Comparisons to the US Solvency Regime:
Solvency II
process that links the required capital to the insurer’s specific risk profile
attempts to figure out how much capital / surplus a company should hold
3 pillars of Solvency II
1) Quantification: capital requirements quantified
2) Governance: supervisory activities
3) Transparency: supervisory reporting and public disclosure
Pillar 3) Transparency: supervisory reporting and public disclosure
Showing the reporting of IC position to both the supervisors as well as the public
Pillar 1: Quantification: capital requirements quantified
(most testable)
Calculates free surplus which is based on the following:
1) Solvency capital Requirement
- The required capital limit the probability of ruin over the year to 0.5%
- a company with lower capital is subject to regulatory intervention
2) minimum capital Requirement (MCR)
- a company with lower capital will lose its license and not be permitted to operate
3) technical provisions
-include reserves and risk margin
-similar calculation as P_GAAP, where cost of capital exceeding the risk free rate (R-i) = 6%
Pillar 1: Quantification: capital requirements quantified
Solvency capital Requirement
calculated using:
1) standard formula provided by the regulator
-Similar to the RBC used in US
-conservative
2) internal models: will need to obtain approval to use this by regulators/independent third party
-can potentially be manipulated
-more tailored to the company to provide a more appropriate capital requirement
-can be difficult to calculate and company needs to come up with this specialized model
-will typically produce lower capital requirements than the standard
3) mix of both
Free Surplus
Free Surplus = Assets - Technical Provisions - SCR
Excess Surplus thats available on top of the SCR (Solvency capital requirement)
Company can do whatever they want with this (i.e engage in riskier investments, return to owners, etc)
MCR will be a component of the SCR.
Pillar 2) Governance: supervisory activities
focuses on activities of the regulators
provides supervisors with:
1) means of identifying firms with higher risk profile
2) power to intervene
requires insurers have implemented a governance structure to address the following FUNCTIONAL AREAS:
1) Internal Audit
2) Actuarial
3) risk management
4) Compliance
5) ORSA
Pillar 2) Governance: supervisory activities
FUNCTIONAL AREAS:
Internal Audit
produce a report at least annually to the board about:
-deficiencies od internal controls
-shortcomings in compliance with internal policies
Pillar 2) Governance: supervisory activities
FUNCTIONAL AREAS:
Actuarial
ensure methods and assumptions used to derive the technical provisions are reasonable
perform a retrospective analysis of best estimates vs. experience
opine on the overall underwriting policy and adequacy of reinsurance arrangements
Pillar 2) Governance: supervisory activities
FUNCTIONAL AREAS:
Risk Management
monitor the risk management function
ensure the internal model has been integrated with the risk management function
there should be a feedback loop between the model and the risk management function
(i.e information from the risk management function should be parameterizing the internal model. and the findings from internal model can be used to refine the risk management strategy)
Pillar 2) Governance: supervisory activities
FUNCTIONAL AREAS:
Compliance
ensure that internal control system is effective to comply with all applicable laws and regulation
promptly report ant compliance issues to the board
Pillar 2) Governance: supervisory activities
FUNCTIONAL AREAS:
ORSA
Own risk and solvency assessment
an internal assessment of the solvency need based on the risk profile
At minimum ORSA should contain info about:
-overall solvency need based on risk profile, tolerance, business strategy
-compliance with capital requirements and requirements of the technical provision (MCR and SCR)
-extent to which the risk profile deviates significantly from the assumptions underlying the SCR
results from ORSA need to be reported periodically
Pillar 3) technical provisions
focuses on increasing the transparency of the insurer’s risk and capital provision
includes including and disclosing the capital position derived from pillars 1 and 2 to the supervisor and financial markets:
intention: give the market sufficent info to exercise its disciplinary function
i.e if company isnt operating appropriately -> impact the stock price -> cost more money to get loas -> interest rates will increase -> employees will not want to work / may need to pay them more -> policy holders may not want to pay high premiums.
SMI - solvency modernization Initiative
Solvency 2 is designed to be a group wide solvency regime
Whereas US regime is focused on the regulation of individual atatutory entities
ORSA Continued
3 key areas that the ORSA summary report should cover that will help provide state commissioners with a high level understanding of insurers’ ORSA
1) Description of the insurer’s risk management framework (i.e
2) Insurer’s assessment of the risk exposure (i.e shows quantitative and/or qualitative assessment of the risk exposure in a normal and tressed environment)
3) Group assessment of Risk Capital and Prospective Solvent Assessment (i.e looking at IC’s process to asses capital adequacy and how it is embedded into the management culture)