Currency Risk in the Valuation of Policy Liabilities for Life and Health Insurers

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Educational Note Currency Risk in the Valuation of Policy Liabilities for Life and Health Insurers Committee on Life Insurance Financial Reporting December 2009 Document 209121 Ce document est disponible en français 2009 Canadian Institute of Actuaries Members should be familiar with educational notes. Educational notes describe but do not recommend practice in illustrative situations. They do not constitute Standards of Practice and are, therefore, not binding. They are, however, intended to illustrate the application (but not necessarily the only application) of the Standards of Practice, so there should be no conflict between them. They are intended to assist actuaries in applying Standards of Practice in respect of specific matters. Responsibility for the manner of application of Standards of Practice in specific circumstances remains that of the members in the life insurance practice area.

To: From: All Life Insurance Practitioners Tyrone G. Faulds, Chairperson Practice Council Memorandum B. Dale Mathews, Chairperson Committee on Life Insurance Financial Reporting Date: December 2, 2009 Subject: Educational Note Currency Risk in the Valuation of Policy Liabilities for Life and Health Insurers The purpose of this educational note is to emphasize the importance of providing for currency risk in the valuation to the extent that it is not hedged and to provide additional guidance in doing so. The note is consistent with the recent changes to the Standards of Practice Practice- Specific Standards for Insurers, Subsection 2340 Foreign Exchange (http://www.actuaries.ca/members/publications/2009/209090e.pdf, September 2009). In accordance with the Institute s Policy on Due Process for the Approval of Guidance Material Other than Standards of Practice, this educational note has been prepared by the Committee on Life Insurance Financial Reporting and has received final approval for distribution by the Practice Council on November 26, 2009. As outlined in subsection 1220 of the Standards of Practice, The actuary should be familiar with relevant Educational Notes and other designated educational material. That subsection explains further that a practice which the Educational Notes describe for a situation is not necessarily the only accepted practice for that situation and is not necessarily accepted actuarial practice for a different situation. As well, The Educational Notes are intended to illustrate the application (but not necessarily the only application) of the Standards, so there should be no conflict between them. If you have any questions or comments regarding this educational note, please contact Dale Mathews at her CIA Online Directory address, Dale_Mathews@manulife.com. TGF, BDM

TABLE OF CONTENTS 1. INTRODUCTION... 4 2. BASE SCENARIO... 5 3. PROVISION FOR ADVERSE DEVIATIONS... 6 4. EXAMPLES... 7 3

RESERVING FOR CURRENCY RISK 1. INTRODUCTION The purpose of this educational note is to emphasize the importance of providing for currency risk in the valuation to the extent that it is not hedged and to provide additional guidance in doing so. Currency risk can be defined as the risk of incurring losses resulting from adverse movement in exchange rates. Because exchange rates can be very volatile in both the short and long terms, often more so than interest rates (see section 4. Examples), they can expose companies to substantial risks of incurring losses when liabilities and assets are denominated in different currencies. This note would apply to all asset types, although for equities and some other types of investments, judgement would be required to assess whether currency risk is already included in return assumptions. One such example would be where liabilities are backed by the shares of a foreign-listed multinational company that transacts business mostly in the currency of the liabilities. The wording of the Standards of Practice has been changed to reflect the fact that there may be significant interest rate differentials in countries using different currencies. In such a case, the market is expecting one currency to appreciate (or depreciate) relative to the other currency (otherwise, if the foreign exchange rates were expected to remain fixed at the foreign exchange rates at the balance sheet date, this would provide an arbitrage opportunity to invest in the currency yielding the highest return). Paragraph 2340.16 of the Standards of Practice states, The needed assumptions would include foreign exchange rates when policy liabilities and their supporting assets are denominated in different currencies. Paragraphs 2340.17 through 2340.19 of the Standards of Practice state.17 The base scenario used to develop the assumption for foreign exchange rates would be based on currency forwards. If currency forwards are not available, the forward exchange rates would be derived based on risk-free interest rate differentials where available. If neither is available, the actuary would use his or her best judgment to develop an appropriate approach..18 A provision for adverse deviations would be developed from a scenario using adverse movements in the exchange rate. Such movements would reflect the historical volatility in the exchange rate over the applicable period. The provision for adverse deviations would be the excess of the policy liabilities based on this adverse scenario over the policy liabilities calculated using the base scenario..19 A minimum provision for adverse deviations would apply. This would be the excess of the policy liabilities resulting from the application of an adverse five percent margin to the projected exchange rates underlying the base scenario over the policy liabilities calculated using the base scenario. 4

The remainder of this note will provide guidance on the application of this Standard of Practice. Some currency risk exposure situations are Canadian branches of foreign companies where some of the assets supporting the Canadian liabilities are denominated in non-canadian currency, Canadian companies operating in countries where the local liabilities are backed by non-local denominated currencies, universal life index-linked accounts where the credited rate is based on a foreign index but supported by a Canadian denominated asset, and Canadian companies where the liabilities (other than expenses) and the assets are Canadian denominated, but the expenses are US denominated. 2. BASE SCENARIO The base scenario assumption would be taken directly from currency forwards, or their equivalent. When currency forwards are not readily available, risk-free interest rate differentials can be used to derive a forward rate, F, as, F = S x ((1 + i a )/(1 + i b )) m where F is the corresponding forward exchange rate, S is the spot exchange rate, expressed as the price in currency a of a unit of currency b, i a and i b are the risk-free interest rates for the respective currencies (if risk-free interest rates are not available, deduct an appropriate amount for C1 risk for each country), and m is the common maturity in years for the forward rate and the two interest rates. The underlying theory is that of interest rate parity, which is a relationship that must hold between the spot interest rates of two currencies if there are to be no arbitrage opportunities. However, the empirical evidence for the theory is unconvincing. In the IMF Staff Papers Vol. 51, No. 3 2004 International Monetary Fund titled, Monetary Policy and Long-Horizon Uncovered Interest Parity by Chinn and Meredith 1, the authors conclude that the simple form of the UIP [uncovered interest parity] condition is essentially useless as a predictor of short-term movements in exchange rates Over longer horizons, however, our results suggest that UIP may significantly outperform naive alternatives such as the random walk hypothesis, although it is still likely to explain only a relatively small proportion of the observed variance in exchange rates. Nonetheless, in spite of its shortcoming, the theory has the important advantage of putting assets denominated in different currencies on equal footing. Choosing a higheryielding foreign bond over a local one (in this context, local is meant to be the currency in which the liability is denominated) without an offsetting depreciation of the currency 1 See http://www.ssc.wisc.edu/~mchinn/chinn_meredith_imfsp.pdf 5

would lead to lower policy liabilities. In light of the high volatility of exchange rates, as shown in section 4, this would appear to be both imprudent and difficult to justify. Let us consider two examples. First, consider a company that has a choice of investing between two risk-free 10-year strip bonds (for simplicity, C1 risk is assumed to be zero in both cases). The first one denominated in the same currency as the liability, yields 5% risk-free to maturity. The other, denominated in a foreign currency, yields 7% risk-free. Assuming that the current exchange rate is 1.000, the best estimate for the exchange rate in 10 years would be (1.05/ 1.07) 10 multiplied by the current rate. The result is 0.828. The foreign currency would, therefore, be expected to depreciate by 17.2% over the 10-year period. The C1 deduction would include sovereign risk in the case of a bond issued by a sovereign government. Some developing countries may not have deep or liquid bond markets, making this exercise difficult. In such cases, the actuary is encouraged to seek the input of individuals knowledgeable in techniques or theories available to determine such values. An example would be International Finance Theory and Policy by Steven M. Suranovic dealing with the purchasing power parity theory 2. Second, consider a company that decided to back its 30-year liabilities with a foreign stock index. Its assumed best estimate return over the 30-year period would be reduced by the expected currency depreciation. So, if the best estimate return were 9% and the 30-year interest rates were 7% and 8%, respectively, its currency-adjusted return would become 7.99% where (1.07/1.08) 30 x 1.09 30 = 1.0799 30. Note, however, that there can be unusual instances where assets denominated in a different currency than that of the liabilities would not necessarily create a currency risk exposure. Such situation would occur where U.S. liabilities are supported by the shares of Canadian companies that transact a significant percentage of their business in U.S. dollars and who report their financial results in that currency. In such cases, it is expected that movements between the Canadian and U.S. currencies would largely be reflected in the share prices. This note cannot possibly cover all possible situations and the actuary would apply the spirit of this note to the circumstances of his or her company. If the actuary believes that his or her company s position is such that a full adjustment for currency is not necessary, he or she would document this rationale. 3. PROVISION FOR ADVERSE DEVIATIONS Paragraph 1740.05 of the Standards of Practice states, The margin for adverse deviations in each assumption should reflect the uncertainty of that assumption and of any related data. Historical evidence indicates that currency volatility increases with time but decreases with the degree of integration of the economies of any two countries. 2 See http://internationalecon.com/v1.0/finance/ch30/f30-1.html 6

To establish a provision for adverse deviations, the actuary would develop a scenario reflecting historical volatility of that exchange rate over periods consistent with the length of time over which the currency mismatch is expected to exist. The provision for adverse deviations would be equal to the excess of the policy liability calculated using this scenario over the corresponding liability calculated using the base scenario. A minimum provision would apply. This would be taken as the increase in the policy liability resulting from the application of an adverse 5% margin to the projected exchange rates underlying the base scenario over the amount calculated using the base scenario. An acceptable approach to reflecting volatility would be to use one standard deviation of the changes in the exchange rate as the measurement. The actuary would apply the standard deviation in the direction that produces an adverse movement in the exchange rate of this amount over the projection period. The use of one standard deviation establishes an unbiased measure. In situations where the actuary feels there is strong economic evidence that one currency will appreciate (or depreciate) relative to the other and the mean historical movement over appropriate periods is consistent with this direction, the actuary would consider using the mean plus or minus one standard deviation as the measure of volatility. In the special case where one currency is pegged to another well established currency such as the US dollar, if the pegging has been present for an extended period of time, and there is only a nominal interest rate differential between the two countries, a margin for adverse deviations of less than 5% may be appropriate. Where the un-pegging of such a currency is deemed to be a remote possibility, the consequences of un-pegging are not necessarily provided for in the policy liability. The approach to calculating standard deviation illustrated in the examples assumes implicitly that the exchange rate follows a random walk, that is, that the exchange rate does not revert toward a long-term mean. While this assumption might not be critical for relatively short projection periods, it becomes important as the projection period lengthens. The assumption of mean reversion results in smaller confidence intervals for the projected exchange rate compared to the random walk hypothesis. Therefore, the actuary might consider mean reversion for establishing the margin for adverse deviations when this assumption is supported by the data. 4. EXAMPLES This section illustrates historical exchange rates for two currency combinations and the development of the base scenario, as well as the additional scenario to determine the provision for adverse deviations. With regard to practical implementation in a deterministic Canadian Asset Liability Method (CALM) valuation, the base scenario assumptions for foreign exchange rates, along with appropriate margins as developed consistent with this guidance would apply in all interest scenarios being tested. 7

Example 1 Canada US exchange rates The following graph shows the monthly exchange rate between the US dollar (USD) and the Canadian dollar (CAD) for the period of January 1975 to December 2007. USD vs. CAD Exchange Rate 1.70 1.65 1.60 1.55 1.50 1.45 1.40 1.35 1.30 1.25 1.20 1.15 1.10 1.05 1.00 0.95 0.90 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 The highest point during that period was $1.6086, which was reached in February, 2002. Conversely, the lowest point of $0.9499 took place in October, 2007. The USD depreciated by 40.9% between the high and low points. Using the 396 monthly rates, the following statistics result for the change in the exchange rate over monthly, 1-year and 10-year periods. Statistic Monthly 1-Year Periods 10-Year Periods Mean 0.000.003.089 Standard Deviation.015.056.176 (1) Standard Deviation (2).053.169 8

(1) is based on the 1-year and 10-year periods developed from the monthly data. (2) is equal to the standard deviation over one month periods multiplied by 12 for 1-year periods and by 12 x 10 for 10-year periods. Consider a liability of $1,000 denominated in CAD and payable at the end of 10 years. The assets backing this liability are denominated in USD and the currency risk is not hedged. The following table illustrates the construction of the base scenario exchange rate projection, the adverse scenario based on historical volatility and the scenario reflecting the minimum 5% margin. The scenarios are constructed as of September 30, 2008. At that time, rates were, Exchange Rate: 1.00 USD buys 1.059 CAD U.S. 10-year risk-free rate: 3.83% Canadian 10-year risk-free rate: 3.72% As the risk-free rates in Canada and the U.S. are fairly close, there is little implied movement in the exchange rates. In the base scenario, the exchange rate moves from 1.059 to 1.048 over 10 years. The base scenario liability in CAD at September 30, 2008 is 694.02, which, because of the reflection of the interest forward rates, is the same as if the assets were denominated in CAD. If exchange rates are assumed to remain unchanged, the liability reserve would be 686.71 CAD. In the adverse scenario, one standard deviation of.176 is used to project the exchange rate. The projected exchange rate at the end of year t is obtained from the starting rate of 1.059 as 1.059 x ((1-.176) 1/10 ) (10-t). The exchange rate at the end of 10 years is.877 and the resulting liability is 833.38 CAD which produces a provision for adverse deviations of 139.36 or 20.1%. Finally, application of a 5% adverse margin to the projected exchange rates in the base scenario produces a liability of 730.48 CAD. The results are summarized in the table below. Canada US Exchange Rates Liabilities in CAD Liability assuming no change in exchange rates 686.71 Base Exchange Rate Scenario Liability 694.02 Adverse Exchange Rate Scenario Liability 833.38 Liability based on 5% minimum margin scenario 730.48 Liability Held 833.38 Provision for Adverse Deviations 139.36 9

Example 1 - Canada / U.S. Time Liability in CAD 0 1 2 3 4 5 6 7 8 9 10 U.S. risk-free interest rate 3.83% 3.83% 3.83% 3.83% 3.83% 3.83% 3.83% 3.83% 3.83% 3.83% 3.83% Canada risk-free interest rate 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% Base Scenario Projected Exchange Factor {(1.0372/1.0383)^(10-n)} 0.989 0.991 0.992 0.993 0.994 0.995 0.996 0.997 0.998 0.999 1.000 Projected Exchange (1 $US buys X CAD) Sept. 30, 2008 1.059 1.058 1.057 1.056 1.055 1.054 1.052 1.051 1.050 1.049 1.048 Ultimate Exchange (1 $US buys X $CAD) 1.048 1.048 1.048 1.048 1.048 1.048 1.048 1.048 1.048 1.048 1.048 Asset is Purchased on USD Value in USD 655.30 680.39 706.45 733.51 761.60 790.77 821.06 852.51 885.16 919.06 954.26 Value in CAD at Projected Rates 694.02 719.84 746.62 774.39 803.20 833.08 864.07 896.22 929.55 964.13 1,000.00 For Comparison Value in CAD if invested directly in CAD Bond {1000/(1.0372)^n} 694.02 719.84 746.62 774.39 803.20 833.08 864.07 896.22 929.55 964.13 1,000.00 Value in CAD if invested in USD Bond - assume no change in exchange rates 686.71 713.01 740.32 768.67 798.11 828.68 860.42 893.37 927.59 963.11 1000.00 Adverse Scenario Projected Exchange Factor {((.824^1/10))^(10-n)} 0.824 0.840 0.857 0.873 0.890 0.908 0.925 0.944 0.962 0.981 1.000 Projected Exchange (1 USD buys X CAD) Sept. 30, 2008 1.059 1.039 1.019 0.999 0.980 0.961 0.943 0.925 0.907 0.890 0.873 Ultimate Exchange (1 USD buys X CAD) 0.873 0.873 0.873 0.873 0.873 0.873 0.873 0.873 0.873 0.873 0.873 Asset is Purchased in $US Value in USD 786.88 817.02 848.31 880.80 914.53 949.56 985.93 1,023.69 1,062.89 1,103.60 1,145.87 Value in CAD at Projected Rates 833.38 848.71 864.32 880.22 896.41 912.90 929.69 946.79 964.20 981.94 1,000.00 Scenario Reflecting 5% Margin Projected Exchange (1 USD buys X CAD) Sept. 30, 2008 1.0590 1.0051 1.0040 1.0030 1.0019 1.0008 0.9998 0.9987 0.9976 0.9966 0.9955 Ultimate Exchange (1 USD buys X CAD) 0.9955 0.9955 0.9955 0.9955 0.9955 0.9955 0.9955 0.9955 0.9955 0.9955 0.9955 Asset is Purchased on USD Value in USD 689.79 716.20 743.64 772.12 801.69 832.39 864.27 897.38 931.75 967.43 1004.48 Value in CAD at Projected Rates 730.48 719.84 746.62 774.39 803.20 833.08 864.07 896.22 929.55 964.13 1000 10

Example 2 Canada Jamaica exchange rates The following graph shows the monthly exchange rate between the Jamaican dollar (JAD) and the Canadian dollar for the period of January 1991 to December 2007. CAD vs. JAD 71.90 66.90 61.90 56.90 51.90 46.90 41.90 36.90 31.90 26.90 21.90 16.90 11.90 6.90 1991 1992 1993 1994 1995 1996 1997 1998 Exchange rate 1999 2000 2001 2002 2003 2004 2005 2006 2007 The highest point during that period was JAD 74.94, reached in October 2007. Conversely, the lowest point of JAD 6.985 took place in January 1991. The Canadian dollar appreciated by 972.87% in the 202 months separating the high and low points. Using the 204 monthly rates the following statistics result for the change in the exchange rate over monthly, 1-year and 10-year periods. Statistic Monthly 1-Year Periods 10-Year Periods Mean.012.150 1.223 Standard Deviation.046.313.587 (1) Standard Deviation (2).160.506 11

(1) is based on the 1-year and 10-year periods developed from the monthly data. (2) is equal to the standard deviation over one month periods multiplied by 12 for 1-year periods and by 12 x 10 for 10-year periods. Consider a liability of 1000 denominated in JAD and payable at the end of 10 years. The assets backing this liability are denominated in CAD and the currency risk is not hedged. The following table illustrates the construction of the base scenario exchange rate projection, the adverse scenario based on historical volatility and the scenario reflecting the minimum 5% margin. The scenarios are being constructed on September 30, 2008. At that time, rates were, Exchange Rate: 1.00 CAD buys 72.40 JAD Canadian 10-year risk-free rate: 3.72% Jamaican 10-year risk-free rates: 13.0% (assumed) In this example, the risk-free rates in Jamaica are much higher than in Canada and there is, therefore, considerable implied movement in the exchange rates. In the base scenario the exchange rate moves from 72.4 to 170.6 over 10 years. The liability in JAD at September 30, 2008 is 294.59, which, because of the reflection of the interest forward rates, is the same as if the assets were denominated in JAD. If the exchange rates are assumed to remain unchanged, the liability would be 694.02 JAD. For the adverse scenario, the actuary might feel that there is strong economic evidence that the JAD will continue to depreciate versus the Canadian dollar and this is directionally consistent with the historic mean. Therefore, the mean minus one standard deviation of (1.223 -.587) or 0.636 is used to project the exchange rate. The projected exchange rate at the end of year t is obtained from the starting rate of 72.40 as 72.40 x ((1 + 0.636) 1/10 ) (10-t). The exchange rate at the end of 10 years is 118.4 and the resulting liability is 424.20 JAD producing a provision for adverse deviations of 129.61 JAD or 44%. Finally, application of a 5% adverse margin to the projected exchange rates in the base scenario produces a liability of 310.09 JAD. The results are summarized in the table below. 12

Canada Jamaica Exchange Rates Liabilities in JAD Liability assuming no change in exchange rates 694.02 Base Exchange Rate Scenario Liability 294.59 Adverse Exchange Rate Scenario Liability 424.20 Liability based on 5% minimum margin scenario 310.09 Liability Held 424.20 Provision for Adverse Deviations 129.61 13

Example 2 - Jamaica / Canada Time Liability in JAD 0 1 2 3 4 5 6 7 8 9 10 Canada risk-free interest rate 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% 3.72% Jamica risk-free interest rate 13.00% 13.00% 13.00% 13.00% 13.00% 13.00% 13.00% 13.00% 13.00% 13.00% 13.00% Base Scenario Projected Exchange Factor {(1.13/1.0372)^(10-n)} 2.356 2.162 1.985 1.822 1.672 1.535 1.409 1.293 1.187 1.089 1.000 Projected Exchange (1 CAD buys X JAD) Sept. 30, 2008 72.400 78.878 85.935 93.624 102.00 111.13 121.07 131.902 143.703 156.560 170.568 Ultimate Exchange (1 CAD buys X JAD) 170.568 170.57 170.57 170.57 170.57 170.57 170.57 170.568 170.568 170.568 170.568 Asset is Purchased on CAD Value in CAD 4.07 4.22 4.38 4.54 4.71 4.88 5.07 5.25 5.45 5.65 5.86 Value in JAD at Projected Rates 294.59 332.88 376.16 425.06 480.32 542.76 613.32 693.05 783.15 884.96 1,000.00 For Comparison Reserve in JAD if invested directly in JAD Bond {1000/(1.13)^n} 294.59 332.88 376.16 425.06 480.32 542.76 613.32 693.05 783.15 884.96 1,000.00 Reserve in $Jam if invested in $Can Bond - assume no change in exchange rates 694.02 719.84 746.62 774.39 803.20 833.08 864.07 896.22 929.55 964.13 1000.00 Adverse Scenario Projected Exchange Factor {((1.636^1/10))^(10-n)} 1.636 1.557 1.483 1.411 1.344 1.279 1.218 1.159 1.103 1.050 1.000 Projected Exchange (1 CAD buys X JAD) Sept. 30, 2008 72.400 76.053 79.891 83.922 88.156 92.604 97.277 102.185 107.341 112.757 118.446 Ultimate Exchange (1 CAD buys X JAD) 118.446 118.446 118.446 118.446 118.446 118.446 118.446 118.446 118.446 118.446 118.446 Asset is Purchased in CAD Value in CAD at Projected Rates 5.86 6.08 6.30 6.54 6.78 7.03 7.30 7.57 7.85 8.14 8.44 Value in JAD at Projected Rates 424.22 462.20 503.59 548.67 597.80 651.32 709.64 773.17 842.40 917.82 1,000.00 Scenario Reflecting 5% Margin Projected Exchange (1 CAD buys X JAD) Sept. 30, 2008 72.4000 74.934 81.638 88.943 96.900 105.570 115.016 125.307 136.518 148.732 162.040 Ultimate Exchange (1 CAD buys X JAD) 162.040 162.040 162.040 162.040 162.040 162.040 162.040 162.040 162.040 162.040 162.040 Asset is Purchased in CAD Value in CAD 4.28 4.44 4.61 4.78 4.96 5.14 5.33 5.53 5.74 5.95 6.17 Value in JAD at Projected Rates 310.09 332.88 376.16 425.06 480.32 542.76 613.32 693.05 783.15 884.96 1000 14