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Economic Capital Overview and Recent Trends

ERM Symposium April 24, 2006

Hubert Mueller, (860) 843-7079 Hubert.Mueller@TowersPerrin.com

2006 Towers Perrin

Overview

Economic Capital Overview and Recent Trends

Aggregation

2005 Towers Perrin

Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

OVERVIEW AND RECENT TRENDS

ERM Governance and Economic Capital Governance policies, procedures, tools, resources ERM Framework decision criteria Economic Capital metrics Analytics tools

1. 2. 3.

An appropriate governance structure should be in place to articulate the policies and procedures for managing the enterprise, supported by appropriate tools and resources An ERM framework should specify the firms decision criteria for risk taking and capital utilization The analytics should generate the appropriate financial measures required for making business decisions

2006 Towers Perrin

Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

OVERVIEW AND RECENT TRENDS

The concept of EC was developed in the banking sector

Basel I requires holding appropriate levels of capital for different financial risks S&P AAA rating requires banks to hold capital at the 99.90% level Basel II expands the concept to operational risks Quarterly reporting of operational risk exposure Insurance companies have picked up the EC concept only in the last several years Rating agencies are starting to give credit for internal models Regulatory changes are accelerating pace of change Larger companies are setting up proprietary stochastic models The European CRO Forum is in the process of recommending standards for the acceptance of internal models for compliance with the new Solvency II capital standards

2006 Towers Perrin

Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

OVERVIEW AND RECENT TRENDS

When calculating EC, three alternative approaches are commonly used to measure risk: Risk of ruin, VAR and TVAR
Financial results from a series of Stochastic Scenarios

+
1) TVAR captures the full extent of losses in the event of ruin

3) Risk of ruin is the probability of loss given the capital held

100% Cumulative Probability

2) VAR quantifies the capital required to withstand losses at a particular probability level

Required Economic Capital (REC) = sufficient surplus capital to cover potential losses, at a given risk tolerance level
2006 Towers Perrin Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

OVERVIEW AND RECENT TRENDS

When calculating EC, financial services companies use a range of different confidence levels

Most insurers use expected shortfall risk (CTE or TVAR) or risk of ruin Variable annuity RBC is based on CTE90 level Most banks use VAR Choice of confidence level and implied rating: Most European insurers are using one-year confidence levels ranging from 99.5% to 99.99% European regulators appear to be converging towards a one-year 99.5% confidence level for Solvency II Confidence levels are typically linked to a target risk appetite and financial strength rating Where longer time horizons are used, a lower multi-year confidence level can be justified (e.g., AA over five years vs. AA over one year) Moodys and S&P have suggested using 99th percentile for AA financial strength rating Fitch is using a 98.2 CTE level for AA rating
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2006 Towers Perrin

OVERVIEW AND RECENT TRENDS

Definitions of EC: Best estimate liability approach Economic Capital is The level of assets, in addition to the Best Estimate Liability, required to pay future policyholder benefits at the chosen Security Factor Economic Capital covers the volatility in: The runoff of existing business The future business (pricing risk) Best Estimate Liability is The best estimate projection of non-investment cash flows Discounted at the asset returns under the best estimate economic scenario Security Factor is Based on a risk of ruin level that is consistent with the companys financial strength rating Commonly used in North America
2006 Towers Perrin Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

Economic Capital Reserve margins

Pricing risk Runoff risk Needed Assets Best Estimate Liability

Statutory reserve

OVERVIEW AND RECENT TRENDS

Definitions of EC: Market-consistent balance sheet approach

Economic Capital is Measured as the difference in market-consistent net assets between normal conditions and stressed conditions The stress tests applied are each calibrated to a probability level over a one-year time horizon, consistent with the companys Normal conditions Stressed conditions financial strength rating Separate stresses are applied to cover a variety of market, credit and insurance risks that might occur over the projected time horizon Results are aggregated using a correlation matrix approach
Net assets MV Assets MCV Liabs MV Assets Net assets MCV Liabs

Net assets

Net assets

Economic Capital

Normal

Stressed

Commonly used in Europe


2006 Towers Perrin Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

OVERVIEW AND RECENT TRENDS

The calculation of EC should include all material risks

Overall Risk Profile

Risk Aggregation

Market Risk Interest Rates Equities Real Estate

Credit Risk Defaults Spreads Counterparty

Liquidity Risk Asset/Liability Risk Hedging Programs

Insurance Risk Mortality Lapses Reserves

Operational Risk Distribution Systems People

2006 Towers Perrin

Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

OVERVIEW AND RECENT TRENDS

There is no right or wrong approach to building an economic capital model

Decision 1: Period for assessment

Decision 2: Definition of capital

Decision 3: Measure of risk

Decision 4: Risks to include

Decision 5: Decision 6: Quantification Aggregation methodology

One year

Statutory

Risk of ruin

Market Credit

Stochastic modelling Stress Testing Factor based

Additive

n years

GAAP

VAR Insurance

Variance/ Covariance Stochastic

Run-off of portfolio

Economic

TVAR or CTE

Operational Liquidity

Six key decisions need to be made, and the approach taken should reflect the nature of the company and managements objectives
Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

2006 Towers Perrin

OVERVIEW AND RECENT TRENDS

By combining models, insurance companies are able to measure diversification benefits

Enterprise Diversification Benefit


Economic Capital

Sum of P/C Segments

P/C diversification effect Aggregated P/C Business Cross Sector diversification effect Aggregated Total

Sum of Life/Health Segments

Life/Health diversification effect

Aggregated Life/Health Business

2006 Towers Perrin

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10

OVERVIEW AND RECENT TRENDS

Recent developments encouraging the use of EC

Basel II Solvency II/European CRO Forum OSFI regulation for segregated funds (CAN) C-3 Phase II: RBC for variable annuities (VA) U.S. Proposed stochastic reserves for VAs and UL products U.S. GAAP SOP 03-1: explicit reserves for guarantees U.S. General need to develop risk profiles and perform hedging analysis Measuring Economic Value/Market Consistent Embedded Value (MCEV) Measuring exposure to catastrophic events Demands and increasing scrutiny by rating agencies/regulators Calculating EC is becoming an important tool for insurers in guiding risk-based decision making

2006 Towers Perrin

Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

11

OVERVIEW AND RECENT TRENDS

The European CRO Forum is establishing guidelines for admissibility of internal EC models for Solvency I

European Chief Risk Officer Forum is establishing guidelines for calculation of EC and diversification of risk Principles for Regulatory Admissibility of Internal Models (June 2005) Solvency Capital should be set to ensure a standardized likelihood of economic loss to policyholders Internal models should be based on adverse movement in Economic Value of (Assets Liabilities), calibrated to a target annual level of 99.5% probability of solvency All material risks affecting the balance sheet should be modeled Internal risk models should be fully implemented inside the company, and reviewed (at least) annually The CRO Forum advocates the admissibility of diversification benefits In December 2005, the CRO Forum published a subsequent report discussing suggested solutions to major issues in Solvency II EC is to be based on a market-consistent approach

2006 Towers Perrin

Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

12

OVERVIEW AND RECENT TRENDS

All major US rating agencies are developing or enhancing their capital adequacy models Standard & Poors (S&P) is currently enhancing its capital adequacy model to reflect changes brought about by the proposed CTE 90 capital for VA RBC Required capital will only be based on the stochastic model (not Standard Scenario) CTE level will be calibrated to rating category Partial credit for hedging, no phase-in EC will be incorporated into S&Ps overall ERM framework by the fall of 2006 Fitch is also revising their VA capital adequacy model to incorporate CTE methodology E.g., AA Fitch rating will require capital based on CTE(98.22) level Partial credit for hedging will be provided AM Best and Moodys are also in the process of enhancing their capital adequacy models

2006 Towers Perrin

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13

OVERVIEW AND RECENT TRENDS

Leading-edge companies maximize value by relating decisions on the risks they take to decisions on the capital they use
Value Creation

Return on Risk

Value Management

Capital Costs

Portfolio of Enterprise Risks Risk Structure

Capital Adequacy Risk and Capital Management

Portfolio of Capital Resources Capital Structure

How much capital do I need?

What type of capital do I need?

Economic Capital
Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

2005 Towers Perrin

14

Overview

Economic Capital Overview and Recent Trends

Aggregation

2006 Towers Perrin

Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

15

AGGREGATION

Aggregation approaches can significantly reduce capital requirements, but must be demonstrably robust Approach 1. Approximate analytical approach using standalone economic capital and correlations 2. Use marginal distribution functions, correlations and aggregate using Monte Carlo simulation 3. Build/approximate joint distribution function and solve analytically/by numerical integration Advantages Quick to execute High degree of accuracy Can attribute diversification easily Easy to understand More accurate Disadvantages Accuracy of the approximation is poorer the more varied the risk distributions Difficult to build Time consuming to run many simulations Difficult to disaggregate Most accurate Almost impossible to build joint distribution in practice Cannot attribute diversification benefits back to risks and businesses
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2006 Towers Perrin

16

AGGREGATION

One aggregation approach is to combine risks based on statistical measures of their variances and covariances

Asset Class 1

Product Class 1

Asset Class 2

Covariance Matrix

Product Class 2

Asset Class 3

Product Class 3

Fundamental construct Each risk is reduced to a statistical distribution of financial outcomes Linkages between risks described via a covariance matrix Aggregate result obtained either analytically or via Monte Carlo simulation
2006 Towers Perrin Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

17

AGGREGATION

One fundamental approach is to combine risks based on statistical measures of their variances and covariances
The key to this approach is the specification of a correlation matrix Correlations based on available empirical evidence, informed judgment, conservatism Covariances usually assumed to be constant across distribution, facilitating simplified analytic solutions

Correlation Matrix
18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1
0 0.2 0.4 0.6 0.8 1

In its most simplistic implementation: Each risk is assumed to be normally distributed Correlation between risks is assumed to be linear Then the Economic Capital for each risk can be combined by the formula Aggregate Capital = i j ij Ci C j
1 2 3 4 5 6 7 8

-0.2

9 10 11 12 13 14 15 16 17 18

Where Ci is the economic capital required for the ith risk at the required confidence level and ij is the correlation coefficient between ith and jth risk While convenient analytic solutions are desirable, they may require simplifying assumptions that are too approximate In these situations, statistical aggregation can still be accomplished, but may require Monte Carlo simulation
2006 Towers Perrin Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

18

AGGREGATION

An alternative approach is to develop a structural risk model, and then link all asset and product behavior to it

Asset Class 1

Product Class 1

Asset Class 2

Economic Scenario Generator

Product Class 2

Asset Class 3

Product Class 3

Fundamental approach Each systemic risk is described by a stochastic equation in the ESG; linkages between systemic risks are also built into the equations ESG generates scenarios, representing plausible sets of future conditions All assets and products are subjected to common set of scenarios, with their behavior linked to systemic variables Aggregate results can be obtained additively by scenario
2006 Towers Perrin Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

19

AGGREGATION

Typically at the product level and up, financial behavior of the product and associated assets are linked to ESG variables Economic Scenario Generator
Inflation Interest Rates Credit Costs Currency Exchange GDP

Projected Financials Asset Behavior Models


Risk Profile = Distribution of Future Financial Results

Product Behavior Models

Company Strategy
Investments Products Capital/Structure Reinsurance/Hedging Operating

Aggregation upward is accomplished by adding risk profiles scenario by scenario


2006 Towers Perrin Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

Probability

Catastrophes and Random Claims

20

AGGREGATION

Both approaches require correlation assumptions; differences are in what is correlated and where in the analysis
Method
Statistical Correlation Approach Structural Scenario Approach

Risk Driver
Correlation assumptions applied within BU model Related by SDE,* including correlations

Risk
Statistics describe risk

BU Capital
Calculated on BU tail statistics

Aggregation
Apply aggregation equation with correlation adjustment to BU capital Sum BU results to get aggregated tail scenario value

Scenarios determine risk

Calculated on BU tail scenarios

Complexity of interactions between risks can influence choice of method: Correlation matrix captures relationship between two risks, but that may not be sufficient for more complex risk dynamics Example: multi-trigger products with payoffs that are functions of event risk, financial risk and policyholder behavior Statistical correlation approach requires correlation factors to be used as inputs in two places: Risk drivers within the BU economic capital calculation BUs at the aggregate economic capital calculation Correlations between risk drivers (systemic variables) represent only one factor in SDE; correlations between BUs emerge from the scenarios and can be evaluated against experience
*Stochastic differential equations.
2006 Towers Perrin Proprietary and Confidential Not for use or disclosure outside Towers Perrin and its clients

21

Introducing a Global, Integrated, Insurance Capital Platform


Jeff Mohrenweiser Manager of Insurance Modeling / Quantitative Applications Jeff.Mohrenweiser@FitchRatings.com

ERM SYMPOSIUM April 24, 2006

View of Insurer-developed Economic Capital Models Fitchs Economic Capital Modeling Decisions How to assess Economic Capital Models

Fitch Ratings

April 11, 2006

Risk Assessment - Fitch Ratings Criteria (est. 1996)


Industry Review Organization Review
Parent financial strength and financial flexibility Upstream dividend requirements Potential need to divert capital to underperforming affiliates Business synergies Formal guarantees or support agreements

Management Review
Strategic vision Appetite for risk Credibility of track record for meeting expectations Controls and risk management capabilities Depth, breadth and succession plans Key executives accomplishments

Operational Review
Distribution mix Market position Franchise value Expense efficiency Underwriting and pricing experience Product mix Administrative / technology capabilities

Financial Review

Level of orderly competition Industry competitive advantage Barriers to entry / exit Regulatory, legal and accounting environment

Operating performance Capital adequacy Investment quality Asset / liability and liquidity management Financial flexibility

Our business is to provide credit opinions, not solvency requirements.


Fitch Ratings April 11, 2006 2

FITCHS VIEW OF ECONOMIC CAPITAL MODELS The Long and Winding Road
Principal-based reserving

Solvency II

C3-II ECR

C3-I

Fitch Ratings

April 11, 2006

Industry Observers face many challenges with Company Capital Models


Stochastic Europe

Progress
U.S.

Methodology
Factor-based

Transparency
Calibration Organization Assumptions

Resources
Tools
Fitch Ratings April 11, 2006 4

Comparability Monkey Wrenches


GAAP Bermuda IFRS Reinsurers Multi-lines Enterprise Aggregation Multi-nationals

Accounting Consolidated Statutory

Correlation

Risks

Pension Deficits Available Capital

Methodology Discounting Time Horizon Goodwill DAC

DATA
Fitch Ratings April 11, 2006 5

FITCHS ECONOMIC CAPITAL MODEL

Global, Integrated, Stochastic Tool

Fitch Ratings

April 11, 2006

A Standardized Platform v. Model v. Philosophy


Stochastic platform with interactive surveys using consistent assumptions

Current regulatory models

Optimal Spot for Fitch is Vertical

Insurers internal capital philosophy

Simpler
Less than vertical is unresponsive > Arbitrary adjustments > Incomplete scope

Complexity
Past vertical is inefficient > Too much data > Too much time > Lack of comparability
April 11, 2006 7

Fitch Ratings

Philosophy of the Fitch Platform


An analytical tool, not a rating machine
In some cases, the rating opinion may be HIGHER or LOWER than the model result

Need consistency
Between products Between sectors Between countries

Efficient, yet Robust


Exposures based on public data sources Assumptions based on industry v. company credibility Create an open box

Fitch Ratings

April 11, 2006

Some Platform Decisions


Item Definition Fitch Decision

Role of Capital

Define the purpose of capital when establishing a capital standard Time period over which a company will assume additional risk producing positions Sources of risk producing exposure

Limit the risk that assets are insufficient to pay claims over the lifetime of policyholder obligations. Include run-off of current obligations and one-year of new business on relevant products. Includes ALM (Market, Interest), Credit, Reserve, Underwriting and Natural Catastrophe Items generating risk exposure will be allowed to fluctuate over the run-off of liabilities - annual time step with maximum of 30 years. The model will focus on Conditional Tail Expectation (CTE) but also produce additional risk measures such as Value of Risk (VaR), Comparables. Calibrated primarily using bond default data along with rule of thumb measures.
April 11, 2006 9

Treatment of New Business Risk Elements in Model Modeling Time Horizon

Time period over which risk exposure sources will vary and generate volatility

Risk Measures

Statistical measure to determine relative risk from risk distributions generated by allowing risk exposure sources to vary over the risk exposure horizon Methodology for tuning results of the capital model to meaningful capital indications

Model Calibration

Fitch Ratings

Modeling Methods Risk Elements Captured


ALM (Market) Risk
Incorporates risk-free yield curve (bonds, mortgages), real estate and equity returns (DAX, FTSE, CAC). Use a proprietary, integrated scenario generator. Life: Use MoSes platform.

Credit Risk
Incorporates defaults, migration and spread volatility Use common market indices to establish parameters for asset type and quality Over 50 asset buckets. Stochastically model reinsurer default risk

Reserve Risk
Use Mack Method Utilize several checks to ensure data integrity If checks fail, use Industry assumptions leveraged by Underwriting Risk parameters. Incorporates reserve adequacy analysis

Underwriting Risk
Use a collective risk model of frequency and severity of losses. Relies on ELR, Attachments, Limits Factors one year of new business.

Catastrophe Risk
P/C: Use AIR (Catrader) software. Life: Use Lee-Carter methodology trend, volatility, shocks

Aggregator
Each Company will potentially have unique risk curves
Consistent economic scenario set Similar Cat event set Correlated random numbers

Fitch Ratings

April 11, 2006

10

Dashboards Industry Comparisons


GOOD

R E S E R VE R IS K
BAD

BAD
US - Al l Ot h e r US - Au t o P D US - Sp e c i a l P r o p US - P r o d Li a b - C M US - P r od Li a b - Oc c US - R e i ns B US - R e i ns A&C US - In t e r n a t i on a l US - Ot h Li a b - C M US - Ot h Li a b - Oc c US - Sp e c Li a b US - M e d M a l - C M US - M e dM a l - Oc c US - C M P US - WC

GOOD

US - C AL US - P P A Li a b US - H/ O &F/ O

A s s e t R e t u rn
0% 2 5% 50 % 75% 10 0 %

ESTIMATED RISK CHARGES Risk Driver Exposure Asset 22,528,280 Underwriting 14,463,360 Net Reserve 13,695,190 Reinsurance Credit 4,321,680 Catastrophe 3,452,285 A&E 4,134,638 UNDIVERSIFIED REQUIRED CAPITAL SAMPLE Value-at-Risk 99.90 99.00 97.50 12,535,283 4,540,239 2,762,578

CATASTROPHE RISK

Est. Req Cap 2,010,000 1,460,000 3,100,000 40,000 610,000 1,160,000 8,380,000 Asset Risk

Risk Charge 9% 10% 23% 1% 18% 28% -17%

10 0 %

75%

50 %

Diversification Liability Risk Benefits Asset v. Liability Total Benefit 1,156,680 7,223,320 Req Cap:

2 5%

-1% -11% 16%


0% 2 50 50 0 10 0 0 Y e a r Ev e nt 2 50 0 50 0 0 10 0 0 0

Fitch Ratings

April 11, 2006

11

Capital Assessment Score Comparing what is needed versus what is available


REQUIRED CAPITAL FITCH AVAILABLE CAPITAL
9 ,0 0 0 ,0 0 0 8 ,0 0 0 ,0 0 0 7,0 0 0 ,0 0 0 6 ,0 0 0 ,0 0 0 5,0 0 0 ,0 0 0 4 ,0 0 0 ,0 0 0 3 ,0 0 0 ,0 0 0 2 ,0 0 0 ,0 0 0 1,0 0 0 ,0 0 0 0

Defined by Balance Sheet Assessment

BBB-

BBB BBB+

A-

A+

AA-

AA

AA+

AAA

Defined by Model Results


Fitch Ratings April 11, 2006 12

Calibrating Results Historical Bond Default Experience


Probability of Default

Thresholds need to be:


Realistic Transparent Meaningful
B

Avoid arbitrariness

BB

BBB

A AA AAA 0 5 10 15 Time Horizon 20 25 30

Fitch Ratings

April 11, 2006

13

ASSESSING INTERNAL CAPITAL MODEL PLATFORMS No one shoe fits all

Fitch Ratings

April 11, 2006

14

Analytical Tool: No perfect solution


Fitch Capital Model
Weighting based on Credibility and Transparency of Company Model and type of business

Establishes Minimum Requirement

Provides Discussion Insights

Capital Adequacy

Regulatory Requirements
Creates Consistent Principles
Fitch Ratings

Insurers Internal Capital Models

April 11, 2006

15

Basic Precepts
Sophistication should match the complexity of the enterprise Platform needs to be fully vetted
Inputs Models Outputs
INPUT DESIGN IMPLEMENTATION
MODELING METHODS

Transparency
A Standardized Platform breaks down a complicated process, involving many resources over several years Garbage in, Garbage out

Whats in the Toolbox?

OUTPUT CRITERIA

Cant manage what you cant measure

Fitch Ratings

April 11, 2006

16

Review of Company Capital Models


Understanding of the Model
Tools used (Excel, Moses etc.) and Risks Captured Model Methodology (Monte Carlo Simulation, Closed Form Solutions, Factors) Time horizon and calibration

Model Development and Use


Who developed and what data was used? How is it being maintained and updated? Who runs the model? How often is the model run?

Model Methodology
Discount rate (portfolio rate, risk free?) Source of Generated Economic Scenarios and Parameterization Available Capital Definition

Outputs of the model


Breakdown of capital requirements by risk/geography Integration into Risk management framework
Fitch Ratings April 11, 2006 17

Important Points to Note: Capital Model Issues


Diversification credit
If correlation between risks is less than one then capital required is less than sum of parts

Value at Risk v Conditional Tail Expectation (VAR v CTE)


VAR is more intuitive but not a coherent risk measure

Available capital
Depends on accounting regime - important not to double count some elements included as part of required capital

Aggregation of results
How to sum results between entities and across regions

Calculation of correlations
What experience was used? Where is the expert opinion?
Fitch Ratings April 11, 2006 18

Role of Rating Agencies after Solvency II


Some differences but no major changes expected:
Internal Capital models will be a useful input to the rating process Regulation and Risk management may improve for companies

Will Rating agencies still be Important?


Many companies want to be better than BBB if this is the standard set by regulators Regulators do not disclose their view of financial strength Regulators are only one party forming a view as to financial strength, other views (e.g. from rating agencies) helpful for the market Rating agencies evaluate financial strength from a bondholder standpoint in addition to policyholders

Fitch Ratings

April 11, 2006

19

10

Summary
Infancy stage of Economic Capital Models There is general consensus but no consistency Substantial challenges
Resources Understanding Pay back

Necessity
Insurance is the risk-assuming business Statistics: The only science that enables different experts using the same figures to draw different conclusions. Evan Esar, American Humorist (1899 1995)

Fitch Ratings

April 11, 2006

20

11

Economic Capital A Regulatory Perspective


ERM Symposium, April 24, 2006

NAIC Risk Focused Surveillance Framework


Adopted June 14, 2004

Framework Cycle
Risk Focused Examinations Off-Site Risk-Focused Financial Analysis Internal/External Changes Priority System (CARRMEL) Supervisory Plan Insurer Profile Summary

Financial Condition Examiners Handbook


Examination Objectives:
Accuracy (AC) Recorded transactions and account balances are mathematically accurate, are based on correct amounts and have been classified into the correct account. Completeness (CO) All transactions and account balances that should be recorded in the Annual Financial Statement were recorded. Compliance (CM) Business transactions and affairs have been conducted in accordance with state insurance codes, other state laws or department directives. Cutoff (CT) All transactions are recorded in the correct accounting period. Existence (EX) Recorded transactions occurred and are not fictitious and recorded assets and liabilities existed as of the balance sheet date. Obligation (OB) and Ownership (OW) Recorded liabilities are obligations of the company and recorded assets are the rights of the company at the balance sheet date. Valuation (VA) Assets and liabilities are valued in accordance with state statute and NAIC accounting guidance. Presentation and Disclosure (PD) The elements of the Annual Statement are properly classified and all disclosures are accurately included in the Annual Statement.

CARRMEL
Priority System Based on Ratios and Analysis to Measure:
Capital Adequacy Asset Quality Reinsurance Reserves Management Earnings Liquidity

Off-Site Risk-Focused Financial Analysis


Financial Analysis includes:

Risk Assessment Results Financial Analysis Handbook Process Ratio Analysis (IRIS, FAST, Internal Ratios) Actuarial Analysis Update with internal/external changes

Sample Management Letter


Confidential Document:
The Board of Directors (Board) has a duty to ensure that XYZ Insurance Company is operated in a safe and sound manner in the best interest of the policyholders. The ABC Department of Insurance (the Department) is charged with the responsibility to protect insurance consumers and other creditors.

Sample Management Letter


The Department has identified the following risks and concerns that impact the Companys overall financial position and need to be addressed by the Board: Capital Adequacy, Earnings, Pricing, Underwriting
Insurance Department would insert description of concerns.

Corporate Governance/Risk Management


Insurance Department would insert description of concerns.

Sample Management Letter


Action to be Taken by the Board and Management
Provide key performance indicators and goals utilized by management and the Board to monitor the progress and effectiveness of the 200X business plan. Provide the companys three-year business and financial plan. The financial projections should be on a statutory basis and approved by the Board. The plan should include a projected income statement, balance sheet, statement of cash flow, as well as a risk based capital calculation for all three years. Key business assumptions and projections utilized in the forecast should be fully described.

Risk-Based Capital
1. 2. 3. 4. 5. 1. 2. 3. 4. 5. 6. Asset Risk-Affiliates Asset Risk-Other Insurance Risk Interest Rate Risk and Health Credit Risk Business Risk > 250% > 200% to <250% > 150% to < 200% > 100% to < 150% > 70% to < 100% < 70% No action level Trend test level Company action level Regulatory action level Authorized control level Mandatory control level

Risk-Based Capital Plan


The RBC plan is a comprehensive financial plan which 1) identifies the conditions in the insurer which contribute to the Company Action Level Event; 2) contains proposals of corrective actions which the insurer intends to take and would be expected to result in the elimination of the Company Action Level Event; 3) provides projections of the insurers financial results in the current year and at least the four succeeding years, both in the absence of proposed corrective actions and giving effect to the proposed corrective actions, including projections of statutory operating income, net income, capital and/or surplus. The projections for both new and renewal business might include separate projections for each major line of business and separately identify each significant income, expense and benefit component; 4) identifies the key assumptions impacting the insurers projections and the sensitivity of the projections to the assumptions; and 5) identifies the quality of, and problems associated with, the insurers business, including but not limited to its assets, anticipated business growth and associated surplus strain, extraordinary exposure to risk, mix of business and use of reinsurance in each case, if any.

RBC Checklist
Determine whether concerns exist regarding the insurers risk-based capital position. Review the Five-Year Historical Data Schedule, Risk-Based Capital Analysis.
Is the ratio of Total Adjusted Capital divided by Authorized Control Level Risk-Based Capital less than or equal to 250%?

Yes

No

Has there been a significant change (XX%) in the ratio of Total Adjusted Capital divided by Authorized Control Level Risk-Based Capital from the prior year?

Yes Yes Additional procedures:

No No

Has the Authorized Control Level Risk-Based Capital increased by more than YY% from the prior year?

If required by statute, obtain a copy of the insurers RBC Plan and review. Review all items that generate significant RBC charges to ensure that these factors have been considered in the overall analysis of the insurer.

Forecast: Life RBC


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LR001 Jurat Page LR002 Bonds LR003 MEA LR004 Mortgages LR005 Stock LR006 Separate Accounts LR007 Real Estate LR008 Other LT Assets LR009 Sch. BA Mortgages LR010 Concentration Factor LR011 Stock Concentration Factor LR012 Miscellaneous Assets LR013 Replications LR014 Reinsurance LR015 Off-Balance Sheet LR016 Health Premiums LR017 Underwriting Risk-Exper. LR018 Underwriting Risk - Other LR019 Managed Care Credit LR020 Long-Term Care LR021 Health Claim Reserves LR022 Life Insurance LR023 Premium Stabilization LR024 Interest Rate Risk LR025 Credit Risk LR026 Business Risk LR027 Calculation of Tax Effect LR028 Calculation of ACL LR029 Capital Notes LR030 Total Adj. Capital LR031 RBC Level of Action LR032 Trend Test LR033 Additional Info. Req. LR034 Sensitivity Tests - ACL LR035 Sensitivity Tests - TAC LR036 Affiliated Summary LR037 Affiliated Crosschecking LR038 Affiliated Detail LR039 Modco Bonds - Ceded LR040 Modco Bonds - Assumed LR041 Modco All Other - Ceded LR042 Modco All Oth - Assumed LR043 C-3 Exemption Test All Other Data

2005 Changes to Life RBC


LR024 Interest Rate Risk and Market Risk Line (35)
Source is company records.

Line (33) Instruction


Enter in Column (3) the pre-tax interest rate risk results of cash flow testing per the Appendix 1a methodology. Line (33) should only be completed if the answer to Line (14) or Line (22) of LR043 Exemption Test: Cash Flow Testing for C-3 RBC is Yes or if the company chooses to do C-3 RBC cash flow testing on a continuing basis. Once a company chooses to use the C-3 RBC cash flow testing method to calculate RBC it must continue to do so unless regulatory approval from the domiciliary jurisdiction is received to go back to the factor-based method.

Line (23) was added to LR043 Exemption Test: Cash Flow Testing for C-3. Cash Flow Testing for C-3 RBC
LR043 Exemption Test: a company may be required to perform cash flow testing to determine its RBC requirement. A practical method of measuring the degree asset/liability mismatch exists

https://www.actuary.org/life/phase2.asp

C3 Phase II Q&A audio from the NAICs 2005 winter meeting


http://www.actuary.org/life/phase2_session.asp http://www.naic.org/documents/committees_e_capad_winter05_PhaseII_ QAsession.pdf The speakers for the Q&A session included: Philip Barlow, chairman of the NAICs Life RBC Working Group John Bruins, ACLI Larry Bruning, chairman of the NAICs C3 Phase II Results Subgroup Tom Campbell, chairperson of the Academys Variable Annuity Work Group Lou Felice, chairman of the NAICs Capital Adequacy Task Force, which oversees the Life RBC Working Group Larry Gorski, vice chairperson of the Academys Capital Adequacy Subcommittee and chair of the Academys Experience Studies Subcommittee

2006 Life RBC Agenda


Variable annuity (C-3 Phase II) - monitoring and refinements to modeling approach Expanding C-3 Phase I cash flow testing to all insurers with at least $100 million of admitted assets Finalize modified coinsurance dividend liability issue How unauthorized reinsurance impacts the ceding companys risk-based capital requirements Expansion of the modeling approach to life products (C-3 Phase III) and other products Recognition of effective hedges in risk-based capital

AAA Medicare Part D Subgroup December 2005


B. Recommended Factors for 2006-07. For the period 2006-07, during which the initial level of Risk-Corridor Protection applies Underwriting Risk Factors for Standard Coverage:
Initial Factor 0.141 Excess Factor 0.109

Discount Factors for Standard Coverage:


Risk-Corridor Protection only 0.500 Reinsurance Coverage and Risk-Corridor Protection 0.650 Underwriting Risk Factor for Supplemental Benefits 0.120

Principle-based Approach
Captures all of the material risks, benefits and guarantees in the contract using basic risk analysis and risk management techniques
Provides an appropriate level of conservatism that is consistent with the objectives of statutory reporting Only requires a modeling and or stochastic approach be used when necessary to properly capture the risks of the contract For some products, a deterministic, single scenario approach is adequate to capture the risks of the contract

For products with, material tail risk of a high level of uncertainty in cash flows arising from policy owner options in the contract, a stochastic approach may be necessary A stochastic approach does not require that all assumptions be stochastically modeled

New Long-Term Care Page


A new page LR020 Long-Term Care was added to the RBC formula for yearend 2005 risk- based capital. Previously, the risk-based capital charge for long-term care business had been based on premiums only. Now, the RBC charge will be based on a combination of premiums and a twoyear premium to loss ratio multiplied by total claims. The premiums will be multiplied in a tiered factor calculation as follows: Other Long-Term Care Premium Pre-tax Factor First 50 Million Over 50 Million 0.154 0.046

LTC (cont.)
A ratio of premiums to claims is calculated for the current year and prior year. For the loss ratios to be used, the current year and prior year premiums must be greater than zero. In addition, the current and prior year claims incurred must be greater than or equal to zero. Otherwise, the current year incurred claims are used instead of the two-year loss ratio multiplied by the current year premiums.

LTC (cont.)
The result of the claims ratio or the current years incurred claims is multiplied by tiered factors as follows: If Current Year LTC Premium Positive: Negative or Zero: Long-Term Pre-Tax Pre-Tax Care Claims Claim Factor Claim Factor First 35 Million Over 35 Million 0.385 0.569 0.123 0.185

The LTC premium charge and claim charge would be combined and then reduced by 35% on the tax adjustment page.

Non-Cancelable Long-Term Care Business


All non-cancelable long-term care business receives one standard charge based on premiums on LR016 Health Premiums.
Only premiums and not claims are not used to calculate RBC for non-cancelable long-term care.

The non-cancelable long-term care business should be excluded from the new Long-Term Care page that was added for 2005.
Non-cancelable long-term care premium receives a pre-tax RBC charge of 15.4%. The after-tax factor is approximately 10%.

LR003 Industry Normalized Loss Ratio


The Industry Normalized Loss Ratio shown on LR003 Mortgage Experience Adjustment Factor Line (12) was estimated to be approximately 0.014% for year-end 2005. However, that factor was not be finalized until around December 2, 2005. It is easy to forget to replace the preliminary factor with the final one. The ratios for the current and previous risk-based capital reports are as follows:
Year End 2005 0.013% Year End 2004 0.018% Year End 2003 0.020% Year End 2002 0.024% Year End 2001 0.032% Year End 2000 0.043% Year End 1999 0.060%

LR018 Workers compensation carve-out business


Workers compensation carve-out business factors were changed for page LR018 Underwriting Risk
Other Lines (4), (5) and (6.3). This is due to the factors for the calculation being phased in over a three-year period as follows: 2004 2005 2006 Factors Factors Factors Line (4) Net Premiums Written 0.121 0.243 0.364 Line (5) Claim Liability and Reserve 0.116 0.231 0.347 Line(6.3) Unaffiliated Reinsurance Recoverables 0.020 0.040 0.060

Annual Statement
Five-Year Historical Data (publicly available) Current and four previous years Risk-Based Capital Analysis
Authorized control level risk-based capital Total adjusted capital Trend of ratios indicates stability, growth, or decline

Principles-based Peer Review


Same qualifications as valuation actuary?
Precept 2: Only perform services when qualified Keep current with changes in standards of practice

Should not review own work


Precept 7: Avoid conflict of interest (some exceptions)

Independence
Should be defined in regulation or qualification standard SEC and NAIC definitions may differ

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