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IAN - Reinsurance: 1 When Is IFRS 17 Used To Reinsurance Contracts ?
IAN - Reinsurance: 1 When Is IFRS 17 Used To Reinsurance Contracts ?
This International Actuarial Note (IAN) is promulgated under the authority of the
international Actuarial Association. It is an educational document on an actuarial
subject that has been adopted by the IAA in order to advance the understanding of the
subject by readers of the IAN, including actuaries and others, who use or rely upon the
work of actuaries. It is not an International Standard of Actuarial Practice ("ISAP") and
is not intended to convey in any manner that it is authoritative guidance.
This note is structured in the form of a series of questions and answers. It is not
applicable to reinsurance contracts that are considered to be Financial Instruments
under IFRS.
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2 What constitutes significant insurance risk transfer for reinsurance?
Under IFRS , an insurance contract is one under which one party accepts
significant risk, other than financial risk, from another party by agreeing to
compensate the other party if a specified uncertain future event (the insured
event) adversely affects the other party.
Under IFRS, the insurance risk is significant whenever an insured event could
cause the insurer to pay significant additional benefits in any scenario,
excluding scenarios that lack commercial substance (i.e. have no discernible
effect on the economics of the transaction). IFRS specifically says this
condition may be met even if the insured event is extremely unlikely or even
if the expected (i.e. probability-weighted) present value of contingent cash
flows is a small proportion of the expected present value of all the remaining
contractual cash flows
For reinsurance, there are two specific exceptions to the above general
principles
2
.
5 How are reinsurance contracts held measured ?is the value of reinsurance
contracts held determined ?
6 Does the asset or liability for reinsurance held asset have a CSM ?
4
expense of purchasing reinsurance and should be spread over the period in
which the service is received.
This means that where an entity has transferred risk to a reinsurer, there is
an attempt to ensure consistency in how changes in the fulfilment cash flows
associated with the risks transferred is treated in the CSM of the reinsurance
held and the gross insurance liabilities, even in the situation where a group of
contracts in the gross insurance liabilities is onerous.
7 Does the existence of reinsurance held impact the determination of the CSM
and onerous contract testing of the gross insurance liabilities ?
5
As covered in question 4, an entity’s approach to diversifying its risk
exposure, including reinsurance, may impact the risk adjustment for a
group of insurance contracts in the gross insurance liabilities.
However this would be an indirect rather than direct linkage for a
specific reinsurance held treaty.
The allowance should reflect the current financial condition and credit
standing of the reinsurance counter party, as well as the potential for these
conditions to change over time.
The assumptions used for the estimates of future cash flows for business
ceded and reflected in the reinsurance held would normally be logically
aligned with those used for the gross insurance liabilities on the same
business. That is to say, assumptions related to policyholder behavior or
insured decrements (e.g. mortality rates, morbidity rates) on the underlying
gross insurance liabilities would normally be consistent between the gross
insurance liabilities and where these assumptions are used to help determine
the reinsurance held asset. Other assumptions, such as expenses as
expenses, may be different.
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In addition, other variables and determinants of the cash flows, including the
contract boundary, may be different depending on the terms of the
reinsurance.
The grouping for business covered by reinsurance held may be different than
the contract grouping for the same underlying business business in the gross
insurance liabilities.
Under IFRS 17, contracts are required to be grouped. In addition, under IFRS
17 the general approach is that unless a contract contains components that
would be within the scope of another standard if they were separate contracts,
the contract is contemplated as the most basic unit of account.
This is true not only where the risks covered are different, but, even where the
reinsurance is proportional reinsurance on underlying gross insurance
liabilities. This is because the reinsurance held and the gross insurance
liabilities, are de-linked.
11 How is the reinsurance held risk adjustment for non financial risk
determined ?
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A specific definition for the determination of the risk adjustment for
reinsurance contracts held is provided in IFRS 17 that replaces the general
definition used for insurance and reinsurance contracts issued in paragraph
37 of the standard. Under the definition for reinsurance held, the quantum of
the risk adjustment for non financial risk represents the amount of risk being
transferred by the holder of a group of reinsurance contracts to the issuer of
those contracts (para B64 IFRS 17|).
The risk adjustment for the reinsurance held can therefore conceptually be
thought of as the difference in the risk position of the entity with (i.e. net
position) and without (i.e. gross position) the reinsurance held. As a result,
the appropriate risk adjustment for the reinsurance held can usually be
determined most easily based on the difference between these amounts.
12 What are the considerations when a reinsurance held contract may cover
multiple years of underlying insurance contracts or risk attachments?
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Grouping of proportionate reinsurance held coverages based on
underlying cession date can better align with groupings for the
underlying insurance coverages since the latter cannot group contracts
issued over more than a 12 month period. This alignment is difficult for
other multiple year reinsurance held coverages.
Proportionate reinsurance held contracts that are open for new risk
attachments for one year, where each risk attachment has a one year
coverage period, are eligible to be considered for the PAA (Premium
Allocation Approach) which is limited to contracts with coverage
periods of one year or less. Other multiple year reinsurance held
contracts would not fall into this eligibility criteria.
Grouping of proportionate reinsurance held coverages based on
underlying cession date can help avoid CSM discount rate mismatches
with respect to discount rates. The IFRS 17 application guidance states
that, when determining the discount rates for initial recognition, “an
entity may use weighted-average discount rates over the period that
contracts in the group are issued, which applying paragraph 22 cannot
exceed one year” [para B73 IFRS 17]. |Other multiple year reinsurance
held contracts would not be able to avoid mismatch using this
paragraphin this manner.
For non proportionate reinsurance held, the cash flows would need to
include estimates of the future new business over the full expected
duration of the contract. Therefore a projection of new cessions to be
added and / or other future risk attachments would need to be
included, even though cash flows from these items would not be
included in the underlying insurance contract valuation
Proportionate reinsurance is not a defined term in IFRS 17. In the Basis for
conclusions there is a reference to the distinction between proportionate
versus non proportionate reinsurance [Para BC304] . “In some cases, the
reinsurance contract held covers the losses of separate contracts on a
proportionate basis. In other cases, the reinsurance contract held covers
aggregate losses from a group of underlying contracts that exceed a specified
amount” . BC 305 then goes on to discuss the different treatment based on the
classification into one of these two categories.
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individual life YRT coverages may be considered a proportionate coverage
under this definition.
14 Would the contract boundary used for reinsurance issued and reinsurance
held for the same contract necessarily be the same |?
The contract boundary would not necessarily be the same. Provisions in the
reinsurance treaty concerning rate adjustment, recapture etc may lead to
different contract boundaries. As an example, if a contract allows the entity
issuing the reinsurance an annual full and unilateral right to adjust
reinsurance premiums without restriction, it is likely to be considered a one
year contract by the issuing entity. However, for the assuming entity, it likely
would be modelled as a longer duration contract reflecting the best estimate
of the behaviour of the issuing company with respect to future rate
adjustments.
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16 Can Reinsurance contracts qualify as insurance contracts with direct
participation features ?
Where an entity has entered into reinsurance contracts to assume risk and
obligations, the value of these contracts is shown on the balance sheet as
part of the gross insurance liabilities or assets, the differentiation whether
asset or liability decided on the level of the grouping of insurance contracts..
Data issues are frequently more prevalent for reinsurance issued business, as
the reinsuring entity is further removed from the underlying risks, and is
reliant on ceding company for underlying data on insured risks. This means
that there is frequently more use of approximations both in terms of data and
modeling approach. Actuaries performing such valuations should therefore
ensure that techniques used are appropriate and produce reasonable
approximations.
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19 What are the considerations when a reinsurance issued contract may cover
multiple years of underlying insurance contracts or risk attachments?
The cash flows would need to include estimates of the future new business
over the full expected duration of the contract. Therefore a projection of
new cessions to be added and / or other future risk attachments would
need to be included
The IFRS 17 application guidance states that, when determining the
discount rates for initial recognition, “an entity may use weighted-average
discount rates over the period that contracts in the group are issued, which
applying paragraph 22 cannot exceed one year” [para B73 IFRS 17]. When
a reinsurance contract covers multiple session years, determining how to
apply the discount rate guidance will require interpretation. A strict
interpretation that discount rates may only be averaged taking into
account the initial year that a contract is inforce may produce an economic
mismatch when a reinsurance contract is open for multiple years and new
sessions are added in subsequent years after the initial contract year.
Techniques to address this could include using discount rates better
matched to when new cessions / risks are added to a reinsurance treaty. It
is outside the scope of this note to provide guidance on whether use of
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such techniques may be appropriate in the specific circumstances being
considered .
THE PAA may be difficult to apply for contracts where the coverage period
is only 1 year, but new risks attach after the inception date (since PAA is
limited to one year contracts)
Other Questions
Other Possible Topics that have been suggested for the IAN
- Specific considerations with respect to cat bonds(eg multi year cat bonds
that attach on rolling basis for underlying risks
- treatment of contract features such as deposits, premium payment in arrears,
cash flows only on settlement dates once a year
-
- Considerations with respect to ‘true up’ of reinsurance contract cash flows
and CSM recognized at inception for actual versus expected differences (eg
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differences in actual versus future projected cession additions in periods
subsequent to initial contract reporting)
- Presentation issues(eg ceding commissions netted against ceded premium,
showing reinsurance contracts held revenue as net in the P&L)
- special considerations with respect to determining reinsurance contract
boundary
[ note, one or more Q&A need to be drafted to address specific cat bond issues..one
issue is approach for multi year cat bonds that attach on rolling basis for underlying
23 presentation issues ?
[note, one or more Q&A need to be drafted to address presentation issues…one item
is the presentation of ceding commissions which are netted against ceded premium]
1 year contract years]]
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