SAO PURPOSES
1) state appointed actuary’s opinion about the reasonableness of the insurer’s reserves
2) notify stakeholders about the significant risks and uncertainties that may impact the reserves
3) disclose whether the risks could produce significant adverse material deviation
Qualified Actuary
1) meets education, experience and continuing CE
2) has a designation
3) member who of professional actuarial association that requires adherence to the Academy’s Code of Professional Conduct as well as the U.S Qualification Standards (AAAA)
Appointment Procedures
need to be appointed by the board by 12/31
does not need to be reappointed annually
Qualification Documentation
provided by the AA to the board when appointed
needs to be provided on an annual basis
Documentation Sent to the Commissioner
within FIVE days of appointment, the company needs to provide the following:
Name and title of Actuary
Manner of appointment (employee vs consultant)
Statement that the person meets the requirements to be a qualified actuary and the respective documentation
Replacement Procedures
If actuary is replaced, the insurer needs to:
Notify the DOI in 5 days
Within 10 days provide an additional letter to the commissioner stating :
1) if there were disagreements with the actuary regarding certain topics within the past 24 months
-Include disagreements that are resolved AND not resolved
- include a description of disagreement and the nature of its resolution (or a statement that it was not resolved)
2) needs to include a response from the former AA stating if they agree with the statements
3) May be appropriate to include disagreements regarding the AOS
(SAO is mandatory, AOS is optional)
Replacing Actuary
should review all of these documents to understand and get comfortable around
Exemptions from producing SAOs
Insurer may be exempted:
1) small companies
-under 1M total D&A WP in a CY
AND
-under 1M total D&A L+LAE reserves at YE
2) INSURERS under supervision or conservatorship
-insurers already being scrutinized by regulators. SAO will not provide additional benefits / value.
3) nature of business
-catchall bucket
4) Financial hardship
-reasonable cost of SAO would exceed the lessor of
a) 1% of capital and surplus from the latest quarterly statement
b) 3% of the D&A WP during the year
SAO STRUCTURE
1) identification
2) Scope
3) opinion
4) relevant comments
Identification
include:
1) AA
2) relationship to company (Chief / cosnsultant)
3) qualification for acting as AA
4) date of appointment
5) state the appointment was made by the board
Scope
Need to include the reserve elements and basis of presentation of reserves.
Reserve items can include:
1) L+LAE Reserves
2) Retro Reins Assumed
3) UEPR for LDC
4) UEPR for Extended reporting ENdt
5) Other reserve items for which the AA is opining
RMAD - qualitative factors supporting RMAD
When there is RMAD, consider:
1) ceded significant reserves to a reinsurer of weak financial strength
-IC may not recover from RC and net reserves will jump unreasonably
2) Long tailed or high volatility LOBs
-could be reflected in a wider range which would cause the reserves + difference in the surplus and control level to fall within range
3) catastrophes that occurred late in the year
4) unreported excess insurance claims since the retention has not been breached
-xs insurance claims that have not pierced into the layer. if they do pierce, it could result in high severities.
5) high volume of policies with high retained limits relative to claim volume
- high volatility (the actuary SHOULD increase range of reserves)
6) company writes xs layers with potential high severity claims
RMAD - Conclusion
if RMAD conclusion is reached from a quantitative standpoint but not at a qualitative stand point. the AA can say there is NO RMAD (low chance of RMAD)
Factors that cause RMAD
AA needs to comment even if she believes no RMAD
-A&E, CD, CATs
AA does NOT need to comment on risks due to judicial decisions, regulatory actions, polictical/social forces (impacts all companies)
AA not required to provide an exhaustive list
*Consider combination of factors that cause RMAD
-company growing rapidly in a soft market
Combination of Factors that cause RMAD
*Consider combination of factors that cause RMAD
-company growing rapidly in a soft market(business is underpriced-> book is under reserved)
-adverse medical inflation on a large XS WC book
-significant upward shift in limits and attachment point, combined with reduction in reinsurance (retaining more business with less reinsurance coverage)
Scenarios for qualified opinion
1) AA determines insufficient info to conduct analysis/determine the materiality of a potential material portion of reserves
-disclosure is necessary
2) AA does not review a portion that is outside the scope of review
-helpful to disclose info on its matreriality
Scenarios for no opinion
AA cannot reach a conclusion due to limitations in data, analyses, assumptions or related information
-must describe why no opinion could be given
NAIC PREAMBLE
Includes accounting details relavant to statutory accounting
NAIC PREAMBLE:
Unique Components
Different accounting concepts covered:
1) Conservatism
2) Consistency
3) Recognition
NAIC PREAMBLE: Conservatism
Purpose: Financial reporting for insurers requires substantial judgment and estimates.
Conservatism:
-prevents sharp fluctuations in surplus (surplus that plummets)
SAP is conservative in SOME respects but NOT unreasonably conservative over the span of economic cycles.
Translation: Consistent and balanced surplus and measurement of income, I.E not overstating surplus or understating income
NAIC PREAMBLE: Consistency
Provides accurate indication
Envt is changing and may be necessary to make updates (changes accounting principles)
NAIC PREAMBLE: Recognition
Solvency measurement is focused on determining the financial condition via analysis of the balance sheet
the income statement is a secondary focus as it demonstrates the insurer’s ability to exist as a going concern
NAIC PREAMBLE: Asset Recognition
Neet to make sure the assets are able to satisfy various obligations
if the assets:
- have economic value other than what can be used to fulfill policyholder obligations
-unavailable due to encumbrances (real estate with mortgage balance outstanding)
then: the assets should not be recognized in the measurement of surplus
NAIC PREAMBLE: Liability Recognition
Recognized when incurred