CAPITAL ADEQUACY AND SOLVENCY

Transcription

1 CAPITAL ADEQUACY AND SOLVENCY The views of a Multinational Life Insurer Keith Weaver SVP & CFO, Asia Manulife Financial October 28, 2004

2 Manulife Financial #2 Insurance company in North America based on market capitalization Head Office Toronto, Canada Direct selling operations in Canada, USA, Japan, Hong Kong, Philippines, Indonesia, PR China, Taiwan, Malaysia, Vietnam, Singapore, Thailand Merged with John Hancock in 2004 Biggest impact on North America In Asia, biggest impact on Singapore with additional minority interests in Malaysia, Thailand, China 2 Indonesia, Philippines were small and merge easily into Manulife s local companies

3 Solvency #1 priority of regulators is to ensure that companies can meet their obligations 3

4 Solvency Appropriate reserves must be set up AND Suitable additional capital should be held to meet unforeseen circumstances (Solvency Margin) 4

5 Solvency Margin The size of the required solvency margin should be related to the risks inherent in the insurer s balance sheet The size of the required solvency margin should take into account the conservatism included in the valuation basis Manulife supports regulatory approaches that define sensible reserves and a required solvency margin 5

6 Shareholder Returns Overly conservative reserves or capital discourages investment Shareholders expect adequate returns on investment Investment is both strain on new business and regulatory capital 6

7 Valuation / Capital Flaws Design can t be perfect but. Design flaws can increase risk Flaws can create non-level playing field Flaws can distort statutory income Flaws can affect S&P Ratings Valuation basis and capital requirements should be complementary 7

8 CGAAP Valuation Overview Gross premium reserves Explicit assumptions New CALM requires explicit asset modelling All benefits are valued including policyholder illustrated dividends Assumptions: best estimates plus margins Benefits: can monitor assumptions etc. Benefits: reasonable earnings patterns Requires extensive actuarial expertise 8

9 Canadian Capital Overview 9 MCCSR: Minimum continuing capital solvency requirement Detail factor approach: Types of risk (asset default, mortality, etc.) Covers negative reserves / CSV deficiencies Rules on forms of capital Benefits to insurer: clear cut rules (altho complex). Benefits to regulator: Can monitor ratio and take action Can fine tune for new risks

10 Risk Based Capital Manulife prefers Risk Based Capital Detailed factor approach (e.g. MCCSR) is better than Composite approach Traditional simplified solvency ignores risk and doesn t require valuation of all benefits (e.g. Terminal Dividends) 10

11 Necessary Conditions for RBC Regulator expertise Professional body of actuaries Developed capital markets Stable practices in local insurance market 11

12 RBC Issues Actuarial work intensive - difficult for small life companies Precision is misleading Creative tension on levels and factors 12

13 Manulife supports single international accounting and valuation model for life insurance plus Standardized RBC approach BUT This will be difficult! 13

14 Problems for Multinational Insurers Filings on multiple bases Some multinational insurers are impacted by double solvency standard (home country + local) Typically occurs when home jurisdiction looks at consolidated solvency (vs local regulatory focus on local solvency) This can create many anomalies in treatment of essentially similar products and risks 14

15 Problems for Multinational Insurers Companies subject to double regulations are at competitive disadvantage since they are subject to additional constraints Uneven playing field is concern with no uniform approach to consolidated regulation RBC should be on local operations only at this time 15

16 Holding Companies Companies establish legal structures for several reasons (limited liability, taxes, etc.) Global approach must distinguish between Holding Companies and Operating Companies RBC metrics should focus on operating companies Risk evaluation for holding companies should be based on risks at that level 16

17 Perils of Global Approach to Regulation Regulators in one jurisdiction often do not understand other markets Products can be quite different Investment climate can be quite different Regulators should focus on their own jurisdiction 17

18 Two Tier Approach Simple RBC measure for small companies More sophisticated RBC methodology for those companies able to develop appropriate models 18

19 Risk Diversification RBC formulas should recognize risk diversification Key way of controlling solvency risk 19

20 Financial Reinsurance Regulators should be wary of giving too much credit for financial reinsurance Companies can reinsure the safe risks and only retain the marginal risks Issue recognized by OECD Manulife supports regulation of FinRe in order to ensure industry soundness and consistency of regulation. 20

21 RBC Must Have Teeth Objective is to avoid insolvencies RBC must be adequate and strongly enforced Exceptions should not be granted 21

22 Manulife strongly prefers a strong RBC regime to a reliance on policyholder protection funds! 22

23 Policyholder Protection Funds RBC must be in place before PPF is introduced RBC allows regulator to monitor financial condition of insurers Action can and should be taken before serious losses occur Result: minimal claims on PPF Objection (strong companies supporting weak companies) to PPF are minimized 23

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