be imposed on cuts to education and infrastructure spending. Where possible, cuts in these areas should be offset by measures to make the investments more efficient or compensated through increased private-sector involvement. McKinsey (2013), ‘Infrastructure Productivity. ’(http://www.mckinsey.com/insights/engineering_ construction/infrastructure_productivity) 34 24 Closing the long-term investment gap: the dual role of the insurance sector Many potential investors are holding back on LTIs and their reluctance in this regard may delay a more robust economic recovery.” • Demographic developments are likely to pose additional barriers to long-term financing. The saving behavior of people follows a life cycle with increasing saving rates during working age and negative saving rates in retirement. The aging population, especially in advanced economies, leads to a decline in the proportion of the population that is working and saving. As a result, savings rates could decline over the coming years. In addition, since older people tend to prefer investments with less risk, the availability of funding for risky LTIs will likely decrease as the population ages. This demographic development will also put an increasing fiscal burden on countries that continue to adhere to public pay-as-you-go pension systems, further limiting the ability of governments to invest. To deal with these challenges, it will be important to promote savings for retirement. 7.3.2 Transformation of savings into investments Banks, as one of the main providers of funding for real estate and a significant funding source for equipment and infrastructure, have become increasingly reluctant to lend, especially when it comes to granting loans with a longer maturity. One reason is the short-term nature of banks’ liabilities, which limits their ability to provide long-term funding. Stricter regulations and enhanced risk management practices imposed in the wake of the financial crisis appear to have further constrained lending. Tighter regulation governing liquidity is making illiquid, long-term lending less attractive. These factors have affected long-term lending, especially in the five- to seven-year segment. In certain countries the impact is felt particularly by private households and small- and medium-sized enterprises (SMEs) with limited access to capital markets.35 7.3.3 Private sector incentives to invest in long-term assets • LTIs are attractive in part because of their long life span. Hence, LTIs become less attractive if they are at risk due to fires, floods, accidents or other adverse events. Economic losses caused by natural catastrophes have been rising in recent decades. This trend is expected to continue as population density and property values increase in catastrophe-prone coastal areas. • The deep and entrenched financial and economic crisis has made prospects for long-term economic growth less certain. Many potential investors are holding back on LTIs and their reluctance in this regard may delay a more robust economic recovery. Entrepreneurs willing to accept economic risk are needed to break this cycle. Public policy could help by adopting prudential monetary and fiscal policies, thus providing the basis for a stable economic environment with low inflation and reduced cyclical volatility.36 • In response to sovereign debt problems, as well as out of concern for the environment, tax regimes and public subsidies in advanced market economies are undergoing rapid and far-reaching changes. This is creating an additional layer of uncertainty that hampers LTIs. To promote LTIs, policymakers should aim to secure a sound macroeconomic and institutional framework with predictable taxes and a high degree of contract certainty. Especially in emerging economies, weak property rights, social unrest and the risk of severe political disruption contribute to uncertainties. These factors also constitute major concerns for long-term investors. According to the ‘2013 SMEs’ Access to Finance survey’ by the European Commission (2013), access to finance was the most pressing problem mentioned by SME managers in peripheral Europe. However, it was the least-mentioned problem in Germany, Austria and Luxembourg. 35 See also principle one of OECD (2013), ‘G20/OECD High-Level Principles of Long-Term Investment Financing By Institutional Investors,’ DAF/AS/WD(2013)16. 36 Closing the long-term investment gap: the dual role of the insurance sector 25 As LTIs are subject to the major challenges outlined here, doubts are growing as to whether there will be sufficient LTIs to achieve an economic growth rate that is both sustainable and high enough to reduce unemployment. Difficulty obtaining appropriate long-term funding for public infrastructure projects and inadequate funding for LTIs carried out by SMEs in peripheral European countries are among the main challenges. In other segments and countries, private-sector LTIs face economic, legal and political risks and, increasingly, the threat to property posed by natural catastrophes. If these risks are not adequately compensated by higher returns, LTIs will be postponed or simply not undertaken at all. Given the long-term nature of their liabilities, many insurers and pension funds are able to hold long-term assets that are not traded in liquid markets. They could thus help to fill the funding gap for certain LTIs, especially for infrastructure. In addition to providing long-term funding, insurers facilitate LTIs; they provide insurance coverage for certain risks (mainly property risk) and offer risk management services to mitigate those risks. 26 Closing the long-term investment gap: the dual role of the insurance sector Closing the long-term investment gap: the dual role of the insurance sector 27 Disclaimer and cautionary statement This publication has been produced solely for informational purposes. The analysis contained and opinions expressed herein are based on numerous assumptions. Different assumptions could result in materially different conclusions. 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