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OAC

Solvency 2:
The value and risk of Value at Risk

Solvency 2 has now been given the The problem here is that the process actually more like 1-in-10, and occurs
formal go ahead with a planned will clearly not always directly follow broadly in line with common economic
introduction date of 31 October 2012. the distribution – practise will not cycles of expansion followed by
This date is fast approaching, so it is always follow statistical theory. This contraction.
important that all stakeholders are can be ‘lost’ in the science ruling the
concentrating on fully understanding VaR calculation, with the result that The problem is compounded where
and implementing the requirements. the VaR is considered to be fact, with there is little or no historical statistical
sight being lost of the actual risk data as the 1-in-200 event is
This Topical Article discusses the itself being considered. This issue effectively anecdotal. The issue boils
method used for determining firms’ is compounded by the fact that the down to what ‘feels’ like a 1-in-200
solvency levels, and some of the process will deviate furthest from event. This is highly subjective and it
OAC Topical Article > Insurance Consulting Edition > Published July 2009

concerns that have been raised over the assumed pattern during extreme quickly becomes very difficult to judge
its use – since the method used is situations. what is a 1-in-100 event (say) and
based on that which seemingly failed what is a 1-in-200 event: both are by
to protect the banks during the recent To illustrate this point, statistical definition rare, yet one is twice as rare
financial downturn. analysis on UK equity returns 18 as the other!
months ago suggested that a suitable
The Solvency Capital Requirement 1-in-200 event was a fall in markets Why wasn’t the recent downturn
of around 40% over a one year time ‘predicted’?
One of the central aspects of Solvency horizon. The graph below shows
2 is the introduction of the Solvency monthly FTSE 100 Index levels Criticism has been levelled at the Basel
Capital Requirement (SCR), which is and demonstrates that, in fact, 2 regime, and in particular the concept
the additional capital that firms need movements of this magnitude occur of VaR, for not ensuring that the banks
to hold to cover the risks facing their fairly frequently – certainly more than remained resilient throughout the
business. The SCR is based on a once every 200 years! Just since 1984 recent crisis in the financial markets.
‘Value at Risk’ (VaR) measurement, for example, the FTSE 100 Index has While it is true that the scale of the
similar to that introduced for the fallen 28% in 2001, 37% in 2003 and downturn was not anticipated by the
banking industry under the Basel 2 42% in 2008. regulatory measures in place, VaR is
regulations in 2004. In brief, VaR not designed to ensure ‘zero failure’
seeks to place a maximum loss that So what we might consider as extreme (indeed, losses of similar magnitude
could be expected, with a given events are not really anything of the to the 1-day 99.5% VaR would be
probability (or confidence level), over sort; for UK Equity markets, it might expected 1-2 times in any given year).
a specific time horizon. The banking simply be that what we consider at To do this would require very large
system generally looks at one day present to be a 1-in-200 event is amounts of available capital, meaning
VaR, while the SCR calculation under
Solvency 2 uses one year. The
confidence level is usually chosen FTSE 100 Index (1984 to 2009)
such that the associated probability
is very small, typically 0.5%, which 8000

gives rise to the ‘1-in-200 event’.


7000

What is a ‘1-in-200’ event?


6000

The concept of VaR (and more


specifically confidence intervals) 5000

comes from statistical theory: where


a process conforms, or has historically 4000

conformed, to a known statistical


distribution, we can compute 3000

confidence intervals around the


possible outcomes of that process.
2000
So if we can fit such a distribution to
a process we are interested in – eg
1000
equity returns over a one year period
– we can derive these confidence
intervals eg the fall in the equity 0
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market consistent with a 1-in-200


year event.
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Page 2 OAC Topical Article > Insurance Consulting Edition > Published July 2009

that only those firms with suitably deep Further, forcing the whole balance sheet suppose that recent events would have
pockets could compete in the market. to be considered shows just how different been significantly worse without the
risks interact (many of which may move in improved systems in place thanks to these
The failings of the regime may be because opposite directions). measures.
too much reliance was placed on VaR.
This may have been implicitly encouraged Analysing VaR also helps the Board to Solvency 2 will certainly present a
by the Basel 2 regime itself, in placing formalise the management actions it challenge but it is to be hoped that this
VaR at the forefront of the strategy. In needs to take under stressed conditions will help embed a greater understanding
other words, rather than all the risks in advance, rather than only considering and transparency in insurers’ assessment
in the business being fully understood, what to do once such events have of risk. While many firms already claim to
the temptation may have been to look occurred. VaR can be calculated without have a deeply embedded risk management
at VaR and assume that as long as this any such reactive measures in place; culture, a key aim of Solvency 2 is a more
was “reasonable” (ie easily covered by then suitable actions considered (for transparent demonstration of this, and the
available capital) then everything was example the sale of equities at certain SCR, as part of the Solvency 2 process, is
“OK”. “trigger” points of an agreed index) until a designed to help prove this.
satisfactory reduction in VaR is achieved.
It is also questionable whether holders of These actions can then form part of the
many new asset types eg collateralised Board’s formal procedures, so that it How can OAC help?
debt obligations (CDOs), fully understood immediately knows what it needs to do as
how such assets would behave under equity markets fall (for example) without OAC is committed to the positive
stressed conditions. This would make it having to only start considering such change that Solvency 2 is introducing.
almost impossible to make any realistic actions during the storm itself. We are helping firms deal with
assessment of the VaR needed to back Solvency 2 by:
those asset types. As recent events demonstrate, the
most significant danger arises when n calculating Solvency 2 capital
Is Value at Risk still a valid measure? the measure becomes the control itself requirements on our state-of-
– and regulation allows this to occur. The the-art financial modelling tool
VaR remains an extremely useful measure control must always be the relevant risk Mo.net (we have a QIS4 model
of risk. It supplies an objective assessment management function (and the Board), that models the majority of
of the total risk faced by the firm, and who will of course make extensive use of insurance business);
more importantly the contribution each such measures as VaR. Simply minimising n training executives and non-
individual risk makes. Using VaR the VaR must not be their primary objective. executives on the implications of
Board can therefore very easily see which Instead it should be to ensure that the risk Solvency 2;
are its most significant risks, and ensure profile matches the risk appetite of the n assisting them project manage
they satisfy its risk appetite. If they do company. The VaR measure is but one their implementation plans;
not, then the risks need to be mitigated, tool available to the Board in making that n providing general help and
with the effectiveness of suitable assessment. support; and
mitigation strategies measured by looking n monitoring and auditing the
at the reduction in VaR they supply. Conclusion implementation of Solvency 2
across their business.
A useful phrase that has emerged from the So do we know what 1-in-200 events are?
recent financial downturn is “If you don’t The answer is probably not. Even for risks Of course we can also help by
fully understand an asset, don’t buy it. If where we have a reasonable amount of providing AFH and WPA services and
you don’t understand a liability, don’t write credible statistical data, recent events we would be delighted to talk to firms
it”. While this may seem common sense, have shown that models don’t quite work looking to get the best value from
it is not always the case that the decision in the real world. The recent “failings” of their actuarial suppliers: our unique
makers fully understand the effect that VaR arose from the difficulty in estimating working methodology ensures that
complex financial instruments such as what these 1-in-200 events are, rather our rates are highly competitive.
CDOs may have on its balance sheet than the method itself being flawed.
(especially in extreme situations). A VaR- For more information contact:
type measure will force this understanding. But it would be unfortunate if the many
Without VaR the Board may only be able significant positives introduced with the
to form subjective opinions on what it use of capital models were tarnished by David Gregson
considers are its chief risks, and so may recent events, as if they were somehow to Consultant Actuary
be “surprised” by a risk that had not been blame. Instead the lessons learned should +44 (0)20 7278 9500
considered to be suitably significant to provide useful refinements to how the david.gregson@oacplc.com
consider. VaR would highlight such risks Solvency 2 process evolves, and where oacplc.com/insuranceconsulting
via their contribution to the aggregate. the focus falls. It is not unreasonable to

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