SEAC Fall 2017 Meeting Valuation Seminar Wednesday, November 15, 2017

Transcription

1 SEAC Fall 2017 Meeting Valuation Seminar Wednesday, November 15, 2017 Shawn Parks, FSA, MAAA President, ARC GA Bob Crompton, FSA, MAAA Vice President, ARC GA

2 WARNING: Contents of this presentation under pressure. Shake well before using. Batteries not included. Some assembly required. Avoid prolonged exposure to this presentation. Void where prohibited. Use only as directed. This presentation may not be suitable for young children or accountants. Side effects are uncommon, but may include itching, redness, occasional fainting, and uncontrollable desire to sleep. If symptoms persist, discontinue use and consult a physician. No animals were harmed in the making of this presentation. Do not read this presentation while operating a vehicle or heavy machinery. This presentation may contain nuts. Objects in this presentation may be closer than they appear. Any resemblance between this presentation and others, especially good ones, is purely coincidental. Names have been changed to protect the innocent. This presentation is meant for educational purposes only. Prices higher in Alaska and Hawaii. Not intended as legal advice. The thoughts and opinions expressed are our own and do not represent the views of the NAIC, AAA, ASB, ARCGA, AARP, ACLU, or YMCA. Do not remove this disclaimer under penalty of law.

3 Regulatory Framework ASB Activities AAA Practice Notes

4 Statutory Regulatory Authority 4 Hierarchy 1. State Legislature / State Insurance Department 2. Statements of Statutory Accounting Principles (SSAPs) in NAIC Accounting Practices and Procedures Manual 3. Actuarial Standards of Practice (ASOPs) 4. NAIC Actuarial Guidelines (now part of VM) 5. AAA Practice Notes Regulatory Framework

5 Statutory Regulatory Authority 5 State NAIC AAA Laws Regulations Bulletins Valuation Manual APPM Actuarial Guidelines Model Laws and Regs ASOPs Practice Notes Regulatory Framework

6 NAIC Valuation Manual

7 Valuation Manual Standard Valuation Law As of Oct 2017, adopted in 47 States (not in AK, DC, MA, NY, PR) Valuation Manual adopted 2012; amended many times threshold (42 states; 75% premium) reached in 2016 effective for Life, A&H and deposit-type contracts issued January 1, 2017 and later company may defer until 2020 maintained by LATF and HATF Regulatory Framework

8 Valuation Manual 8 Examples of Risks included in PBR: Policyholder behavior Mortality Interest rate Asset default Separate account fund performance Performance of indices for contractual guarantees Examples of Risks not included in PBR: General business risks Those not associated with the policies being valued Regulatory Framework

9 Valuation Manual 9 I. Introduction II. III. IV. Reserve Requirements Actuarial Opinion and Report Requirements Experience Reporting Requirements V. Valuation Manual Minimum Standards Regulatory Framework

10 Valuation Manual 10 Company-Wide Exemption Less than $300m of ordinary life premiums, Group of life insurers less than $600m, Adjusted Capital 450% of authorized control level RBC, Appointed Actuary provides unqualified opinion, and Any Universal Life with Secondary Guarantee (ULSG) issued or assumed meets definition of non-material secondary guarantee Can be vetoed by Commissioner Regulatory Framework

11 Valuation Manual 11 V. Valuation Manual Minimum Standards VM-01 Definitions VM-02 Minimum Nonforfeiture VM-05 Standard Valuation Law VM-20 PBR for Life Products VM-21 PBR for Variable Annuities VM-22 PBR for Fixed Annuities (under development) VM-25 Health Insurance VM-26 Credit Life and Disability VM-30 AOMR VM-31 PBR Actuarial Report VM-50 Experience Reporting Requirements VM-51 Experience Reporting Formats Regulatory Framework

12 Valuation Manual 12 V. Valuation Manual Minimum Standards (cont.) VM-A CARVM/CRVM VM-C Actuarial Guidelines VM-G Corporate Governance VM-M Mortality Tables Regulatory Framework

13 Next Topic ASB Activities 13 Any Questions Before We Change Topics? Regulatory Framework

14 ASB Activities ASOPs Other

15 Actuarial Standards Board (ASB) Activities 15 Newly Adopted ASOP ASOP 52 Principle-Based Reserves for Life Products under the NAIC Valuation Manual (Oct 2017) effective for valuation dates Dec 31, 2017 and later Recent ASOP Revisions ASOP 21 Responding to or Assisting Auditors or Examiners in Connection with Financial Audits, Financial Reviews, and Financial Examinations effective for fiscal periods beginning on or after Dec 15, 2016 ASOP 23 Data Quality effective April 30, 2017 ASOP 24 Compliance with the NAIC Life Insurance Illustrations Model Regulation effective April 30, 2017 Regulatory Framework

16 Actuarial Standards Board (ASB) Activities 16 New ASOPs In-Process Modeling expected to be approved Dec 2017 Capital Adequacy Assessment 2 nd Exposure Draft (ED) expected early 2018 Setting Assumptions 2 nd ED expected Mar 2018; ETA 2019 Pricing Life Insurance and Annuity Products comment deadline for 2 nd ED closed on Oct 31; likely approval of final release Jun 2018 Regulatory Framework

17 Proposed Modeling ASOP 17 Definition of Model A simplified representation of relationships among real world variables, entities, or events using statistical, financial, economic, mathematical, or scientific concepts and equations. Uses of a Model Help explain a system Study the effects of different parts of a system Derive estimates Guide decisions Regulatory Framework

18 Proposed Modeling ASOP 18 Components of a Model Input delivers assumptions, parameters and data into model Processing transforms inputs into estimates Output translates estimates into useful business information Life Cycle of a Model Specification phase Implementation phase Production phase Regulatory Framework

19 Proposed Modeling ASOP 19 Key Concepts Make reasonable attempt to understand models developed by others If reliance on another actuary, be satisfied that he/she has applied the ASOP Is the model suitable for the intended purpose? Manage Model Risk through appropriate model governance Communicate results consistent with ASOP 41 Detailed section on Assumptions and Parameters Regulatory Framework

20 Proposed Assumptions ASOP 20 Source: SOA 2017 Annual Meeting Session 174 PD Regulatory Framework

21 Actuarial Standards Board (ASB) Activities 21 In-Process ASOP Revisions ASOP 17 Expert Testimony by Actuaries on agenda for approval at the March 2018 meeting ASOP 2 Non-guaranteed Charges or Benefits for Life Insurance Policies and Annuity Contracts 1 st ED expected Apr 2018 ASOP 11 Financial Statement Treatment of Reinsurance Transactions Involving Life or Health 1 st ED expected late 2018 ASOP 22 Statements of Opinion Based on Asset Adequacy Analysis by Actuaries for Life or Health Insurers task force just formed Regulatory Framework

22 Actuarial Standards Board (ASB) Activities 22 Other Activities Task Force on IFRS 17 Impact to U.S. formation approved Sep 2017 Task Force on Big Data formation expected to be approved Dec 2017 Regulatory Framework

23 ASOPs Relevant to Life Valuation 23 Regulatory Framework

24 ASOPs Relevant to Life Valuation 24 Applicability Guideline lists the following: 2,5,7,10,11,12,15,18,21,22,25,40,42,48 (add 52) Regulatory Framework

25 ASOP7 Cash Flow Testing 25 When to use cash flow testing Asset considerations Liability considerations Modeling Regulatory Framework

26 ASOP10 U.S. GAAP 26 Type of assumption Best-estimate Market-estimate PADs Regulatory Framework

27 ASOP11 Reinsurance 27 Consider all cash flows Consider reinsurance terms Regulatory Framework

28 ASOP 22 Asset Adequacy 28 Consider other applicable ASOPs Methods Other considerations Regulatory Framework

29 ASOP 40 XXX Deficiency Mortality 29 Model requirements X-factor classes Other considerations Experience reviews Regulatory Framework

30 AAA Activities Practice Notes

31 Recent AAA Practice Notes 31 Principle-Based Reserves (Final May 2017) Not current practice, but views of actuaries involved in PBR development Asset Adequacy Analysis (Final Sep 2017) Q103: Regulators suggestions for improvements in opinions and memoranda Section L (Q ): Impact of AG43, PBR, and Other Nonformulaic Valuation Standards Reinsurance (ED May 2017) Updates include Dodd-Frank, PBR, and AG48 Regulatory Framework

32 NAIC Activities Streamlining Project

33 Streamlined Actuarial Reporting 33 NAIC Project Companies currently submit up to 19 standalone reports Improving communication of information by avoiding repetition of data and facilitating data capture Summary-level reports and electronic links Pilot involved 10 companies and 7 states Regulatory Framework

34 References 34 NAIC ASOPs AAA Applicability Guidelines (a little dated) Practice Notes Regulatory Framework

35 Next Up Break! 35 If you ask questions now, you will be delaying the break Regulatory Framework

36 Financial Reporting Controls Some General Considerations But Mostly A Discussion of Spreadsheet Controls

37 Requirements for Creating Good Controls 37 Understanding of the Biz It helps to know the Biz processes too Consistency & Congruency w/ How Process Owners Work The Control Must Do The Thinking Not The Reviewer Controls

38 Spreadsheets The Black Hole of No Control Environment 38 Controls

39 Desktop App vs. Macros 39 Control Environment No uncontrolled changes Ease of Distribution Technology vs. Wrecknology Multi-threaded application No need to convert files to *.xlsm Controls

40 See the Article for Supplementary Information 40 Controls

41 Formula Listing 41 Metrics For Formula Count For Each Worksheet Controls

42 Formula Listing 42 Auto-fit this column & scan for formulas that fill the column Listing of All Formulas in One Place Worksheet Name Cell Formula Current Value Formulas w/ constants are highlighted with RED fill and WHITE font. There are 312 occurrences of constants. 1 Reserve Summary C9 ='Trad'!D45 197,103,261 2 Reserve Summary D9 ='Trad'!E45 193,331,261 3 Reserve Summary E9 ='Trad'!F45 193,943,838 4 Reserve Summary C10 ='Bank'!N72-'Bank'!N83 1,327,193,384 5 Reserve Summary D10 ='Bank'!O72-'Bank'!O83 1,394,889,616 6 Reserve Summary C11 ='Acquired'!N15 41,374,518 7 Reserve Summary D11 ='Acquired'!O15 35,436,540 8 Reserve Summary S9 =AVERAGE(OFFSET(OFFSET(Q9,0,0,1,-2),0,0,1,-$S$7)) 180,336,812 9 Reserve Summary S10 =AVERAGE(OFFSET(OFFSET(Q10,0,0,1,-2),0,0,1,-$S$7)) 1,978,348, Trad Q8 =16394*0.98*0.98*0.98*0.98*0.98*0.98* , Trad Q11 =38832*0.98*0.98*0.98*0.98*0.98*0.98*0.98*0.98*0.98*0.98*0.9 29, Trad Q24 =P ,500, Acquired C26 =#REF! #REF! 14 Acquired D26 =#REF! #REF! Controls

43 Tracking Hard-Coded Entries 43 Simple Option Highlight Hard-Coded Numbers Controls

44 Tracking Hard-Coded Entries 44 More Sophisticated Allow Spreadsheet User to Search & Replace if Appropriate Controls

45 Generalized Search & Replace 45 SEARCH & REPLACE CAN BE APPLIED TO ANY SPECIFIABLE EXCEL RANGE! Cells with value > threshold Error cells Formulas that include hard coded values Cells with specified formatting Cells that contain the string S-E-X Controls

46 Generalized Search & Replace 46 WE VE MADE SEARCH & REPLACE EVEN BETTER! Now with user-selected focused-search Controls

47 Dependencies & Validation Controls 47 Some EUC Standards Specify Validation Controls on Manual Inputs. Reviewing Dependencies Helps Determine Appropriate Validation Limits, Such as N Rather Than No Controls

48 Downstream Dependencies aka Reverse Links 48 There is NO EASY WAY to determine downstream dependencies, but you can construct automation to perform checking Controls

49 Links Listing 49 A compilation of all links in a workbook allows comparison with prior period links, making review of updates easier. Controls

50 Next Topic GAAP Update 50 Any Questions Before We Change Topics? Controls

51 GAAP Update FASB Exposure Draft on Long Duration Contracts Issued 9/29/2016

52 Targeted Improvements in Long- Duration Contracts 52 GAAP Update Targeted Improvements

53 Targeted Improvements in Long- Duration Contracts 53 Effective Date Not yet determined GAAP Update Targeted Improvements

54 Targeted Improvements in Long- Duration Contracts 54 Reserve Changes Retrospective unlocking Discount Rates pegged to market DAC Changes Simplification of amortization No loss recognition Additional Liabilities Additional Disclosures GAAP Update Targeted Improvements

55 Targeted Improvements in Long- Duration Contracts 55 Reserve Changes Annual Unlocking Applied retrospectively Cumulative catch-up in earnings Revised net premium ratio applied subsequently Limitations Net premium ratio <= 100% No negative reserves Gone! PADs use estimates of expected experience Loss Recognition Testing GAAP Update Targeted Improvements

56 Targeted Improvements in Long- Duration Contracts 56 Reserve Changes Discount Rates Based on high-quality fixed income yields Maximize the use of market observables Reflect the liability duration Balance Sheet Update the discount rate every year Change goes through OCI Income Statement reserve accretion rate held constant GAAP Update Targeted Improvements

57 Targeted Improvements in Long- Duration Contracts 57 DAC Changes Simplified Amortization According to in force No interest accretion Prospectively update for changes in expected lapses Reduce DAC when A/E in force < 100% Not Applicable to Investment Contracts GAAP Update Targeted Improvements

58 Targeted Improvements in Long- Duration Contracts 58 Additional Liability for Benefit Features New Category of Liability Market Risk Benefits Applicable to Separate Account Products Where Insurer Has More Than Nominal Market Risk Valued at Fair Value Some Changes in Reserve Go Through OCI, Balance Through Normal Income GAAP Update Targeted Improvements

59 Targeted Improvements in Long- Duration Contracts 59 Disclosures Dis-aggregated roll-forwards Qualitative & quantitative info Reconciliation to the carrying amount & certain income statement activity Disclosures for various liabilities Future p/h benefits & additional liability Market risk benefits P/H account balances GAAP Update Targeted Improvements

60 Big 4 Comment Letter Results 60 View of Different Aspects of Exposure Draft DT EY KPMG PwC Retrospective Reserve Unlocking Proxy Discount Rates Discount Rate Update DAC Simplification DAC Expunge Impairment Testing DAC Include Investment Contracts Par Policy Treatment Market Risk Benefits GAAP Update Targeted Improvements

61 Big 4 Comment Letter Results 61 Comments on Additional Items Deloitte EY Provide additional guidance on wtd. avg. q(x) & w(x) Provide instructions / examples on FX rollforwards Consider feedback on costs/benefits of disclosures Many specific concerns regarding disclosures Concern on market risk benefit liability disclosed separately GAAP Update Targeted Improvements

62 Big 4 Comment Letter Results 62 Comments on Additional Items KPMG PwC Disclosures about undiscounted items & average q(x) & w(x) may not provide much value Market risk benefit liabilities should be disclosed similarly to other fair value instruments Disaggregation of DAC no longer provides meaningful information None GAAP Update Targeted Improvements

63 Next Topic PBR Assumptions 63 Any Questions Before We Change Topics? GAAP Update Targeted Improvements

64 PBR Assumptions for Valuation Requirements & Challenges

65 Assumptions 65 VM-01 Definitions VM-05 Assumptions Discussed in a General Way VM-20 Section 3 C. Net Premium Reserve Assumptions VM-20 Section 9 - Titled Assumptions VM-21 Assumptions for VA s, As Well as Disclosure Requirements VM-31 PBR Report Includes Requirements for Assumption Disclosure PBR Assumptions

66 General Requirements for Assumptions 66 Prudent Estimate Assumptions = Anticipated Experience + Margin Based on Company Experience Where Relevant & Credible Use Industry Experience With Adjustments As Needed PBR Assumptions

67 General Requirements for Assumptions 67 Must Perform Sensitivity Tests Annual Review & Update As Required PBR Assumptions

68 Mortality Assumptions 68 Exposure period limited to between 3 & 10 years Must define mortality segments Credibility methods defined Rules for combining segments to increase credibility PBR Assumptions

69 Credibility 69 Where industry basic table = 2008 VBT Limited Fluctuations, Bühlmann Empirical Bayesian, or other Where industry basic table = 2015 VBT Limited Fluctuations or Bühlmann Empirical Bayesian Apply one method only to all biz approval needed to change methods Apply to entire exposure period no variation by duration PBR Assumptions

70 Mortality Margins 70 Prescribed margins applicable to experience tables & industry basic tables In some situations, margin > prescribed PBR Assumptions

71 Policyholder Behavior & Misbehavior Assumptions 71 Presumed to be defined by scenario unless evidence that it can be modeled statically Extreme misbehavior assumptions not required Must assume increasing policyholder efficiency Margins required Required Sensitivity Testing PBR Assumptions

72 Expense Assumptions 72 Stochastic expenses = deterministic expenses + variation for inflation No expense efficiency improvements allowed Must use fully allocated expenses Margins required PBR Assumptions

73 Investment Assumptions 73 Reasonable in light of ALM strategy Scenario generator Prescribed default and spread assumptions Must pay attention to reinvestment and rebalancing PBR Assumptions

74 Challenges 74 DEFINITION 2.1 Anticipated Experience Assumption An expectation of future experience for a risk factor given available, relevant information pertaining to the assumption being estimated PBR Assumptions

75 Challenges 75 THE PATH FROM EXPERIENCE STUDIES TO ASSUMPTIONS IS NEVER STRAIGHT Granularity of assumptions vs experience Smoothing Trending Applicability Industry data Under-determined items such as policyholder efficiency PBR Assumptions

76 Challenges 76 WHAT DOES EXPECTATION OF FUTURE EXPERIENCE REALLY MEAN? Problem or Opportunity? PBR Assumptions

77 Another Challenge - Professional Judgment 77 Professional Judgment Mentioned in Several Places** Disclosure Requirements for Professional Judgment VM 31 Section 3 C.7.a PBR Report Requirements Description of the method used to determine anticipated experience assumptions for each material risk factor, including the degree to which the assumptions are based on experience versus actuarial judgment or other factors, and the source of the experience (e.g., company experience versus industry study). ** The Valuation Manual seems to use Professional Judgment and Actuarial Judgment interchangeably PBR Assumptions

78 FINIS 78 Questions / Comments PBR Assumptions