Mr.kannan FIMDA Udaipur

Solvency II –Lessons for India Dr R Kannan Member (Actuary) IRDA Udaipur- 08.01.2011 Timing of Solvency II process 2001 Solvency I Decision to Solvency II 2011 Solvency II Directive European Commission Decision European Council & Parliament Implementatio n Member states Answers to Calls for Advice CEIOPS QISI QIS2 QIS3 More QISI Various consultation papers Preparation of solvency II, participation to QIS Respond to consultation papers Insurance industry Udaipur- 08.01.2011 Changing role of Risk management ? The insurance industry has undergone a process of de-regulation which enabled them to take more risk and explore competitive edges of the market The drive for competitive forces led to fall in premiums which had to be compensated by taking on investment risk In the life segment unit linked products becoming more popular Capital markets have become more volatile Part could be attributed more efficient and linkage to globalized markets Investment strategies have become a more important source of income This places additional importance on investment strategy as a source of risk In late 1990s and early 2000s the number of insurers becoming insolvent grew significant world over especially in Europe The difference between bank and an insurance company and hence the risk management principles have to recognize the nature of insurance business: – Cash on hand – Liability estimation – Duration of assets and liabilities Udaipur- 08.01.2011 Background for Sol II Their novelty compared with the current best practices The strategic nature of the problems Huge level of investment likely to be required to comply with the coming Solvency II framework The European Commission asked CEIOPS to launch a wide consultation process with the industry players The result: A first wave of 12 consultation papers was published on 26 March 2009 A second wave of 24 CPs was published on July 2009 A third wave of 17 CPs was published on November 2009 The outcomes from these consultations assisted CEIOPS in issuing final advices to the Commission The European Commission published QIS5 technical specifications on July 2010 Udaipur- 08.01.2011 Three pillar approach Pillar - I Pillar - II Pillar - III Financial Requirem ent Superviso ry review process Disclosur e& Market discipline Valuation of technical provisions and solvency requirements (SCR / MCR) Supervisory powers governance guidelines Udaipur- 08.01.2011 Disclosure requirements and supervisory reporting Risk Categories Risk Risk Investment Investmentrisk risk Market Marketrisk risk (Incl ALM) (Incl ALM) Credit CreditRisk Risk Underwriting Underwriting Risk Risk Life Life Risk Risk NonLife NonLife Risk Risk NonNon-financial financial risk risk Operational Operational Risk Risk Business Business Risk Risk Udaipur- 08.01.2011 Basic forms of Risk Management Risk Management Risk control Safety Control, prevention measures Risk financing Risk reduction Risk retention Withdrawal Risk Transfer Diversification Hedging Udaipur- 08.01.2011 Role of capital Why capital is required? – Capital is required to absorb extreme unexpected losses caused by various risks – Capital guarantees long term continuity Without continuity the insurer could not obtain future profits – When rating established by the rating agencies they also look at financial aspects of the insurer and the amount of capital – When their capital falls below certain limits it could have negative consequences for rating – Capital is also required to protect policyholders’ interest and thus protect the stability of the economic system Udaipur- 08.01.2011 Guiding Principles The guide is based on six main themes: Economic balance sheet Data management Standard formula (SCR solo and SCR group) Internal model Risk governance and supervisory review Disclosure Udaipur- 08.01.2011 Economic Balance Sheet In addition to the methods of valuation of the different components of the balance sheet, it is important to highlight an important principle reinforced in the first wave of consultation: – Convergence of the regulatory environment: CEIOPS has chosen a pragmatic approach by defining the economic valuation of the different components of the Solvency II balance sheet according to the IFRS principles Udaipur- 08.01.2011 10 Technical provisions The Solvency II framework directive will lead to major changes in the valuation of the balance sheet items compared to the current local GAAP and, in particular, in the valuation of insurance liabilities which will need to be undertaken on a market-consistent basis Technical provisions will typically be estimated on a proxy to a market value, i.e., a best-estimate basis allowing for the time value of money supplemented by a risk margin It will now become important that companies focus on the projection of future cash flows In projecting cash flows, companies need to bear in mind that: Cash flows should be estimated taking into account gross amounts recoverable from reinsurance contracts Cash flows should account for the full lifetime of existing insurance contracts and reflect policyholder behavior and management actions Udaipur- 08.01.2011 13 Technical Provisions CEIOPS has retained a cost-of-capital approach for the estimation of the risk margin with a rate of at least 6% It is important to note that in QIS5, the risk margin is calculated at an undertaking level and not at a line-ofbusiness level This means that undertakings will enjoy the diversification benefits between lines of business within the risk margin Should an undertaking decide to transfer a line of business, the contribution of each line of business to the risk margin can be allocated separately Udaipur- 08.01.2011 14 Internal Models The analysis of all measures relating to internal models (or models used for the parameterization of the standard formula) is a central element of the path towards Solvency II Features of internal model include : – – – – – – Assumptions for future management actions Process to be followed for the approval of an internal model Tests and standards for internal model approval Partial internal models Treatment of future premiums Segmentation for the calculations Udaipur- 08.01.2011 15 Main challenges for internal models The need to have the internal model approved before being allowed to use it for regulatory solvency requirements is a major development for the teams working on capital models Use test Statistical quality Calibration The need to show that the internal model is clearly relevant and integrated into daily risk management and decision-making process The settings of the internal model (data, assumptions, methods, tools) must be accurate and credible The internal model must be consistent with SCR framework (i.e., at least a 99.5% confidence level over a one-year time horizon) Udaipur- 08.01.2011 16 Steps to follow for the completion of an approval application Based on the experience of developing actuarial models, the documentation for the approval process needs to be produced along with the development and the validation of the model The documentation would also include information gathered during discussions with the supervisor in the context of the pre-application process Udaipur- 08.01.2011 17 Governance and supervisory review Adequate and operational structure Clear allocation of tasks and responsibilities Transparency of the organization Efficient information systems on all business activities Internal control and internal audit are largely defined and required in the current regulatory environment in a similar way to that set out in the Solvency II directive Risk management and actuarial functions already exist but are not properly defined; hence there should be some significant changes with Solvency II Udaipur- 08.01.2011 18 Governance and supervisory review The main changes within the Solvency II directive in terms of governance are: Requirement of formal governance in order to implement efficiently policies decided by the management body Requirement of a full system of governance ensuring: – – – Identification, assessment and management of risks Efficient communication of information Reporting of a consolidated view of the risks Udaipur- 08.01.2011 19 Risk management and actuarial functions - ambiguous roles For the risk management function, CEIOPS prescribes (for large companies) the creation of a chief risk officer (CRO) who will be responsible for: Leading the risk management function Reporting the risk exposure to the administration and business operation Maintaining a consolidated view of the risks through the ORSA (own risk and solvency assessment) CEIOPS recommends that the risk management function has leadership of the internal model in terms of conception, maintenance and management of results The actuarial function contributes to the implementation of the internal model Udaipur- 08.01.2011 20 Risk management and actuarial functions - ambiguous roles These recommendations not remove the ambiguities and difficulties of implementation: CEIOPS defines the actuarial function as the role of controlling and reporting technical provisions by means of an actuarial report: Coordination and control of the technical provisions valuation Statement of opinion regarding underwriting and reinsurance policies – the actuarial function should express an opinion independently from any other administration or business operation department This is another point where there are ambiguities in the roles of the risk management function and the actuarial function, in particular for the leadership on the best estimate reserves computation in the SCR calculation: The ownership of the model and the consolidated vision of the risks would mean that the calculation of the SCR (and hence of the best estimate reserves under Solvency II) should be the responsibility of the CRO This would appear to restrict the role of the actuarial function Udaipur- 08.01.2011 21 Own risk and solvency assessment (ORSA) principles The overall solvency needs taking into account the specific risk profile, approved risk tolerance limits and the business strategy of the undertaking The compliance with the capital requirements and with the requirements regarding technical provisions The extent to which the risk profile of the undertaking deviates significantly from the assumptions underlying the SCR, calculated with the standard formula or with its partial or full internal model The ORSA principles should be applied in a proportionate manner having due regard to the nature, scale and complexity of the activities of the undertaking concerned Udaipur- 08.01.2011 22 Lessons from Solvency II exercise for India Solvency II is unquestionably the most significant regulatory change for the insurance industry that is happening right now and continues to be widely reported in the industry press We have started the process of estimating economic capital and yet a long way to go for risk mapping and risk reporting One benefit of moving the effective start date to Jan 2013 would be to align the rules to the effective financial reporting year for most European insurers This would make life a bit easier for most firms but the reality remains that firms must be fully compliant from day one and implementation should already have started in all firms We are working on IFRS and this issue need to be addressed in future Solvency II is needed to strengthen the regulatory framework for insurers in Europe and enable both supervisors and firms to move on from the confines of an outdated European regime that stands in the way of the adoption of modern methods and the spread of best practice Our solvency regime is robust but there is no complacency in examining the alignment with accounting disclosure Udaipur- 08.01.2011 23 Lessons from Solvency II exercise for India Solvency II will fundamentally transform the capital adequacy and risk management regime for the European insurance industry The requirements for delivering and demonstrating the standards of risk management and governance will be challenging, and especially so for groups that operate in multiple countries We have already initiated this exercise It will require greater disclosure and transparency, together with additional and more frequent reporting We have already initiated disclosures and this will be strengthened in the light of our experience it puts robust risk management firmly at the centre of the new regime; insurers will be required to focus on the early identification, quantification and management of the risks that they face, or will face in the future, through the forward-looking Own Risk and Solvency Assessment We have already developed “early warning system” for life and this needs to be strengthened Shortly we will be finalizing the guidelines for non-life industry also Udaipur- 08.01.2011 24 Lessons from Solvency II exercise for India One consequence of the market consistent approach to the valuation of liabilities is that there will be no arbitrary prudence in technical provisions This needs a closer examination Solvency II is also very clear that the responsibility for the running of the firm rests firmly on the shoulders of senior management This means that senior management and the Board must be able to demonstrate they are fully in control of their firm and that they fully understand the risks that the firm is running, or might face in the future We have already positioned “corporate governance principles” and they need to be strengthened Another big shift in the regulatory landscape as a result of Solvency II means that there will be an increased focus on groups and the joint supervision of groups The supervisory colleges will play an increased role and this will mean an adjustment of the mindsets for supervisors under Solvency II This is not a pressing issue now, however we are addressing this Udaipur- 08.01.2011 25 Lessons from Solvency II exercise for India Insurers will also need to report more information, more frequently to their supervisors For example, under the new regime, it is likely that firms will need to report all their individual asset exposures to their supervisor every quarter This is a big change and the bigger the firm, and the more complex the investment strategy, the more work there will be to get this up and running We have already moved on this It is a fundamental precondition for the proper understanding of risks that they are measured on an objective and consistent basis It will be a big step forward for Europe to move to a common valuation basis It is absolutely necessary that the solvency capital requirement (SCR) and the minimum capital requirement (MCR), or internal models – will be based on the Solvency II balance sheet We have to initiate our own work on internal models Udaipur- 08.01.2011 26 Thank you Udaipur- 08.01.2011 27