Session 9: Panel on Assets Jeffery Yong IAIS Secretariat Regional Training Seminar IAIS-ASSAL San Salvador, 24 November 2010

Session 9: Panel on Assets224 Nov 2010 San Salvador Agenda 1.Introduction - lessons from the financial crisis 2.International standards 3.Summary

Session 9: Panel on Assets324 Nov 2010 San Salvador Lessons from the financial crisis – mainly on asset side of the balance sheet Note : This list is not exhaustive.

Session 9: Panel on Assets424 Nov 2010 San Salvador Proposed structure of the new ICPs ICP 18 Risk Assessment and Management ICP 19 Insurance activity ICP 20 Liabilities ICP 21 Investments ICP 22 Derivatives and similar commitments ICP 23 Capital adequacy and solvency ICP 14 Valuation ICP 15 Investment ICP 16 Enterprise risk management for solvency purposes ICP 17 Capital Adequacy Standard on valuation Guidance on valuation Standard on investments Guidance on investments Standard on ERM for solvency purposes Guidance on ERM for solvency purposes Standard on capital requirements Standard on internal models Guidance on capital requirements Guidance on internal models EXISTING ICPS NEW ICP STRUCTURE

Session 9: Panel on Assets524 Nov 2010 San Salvador Total balance sheet approach to recognise interdependencies Supervisory assessment of the financial position AssetsLiabilities and capital requirement Financial position AssetsLiabilities Technical provisions Best estimate policy obligations Risk margin Value of assets for supervisory purposes Capital requirement Liabilities Available capital Public financial reporting Liabilities Capital

Session 9: Panel on Assets624 Nov 2010 San Salvador An example of asset composition

Session 9: Panel on Assets724 Nov 2010 San Salvador Agenda 1.Introduction - lessons from the financial crisis 2.International standards 3.Summary

Session 9: Panel on Assets824 Nov 2010 San Salvador Basis for establishing regulatory investment requirements The supervisory regime establishes requirements that are applicable to the investment activities of the insurer. The supervisory regime is open and transparent as to the regulatory requirements that apply and is explicit about the objectives of those requirements.  Financial requirements alone not sufficient – need to complement with quantitative/qualitative requirements to limit investment risks by insurer.  Factors to consider when setting requirements: Quality of risk management and governance Quality of capital resources Disclosure framework Cost of compliance Risk sensitivity of solvency regime  Transparency facilitates comparisons across jurisdictions – particularly important for cross-border insurance groups  Explicit objectives can help to identify consistency with other requirements – regulatory capital requirements, determination of capital resources and valuation of assets and liabilities.

Session 9: Panel on Assets924 Nov 2010 San Salvador Rules-based vs. Principles-based Limits on asset types Form - % of investments; capital charges; deductions from capital resources Easy to enforce and explain to court Deter insurer from investing in inappropriate assets BUT – stifle innovation; disincentivise risk management; one-size does not fit all Principles on investment strategy More flexibility for insurer to choose strategy that meets its risk profile and objectives Less frequent revisions in response to market developments BUT – innovative instruments riskier than originally assessed; difficult to enforce actions – open to interpretations Rules-based Principles-based

Session 9: Panel on Assets1024 Nov 2010 San Salvador Minimum requirements - security, liquidity and diversification Security Restrict investment exposure to high risk investments (default, lost of value, custodianship) Limits of using external credit ratings – conduct own due diligence Derivatives – assess underlying assets and counterparty risk Liquidity Able to realise/liquidate investments at any point in time Insurance groups – due regard to impediments to cross-border transfer of assets particularly in winding up Diversification Diversify within risk category – pooling of same risks (e.g. shares of different companies) Diversify between risk categories – uncorrelated investments (e.g. different asset classes, geographical spread etc.)

Session 9: Panel on Assets1124 Nov 2010 San Salvador Investments should be appropriate to the nature of liabilities ASSETS Timing of liability cashflows Amount of liability cashflows Policy guarantees & options Unit-linked policies Currency of liabilities Mismatching risk  higher technical provisions and/or capital requirements

Session 9: Panel on Assets1224 Nov 2010 San Salvador Risk assessibility The solvency regime requires the insurer to invest only in assets whose risks it can properly assess and manage. The solvency regime establishes quantitative and qualitative requirements on the use of more complex/less transparent assets and investments in lightly/non-regulated markets.  Invest only in assets that the insurer can identify, measure, monitor, control and report – including reliable valuation.  Assess maximum loss possible – look through underlying assets.  Particular attention on complex asset classes – implicit obligations of support, increased correlation in times of stress.  E.g.- pre-approval of an insurer’s derivative investment plan – describe controls and test process.

Session 9: Panel on Assets1324 Nov 2010 San Salvador Requirements on specific financial instruments Off Balance Sheet Structures Consider whether should permit – circumventing requirements? Investment strategy of OBS may be different from the insurer’s May impact ability to meet policyholder obligations especially in times of stress Structured Credit Products Difficult to assess inherent risk underlying the reference instrument – e.g. subprime mortgages Impose quantitative/qualitative requirements on investments/originator Consider treatment in other financial sector, “skin in the game”, transparency of underlying asset, insurer’s control system Derivatives Obtain information on insurer’s policies and procedures on the use of derivatives – rationale for transactions Should be used for risk management and not speculative investment – consider prohibition Suitable counterparties and tradability of the derivative

Session 9: Panel on Assets1424 Nov 2010 San Salvador Agenda 1.Introduction - lessons from the financial crisis 2.International standards 3.Summary

Session 9: Panel on Assets1524 Nov 2010 San Salvador Summary of key points During the recent global financial crisis, insurers were mainly affected due to their investment activities. Regulatory and supervisory requirements on investments need to incentivise insurers to have sound investment policies without being too restrictive. Sound asset-liability management policies has proven to be a powerful tool to manage risk.

Session 9: Panel on Assets1624 Nov 2010 San Salvador Some final thoughts Need to avoid insurers becoming too-big-to-manage or too-complex-to- understand Insurers should have better understanding on risk interdependencies Avoid mistakes in other sectors

Session 9: Panel on Assets1724 Nov 2010 San Salvador Thank you for your attention. Any questions/ comments?