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Diploma in Insurance M92 Insurance Business and Finance
Chapter 10: Financial Strength of Insurance Companies
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Learning objectives By the end of this module, you should be able to:
Analyse the financial strength of insurance companies Explain the role of rating agencies and the rating process Explain the regulatory solvency requirements
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Rating agencies Solvency margins and regulatory requirements
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Rating agencies Solvency margins and regulatory requirements
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What do large insurers (or reinsurers) pay rating agencies to do?
Why pay somebody else to do this? What do large insurers (or reinsurers) pay rating agencies to do? Give an opinion of their financial strength a measure of their ability to pay claims Four main agencies - Standard and Poor’s AM Best Moody’s Fitch Customers are buying a promise Commercial customers/brokers may use financial strength ratings before placing business
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For insurers Independently demonstrates to customers its ability to pay claims Allows financial strength comparisons between insurers Allows a very strong insurer (AAA) to charge higher premiums and transact a wider range of business Brokers/customers may decide own risk appetite based on rating (e.g. minimum A rated insurer)
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Rating methodology Qualitative and quantitative data used
Objective judgements based on data Takes account of unique dynamics of each insurer Analytical framework is used
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Economic and industry risk Competitive position Management and corporate strategy Enterprise risk management (ERM) Operating performance Investments Capital adequacy Liquidity Financial flexibility Analytical framework See Figure 10.1 in text book for Standard and Poor’s insurance ratings framework All interconnected, but weighted according to specific company circumstances. E.G The amount of capital a company has affects strategy, competitive position, etc.
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Standard and Poor’s Website
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The Ratings – Approximate comparisons
What would you think about an insurance company with a rating below the table? What would they have to do about it?
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Typical rating process
Insurer/Agency sign contract 2 Analysts – day with senior executives Exhaustive analysis over weeks Lead analyst recommends rating to committee of eight Committee votes Insurer told rating – Accepts or appeals it Regular monitoring and annual review
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Rating agencies Solvency margins and regulatory requirements
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Overriding regulatory requirement
‘A firm must at all times maintain overall financial resources, including capital resources and liquidity resources, which are adequate, both as to amount and quality, to ensure that there is no significant risk that its liabilities cannot be met as they fall due.’ GENPRU
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The board must determine an insurer’s risk appetite
Typical risk statement includes: Statement of risks acceptable for the company to bear Risks that are not acceptable Probability of failure that is not acceptable Maximum loss acceptable for one incident Used to set: Risk acceptance criteria An investment policy A reinsurance policy Other financial and risk policy statements PRA Requirement – Probability of failure to be no more than 1 in 200 within a 12 month time scale.
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EU Solvency II Directive
Established EU-Wide capital requirements, valuation techniques Replaced Solvency I on 1 January 2016 Enhances policyholder protection Aims to create safer and more resilient insurance sector
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Four level process Level 1: Framework principles Level 2: Level 3:
Solvency II framework directive Lays down essential framework principles Level 1: Framework principles Implementing measures Set out requirements insurers must meet Level 2: European Insurance and Occupational Pensions Authority (EIOPA) set out common standards and guidelines Level 3: Guidance More vigorous enforcement action than before Co-operation between member states regulators and private sector Level 4: Enforcement
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The three pillars Pillar 1: Demonstrating adequate financial resources
Key quantitative requirements Solvency Capital Requirement (SCR) and Minimum Capital Requirement (MCR) Full or partial approved internal model or based on EU standard formula Pillar 2: Demonstrating adequate governance system Risk identification and management Own Risk and Solvency Assessment (ORSA) Includes overall process by the supervising authority (PRA in UK) Pillar 3: Public disclosure and regulatory reporting Insurers must publish risks they face, capital adequacy and risk management Transparency and openness required
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The three pillars Pillar 1: Demonstrating adequate financial resources
Key quantitative requirements Solvency capital requirement and Minimum capital requirement Full or partial approved internal model or based on EU standard formula Pillar 2: Demonstrating adequate governance system Risk identification an management Own Risk and Solvency Assessment (ORSA) Includes overall process by the supervising authority (PRA in UK) Pillar 3: Public disclosure and regulatory reporting Insurers must publish risks they face, capital adequacy and risk management Transparency and openness required
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Financial Resources (Pillar 1)
Balance sheet to be based on market consistent valuations Assets and liabilities must reflect current values at which they would be traded in the market Not their original accounting values Source:
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Solvency II – 3 Tiers of Capital
Shareholder’s equity Retained earnings Able to absorb day to day losses – going concern basis Tier 1: Highest quality Subordinated debt Only needs to absorb losses on insolvency Tier 2: Lower quality Only limited loss absorbing capability Unlikely to be significant under Solvency II Tier 3: Lowest quality
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Source: https://www. bankofengland. co
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Two capital requirements
Solvency Capital Requirement (SCR) Amount of capital required to meet unexpected losses over the next year Up to statistical level of 1 in 200 event Robust requirement Aim for insurers to withstand all but most severe shocks Minimum Capital Requirement (MCR) Below this level policyholders are exposed to unacceptable level of risk Corresponds to 85% probability of adequacy in following year
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Supervisory ladder intervention
Source:
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Inadequate capital – 2 options
Raise more regulatory capital Issue new shares New long term debts to meet PRA Tier 1 and Tier 2 requirements Reduce regulatory capital requirement Business volumes – especially long tail Reinsurance Switching from higher risk to lower risk investmentd
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Calculating SCR Standard formula used by most European firms
Identify the firms market and underwriting risks Prescribed calculation method used to calculate capital needed to cover those risks Calculating SCR
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Calculating SCR - Alternative
Internal model used Doubles up as firm’s risk management/decision making process PRA take proportionate approach to how complex the modelling should be Calculating SCR - Alternative
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Balance required Regulatory Capital Returns on equity
ID © Stefan Hermans | Dreamstime.com
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The three pillars Pillar 1: Demonstrating adequate financial resources
Key quantitative requirements Solvency capital requirement and Minimum capital requirement Full or partial approved internal model or based on EU standard formula Pillar 2: Demonstrating adequate governance system Risk identification an management Own Risk and Solvency Assessment (ORSA) Includes overall process by the supervising authority (PRA in UK) Pillar 3: Public disclosure and regulatory reporting Insurers must publish risks they face, capital adequacy and risk management Transparency and openness required
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Good governance and risk management required
PRA: Senior Insurance Managers Regime (SIMR) Ensure accountability of senior managers Clearly defined responsibilities Honesty, integrity and competence expected
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Own Risk and Solvency Assessment (OSRA
Regulatory capital requirements may not capture all risks Can be difficult to quantify (e.g. cyber risk) Risks change over time – business plans span many years OSRA requires firms to understand and manage all their risk exposures Can be complex – especially in an insurance group where some activities are not regulated Parent company may have Tier 2 debt but pass to a subsidiary as Tier 1 equity
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The three pillars Pillar 1: Demonstrating adequate financial resources
Key quantitative requirements Solvency capital requirement and Minimum capital requirement Full or partial approved internal model or based on EU standard formula Pillar 2: Demonstrating adequate governance system Risk identification an management Own Risk and Solvency Assessment (ORSA) Includes overall process by the supervising authority (PRA in UK) Pillar 3: Public disclosure and regulatory reporting Insurers must publish risks they face, capital adequacy and risk management Transparency and openness required
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Solvency and Financial Condition Report (SFCR)
Must be published annually by firms Quality and standard of report set out in Solvency II Approach to Solvency II (e.g. internal model used) Any non compliance with solvency requirements Reasons and consequences of non compliance Measures taken to resolve non-compliance
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Brexit Solvency II legislation piloted in UK
UK prominent member of International Association of Insurance Supervisor (IAIS) Likely that Solvency II (or similar) will continue to apply Already part of English Law, so would need to be repealed by parliament Direct delegated EU regulations under Solvency II not directly part of English law Some unpicking needed? ID © Elnur | Dreamstime.com
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Lloyds – until Brexit Way it conducts business unchanged
Continues to be subject to Solvency II Retains its EU rights No existing policies/renewals if existing EU member may be affected by referendum result Policies legally binding and claims will be met Multi year policies remain legally binding even after Brexit Brexit does not affect Lloyd’s trading outside EU Setting up new EU insurance company based in Brussels (trading from 1/1/19)
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Stress and scenario testing
Important part of planning and risk management Regulatory requirement – robust and effective stress testing Proportionate/relevant to the insurance business PRA conduct own stress tests periodically What would be the result in this scenario? Reverse stress tests also required What scenarios/circumstances would render the business unviable?
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Actuary role in Solvency II
EU Regulators regard actuarial information as: ‘..indispensable to an adequate system of governance…’ Must be carried out by person with sufficient knowledge of actuarial and financial mathematics (not necessarily qualified actuary) Object is for actuarial function to contribute to effective system of risk management Use internal model to understand reserving volatility and assess firms financial provisions
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Rating agencies Solvency margins and regulatory requirements
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Economic and industry risk
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Competitive position
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Management and corporate strategy
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Enterprise risk management (ERM)
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Operating performance
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Investments
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Capital adequacy
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Liquidity
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Financial flexibility
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