Tag Archives: Europe

Can a bonus malus system evaluate motor liability insurance risk better?

Under a bonus malus system, motor liability insurers can adjust policyholders’ premiums based on individuals’ claims histories. For instance, a customer may receive a reduction, or “bonus,” on a premium if no claim is made during the previous year. Conversely, the customer may receive a premium increase, or “malus,” if a claim is made during the previous year.

In this article, Milliman actuary Diana Dodu provides an analysis of bonus malus systems in several European countries. She highlights the similarities and differences between the system designs in each country.

Here is an excerpt:

• Countries that do not have a specific system defined by law, such as Poland, where the system is fully liberalised and insurers have the liberty to provide own risk coefficients and load back the premium to obtain balance; Estonia, where insurers can design their own rules and where it may seem that the maximum bonus can be achieved within several years of claims free driving; and Lithuania, where according to the Law on Compulsory Motor Third Party Liability Insurance effective from 17 May 2007, premiums are fixed by the insurer and companies can take into account risk factors.

• Countries where the bonus malus system is defined in the legislature, requiring insurers to take into consideration loss history, but which grant freedom to insurance companies to design their own rules, which is present in countries such as the Czech Republic and Slovakia.

• Countries that are regulated by law, such as Italy and Romania… and Hungary, where according to law NGM 21/2011, the number of classes are predefined as well as movement between classes depending on the number of accidents, and insurers are obligated to issue accident and claim certificates, but are also allowed to use historical data for the purposes of classification to calculate additional correction factors, and Serbia, where the bonus malus system is defined in the law on compulsory traffic insurance but insurers can use correction coefficients if they do not contradict the ones mandated by law.

• Countries such as Croatia, where there seems to be a defined system, but companies offer extra benefits such as additional bonuses above the maximum and protection of the bonus (after several years of no claims, insureds can pay an additional premium to protect the bonus in case they have an accident in the subsequent year), and Slovenia, where you can also protect your bonus, while the future premium in cases of protection of the bonus would depend on the number of accidents in past periods.

• Latvia, where companies can set premiums based on prior histories with a conversion system in which it seems that it is more difficult to move towards bonus classes and where the system is evaluated annually (on September 15).

Milliman analysis shows uncertain future for embedded value reporting in European insurance market

Milliman has announced the availability of a new report detailing embedded value (EV) results for 19 major insurance companies in Europe. The report examines trends among the companies reporting EVs as of year-end 2016, comparing practices adopted and discussing reporting issues following the implementation of Solvency II in Europe and the move toward the global adoption of International Financial Reporting Standards (IFRS).

“The future of embedded value reporting in Europe remains uncertain—although there has been increased alignment between EV and Solvency II reporting, we have continued to witness a gradual reduction in the number of firms reporting on an EV basis,” said Philip Simpson, a principal and consulting actuary in Milliman’s London office. “And with Solvency II disclosures via the SFCR lacking information around new business or analysis of change, for example, there is potentially a void appearing in the level of granularity of financial information reported.”

The release of the final IFRS 17 standard in May 2017 could signal an alternative reference point for Market Consistent Embedded Value (MCEV). And with substantial disclosure requirements involved, this may allow a sufficient amount of information to be obtained about the profitability of the business. However, the preparation of accounts under IFRS 17 gives rise to a different interpretation and timing of profit and loss compared with an EV basis, which will need to be considered. Ultimately time will tell whether companies use Solvency II or IFRS 17 as the reference point for MCEV.

Key insights from the European report include:

• There has been an ongoing, though moderate, reduction in firms reporting on an embedded value basis in 2016 compared with 2015.
• An amendment to the European Insurance CFO Forum Market Consistent Embedded Value Principles© (the MCEV Principles) was issued in May 2016, which permits the use of the projection methods and assumptions for market-consistent solvency regimes (e.g., Solvency II) in EV reporting. In light of this, during 2016 companies continued to change their approaches, with a continued trend to align EV and Solvency II reporting.
• The CFO Forum members (that disclosed their embedded values at the end of 2016) reported a combined embedded value of GBP 263 billion (EUR 308 billion) at the end of 2016 compared with GBP 246 billion (EUR 288 billion) at the end of 2015. Experience amongst the companies studied was mixed, with around half of companies experiencing an increase in embedded value compared with 2015.
• Overall, results for new business were fairly positive for the majority of companies in the report. The total value of new business (VNB) written by the current CFO Forum members (that disclosed their values of new business at the end of 2016) was GBP 11.3 billion (EUR 13.3 billion) in 2016, compared like-for-like with GBP 10.1 billion (EUR 11.9 billion) in 2015.

To download the report, click here.

Choosing a location for insurance or reinsurance companies

In the wake of recent Brexit developments, many United Kingdom (re)insurance entities are assessing their options. This briefing note by Michael Culligan, Patrick Meghen, and Ciarain Kelly discusses some of the key considerations for companies when deciding on a location and looks at Ireland as a sample location. It provides information on the application process, drawing on extensive experience of past and current licence applications.

Compliance risk: Box-ticking or ticking all the boxes?

‘Box-ticking’ can be a phrase synonymous with poor practice in Enterprise Risk Management (ERM). When poorly executed it can mean going through the motions to display minimum levels of compliance, rather than engaging in any meaningful activity that would deliver any real benefit. Such an approach is not encouraged by regulators.

However, do companies, and indeed individuals, spend enough time making sure they have ticked all the boxes from a compliance perspective? This is an activity that regulators certainly encourage.

With the general direction of regulatory oversight and the formality of Solvency II, companies and boards are now confirming compliance in many areas. There is a risk that the compliance process itself becomes a risk. Compliance risk is one of those intangible issues that can’t be quantified using actuarial models or managed through setting aside capital. It is a risk that is dealt with on a qualitative basis and is managed and controlled rather than measured and capitalised. This means that managing compliance risk might not be front of mind for many companies, especially with such a focus on capital amounts and getting the numbers “right”.

This becomes even more apparent at this time of year, when statutory sign-offs and certifications come into play. If you are being asked to put pen to paper to certify compliance or sign-off on the accuracy of regulatory submissions, how do you know that all the requirements have been adequately met?

The implementation of Solvency II significantly increased the amount of requirements and guidance that companies and individuals have to follow in relation to certifying solvency. This is in addition to increased compliance in other areas over the last number of years, including the Corporate Governance Code in Ireland, policyholder disclosures, etc. A lot of governance tasks that would have developed over time based on industry knowledge and practical sense now have to run the rule against a checklist or a set of requirements.

The very nature of financial reporting is changing to fit this new world. Getting the numbers right is no longer enough, you now also have to evidence how you ensured the figures are accurate and reliable and not misleading. In a Solvency II world the sheer number of requirements (and the very prescriptive and specific nature of some of them) means that the only way to be sure that each and every requirement is covered is to sit down and mark each item off. It is boring, and it doesn’t feel particularly efficient or creative—but it is disciplined and leads to identifying areas for improvement. Going through this value-adding process of identifying and closing gaps in a systematic way clearly is valuable and can help you spot patterns over time. It is also the best way of documenting and demonstrating compliance.

Being able to demonstrate compliance is also a defensive requirement in this new Solvency II world. If an issue arises or a query is raised by a regulator, the drawbacks of ignoring compliance checks quickly become apparent. Your ability to defend what you do now from a challenge in the future depends on your audit trail. So as a parting thought—don’t be afraid to spend some time ticking boxes. It might be more valuable that you think.

The Milliman Solvency II Compliance Assessment Tool distils the Solvency II requirements into easily digestible self-assessment questions and allows insurers to track and evidence their compliance with all the requirements of Solvency II. The tool is already being used by 25 entities in Ireland and the UK. For more information click here.

The emergence of lapse risk transfer

This blog post is part of an ongoing series of blog posts on capital efficiency. To see past posts in this series, please click here.

In recent months, we have seen the emergence of lapse risk reinsurance following the introduction of Solvency II. Lapse risk is one of the key risks that life insurers, and particularly unit-linked life insurers, are exposed to and it is a key component of the Solvency II Solvency Capital Requirement (SCR) for many life insurers. One of the benefits of lapse risk reinsurance is that it can be used to reduce the life underwriting risk capital charge, in addition to reducing the undertaking’s exposure to lapse risk. Many reinsurers are active in this area, and as undertakings begin to consider Solvency II capital efficiency in more detail, it may be an area where we will see further growth during 2017.

Reinsurance treaties
The nature of lapse risk transfer will depend on the most material lapse risk exposure of the cedant—either mass lapse, lapse up, or lapse down.

The mass lapse scenario under Solvency II is calibrated as an instantaneous loss of 40% of the in-force business (for retail business). While the actual occurrences of mass lapse scenarios are difficult to predict, the risk of lapses exceeding 20% to 30% in a given period may be low based on historical data. Reinsurers can therefore offer treaties that cover losses caused by lapses in excess of 20% to 30% in a given period, often setting a maximum threshold of 45% to 50%. In reinsurance parlance, the reinsurance treaty attaches at a level of 20% or 30% and detaches at 45% or 50%. The relevant period would be defined in the reinsurance treaty. The cedant would retain the risk exposure to lapses below the attachment point and above the detachment point.

We are also aware of some reinsurers considering lapse up and lapse down reinsurance. However, there may be significant practical challenges associated with lapse reinsurance of this nature, in particular with regard to defining when an increase or decrease from the long-term average, or best estimate, lapse rates has occurred.

Considerations
There are a number of general considerations in respect of lapse risk reinsurance (as well as other potential considerations, depending on the specific terms of an individual treaty). First of all, there is the premium charged by the reinsurer for transferring lapse risk. The cost is generally set with reference to the reduction in SCR achieved by the transaction. We understand that costs generally vary between around 2% to 3% per annum of the reduction in the lapse risk SCR, depending on the type of deal and the availability of data.

Buy-in from the regulators will be key for these contracts to be effective. There is likely to be a concern that reinsurance could be used to reduce the SCR without a real reduction in the underlying risk. It is difficult to argue that there is no reduction in lapse risk exposure in the example attachment points outlined above. However, it may be more difficult to justify real risk transfer where the treaty is set up in such a way as to only indemnify insurers when a mass lapse of exactly 40% occurs.

Other considerations include the following:
• The interaction between the different lapse risk components of the SCR needs to be considered. If the risk exposure to mass lapse is reduced through the use of reinsurance, the lapse up or lapse down risk module may bite instead. Therefore, the impact of mass lapse reinsurance will be limited to the margin over which the mass lapse SCR capital charge exceeds the next-highest lapse risk capital charge. Understanding this interaction will be an important factor in determining the optimal attachment point for a mass lapse reinsurance treaty.
• Reinsurance introduces additional risks to the balance sheet such as counterparty risk, which is also considered in the Solvency II SCR calculation.
• The impact of such a transaction on the financial statements or International Financial Reporting Standards (IFRS) balance sheet should also be considered.
• If the reinsurance contracts are short-term in nature, there may be a risk associated with getting renewal terms on the same basis.

An alternative
Insurance-linked securities offer an alternative approach to transferring risk compared with traditional reinsurance. Under these transactions, insurance risk is effectively securitised and bought by capital investors through an investment fund. We are aware of a number of insurance-linked security firms that are active in transferring lapse risk.

The solutions can be structured in a similar way to traditional reinsurance deals in terms of attachment and detachment points, although the deals tend to be longer in term than traditional reinsurance contracts (circa three to five years, as opposed to 12 to 18 months). This provides additional benefits in terms of impact on the Solvency II risk margin and also may be more preferable to regulators than short-term contracts. However, this results in slightly higher costs compared with traditional reinsurance deals.

One disadvantage is that insurance-linked security firms generally do not have credit ratings, which can result in a high capital charge for counterparty risk under Solvency II. However, it is possible to reduce this through the use of collateral.

A harmonized EIOPA Recovery and Resolution Framework discussion paper

king-eoinOn December 2, the European Insurance and Occupational Pensions Authority (EIOPA) issued a discussion paper on “Potential Harmonisation of Recovery and Resolution Frameworks for Insurers.” The paper sets out a number of considerations for the development of a harmonized European framework in the recovery and resolution planning space. It is open to comments from stakeholders until February 28, 2017.

Recovery and resolution planning is a very topical subject at present and there are numerous examples of requirements for financial services companies and regulatory authorities to develop recovery and resolution plans and frameworks. For example, larger financial institutions that are classified as globally systemically important financial institutions (G-SIFIs) and globally systemically important insurers (G-SIIs) are required to undertake recovery and resolution planning under the Financial Stability Board’s “Key Attributes of Effective Resolution Regimes for Financial Institutions” and similar requirements adopted by the International Association of Insurance Supervisors. This is also an area of focus for European regulators. In Ireland, for example, Sylvia Cronin, Director of Insurance Supervision at the Central Bank, noted at the European Insurance Forum in March that recovery and resolution for insurers is an area of particular interest for the Central Bank.

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