!@ Quality In Everything We Do International Financial Reporting Standards Applied to Property and Casualty Insurance Jim Christie and Scott Drab November 2004
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!@ Quality In Everything We Do International Financial Reporting Standards Applied to Property and Casualty Insurance Jim Christie and Scott Drab November 2004 Background Cross-border capital flows highlight the need for consistent, understandable financial information BUT insurance accounting has significant local variations The International Accounting Standards Board (“IASB”) is developing a single set of global accounting standards Many countries committed to the objective of global “harmonisation” Drivers for new approach Historical cost accounting models lack relevance Solvency-based approaches do not provide an accurate picture of financial performance Convergence of banking and insurance industries 2 !@ Quality In Everything We Do Phased approach for insurance A phased approach to insurance contracts. Phase I – Implement by 2005 IAS INSURANCE PROJECT Phase II – Implement Fair Value by 2007 / 8 (?) Objective for Phase I is to implement some components of the insurance project by 2005, without delay to Phase II. 3 !@ Quality In Everything We Do Property & Casualty – Phase 1 Key Phase I Issues Defining Insurance Accounting for insurance contracts Disclosures 4 !@ Quality In Everything We Do Definition of Insurance A contract under which the insurer accepts significant insurance risk by agreeing to compensate the beneficiary if the insured event adversely affects the policyholder (Insurance Contracts (Phase I) paraphrased with emphasis added) Significant means at least one scenario with payment of commercial substance with an amount that is not trivial 5 !@ Quality In Everything We Do Insurance vs Financial Risk Financial risk is risk of possible future change in specified interest rate, security price, commodity price, foreign exchange rate, index of prices or rates, a credit rating or credit index or similar variable Insurance risk is risk from contingent events other than financial risk If both financial risk and significant insurance risk are present, contract classified as insurance 6 !@ Quality In Everything We Do Insurance Contract Accounting During Phase I, existing accounting policies apply with certain modifications Prohibited – certain accounting policies are prohibited as they do not meet the IFRS framework Mandated – certain accounting policies must be implemented if they are not already in the existing accounting policies Allowed to continue, but not start – certain accounting policies that do not meet the IFRS framework can continue, but cannot be implemented. Can be started – certain accounting policies can be introduced. Existing accounting policies are those in the primary financial statements 7 !@ Quality In Everything We Do PROHIBITED accounting policies The following policies are prohibited Catastrophe provisions Claim equalisation provisions Offsetting of reinsurance assets and direct liabilities 8 !@ Quality In Everything We Do MANDATED accounting policies The following policies are mandated if not already present Liability adequacy testing Impairment of reinsurance assets 9 !@ Quality In Everything We Do Liability Adequacy Test Current liability adequacy test applies IF 1. Test at each reporting date using current estimates of future cash flows, AND 2. If these are greater than current liability, liability is increased and deficiency flows through profit and loss 10 !@ Quality In Everything We Do IMPAIRMENT of reinsurance assets Reinsurance asset is reduced and reduction flows through income statement if it is impaired Reinsurance asset is impaired if: Objective evidence of an event after initial inception that the cedant may not receive all amounts due The impact of the event can be reliably measured Impairment may be reversed 11 !@ Quality In Everything We Do Accounting policies that may CONTINUE The following policies may continue but companies may not switch to these if they are not already in use Undiscounted liability basis Deliberate overstatement of liabilities 12 Deferred acquisition costs approach !@ Quality In Everything We Do Accounting policies that may be STARTED The following accounting policies may be started, subject to certain restrictions Use of current market discount rates Use of shadow accounting Use of asset based discount rates 13 !@ Quality In Everything We Do Phase I Insurance disclosure requirements IFRS 4 has two high level principles: Principle 1 – Explanation of recognised amounts Principle 2 –Amount, timing and uncertainty of cash flows Fair Value Disclosure for insurance contract assets and liabilities Implementation guidance - runs to 61 paragraphs – but does not create additional requirements! 14 !@ Quality In Everything We Do Principle 1 - EXPLAIN Accounting policies Amounts Assumptions Changes in liabilities Gain or loss on buying reinsurance 15 !@ Quality In Everything We Do Principle 2 – CASH FLOWS Terms and conditions Segment information Risk management policies & objectives Insurance risks covered Run off triangles (claim development) Other risks 16 !@ Quality In Everything We Do PHASE 2 PHASE 2 (in 2007?) 17 !@ Quality In Everything We Do Phase 2 Scope – all insurance contracts Based on asset/liability model, rejecting current deferral/matching model Where liabilities are independent of asset returns, unless Policyholder benefits directly related to asset returns; e.g, linked products Intended to be consistent with IAS 39 18 !@ Quality In Everything We Do Accounting Basis Proposed Move to “underwriting year” accounting, thus no smoothing of results with UPR and DAC Liabilities measured at Fair Value Issues Extra volatility of the insurance result Potential changes to the IT systems Loss ratios for new products to be estimated from day one Re-engineering of claim reserving process Reserves for expenses Gain or loss at issue Renewals/Future Premiums 19 !@ Quality In Everything We Do Discounting Proposed Discounting of reserves will become mandatory Discounting at risk free rate, plus a spread for credit, and MVM’s Valuing options and guarantees Impact Projection of expected cash flows Selection of suitable economic assumptions consistent with market data Need to consider all future events including legislation and technology Re-engineering of the actuarial reserving process 20 !@ Quality In Everything We Do Market Value Margins Proposed Reserves will require a market value margin consistent with observed market risk preferences Market value margin incorporated either by adjusting discount rates OR By adjusting cashflows Consider both diversifiable and non diversifiable risks Impact Need to develop suitable approach and discounting assumptions Need for enhanced disclosures 21 !@ Quality In Everything We Do Other Fair Value Issues Future premiums only included where Uncancelable continuation or renewal rights constraining insurer’s ability to re-price; and Rights lapse if the policyholder ceases premiums No net gain at inception (ignoring indirect costs) unless market evidence Same derecognition rules used for financial assets and liabilities will apply to insurance Reflect all guarantees and options 22 !@ Quality In Everything We Do Types of Estimation Risk 1) Model Risk the risk that the wrong model was used to estimate the insurer’s liabilities 2) Parameter Risk the risk of misestimating the parameters for the model used to estimate the insurer’s claim liabilities 3) Process Risk the risk that remains due to random variation, even if the correct model and the correct parameters are used to estimate the insurer’s claim liabilities 23 !@ Quality In Everything We Do What of risks does MVM include? IAS Draft Statement of Principle 5.4: “The entity-specific value or fair value of an insurance liability or insurance asset should always reflect both diversifiable and non-diversifiable risk.” This implies that model risk, parameter risk, and process risk should be modeled. 24 !@ Quality In Everything We Do However … IAS Draft Statement of Principle, Section 5.10: 25 while it is “conceptually preferable” to reflect parameter risk and model risk, “it is appropriate to exclude such adjustments unless there is persuasive evidence that enables an insurer to [quantify] them by reference to observable market data.” !@ Quality In Everything We Do What is the market’s risk preference? The Fair Value of policy liabilities reflects the risk preferences of the insurance market. What is the insurance market’s risk preference? The 60th percentile of the distribution? The 75th percentile? The 95th percentile? IAS Draft Standard of Principles: the risk preference is “inevitably subjective” (Section 5.29) 26 !@ Quality In Everything We Do Some practical techniques to model the MVM 1) Canadian Provision for Adverse Deviation Includes Parameter Risk & Model Risk 2) Initial Expected Profit Margin Process Risk, Parameter Risk, & Model Risk 3) Poisson Frequency / Lognormal Severity Simulation Process Risk 4) Mack’s Approach Process Risk, Parameter Risk, & potentially Model Risk 27 !@ Quality In Everything We Do Canadian Provision for Adverse Deviation (PFAD) Three components to Provision for Adverse Deviation: 1. Claims Development (2.5% to 15% of discounted gross liabilities) 2. Discount Rate (50 to 200 basis points on interest rate) 3. Reinsurance Recovery (0% to 15% of discounted ceded claim liabilities) The MVM could be set equal to the claims development PFAD. The PFAD does not attempt to model process risk (i.e. size of the company is not considered when determining the PFAD). 28 !@ Quality In Everything We Do Initial Expected Profit Margin If insurance markets are efficient, the DSOP suggests there should be no gain at issue Consequently if a profit is indicated at issue, any theoretical MVM should be scaled so that the result is simply breakeven Are P&C insurance markets efficient? Are there situations where a gain at issue would be permitted? 29 !@ Quality In Everything We Do Frequency / Severity Simulation Determine the distribution of loss reserves using a Monte Carlo approach Frequency often assumed to be Poisson distributed Severity often assumed to be lognormally distributed Data requirements: Pending counts (ultimate counts – closed counts) Unpaid Claims (case + IBNR) Coefficient of Variation for severity (can be based on historical or industry data) 30 !@ Quality In Everything We Do Mack Method Mack Method can be applied to: Paid Losses Incurred Losses Historical Recorded Ultimate Losses Source: Measuring the Variability of Chain Ladder Estimates by Thomas Mack 31 !@ Quality In Everything We Do Conclusions on MVM Many judgments required under IFRS 4 requirements: 1) Should one include parameter & model risk in MVM? 2) How should the risk preference of the market be measured? 3) What approach should be used to model the MVM? 4) Given that you have selected an approach, how should you select your MVM? 32 !@ Quality In Everything We Do Conclusions on MVM Many judgments required under IFRS 4 requirements: 1) Should one include parameter & model risk in MVM? 2) How should the risk preference of the market be measured? 3) What approach should be used to model the MVM? 4) Given that you have selected an approach, how should you select your MVM? 33 !@ Quality In Everything We Do Modeling Phase 2 How would the IASB proposed accounting system compare to US GAAP for a hypothetical Property/Casualty insurance company? We worked with the Group of North American Insurance Enterprises (GNAIE) to model a P&C insurer reporting under US GAAP and the IASB proposed accounting system. We started with very basic assumptions and then showed the incremental effects of: 1. MVMs 2. Growth in Earned Premium 3. Deteriorating Loss Ratios 4. Duration mismatches 5. Own credit risk 34 !@ Quality In Everything We Do Assumptions of the Steady State Model State Model Scenario Assumptions 1998 1999 2000 2001 1 Number of Policies 5,000 5,000 5,000 5,000 2 Growth Rate N/A 0.0% 0.0% 0.0% 3 Loss Ratio 70.0% 70.0% 70.0% 70.0% 4 Risk-Free Interest Rate FLAT 0.0% FLAT 0.0% FLAT 0.0% FLAT 0.0% 5 Gross Market Value Margin - Total 0.00% 0.00% 0.00% 0.00% 6 Ceded Market Value Margin - Total N/A N/A N/A N/A 7 Quality of Insurer 8 Effect of Quality of Insurer on Gross MVM 9 Quality of Reinsurer N/A N/A N/A N/A 0.00% 0.00% 0.00% 0.00% N/A N/A N/A N/A 10 Effect of Quality of Reinsurer on Ceded MVM 0.00% 0.00% 0.00% 0.00% 11 Expense Ratios - Including Change in DAC 25.5% 25.5% 25.5% 25.5% 12 Acquisition Expense Ratio 17.5% 17.5% 17.5% 17.5% 13 Operating Expense Ratio 8.0% 8.0% 8.0% 8.0% 13 US GAAP Tax Rate 35.0% 35.0% 35.0% 35.0% 35 !@ Quality In Everything We Do Fair Value Balance Sheet in a Steady State 1998 1999 2000 2001 2002 459,680 465,530 471,380 477,230 483,080 Reinsurance Receivable 0 0 0 0 0 Unpaid Loss and Loss Expenses Recoverable 0 0 0 0 0 Ceded MVM Provision - Total Risk 0 0 0 0 0 Ceded Credit Risk Provision - Reinsurer Credit Risk 0 0 0 0 0 Reinsurance Asset 0 0 0 0 0 Assets Invested Assets Other Assets 220 220 220 220 220 Total Assets 459,900 465,750 471,600 477,450 483,300 288,400 288,400 288,400 288,400 288,400 0 0 0 0 0 (0) (0) (0) (0) (0) Liabilities Direct Unpaid Loss and Loss Expenses Gross MVM Provision - Total Risk Gross Credit Risk Provision - Own Credit Risk Net Unpaid Loss and Loss Expenses 288,400 288,400 288,400 288,400 288,400 3,150 3,150 3,150 3,150 3,150 0 0 0 0 0 Total Liabilities 291,550 291,550 291,550 291,550 291,550 Total Equity 168,350 174,200 180,050 185,900 191,750 Total Liabilities and Equity 459,900 465,750 471,600 477,450 483,300 Tax Liability Other Liabilities 36 !@ Quality In Everything We Do Fair Value Income Statement in a Steady State 1998 1999 2000 2001 2002 Revenue from Operations 200,000 200,000 200,000 200,000 200,000 Total Net Loss and Loss Expenses Incurred 140,000 140,000 140,000 140,000 140,000 0 0 0 0 0 Release in Net MVM Provision - Total Risk (0) (0) (0) (0) (0) Net Credit Risk Provision (0) (0) (0) (0) (0) 0 0 0 0 0 51,000 51,000 51,000 51,000 51,000 9,000 9,000 9,000 9,000 9,000 Investment Income 0 0 0 0 0 Investment and Interest Expense 0 0 0 0 0 Net Income Before Taxes 9,000 9,000 9,000 9,000 9,000 Taxes - Calculated on US GAAP Net Income 3,150 3,150 3,150 3,150 3,150 Net Income 5,850 5,850 5,850 5,850 5,850 COM BINED CURRENT & PRIOR BUSINESS Net MVM Provision - Total Risk Release in Net Credit Risk Provision Expenses Underwriting Income 37 !@ Quality In Everything We Do Differences in US GAAP & Fair Value: Interest Rates = 5%, MVMs = 12% Comparison of US GAAP and FV Equity 38 1998 1999 2000 2001 2002 US GAAP 170,832 192,335 214,543 237,479 261,167 Fair Value 178,176 199,679 221,887 244,823 268,511 Difference 7,344 7,344 7,344 7,344 7,344 !@ Quality In Everything We Do Differences in US GAAP & Fair Value: Interest Rates = 5%, MVMs = 12% Effects of FV-Specific Elements on FV Equity As compared to US GAAP Equity 30 20 10 0 -10 -20 Premium Recognition Discounting Effects MVM Effects -30 -40 39 !@ Quality In Everything We Do Effects of Written Growth on the Steady State Model Effects of MVM and Discounting on FV Net Income 1998 1999 2000 2001 2002 Addition of MVM Provision (16,800) (16,800) (21,000) (26,250) (32,813) Release of MVM Provision 16,800 16,800 17,745 20,186 23,868 Addition of Discount 14,324 14,324 17,905 22,381 27,977 (14,324) (14,324) (14,986) (16,896) (19,977) 0 0 (336) (578) (945) Unwinding of Discount Net Impact of MVM & Discount 40 !@ Quality In Everything We Do Effects of Written Growth on the Steady State Model Underw riting Incom e - US GAAP and Fair Value 35,000 30,000 25,000 20,000 15,000 10,000 5,000 0 1998 1999 2000 US GAAP 41 2001 2002 Fair Value !@ Quality In Everything We Do Effects of Deteriorating Loss Ratios on the Steady State Model Effects of Recognition of Losses on Unearned Premium 1999 2000 2001 2002 Losses on Net WP*-UEP** Under FV (10,000) (15,000) (20,000) (20,000) Losses on Net UEP Under US GAAP 0 10,000 15,000 20,000 (10,000) (5,000) (5,000) 0 Impact on FV Underwriting Income * WP: Written Premium ** UEP: Unearned Premium 42 !@ Quality In Everything We Do Effects of Deteriorating Loss Ratios on the Steady State Model Underw riting Incom e - US GAAP and Fair Value 35,000 30,000 25,000 20,000 15,000 10,000 5,000 0 1998 1999 2000 US GAAP 43 2001 2002 Fair Value !@ Quality In Everything We Do 1998-2002 Interest Rate Yields Sample Table of Treasury Zero-Coupon Yields Maturity (Years) 44 1997 1998 1999 2000 2001 2002 1.0 5.59% 4.58% 6.07% 5.39% 2.18% 1.32% 2.0 5.75% 4.59% 6.35% 5.17% 3.11% 1.62% 3.0 5.77% 4.60% 6.40% 5.12% 3.66% 2.01% 4.0 5.78% 4.61% 6.44% 5.08% 4.08% 2.42% 5.0 5.80% 4.61% 6.48% 5.04% 4.52% 2.85% !@ Quality In Everything We Do Effects of Real Interest Rates on the Steady State Model Unde rw riting Incom e - US GAAP and Fair Value 20,000 18,000 16,000 14,000 12,000 10,000 8,000 6,000 4,000 2,000 0 1998 1999 2000 US GAAP 45 2001 2002 Fair Value !@ Quality In Everything We Do Effects of Increasing Duration Ne t Incom e Afte r Taxe s - Fair Value 60,000 50,000 40,000 30,000 20,000 10,000 0 1998 1999 2000 2001 2002 -10,000 -20,000 Asset Mat urit y Mat ched 46 Asset Mat urit y of 3.0 Asset Mat urit y of 6.0 !@ Quality In Everything We Do Effects of Own Credit Standing Provision Unde rw riting Incom e - US GAAP and Fair Value 50,000 0 1998 1999 2000 2001 2002 -50,000 -100,000 -150,000 -200,000 US GAAP 47 Fair Value !@ Quality In Everything We Do Effects of Own Credit Standing Provision Claim Payment Patterns Year 48 1 2 3 4 5 6 7 8 9 10 Decelerated 37.0% 15.0% 18.0% 12.0% 6.0% 4.8% 3.6% 1.8% 1.2% 0.6% Actual 45.0% 15.0% 15.0% 10.0% 5.0% 4.0% 3.0% 1.5% 1.0% 0.5% Accelerated 53.0% 15.0% 12.0% 8.0% 4.0% 3.2% 2.4% 1.2% 0.8% 0.4% !@ Quality In Everything We Do Effects of Changing Payout Pattern Underw riting Incom e - US GAAP and Fair Value 11,000 10,000 9,000 8,000 7,000 1998 1999 US GAAP 49 2000 FV - 8% MVM 2001 2002 FV - 16% MVM !@ Quality In Everything We Do Effects of Changing MVM Unde rw riting Incom e - US GAAP and Fair Value 20,000 10,000 0 1998 1999 2000 2001 2002 -10,000 -20,000 -30,000 -40,000 -50,000 -60,000 -70,000 -80,000 US GAAP 50 FV - MVM 12% to 16% FV - MVM 12% to 8% !@ Quality In Everything We Do Effects of Different MVMs in a Fluctuating Environment Unde rw riting Incom e - US GAAP and Fair Value 20,000 10,000 0 1998 1999 2000 2001 2002 -10,000 -20,000 -30,000 -40,000 -50,000 -60,000 -70,000 -80,000 US GAAP 51 FV - 8% MVM FV - 16% MVM !@ Quality In Everything We Do Final Comments Should accounting statements reflect the financial effects of asset-liability mismatch? How large should the MVM be? How comparable will two similar companies be under FV? 52 !@ Quality In Everything We Do Questions [email protected] [email protected] “The Impact of an Anticipated Fair Value Accounting Framework on US GAAP Reporting Property & Casualty Insurers” : www.GNAIE.org 53 !@ Quality In Everything We Do