Implications of Exposure Draft IFRS 4 Phase II and its Implementation

Similar documents
Practical guide to IFRS 23 August 2010

IASB Exposure Draft Insurance Contracts

IASB Staff Paper February 2017

IFRS AT A GLANCE IFRS 17 Insurance Contracts

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

IFRS 17. New Accounting Perspective. KPMG Advisory (China) November 2017

International Financial Reporting Standards (IFRS) Update Life

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

financia fin ancia REporting changes chan

Insurance alert ISAB/FASB Board Meeting Insurance Contracts

Exposure Draft. Indian Accounting Standard (Ind AS) 117, Insurance Contracts. (Last date for Comments: March 31, 2018)

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

New on the Horizon: Insurance contracts

FASB / IASB Insurance Contracts Project Update Webinar

The future of insurance accounting preparing for change

Overview of IFRS17. David Burton

CONTACT(S) Roberta Ravelli +44 (0) Hagit Keren +44 (0)

Using Solvency II to implement IFRS 17

IFRS 17: Insurance Contracts

IFRS 4 Phase 2 Exposure Draft. 15 January 2014

IFRS 17 - Brief overview. Fall School November 2017

IFRS 17 Insurance Contracts. SIAS, Salzburg, 5th and 6th of April, 2018 Dr. Johann Kronthaler

Ind AS 117 Insurance Contracts

Heads Up. One Model, Two Models, Red Model, Blue Model FASB Issues Exposure Draft on Insurance Contracts. In This Issue: Scope

Insurance alert. also decided that acquisition costs should be presented as part of the margin liability rather than as an asset and that,

New IFRS Insurance Contracts Project

The IASB and FASB approach the final Exposure Draft

Insurance Contracts. HKFRS 17 Issued January Effective for annual periods beginning on or after 1 January 2021

In depth A look at current financial reporting issues

Insurance alert Highlights

Get ready for IFRS 17

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

Questions to EFRAG TEG 3 Do EFRAG TEG members have comments on the comparison between US GAAP requirements for insurance and IFRS 17?

Joint Project Watch. IASB/FASB joint projects from an IFRS perspective. December 2011

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

Adviser alert Get ready for IFRS 17: A fundamental change to the reporting for insurance contracts

IASB Update. Welcome to IASB Update. Balance sheet - offsetting. Insurance contracts. June Contact us

Applying IFRS 17. A closer look at the new Insurance Contracts Standard. May 2018

Third Transition Resource Group meeting discussing the implementation of IFRS 17 Insurance Contracts

BACKGROUND BRIEFING PAPER

IFRS 17 Insurance Contracts Towards a DEA Appendix II

IASB Update. Welcome to IASB Update. Amortised cost and impairment. July Contact us

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

FASB provides preliminary views on insurance accounting

17: what to do now. Implications for Singapore insurers

IFRS 17 Life Insurance

Getting to grips with the shake-up

IFRS 17 Insurance Contracts Towards a background briefing paper on Transition

The IASB s technical agenda

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

IFRS Project Insights Insurance Contracts

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

IFRS 17 Insurance Contracts and Level of Aggregation

Comment Letter No. 44

Update No (Issued 4 January 2018) Document Reference and Title Instructions Explanations. Insert these pages after HKFRS 16 Leases.

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

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

IFRS 17. Pivoting towards implementation. IFRS Foundation. Darrel Scott, Board Member Iza Ruta, Technical Manager. Windsor, June 2017

CONTACT(S) Anne McGeachin +44 (0) Andrea Pryde +44 (0)

IASB meeting on 15 November 2016

General insurance reserving

An overview of IFRS 17

Insurance Accounting Alert

CONTACT(S) Jelena Voilo

IASB Projects A pocketbook guide. As at 30 September 2013

IASB/FASB Board meeting Insurance contracts

IAN 100. IFRS 17 Insurance Contracts. Published on [Date]

Headline Verdana Bold IFRS 17: What does the long awaited standard bring? 24 November 2017, Prague

Insurance Contracts. June 2013 Basis for Conclusions Exposure Draft ED/2013/7 A revision of ED/2010/8 Insurance Contracts

NEW EXPOSURE DRAFT IFRS 4 - PHASE , Novembre 7

IASB Projects A pocketbook guide. As at 30 June 2013

SLFRS 4 Insurance Contracts.

IASB Projects A pocketbook guide. As at 31 March 2013

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

Level of Measurement. Darryl Wagner. Insurance IFRS Seminar December 1, Darryl Wagner. Session 10

Application of IFRS 17 Insurance Contracts

Social Benefits. Paul Mason, Principal. IPSASB Meeting March 7 10, 2016 Washington, D.C., USA. Page 1 Proprietary and Copyrighted Information

IASB Projects A pocketbook guide. As at 31 December 2011

IASB Staff Paper May 2014

Transition Resource Group for IFRS 17 Insurance Contracts Determining the quantity of benefits for identifying coverage units

Sailing a Course through Risk Margins

IFRS4 Phase 2 OVERVIEW AND IMPLEMENTATION CHALLENGES

Must know Transition Resource Group debates IFRS 17 implementation issues

New Developments on Revenue Recognition. Uphold public interest

IFRS 17 Insurance Contracts Breakfast Briefing Series Deep Dive event 11 July 2017

IFRS-FA öffentliche SITZUNGSUNTERLAGE. 04. IFRS-FA / / 13:45 15:45 Uhr 04 Insurance Contracts Stand des IASB Projekts 04_05a_IFRS-FA_IC

ED/2013/7 Insurance Contracts; and Proposed Accounting Standards Update Insurance Contracts (Topic 834)

IFRS 17 issues Level of aggregation Draft for discussion

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

Insurance Contracts. First Impressions IFRS 17. July kpmg.com/ifrs

Insurance Contracts Project Overview

AIG Philippines Insurance, Inc. Financial Statements As at and for the years ended December 31, 2016 and 2015

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

NZ IFRS 17 Insurance contracts

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

IFRS 17 issues Reinsurance. Draft for discussion

FINANCIAL INSTRUMENTS. The future of IFRS financial instruments accounting IFRS NEWSLETTER

Business Combinations II

IASB Projects A pocketbook guide. As at 31 December 2013

Question 1 Adjusting the contractual service margin

Transcription:

www.pwc.co.uk Implications of Exposure Draft IFRS 4 Phase II and its Implementation Institute of Actuaries of India Conference 17 October 2011 Gautam Kakar

Agenda Definition and scope of contracts Measurement Model High level overview Individual building blocks Short duration contracts Contract Boundary Unbundling Recognition / derecognition of contracts Participating contracts Reinsurance Presentation of results Disclosures Transition 2

Insurance industry performance The insurance market has underperformed the market 1200 1000 800 600 FTSE100 Insurance companies in FTSE100 400 200 0 Dec-06 Source: Datastream Dec-07 Dec-08 Dec-09 Dec-10 3

Definition and scope of contracts Exposure Draft Definition A contract under which one party accepts significant insurance risk from another party by agreeing to compensate the policyholder if a specified uncertain future event adversely affects the policyholder Insurance risk is defined as any risk other than financial risk Significant risk implies a scenario with commercial substance where the present value of cash outflows can exceed the present value of the premium 4

Definition and scope of contracts Exposure Draft Scope Some contracts are excluded from the scope of the definition including: Product warranties issued by a manufacturer, dealer or retailer Residual value guaranteed provided by a manufacturer, dealer or retailer as well as a lessee s residual value guarantee embedded in a financial lease Contingent consideration payable in a business combination Employers assets and liabilities under employee benefit plans Insurance contracts that the entity holds as a policyholder (this excludes reinsurance contracts) Financial guarantee contracts can no longer be treated as financial instruments if they meet the insurance definition Fixed fee service contracts, where the primary purpose is the provision of services are excluded from the scope. Financial instruments containing discretionary participating features are included in the scope (assuming the contract itself falls under scope) 5

Definition and scope of contracts Implementation aspects Observations The definition of an insurance contract is largely unchanged from IFRS 4 but guidance is more prescriptive The discretion in the treatment of financial guarantees may allow inconsistent interpretation by companies Implementation: The standard applies to all entities, i.e. not just insurers Some contracts may no longer meet the insurance definition Non-clarity: The ED wording is such that it will not always be clear whether a fixed fee service contract is in or out of scope 6

Definition and scope of contracts Update Feedback Pressure to return to the original IFRS 4 definition because: It is well understood It has not generated any issues in practice Some reinsurance contracts covering an entire pool of risks, may not meet the definition criteria because the chance of a loss might be extremely remote, even though individual contracts would typically have significant insurance risk IASB Update Rejected proposal to revert to current IFRS 4 definition to ensure only insurance contracts receive insurance accounting Clarified that a risk transfer is deemed significant if the reinsurance contract transfers substantially all of the risks in the underlying contracts Option to account financial guarantees under IFRS 9 7

Measurement model high level overview Exposure Draft Guidelines A single measurement model is developed to calculate the present value of the fulfilment cash flows using the following building blocks: Eliminates day 1 gain Residual margin Risk adjustment Present value of fulfilment cash flows Time value of money Current unbiased probability weighted estimate of future cash flows 8

Measurement model high level overview Implementation aspects Observations IFRS 4 currently defers largely to local GAAP, which reduces comparability Exit value notion as compared to that of a fulfilment value Liabilities are presented as a single item on the balance sheet The use of IAS 21 for overseas liabilities avoids some of the current mismatches, particularly for property and casualty insurers Implementation: The measurement model (except for the debate on residual margin component), is a current model and hence requires updating at each reporting period The model prohibits a day 1 gain, but losses are recognised immediately The FASB model uses a composite margin instead of the separate risk adjustment and residual margin approach meaning the IASB model may recognise more losses 9

Measurement model cash flows Exposure Draft Guidelines Included if they are incremental at the portfolio level and upto the boundary of the contract Need to arise in the fulfilment of the existing contract Acquisition costs need to be directly attributable to the sale of a policy Should be an explicit, unbiased and probability weighted estimate Based on current estimates that reflect the perspective of the entity Market variables should be consistent with observable market prices Reflect policyholder behaviour including contract features which allow a change in amount, timing or the nature of benefits 10

Measurement model cash flows Implementation aspects Observations Single point estimates will no longer be sufficient The definition of acquisition expenses may be narrower than local GAAP Exclusion of general overheads will understate liabilities Implementation: Significant changes to models and systems will be required Expense allocation systems may need adjusting for the narrower definition Method of selling contracts, i.e. direct sales or third party, would impact results Non-clarity: Limited guidance on determining which costs are incremental at the contract or portfolio level, e.g. non-commission acquisition costs, and which to exclude Policy loans secured against insurance contracts may be either included in cash flows or separately assessed under IFRS 9 11

Measurement model cash flows Update Feedback IASB Update Move to a fulfilment value notion generally well received Many felt the definition of acquisition costs was too narrow, with particular pressure to move to a portfolio level Pressure to also include overhead costs because they are included in pricing models Concern over the level of stochastic modelling expected, in particular for low frequency but high severity events Agreed to move to a portfolio definition for acquisition costs Tentative agreement to include costs for both successful and unsuccessful acquisition efforts to avoid penalising insurers with predominantly direct sales Agreed direct overheads could be included in the cash flows Clarification that expected value refers to the mean value Clarification that it is not necessary to quantify all possible scenarios in all circumstances 12

Measurement model discount rate Exposure Draft Guidelines The discount rate is used to adjust the cash flows for the time value of money They should be consistent with observable market prices for instruments with cash flows whose characteristics match those of the liabilities in terms of timing, currency and liquidity Where contract cash flows depend on the performance of specific assets, their measurement shall reflect that dependence Calculated as risk-free rate plus an adjustment for illiquidity, i.e. bottomup approach Should not reflect the risk of non-performance of the insurer 13

Measurement model discount rate Implementation aspects Observations Discount rates will not be based on the actual assets backing the liabilities Multiple curves might be required for contracts with different benefits Accounting mismatch as change in price of credit risk would affect value of assets but liability measurement excludes some of this market movement Could lead to more volatile profits Potential day 1 losses because discount rate is lower than in premium setting Implementation: Complexities arising from using a curve and determining rates at extreme durations Potential for accounting mismatches Insurers might not be able to capture the asset illiquidity premia in practice Non-clarity: Determining which liabilities ought to have a discount rate adjusted for illiquidity Determining how to calculate the illiquidity adjustment itself 14

Measurement model discount rate Update Feedback Life insurers concerned that fluctuations caused by the discount rate are not reflective of their business Concerns over the feasibility, objectivity and comparability of the illiquidity adjustment Some opposition to the prescription of a bottom-up rate IASB Update Confirmed that government bonds are not always risk free Agreed to revoke the prescription of a bottom-up rate and allow a top down approach to be used Rejected proposal to use pricing assumptions Confirmed a practical expedient would not be provided In favour of not discounting cash flows with insignificant financing requirements, e.g. non-life pre-claims liabilities 15

Measurement model risk adjustment Exposure Draft Guidelines The definition of the risk adjustment initially proposed: the maximum amount the insurer would rationally pay to be relieved of the risk that the ultimate fulfilment cash flows exceed those expected Recent update compensation the insurer requires for bearing the uncertainty inherent in the cash flows that arise as the insurer fulfils the insurance contract There are 3 permitted techniques to calculate it: Confidence level, i.e. value at risk Conditional tail expectation, i.e. tail value at risk Cost of capital Must disclose the confidence level the risk adjustment corresponds to, even if the conditional tail expectation or cost of capital techniques are used The proposals require the adjustment to be measured at the portfolio level 16

Measurement model risk adjustment Implementation aspects Observations Move to an explicit margin is a major change from current implicit models Cost of capital approach may differ from other applications e.g. pricing Diversification benefits from different portfolios are not allowed Profit emergence will differ depending on the technique used Implementation: Calculating probability distributions which bear the scrutiny of market disclosures Selecting the calculation technique to use Selecting the confidence level at which to set the risk adjustment Care needs to be taken to ensure risks are not duplicated Non-clarity: The intended meaning of maximum and exceed in the definition Specification of the 3 techniques would appear to rule out a future, better method 17

Measurement model risk adjustment Update Feedback Generally positive comment outside USA because the explicit adjustment is a current and transparent measure Some opposition because of concerns the information is subjective, costly, open to manipulation and inconsistent with the fulfilment value notion Usefulness of a confidence level equivalent questioned Requests for differ to replace exceed in the definition of the risk adjustment Proposal for changes in the risk adjustment to be recognised in income and not in the residual margin IASB Update Decision to eliminate the limitation of 3 permitted techniques to measure risk adjustment Tentative agreement to recognise changes in the risk adjustment in income rather than in the residual margin 18

Measurement model residual margin Exposure Draft Guidelines A residual margin arises when: PV of future inflows > PV future outflow + risk adjustment Determined within a portfolio by date of inception and length of contract The amortisation basis is defined as follows: on the basis of the passage of time, but on the basis of the expected timing of incurred claims and benefits, if that pattern differs significantly from the passage of time i.e. in a systematic way that represents the insurance coverage Assumptions are locked in, i.e. the residual margin is not re-measured Set to zero if a contract terminates or lapses Accretes interest at the discount rate used at inception 19

Measurement model residual margin Implementation aspects Observations Increases likelihood and potential level of day 1 losses A favourable change in assumptions on day 2 is a recognisable gain Represents future shareholder profits plus the general overheads and nonincremental acquisition costs allocated to the contract Amortisation done without reference to profit emergence Implementation: Tracking the residual margin and its release will be complex and require system development Certain products will have a back-ended amortisation pattern inconsistent with the provision of services Non-clarity: Unclear whether the amortisation pattern can change 20

Measurement model residual margin Update Feedback Most insurers complained that locking in the margin is inconsistent with the rest of the current value model If the margin is locked in then insurers want to use it as a shock absorber for non financial estimate changes Complaints that the amortisation methods are inconsistent with the economies of the contracts IASB Update Use of the residual margin as a shock absorber rejected Agreed to unlock the residual margin for estimate changes Adjusted for both favourable and unfavourable changes No limit to the change (cannot be negative) Should only be made prospectively Amortisation pattern should be consistent with transfer of services under the contract Decisions were very tentative!!! 21

Measurement model short duration contracts Exposure Draft Guidelines A simplified measurement model mandated for contracts of approximately one year or less which do not contain embedded derivatives or options Two components to the simplified model: a) Pre-claims liability, i.e. unearned premium reserve b) Liability adequacy test, i.e. onerous contracts test Pre-claims liability is measured as: Initial premium + future expected premiums incremental acquisition costs Pre-claims liability is amortised in a similar way to the residual margin The liability adequacy test checks whether the present value of the fulfilment cash flows exceeds the pre-claims liability and if so expenses the excess Observation Property and casualty insurers might have to apply two different calculation methods to contracts where only the contract term differs 22

Measurement model short duration contracts Implementation aspects & update Implementation: Requirement to use two measurement models for short duration contracts is an added complexity and unlikely to reduce workload Requirement to amortise the pre-claims liability in a way which reflects the seasonality of claims might be a new approach Liability adequacy test could be at a lower level than current accounting practice Non-clarity: Unclear whether an insurer would be allowed/required to release any pre-claims liability in the event that a claim curtails coverage Unclear if the amortisation pattern can change in response to changes in the pattern of expected claim and benefit payments IASB Debate Approximation to the full model Less restrictive interpretation of approximately one year Simplified model should be permitted rather than mandated 23

Measurement model contract boundary Exposure Draft, implementation aspects & update The boundary of an insurance contract is the point at which: Guidelines IASB Update the insurer is no longer required to provide coverage, or has the right or the practical ability to reassess the risk of the particular policyholder and, as a result, can set a price that fully reflects that risk. Implementation: May impact the treatment of certain contracts, e.g. health contracts, where the regulator imposes constraints on re-pricing for individual policyholders Duration of some contracts might be reduced under the new definition, which may result in the insurer recognising a loss Tentative agreement to modify the definition of the contract boundary such that the ability to re-price risk now rests at the portfolio level 24

Measurement model unbundling Exposure Draft, implementation aspects & update Guidelines IASB Update Insurers are required to unbundle components which are not closely related, e.g. embedded derivatives When unbundling an account balance the charges and fees are not considered part of the investment component Implementation: Measurement approach will depend on whether a contract is unbundled and which components are unbundled Different interpretations could lead to different earnings profiles Approach to unbundling could incur significant costs Non-clarity: Terms such as closely related open to interpretation Unclear how the account charges would be allocated between the different components of the contract Embedded derivatives unbundled when not closely related Goods and services unbundled when revenue recognition project one performance obligation criteria met Account balances unbundled when credited with an explicit return 25

Measurement model recognition & derecognition Exposure Draft, implementation aspects & update Guidelines IASB Update Contracts are recognised at the earlier of when bound by the contract or exposed to the risk under the contract Contracts are derecognised when the obligations are discharged, cancelled or expire Implementation: Contracts will be recognised before they commence which may create reporting and systems difficulties The recognition definition is different from the contract commencement date currently used Legal requirements in local territories may mean contracts are recognised at different times Non-clarity: No guidance on when a substantial modification to a contract should be accounted for as an extinguishment of the contract Agreed to recognise contracts at the start of the coverage period An onerous contracts test will still be required to avoid material misstatement in the accounts 26

Measurement model participating contracts Exposure Draft, implementation aspects & update Guidelines IASB Update Contracts measured in the same way as any other contractual cash flow Investment contracts can also be under scope Contract boundary for investment contracts is the point at which they no longer have a contractual right to participate Implementation: How to decide on a dividing line where the pool consists of a limited/immaterial amount of participating insurance contracts How to treat contracts which can choose to switch between unit linked funds and funds with discretionary participating features Non-clarity: Unclear how future contracts would be within the boundary of existing contracts and the implications of this on inherited estates Agreed for the policyholder participation to be measured on the same basis as the underlying assets 27

Measurement model reinsurance contracts Exposure Draft, implementation aspects & update Guidelines Observation Measured in the same way as for other insurance contracts Where the net cost exceeds the expected value of the recovery a residual margin is set up in the reinsurance asset If the net cost is less than the expected value of the recovery then an immediate gain is recognised Risk of non-performance should be included on an expected value basis when estimating the fulfilment cash flows of the reinsurance asset Reinsurance balances should not offset contract balances Insurance liability and reinsurance asset not necessarily the same value IASB Update Reinsurance gains may now be deferred by setting up a residual margin and recognised over the coverage period 28

Presentation Exposure Draft Guidelines The Statement of Comprehensive Income (SoCI) must show as a minimum: Underwriting margin Gains/losses at initial recognition Non incremental acquisition costs Experience adjustments and changes in estimates Interest on insurance liabilities For the pre-claim liability of short duration contracts insurers should show: Underwriting margin Changes in liability for onerous contracts Premiums, claim and other expenses are treated as deposit receipts/payments and are not presented on the SoCI, except for short duration contracts 29

Presentation Implementation aspects Observations All lines on the SoCI link back to the building blocks All items from insurance contracts are shown in the income section of the SoCI Other Comprehensive Income not used Represents a significant change from the cash flow revenue account presentation insurers currently use to present results Asset/liability mismatches will be shown in the SoCI Implementation: Insurers who do not report embedded value will find the new format more difficult than those that do Conglomerate groups will need to consider how to present their combined result, e.g. with respect to premium income Changes will be needed to general ledgers and accounting systems Management, analysts and investors will need to be educated Non-clarity: A number of areas lack detail, e.g. where to present ceded reinsurance items or interest on the residual margin 30

Disclosures Exposure Draft Guidelines Overarching principle: To help users understand the amount, timing and uncertainty of future cash flows arising from insurance contracts Quantitative and qualitative information about the amounts recognised in the financial statements and the nature and extent of risks is required Reconciliations are required from the opening to the closing aggregate insurance and reinsurance balances for a number of items Specific minimum line items are specified for these reconciliations Methods used and the processes for determining the inputs Measurement uncertainty analysis of inputs that have a material effect on the measurement Claims development tables required initially for 5 years, but rising to 10 Different reporting segments are not permitted to be aggregated 31

Disclosures Implementation aspects Observations The disclosures are more detailed than currently required Comparability of the risk adjustment may not work Additional supplementary reporting information still likely to be required focusing on shareholder value and the amounts and timings of expected distributable earnings Implementation: The sheer volume of information will be onerous to produce Systems might need to be developed to produce the reconciliations Data capture and management may require modifying to ensure all the requirements can be met Analysts will require additional shareholder cash flow information Non-clarity: Reconciliation of contract balances mixes two distinct analysis approaches and its interpretation is unclear for some cash flows Limited guidance on how to determine explanatory items in the reconciliation and in what order 32

Disclosures IASB Updates Aggregation level IASB agreed on Principles based aggregation levels and decided not to retain ED s minimum disaggregation level Measurement Uncertainty ED s proposed requirement to disclose a measurement uncertainty analysis has been deleted. However disclosure of effect of each change in inputs and methods on measurement of insurance liabilities is still required, along with explanation of the reasons for the change Liquidity Risk Maturity analysis to be based on expected maturities and the option to use remaining contractual maturities has been removed 33

Transition Exposure Draft Guidelines Full retrospective application for in-force contracts with no grandfathering of past practices Each portfolio of insurance contracts measured as the present value of the fulfilment cash flows which will exclude any residual margin Existing deferred acquisition costs will be written off Other intangible assets arising from insurance contracts assumed in previous business combinations will be written off Insurers can redesignate an asset currently measured at amortised cost to fair value through profit and loss, but not vice-versa Early adoption is permitted but this must be disclosed 34

Transition Implementation aspects Observations The extent of the opening retained earnings adjustment will depend on past accounting practices and contract profitability In-force contracts will have less future profit than new business because of the lack of a residual margin Estimation of a proper risk adjustment for the in-force contracts at transition is crucial because it will be the primary source of future accounting profit Implementation: For long-term insurers, profit that would have been recognised in future periods will now be recognised in equity Determining assumptions to use to calculate the risk adjustment at transition and the implications this has on future periods Deciding whether or not to value assets at fair value Cannot revalue assets currently at fair value at amortised cost Careful communication of the impact the transition has had on current and future accounting will be needed 35

Insurance project still some way to go Exposure draft Definition and scope Fulfilment cash flows, including acquisition costs Discount rate Risk adjustment Residual margin Participating contracts Modified/UPR approach Unbundling Reinsurance Performance statement Transition/disclosure Re-deliberations No significant change from ED - except financial guarantees Some change from ED Some change from ED Some change from ED; re-deliberations ongoing Potentially significant change; re-deliberations ongoing Potentially significant change; re-deliberations on-going Re-deliberations ongoing Some change from ED Some change from ED; re-deliberations on-going Re-deliberations ongoing Not yet re-deliberated 36

Summary Key challenges Ensuring data is captured at a sufficient level of granularity Updating systems, accounting and actuarial models to be able to report under the new guidelines Agreeing which contracts fall under scope and the degree of unbundling required Deciding the level of prudence to include in the risk adjustment Determining the amortisation pattern for the residual margin Interpreting the areas of uncertainty in a manner which does not disadvantage the company compared to its peers Ensuring staff and management understand the new requirements Uncertainty around when to implement the standard Communicating the impact the new guidelines have on key metrics and being able to successfully explain the effect transition has on profit 37

Thank you Gautam Kakar Principal Consultant, UK + 44 (0) 20 7212 4338 gautam.kakar@uk.pwc.com 2011. All rights reserved. Not for further distribution without the permission of. "" refers to the network of member firms of PricewaterhouseCoopers International Limited (IL), or, as the context requires, individual member firms of the network. Each member firm is a separate legal entity and does not act as agent of IL or any other member firm. IL does not provide any services to clients. IL is not responsible or liable for the acts or omissions of any of its member firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is responsible or liable for the acts or omissions of any other member firm nor can it control the exercise of another member firm's professional judgment or bind another member firm or IL in any way.