IFRS Task Force presentation to NAIC

Similar documents
International Accounting Issues

The Actuarial Society of Hong Kong CASH FLOWS Insurance IFRS Seminar. Bill Horbatt. Session 7

IASB Insurance Contracts Phase 2 Status and IAA Role. November Hyderabad

IASB s Insurance Contracts Exposure Draft: Risk in the Next Decade

IFRS4 An Update. PwC. *connected thinking. Presented by Shu-Yen Liu 7 th November 2007

Society of Actuaries Liability Modeling Project. IASB s Insurance Contracts Exposure Draft: Where are we now? Where are we going?

7 th International Professional Meeting of Leaders of the Actuarial Profession and Actuarial Educators in Central and Eastern Europe

SOA Research Paper on the IFRS Discussion Paper

International Financial Reporting Standards Updates. Joint Regional Seminar on Financial Reporting, June 2006

Cash Flows Included. Darryl Wagner, FSA, MAAA. Insurance IFRS Seminar December 1, 2016 Darryl Wagner. Session 11

IFRS 17 beyond implementation, towards commercial implications

International Financial Reporting Standards (IFRS) Update Life

June 30, Technical Director Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk, CT Dear Ms.

FASB / IASB Insurance Contracts Project Update Webinar

IFRS Insurance Contracts. The state of play or, what is really going on?

NEW EXPOSURE DRAFT IFRS 4 - PHASE , Novembre 7

FRS 104 Insurance Contracts

Future GAAP. Doug Van Dam, FSA, MAAA Principal Consultant msg global solutions, Inc.

financia fin ancia REporting changes chan

INTRODUCTION. Insurance Contracts ITC Comment Letter Summary Final_2.doc 1

The Actuarial Society of Hong Kong IFRS Insurance Contract Phase II Development

Life 2008 Spring Meeting June 16-18, Session 94, Impact of IFRS Insurance Accounting. Moderator Simon R. Curtis, FSA, FCIA, MAAA

Re: Review of International Standard of Actuarial Practice 4 IFRS 17 Insurance Contracts Exposure Draft

Re: NAIC Property and Casualty Reinsurance Study Group s Proposed Changes to Reinsurance Interrogatories

Presentation of items of Other Comprehensive Income

Auditor s views on IFRS 17 Insurance contracts. EFRAG Board meeting 20 March 2018

Article from: Taxing Times. May 2011 Volume 7 Issue 2

IASB /FASB Meeting 10 February A. Reinsurance. Purpose of this paper

Risk Transfer Accounting. Casualty Loss Reserve Seminar

General insurance reserving

IFRS 4 Phase 2 Insurance contracts Update on the industry s response. December 2, 2010

RECENT INTERNATIONAL ACCOUNTING DEVELOPMENTS. Bob Buchanan Dave Finnis Greg Martin

IASB FASB. IFRS in the US. International Accounting and Progress on a New Insurance Accounting Standard

Practical guide to IFRS 23 August 2010

IFRS 4 Phase I and II:

Accounting Update: ASU Charles Lenz, Perr & Knight Sean Nakamura, Accuity LLP Gordon Tom, KMH LLP

Comment Letter No. 44

FASB provides preliminary views on insurance accounting

May 21, 2008 Document

IFRS and Solvency* PD *connectedthinking

Session 143 PD, IFRS Hot Topics. Moderator: R. Thomas Herget, FSA, CERA, MAAA. Presenters:

FRC Roundtable on IASB Revised ED Insurance Contracts

Session 143 PD, IFRS Hot Topics. Moderator: R. Thomas Herget, FSA, CERA, MAAA. Presenters:

111~IIW~I~n~t LEDER LETTER OF COMMENT NO. \ 0 \\J. Telephone (441) International Internationa! Accounting Standards Board.

Implications of Exposure Draft IFRS 4 Phase II and its Implementation

Life 2008 Spring Meeting June 16-18, Session 67, IFRS 4 Phase II Valuation of Insurance Obligations Risk Margins

Study of Alternative Measurement Attributes with Respect to Liabilities

Aggregate Margin Task Force: LATF Update

ASSOCIATION ACTUARIELLE INTERNATIONALE INTERNATIONAL ACTUARIAL ASSOCIATION

TITLE. Presentation Points Convergence in Financial. Additional Points Additional Points. Reporting

Overview of IFRS17. David Burton

The New Risk-Based Capital

Agenda papers for this meeting 1. We have prepared the following agenda papers for this meeting:

A Way Forward for Participating or Discretionary Benefits

Katie Campbell, FSA, MAAA

US GAAP Update What s New

Introduction to IFRS November 2018

Is the Best Estimate Best? Issues in Recording a Liability for Unpaid Claims, Unpaid Losses and Loss Adjustment Expenses. Jan A.

Questions: Who does the agent work for? What was the agent doing at the time of the incident?

Insurance Regulation State or Federal Which Works Best?

NAIC Fall Meeting. December Issues & Trends. kpmg.com/us/frv

IFRS 4 PHASE II DRAFT INSURANCE CONTRACT STANDARD OCI PRESENTATION AS

Article from: The Actuary Magazine. April / May 2015 Volume 12, Issue 2

IFRS 17 and its business implications. What is IFRS 17 and how it is going to change the life of accountants and actuaries

U.S. GAAP & IFRS: Today and Tomorrow Sept , New York. Insurance Contracts Phase II Exposure Draft

Insurance Contracts Project: User Feedback

Framework for a New Standard Approach to Setting Capital Requirements. Joint Committee of OSFI, AMF, and Assuris

Small Company Asset Adequacy

Introduction to International Financial Reporting Standards

The future of insurance accounting preparing for change

IFRS 4 Phase 2 Exposure Draft. 15 January 2014

GAAP Insurance Contracts Project - Life

11/17/2009. Introduction. Outline. Principles-Based Reserving Education Session 7:30-9:00 Maryland Ballroom D. NAIC 2009 Fall National Meeting

ASSOCIATION ACTUARIELLE INTERNATIONALE INTERNATIONAL ACTUARIAL ASSOCIATION EXPOSURE DRAFT FEBRUARY 23, 2007

Solvency II overview

ACTUARIAL ASSOCIATION OF EUROPE

Insurance alert Highlights

November 27, Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT

Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH. 25 October Dear Mr Hoogervorst,

January 30, Dear Mr. Seeley:

NAIC Bulletin Highlights of the National Association of Insurance Commissioners meeting

Accounting & Auditing Update: What changes are in store for your Company

Sailing a Course through Risk Margins

Separate Accounts for Life/Annuity Insurance Companies 3.15 Summary 3.19

to edit Master title style

CEIOPS-Secretariat Committee of European Insurance and Occupational Pensions Supervisors Westhafenplatz Frankfurt am Main Germany

October 25, Mr. Hans Hoogervorst International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom

Kurt Wolfsdorf, President October 16, 2013 Taipei

The Actuarial Society of Hong Kong RISK ADJUSTMENT Insurance IFRS Seminar. Chris Hancorn. Session 11

Article from: Reinsurance News. March 2004 Issue No. 53

Once upon a time life was simple (in Sweden anyway).. Two products on the market Pension Endowment All companies had same product specifications All

Insurance contracts. Agenda. Overview of IASB and FASB s proposals on insurance. Presenters/Administrative. Overview of proposals.

IASB Exposure Draft Insurance Contracts

International Actuarial Association Request for Proposals to prepare an Educational Monograph

Session 7, Industry Leader's Roundtable: IFRS 17 Insights. Moderator: J. Peter Duran, FSA, CERA, MAAA, Ph.D.

October 4, Sent via to Julie Gann. Re: Exposure Draft Dear Mr. Bruggeman:

Notice for Recipients of This Proposed FASB Staff Position

PERFORMING CASH FLOW TESTING FOR INSURERS

TABLE OF CONTENTS. Lombardi, Chapter 1, Overview of Valuation Requirements. A- 22 to A- 26

The Actuarial Society of Hong Kong MEASUREMENT MODELS. Session 5. Tze Ping Chng

Transcription:

IFRS Task Force presentation to NAIC Henry Siegel Chairman, Financial Reporting Committee and IFRS Task Force Risk Management and Financial Reporting Council of the NAIC Interim Meeting of International Solvency & Accounting WG August 22, 2007 1

Agenda The U.S. actuarial profession s international activities Initial reaction to IASB Discussion Paper (DP) Initial reaction to FASB invitation to comment 2

International Activities The Academy has formed a task force that will comment on both IASB and FASB documents. The Society of Actuaries has a project underway to measure the effect of the proposals on U.S. L&H products. U.S. actuaries are working with the International Actuarial Association on their response. Also developing a paper on current estimates and risk margins (Appendix E and F of DP) 3

Problems with the Building Blocks - 1 Explicit, unbiased, market-consistent, probabilityweighted, and current estimates of the contractual cash flows Not possible to do all possible scenarios Even mathematical models exclude certain alternatives at the ends Need to be able to use approximations, particularly for quarterly statements Not clear what an entity - specific vs. portfolio - specific expense is (e.g., impact of health insurer provider discounts on incurred claims) Probability-weighted doesn t apply for many well-accepted nonlife claim liability estimation methods 4

Problems with the Building Blocks 1 (Cont.) Explicit, unbiased, market-consistent, probability-weighted, and current estimates of the contractual cash flows Market-consistent may not exist or be reliable or relevant For non-life, important variation between: settlement strategies, processing systems claim estimation approaches claim incurral dating practices underwriting criteria markets etc. Makes use of industry and/or external data typically suboptimum Goal should be to use best estimates of future cash flows for the company stochastic when needed to value options, etc. We think we know what is needed and want to avoid auditor conflicts over unclear guidance. 5

Problems with the Building Blocks - 2 Current market discount rates that adjust the estimated future cash flows for the time value of money Does using market discount rates mean risk-free? If so, many products may show non-economic losses at issue Need to be able to discount at expected rates when benefits reflect returns (every life product except non-par traditional products) Need to be able to use scenario-based rates, not a set of rates at date of valuation 6

Problems with the Building Blocks - 3 An explicit and unbiased estimate of the margin that market participants require for bearing risk (a risk margin) and for providing other services, if any (a service margin) No market information in general after initial issue No agreed- upon methodology Casualty Actuarial Society study (Fair Value of P&C Liabilities: Practical Implications) showed determining one methodology can lead to very different results. Should not specify one methodology Cost of capital as defined in Solvency II may not be appropriate for accounting concern with gains at issue Quantile methods more consistent with U.S. L&H historical practice We need to discuss service margin further, but our initial reaction is that it s not necessary except, perhaps, in limited circumstances. 7

Eliminate Measurement Restrictions Should include all future cash flows from current contracts Eliminating certain flows changes objective of measurement not market consistent or true exit value Applies to premiums, policyholder dividends, non-guaranteed elements 8

Measurement Attribute Current exit value can be okay, although the words can cause confusion needs better definition Not a run-off situation must be a going concern Not really a transaction to another insurer, too many individual issues in each transaction Not a reinsurance agreement since such agreements don t transfer the total liability 9

Valuation Guidance Appendices E and F are too detailed. Should rely more on actuarial profession to set standards IAA high level for use in countries without developed actuarial professional organizations Individual countries set what is appropriate guidance for their markets. Different markets and products require different guidance. Actuarial Standards Board and American Academy of Actuaries should provide needed guidance. Need to coordinate with auditor guidance. 10

Gains and Losses at Issue DP can cause both non-economic gains and non-economic losses due to: Limitations on cash flows Limitations on discount rates. Even assuming these are eliminated, margin guidance allows significant gains that may not be appropriate Transfers are not based on statutory minimum capital but on company economic capital requirement. Generally, profit on transfer is due to reimbursement of acquisition expenses or expense savings being shared. Other reasons not always involved (e.g., more reliable assumptions or lower margins) Pricing assumes company s own target capital return and own economic capital not minimum statutory requirements. CFO Forum estimates over $7 billion in gains are at issue, if margins are based on cost of capital, as in Solvency II (as some are proposing). 11

Gains and Losses at Issue (Cont.) Will put unhealthy pressure on the estimate to generate gains at issue reduce reserves and generate increasing sales It has been observed that insolvencies generally follow efforts to rapidly grow sales We prefer that margins be calibrated to premium as rebuttable presumption expect that differences will be very rare 12

Unbundling We see no added value in the IASB s proposal. Requirement to show deposit element separately and balance into the total liability would not add useful information. We prefer to unbundle only clearly independent cash flows. 13

Summary An initial reaction is that there are a number of problems that need to be fixed. Implementation will not be easy. Appropriate guidance is needed to achieve comparability and transparency. 14

The FASB ITC The U.S. Gets Involved Some parts of U.S. GAAP, particularly for life, are flawed and need replacement: Problems created by SOP 05-1, Consistent accounting basis without numerous special adjustments Better language to avoid auditor conflicts. Start with IASB Paper, but fix it. Treat Health Insurance in a cohesive manner. Treat policyholder accounting separately. Be sure that the insurance contracts project doesn t disagree with other projects Work in accord. 15