ORSA An International Development

Similar documents
ORSA An international requirement

GUIDELINE ON ENTERPRISE RISK MANAGEMENT

Own Risk and Solvency Assessment (ORSA)

Solvency Assessment and Management: Pillar 2 - Sub Committee ORSA and Use Test Task Group Discussion Document 35 (v 3) Use Test

Does the ORSA add value? Challenges and initial achievements. Lukas Ziewer Risk Management Perspectives, 18/11/2014

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

NAIC OWN RISK AND SOLVENCY ASSESSMENT (ORSA) GUIDANCE MANUAL

Solvency II Insights for North American Insurers. CAS Centennial Meeting Damon Paisley Bill VonSeggern November 10, 2014

Solvency Assessment and Management: Steering Committee Position Paper 34 1 (v 5) Own Risk and Solvency Assessment

International Trends in Regulatory Capital & Target Surplus. Caroline Bennet - Trowbridge Deloitte Jennifer Lang - CBA

Solvency Assessment and Management: Stress Testing Task Group Discussion Document 96 (v 3) General Stress Testing Guidance for Insurance Companies

ERM and ORSA Assuring a Necessary Level of Risk Control

CONSULTATION PAPER ON A RISK- BASED CAPITAL FRAMEWORK FOR THE INSURANCE INDUSTRY IN HONG KONG

American Academy of Actuaries Webinar: The Practice of ERM in the Insurance Industry. Enterprise Risk Management Committee November 19, 2013

Actuaries Club of the Southwest

INSURANCE CORE PRINCIPLES, STANDARDS, GUIDANCE AND ASSESSMENT METHODOLOGY

Developments & Insights in Singapore RBC 2 and Overview of ORSA across Regions

Solvency II Detailed guidance notes for dry run process. March 2010

Risk Appetite Survey Current state of the Insurance Industry

Solvency Projections: What s the point unless you get some value from the results?

Solvency Assessment and Management: Steering Committee Position Paper (v 4) Life SCR - Retrenchment Risk

Introduction to ORSA. OIC Risk Management Seminar 30 June William Song

Actuarial Roles under the Solvency II Framework Dr. Huijuan Liu

IAIS: Enterprise Risk Management for Capital Adequacy & Solvency Purposes. George Brady. IAIS Deputy Secretary General

Finalised guidance. Individual Liquidity Systems Assessment (ILSA) Simplified ILAS BIPRU Firms (ILSA) Simplified ILAS BIPRU Firms.

Agile Capital Modelling. Contents

Link between Pillar 1 and Pillar 2

Defining the Internal Model for Risk & Capital Management under the Solvency II Directive

Capital Adequacy and Supervisory Assessment of Solvency Position

ENTERPRISE RISK MANAGEMENT, INTERNAL MODELS AND OPERATIONAL RISK FOR LIFE INSURERS DISCUSSION PAPER DP14-09

SOLVENCY ASSESSMENT AND MANAGEMENT (SAM) FRAMEWORK

Christina Urias SMI Task Force Chair Director, Arizona Department of Insurance

Southeastern Actuaries Conference 2012 Annual Meeting. Jeffrey S. Schlinsog, CFA, FSA, MAAA

IAA Fund Seminar in Chinese Taipei

Introduction of a new risk-based capital framework in Singapore Convergence or divergence in relation to Solvency II?

Academy Presentation to NAIC ORSA Implementation (E) Subgroup

Solvency II: Implementation Challenges & Experiences Learned

2014 Own Risk and Solvency Assessment (ORSA) Feedback Pilot Project Observations of the Group Solvency Issues (E) Working Group

FIL Life Insurance (Ireland) DAC. Solvency and Financial Condition Report as at 30 June 2016

ERM/ORSA Training Thai General Insurance Association (TGIA)

Guidance on the Actuarial Function MARCH 2018

The road to Solvency II: The Regulatory View

The Role of Finance and Accounting as Critical Players in ERM and ORSA

OIC & ORSA. Thanita Anusonadisai Director of Capital and Solvency Standard Department Office of Insurance Commission, Thailand

Prudential Standard GOI 3 Risk Management and Internal Controls for Insurers

A (personal) view. Philip Whittingham, European Chief Enterprise Risk Officer. 22 March 2010

RED 2.1 & 4.2: Quantifying Risk Exposure for ORSA. Moderator: Presenters: Lesley R. Bosniack, CERA, FCAS, MAAA

Guidance on the Actuarial Function April 2016

1. INTRODUCTION AND PURPOSE

Current status of Solvency II and challenges down the line. Matthew Edwards 11 October 2011

Use of Internal Models for Determining Required Capital for Segregated Fund Risks (LICAT)

Re: Consultation Paper on Commercial Insurer s Solvency Self Assessment ( CISSA CP )

Solvency II. Insurance and Pensions Unit, European Commission

Solvency II dragging Australia into Europe once again

The ORSA opportunity:

PwC Assurance Main contacts

ERM and Reserve Risk

May 2015 DISCUSSION DRAFT For Illustrative Purposes Only Content NOT Reviewed or Approved by the Actuarial Standards Board DISCUSSION DRAFT

ORSA: A relevant part of the governance system within Solvency II

1. INTRODUCTION AND PURPOSE 2. DEFINITIONS

Lloyd s Minimum Standards MS13 Modelling, Design and Implementation

Article from: Risk Management. March 2014 Issue 29

Treatment of Italian Tax Asset under Solvency II

EIOPA Proposal for Guidelines on the preparation for Solvency II. October Milliman Solvency II Update

ORSA reports: gaps and opportunities

Guidance Note: Internal Capital Adequacy Assessment Process (ICAAP) Credit Unions with Total Assets Greater than $1 Billion.

A.M. Best s New Risk Management Standards

PREMIER UNDERWRITING HOLDINGS (GIBRALTAR) LIMITED PREMIER INSURANCE COMPANY LIMITED

Regulation and risk The strategic response to insurance regulatory developments Alex Thomson, May 2013

An Introduction to Solvency II

NAIC OWN RISK AND SOLVENCY ASSESSMENT (ORSA) GUIDANCE MANUAL

The Challenges of Solvency II

Emerging Trends in Quantitative ERM

Subject ST9 Enterprise Risk Management Syllabus

Solvency II Primer Regulatory Update September 2015

The Society of Actuaries in Ireland

The Society of Actuaries in Ireland. Actuarial Standard of Practice INS-1, Actuarial Function Report

ERM and the new world of insurance regulation. Where insurers should focus now to find business value

Guidance paper on the use of internal models for risk and capital management purposes by insurers

Opinion of the European Insurance and Occupational Pensions Authority on the group solvency calculation in the context of equivalence

ERM, the New Regulatory Requirements and Quantitative Analyses

Own Risk and Solvency Assessment

Own Risk and Solvency Assessment (ORSA)

Frequently Asked Questions for The global risk-based Insurance Capital Standard (ICS) Updated 21 July 2017

Risk Appetite for Life Offices IFoA working party

Insurance Summit Mr Raymond Tam Executive Director (Policy and Development) Insurance Authority 21 September 2017

29th India Fellowship Seminar

Regulatory Consultation Paper Round-up

Increased Corporate Governance Requirements for Insurers

Solvency Monitoring and

Session 5: Evolution of ORSA in the US. Moderator: Michael Anthony McComis Jr. MAAA,FCAS

New Actuarial Standards of Practice No. 46 Risk Evaluation in ERM No. 47 Risk Treatment in ERM

Lessons from the ICAS regime for UK insurers

AFM NED Conference Solvency II Business as Usual. Steve Dixon of SDA llp

SOLVENCY & FINANCIAL CONDITION REPORT. SureStone Insurance dac

Sections of the ORSA Report

Solvency and Financial Condition Report 20I6

International Regulatory Developments

Gregg Clifton. CFO Aurigen Reinsurance

Transcription:

ORSA An International Development 25.02.14

Agenda What is an ORSA? Global reach Comparison of requirements Common challenges Potential solutions

Origin of ORSA FSA ICAS Solvency II IAIS ICP16

What is an ORSA? Insurer s own assessment of: A. its risks B. capital needed to protect against those risks Documentation of assessment

ORSA a key management tool Risk Management ORSA Business Strategy Capital Management

ORSA how the pieces fit together

Board responsibility Own risk assessment Own solvency assessment Forward looking Management information Enhance understanding Group wide Continuous process Adequate documentation Objectives of the ORSA

Challenges in achieving objectives Risk that ORSA becomes a compliance exercise Challenges in Planning and organisation Training Communication Culture Need leadership and need to achieve buy in

IAIS ICP16 Assess overall solvency needs Continuity analysis (forward looking assessment) Responsibility with Board and senior management Perform regularly and following significant change Group ORSA required Supervisor should review output of ORSA Document rationale, calculations, actions arising Proportionality recognised Independent review where proportionate

Comparison criteria Quantitative assessment Qualitative assessment Forward looking Continuous compliance Deviation from assumptions Role of board Use of ORSA Frequency Group assessment First submission Exemption Proportionality Required documentation Independent review

Territories covered include IAIS (International) European Union United States Australia Canada Switzerland Singapore Malaysia Bermuda

Common Requirements Large degree of consistency in requirements Quantitative assessment stress tests, reverse stress tests, sensitivities and scenario analyses Qualitative assessment Forward looking perspective Performed on regular basis Proportionality recognised

Specific Points to Note Solvency II Additional requirements Demonstrate compliance on continuous basis with: Capital requirements Technical provision requirements Assess deviation of risk profile from assumptions of SCR Extensive documentation No explicit requirement for independent review 2014 Implementation through FLAOR

Specific Points to Note NAIC Less emphasis on the Role of the Board No explicit requirements to steer/challenge the process Copy of summary report provided to the Board Report must be signed By individual responsible for oversight of ERM process Less emphasis on Use of the ORSA Flexibility on risk capital measure Economic, rating agency and/or regulatory frameworks

Specific Points to Note NAIC Group emphasis Performed consistent with the way the business is managed Whether group, legal entity or other basis Not necessarily required for every legal entity More focused on ERM? Thresholds Annual direct written premium of less than $500 million; or Part of group with annual direct written premium of less than $1 billion

Specific Points to Note NAIC Preparedness Milliman survey March 2013 80% of participants don t currently prepare such a report 33% with no risk appetite statement Strategic, reputational and operational risks hardest to assess Marginal beneficial effect expected 2015 Implementation

Internal Capital Adequacy Assessment Process 2013 Implementation Capital triggers required Specific Points to Note APRA Provide time to rectify problems and restore capital Risk Appetite address all material sources of risk Doesn t matter if they can t be quantified Independent review required Target levels of capital and strategy for maintaining target

Specific Points to Note APRA Initial feedback from APRA on Summary Statements Significant room for improvement Quality not related to Insurer size Problem areas included: Independent review Stress testing Risk appetite Risk assessment Internal controls

ORSA an international development Practical challenges in implementing an ORSA

Questions the ORSA should help answer Understanding of risk profile of the company? Does company have sufficient capital to support business plan? Will company stay within risk appetite going forward? What risks are not covered by regulatory capital? What risks should be monitored more frequently? What scenarios could cause solvency issues? What mitigation options are available in these scenarios? Key sensitivities to capital & profits? Material changes to risk profile over recent period? What would cause company to re run ORSA?

Some challenges and potential solutions 1. Getting the relevant people involved

Who is involved in the ORSA process? Board Others e.g. Senior Management Team (SMT) ORSA Risk Management Function Actuarial Function

Role of the Board Board expected to steer how ORSA is performed and challenge results Involved in the process and users of the outputs Important that this happens and is evidenced Board involvement at start of the process Approve ORSA policy Input into stresses and scenarios Board involvement at end of the process Challenge outputs Evidence that Board take the output of ORSA into account in Business planning and strategy Setting risk appetite Capital management & dividend policy Product development

Some challenges and potential solutions 2. Balance Sheet Projections

Balance Sheet Projections Forward Looking Perspective Own Funds SCR Assets Technical Provisions = Best Estimate Liabilities (BEL) + Risk Margin Project for T = 1..5 Allow for new business Business Planning time horizon

Projections Required to project Assets, Liabilities and SCR Not a trivial task! Responsibility of the Actuarial Function Existing capital projections models may already be available e.g. Financial Condition Reports Approach should be proportionate to the nature scale and complexity of the business Trade off between simplicity and accuracy Need to be able to understand and explain output to Board

Projection methodologies Nested Stochastic Complexity Balance Sheet Roll Forward Deterministic Stochastic For business with complex options and guarantees Accuracy Issues to consider: IT resources and run times Spurious accuracy IMPORTANT: Output must be understood and used by the business

Projecting Assets & Liabilities Deterministic approach may be appropriate for many lines of business Liabilities Run off of Existing BEL and Risk Margin in line with best estimate assumptions Build model points for future new business Assets issues to consider Granular data available on asset holdings? What is the company s ALM strategy? Reinvestment policy for existing assets? What assets are assumed to back new business? What is the company s capital and dividend policy? Rebalancing of portfolio in particular scenarios?

SCR Standard Formula

Projecting SCR Full recalculation for each future year very onerous Significant number of market consistent valuations to calculate opening SCR Projecting forward, total number of calculations mounts up very quickly Key risk drivers, e.g. Sums at risk for insurance risks Growth in equity / property / bonds for market risks Funds under management for future AMCs Other options available Trade off between accuracy and practicality

Some challenges and potential solutions 3. Stress and Scenario Testing

Stress and Scenario Testing Options Stress tests Sensitivity of capital position to particular risks (e.g. an equity shock) Consider risks not covered by regulatory capital (e.g. sovereign) Scenario analysis Combinations of stresses What if scenarios Reverse stress tests Determine outcome e.g. own funds falls below SCR / MCR Solve for stress level

Selection of business scenarios should involve Board and SMT Risk Management Actuarial Function Others (e.g. sales) Consider wide range of scenarios Macro economic scenarios (e.g. multiple dependant market shocks) Insurance risk scenarios (e.g. pandemics, lapse events) Company specific scenarios Historical events that have been encountered Events that are difficult to quantify (e.g. operational errors) Additional considerations Dependencies / Correlations Timing Mitigations Selecting stresses and scenarios

Scenarios Overall Solvency Needs

Some challenges and potential solutions 4. Linking to business plan and strategy

Linking to business plan and strategy

Some challenges and potential solutions 5. Documentation

Documentation Required: ORSA policy Record of each ORSA process Internal Report Supervisory Report Challenge to produce a comprehensive report that covers all the requirements and also meets the needs of all stakeholders Good overview and executive summary Core of report concise focus on key issues Detail in the appendices for interested parties Courage to omit

Company overview Business written, market information Strategic Plan, Risk appetite, Capital strategy etc. Current and future solvency position Base case projection on current business plan Identification of key risks and results of stress testing Risk mitigation strategies and management actions Challenge and conclusions Board and SMT review and challenge Conclusions with respect to capital required to run business Evidence of link between ORSA and strategy Appendices Possible outline of report

The ORSA is about: Risk Management versus Compliance Better risk awareness Understanding the overall solvency needs of the company Increased alignment between risk appetite and strategy More insightful decision making Improved capital efficiency The ORSA is not about: Just addressing the guidelines (ticking the boxes) Creating a very complex process output not understood by Board Designing a complex mathematical model Creating a huge report key messages not clear

Summary ORSA is now an international requirement Significant consistency in requirements across territories Provides similar challenges for companies globally Focus on what ORSA is trying to achieve and develop approach that works for the Company No perfect model, will improve over time There are many benefits to the ORSA if done well!