2004 Casualty Loss Reserve Seminar September 13-14, 2004
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Transcript of 2004 Casualty Loss Reserve Seminar September 13-14, 2004
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2004 Casualty Loss Reserve SeminarSeptember 13-14, 2004
Implications of New International Accounting Standards for Insurance
Companies
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NEW ACCOUNTING RULES WILL APPLY 2005 for IFRS reporting companies.
EU-listed companies and the Caribbean. Australia - possible early adoption.
FASB has stated intention to converge GAAP with IFRSs
US GAAP changes not that far off
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Contributors to PresentationBurt Jay, FSA, MAAA
AAA VP - Financial ReportingAAA Representative to IAA Standards Subcommittee
Dave Congram, ASA, FCIA, FIACanadian Task force to develop process to implement IAA standards in CanadaAuthor, several IAA Exposure Drafts
Bob Miccolis, FCAS, MAAACAS Representative to IAA Standards SubcommitteeChairman, ASB Casualty Operating CommitteeMember, IAA Standards Drafting Group
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Why is a global insurance accounting standard required?
Common global insurance accounting needed to eliminate differences that can be material
GAAP financial reporting cannot rely on regulatory accounting, particularly for multi-nationals
Insurance contracts will no longer be excluded from international accounting standards
IASB has been reconciling accounting differences towards a consistent global approach across industries
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Primary International Standards Affecting Insurance Companies
IFRS 4, adopted March 2004 (effective 1st qtr 2005 for companies reporting under IAS/IFRS)
IAS 32 and 39, Amended December 2003 (Financial Instruments)
Existing IAS 18 Revenue (Service Contracts)
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PRIMARY PROVISIONS OF IFRS 4Applies to Insurance Contracts—must have “significant insurance risk” to use IFRS 4
IFRS 4 allows insurance contracts to be accounted under local GAAP, with certain restrictions (no CAT or equalization reserves)
Liability adequacy test required
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WHAT ABOUT NON-INSURANCE CONTRACTS
Contracts issued by insurance companies that do not meet definition of insurance are considered to be either financial instruments (investment contracts) or service contracts
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SERVICE CONTRACTSGenerally, contracts that are neither insurance contracts or financial instruments (investment contracts) are service contracts
Claim service contracts (ASOs)Self insurance (basic risk financing)Deductibles
Service component of a financial instrument (investment contract), or an insurance contract, may have to be separatedCovered by IAS 18
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IAA Actuarial Standards Exposure Drafts
Actuarial PracticeContract ClassificationMeasurementLiability Adequacy TestingChanges in Accounting policy
Embedded DerivativesDiscretionary Participating FeaturesCurrent EstimatesDisclosureReinsuranceStochastic Models
International Actuarial Practice Guideline IAPG (IAA Class 4 Standard)
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IAA Exposure Draft - Actuarial PracticeSpecific guidance
DisclosuresScope and adequacy of Professional ServicesAccounting requirements
a) Classificationb) Unbundling and Embedded derivative separationc) Measurementd) Participatione) Liability Adequacy Testf) Accounting Disclosure
Relevant KnowledgeMaterial Inconsistencies
General guidance
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IAA Exposure Draft - Classification Paper
Significant insurance risk
IFRS 4Insurance
Contains service elements
Contains Discretionary Participation
Feature?
IAS 18Service Contract
MeasurementCreate financial
assets or liabilities?
Embedded Derivative Test
No
No
Yes
Deposit Component
Yes
Tests
Yes
No
Service Element
Financial Instrument
IAS 39Financial Instrument
Measurement
Tests
Financial Instrument
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IAA Exposure Draft - Measurement Paper
Measurement approaches addressed• Amortized Cost model• Fair Value model• Stage of completion
Structure• Approach• Models and assumptions• Updating• Accounting Constraints
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Revised IAS 39: Measurement
Financial Instrument
Amortized Cost
Fair Value Entire Contract
Options and Guarantees considered
Contains EmbeddedDerivatives
Fair Value
Option Pricing Models
Amortised Cost
Option PricingModels
Financial Markets
ValuationTechnique
MarketCalibration
Derivative
HostYES
NO
ElectionHeld forTrading
YES
NO
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Other IAA Practice Guidelines
Liability Adequacy TestingChanges in Accounting policyEmbedded DerivativesDiscretionary Participating FeaturesCurrent Estimates
DisclosureReinsuranceStochastic Models
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Property/Casualty Insurance AccountingClassification – retroactive risk considered insurance; no special risk transfer rules for ceded reinsurance
Ceded Reinsurance – valued separately as an asset
Unbundling – only required if deposit obligations not fully recognized
Liability Adequacy Testing – Premium Deficiency Reserve – if no existing test, level of aggregation is broadly similar risks managed as a portfolio
Changes in Accounting policy – only if “improvement” no less reliable, no less relevant
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Property/Casualty Insurance AccountingEmbedded Derivatives – certain types of contracts, particularly reinsurance, that include index triggers may be affected
Current Estimates – needed for liability adequacy test, changes in accounting policy
Disclosure – several difficult and very broad requirements
Reinsurance asset impairment – not based on reinsurer ratings
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Changes to P/C Actuarial Practice
Impact on US P/C actuarial practice will depend onFASB view of timing to converge with IASBFASB plans relative to IASB exposure drafts and standardsViews of Insurance Regulators on avoiding 2+ sets of booksUS based insurers with European (or Australian) parents US based insurers with significant European operationsUS listed insurers who are also listed on EU/AU exchangesDisclosure – several difficult and very broad requirements
Some version of Fair Value will be difficult to avoid
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Fair ValueThe main concern about IAS is that they require assets and liabilities to be valued at market value
Market value must be based on an active market with a high volume of transactions
In the absence of a market value, fair value is to be used, based on a valuation using appropriate methods
Such appropriate fair value methods or models should be based on observable market transactions
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Highlights of Fair Value (Phase II)Discounting of P/C Liabilities
Reserves for unpaid loss and loss adjustment expensesReserves for unexpired risks (UPR)
Market Value Margins – added to discounted liabilitiesReflects risk and uncertainty in reservesReflects “market” price (margin) for reserve riskReflects “mark-up” for transaction cost of selling reserves Credit risk adjustment (controversial)
Credit Risk Adjustment Liability adjustment for credit characteristics of the contractReflecting any government guarantees or legal preferences
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Fair Value ConceptsFair value is the amount for which an asset could be exchanged between knowledgeable, willing parties in an arm's length transaction. Fair value is measured, at the balance sheet date, as:
the most probable price reasonably obtainable in the market, the best price reasonably obtainable by the seller, and the most advantageous price reasonably obtainable by the buyer
“Knowledgeable, willing parties” both a willing buyer and a willing seller both reasonably informed about the characteristics of the asset, and state of the market as of the balance sheet date
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Fair Value ConceptsThere is a presumption that an enterprise is a going concern without any intention or need to liquidate, curtail materially the scale of its operations or undertake a transaction on adverse terms.
Fair value is not, therefore, the amount that an enterprise would receive or pay in a forced transaction, involuntary liquidation or distress sale.
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Fair Value - No active and liquid marketWhen there is not frequent activity in a market, the market is not well established or small volumes are traded, quoted market prices may not be indicative of the fair value of the instrument.
Estimation techniques may be used to determine fair value if there is sufficient reliability.
Techniques that are well established include reference to the current market value of another instrument that is substantially the same, such as discounted cash flow analysis and option pricing models
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Fair Value ModelsFair Value “Model” needed to estimate value
No active and liquid marketSmall volume market prices not indicative of fair value
Fair Value Model should have certain characteristics:Mimics market price behavior of an active marketCan be validated by observable market valuesModel assumptions are current and based on observable data
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References to Credit (IAS 39)The discount rate equals the prevailing market rate of interest for financial instruments having substantially the same terms and characteristics, including the creditworthiness of the debtor, the remaining term.
Valuation techniques should incorporate the assumptions that market participants would use in their estimates of fair values, including assumptions about prepayment rates, rates of estimated credit losses, and interest or discount rates.
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Reliability of Fair Value Estimates (IAS 39)Often, an enterprise will be able to make an estimate of the fair value of a financial instrument that is sufficiently reliable to use in financial statements.
The fair value of a financial instrument is reliably measurable if:a) the variability in the range of reasonable fair value
estimates is not significant for that instrument, or b) if the probabilities of the various estimates within
the range can be reasonably assessed and used in estimating fair value.
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Reliability of Fair Value Estimates (IAS 39)The fair value of a financial asset or financial liability may be determined by one of several generally accepted methods.
Occasionally, the variability in the range of reasonable fair value estimates is so great and the probabilities of the various outcomes are so difficult to assess that the usefulness of a single estimate of fair value is negated.
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Can Fair Value for insurance be reliably determined?
IASB has not decided – practical issues to be resolved
IASB recognizes that fair values can not be observed directly from market transactions
IASB sees fair values for insurance using estimates based on models
IASB realizes very little data exists for some risks
IASB sees insurance fair value estimates as not less than what the entity would charge for new contracts
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Is Fair Value relevant for non-traded long term liabilities?
IASB – fair value measurement is not intended as a representation that an insurer could, or should, transfer insurance liabilities to another party.
IASB – fair value of an insurance liability can be regarded as a market-based representation of the value of the future contractual cash flows.
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Credit Risk Adjustment – One ViewCredit risk adjustments do seem to be a separable component of the “fair” market value of financial instruments (such as a bond) in active markets. Where the cash flows are certain, one could compute a credit risk adjustment as the difference between market value and the present value at a risk free rate. Alternatively, the credit risk adjustment could be the addition to the discount rate that produces a present value of cash flows equal to the market value.
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Credit Risk Adjustment – One ViewWith uncertain cash flows, there is no clear division in market value between the “market value margin” that compensates for the uncertainty of the cash flows and the credit risk adjustment.However, if the credit risk adjustment is measured solely in terms of the discount rate, then the market value margin would be the difference between
the market value (no credit risk) for uncertain cash flows, and the market value (no credit risk) for fixed cash flows equal to the expected value of the uncertain cash flows.
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Fair Value and the Capital Markets ViewEconomists in the capital markets field routinely estimate fair market values for many kinds of securitization instruments, some with active markets and others without. In capital markets, the concept of credit risk adjustment for liabilities is relates to how much HIGHER the fair value of liabilities should be above the present value of cash flows at a risk free rate. This means that the fair value of liabilities INCREASES as the credit characteristics worsen.
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Fair Value and the Credit Enhancement ViewThe fair value of the liability for the entity obligated to make payments can be viewed as made up of: a. The present value of the cash flows discounted
at the risk free rate, plus b. The market price of a guarantee to make those
payments. To sell the liability would require a credit enhancement premium if the credit rating had dropped from when the liability was issued.Thus, the credit risk adjustment within the fair value of liabilities is equivalent to a theoretical credit enhancement premium.
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Fair Value and the Credit Enhancement View
Applying this view to insurance, the fair value of an entity’s insurance liabilities should INCREASE because of a drop in the entity’s credit standing.
When the credit standing drops too low, the fair value of the insurance liabilities increases to the point of reducing the surplus to threaten the solvency of the entity, or indicating insolvency.
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Fair Value and the Market Calibration ViewThe fair value of insurance liabilities should reflect market value, including both market value margin and the credit risk adjustment.
The insurance contract obligations at inception can be viewed as pricing a policy at the market value.
IBNR can be viewed as pricing tail coverage at the market value.
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Fair Value and the Market Pricing ViewMarket Value Pricing could be viewed as the market price of a representative portfolio of policies.
This market value price would reflect the uncertainty of the insurers cash flows from these policies.
If differences in observable market prices are consistently related to the credit standing of the insurer, then the liabilities of the lower credit rated insurers would have a HIGHER fair value if the insurers with better credit can get higher market prices.
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Precedents for reflecting credit in the measurement of liabilities?
Existing loan models (IAS 39) require the borrower to recognize the liability initially at the amount of the proceeds received (less transaction costs incurred)
This measures the liability at the contractual amounts payable (interest and principal), discounted at the prevailing interest rates at inception for a loan with those credit characteristics.
Initial measurement of the liability reflects its credit characteristics.
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Why should an insurer report a profit if credit quality of its liabilities deteriorates?
IASB – excluding credit characteristics of a liability from its measurement would require an arbitrary exception to the general principle of measurement at fair value
When the IASB considers performance reporting issues for insurance contracts (phase II), it will consider whether the effects of liability changes due to changes in credit characteristics should be disclosed separately.