CAGNY NOVEMBER 2002 MEETING Federal Charters for P&C Companies Impact on Property/Casualty...
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Transcript of CAGNY NOVEMBER 2002 MEETING Federal Charters for P&C Companies Impact on Property/Casualty...
CAGNY NOVEMBER 2002 MEETING
Federal Charters for P&C CompaniesImpact on
Property/Casualty Actuaries
2
Outline of Discussion
Political ViewpointP&C Federal Charters Task ForceImpact of Federal Charters On
RegulationHow The Academy Will Protect The
Public Interest In Effective RegulationHow The Academy Will Explain The
Casualty Actuarial RoleHow Your Voice Can Be Heard
3
POLITICAL VIEWPOINT
NAIC Modernization Program Deregulation of Commercial Rates Interstate Compact
ACLIABIAAIAOTHERSSTATES RIGHTS VS. DEREGULATION
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ARGUMENTS FOR OPTIONAL FEDERAL CHARTERS
Redundant licensing Higher compliance costs in rate and form filings Need for complex corporate structures to satisfy
state requirements Delayed implementation of new products Subsidation a common part of rate regulation Redundant regulatory costs due to regulatory
structures in 50 states Restrictions lead to self insurance and alternative
markets Reduced and slowed product innovation
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AIA PROPOSED PRINCIPLES FOR FEDERAL REGULATION
Market based approach using competitionNational treatment availableUniform requirements that do not vary by
stateTimely implementation of products and
pricesLevel playing field with other financial
services such as banksUniform technology requirements
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ARGUMENTS FOR STATE REGULATION
State regulation is already in place/ federal regulation may have equal disadvantages when implemented
NAIC Modernization is well underway and will solve most of the current problems
State regulation takes advantage of the federal system and allows different types of regulation to coexist and for the best regulation to emerge
For insurance covering liabilities, the liability system and associated rules and precedent is state based and state regulation of this type of insurance is the best fit
State regulation is closer to the people who buy insurance and problems get solved faster
A federal regulatory system will require a new bureaucracy and will not ultimately replace state regulation
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Federal Charters
AAA SOACAS
P/C Federal Charters Task Force
Chair: Chuck Bryan, FCAS, MAAA
Banking and Financial Services Task
ForceChair: Tim Tongson,
FSA, MAAA
Financial Reporting CouncilP/C Practice Council Life Practice Council
Health Practice Council
Pension Practice Council
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P&C Federal Charters Task Force
Members include Chuck Bryan, John Pedrick, Mavis Walters, Jim Rech, Rich Hoffman, and Rade Musulin and Greg Vass(Academy Staff)
This task force has three objectives:Coordinating with other Academy task forces and
committees on appropriate responses to the proposalsCommunicating the major features of the proposals to
casualty actuaries and soliciting their viewpoints on these issues so that there is a strong awareness of these issues in our profession
Developing position papers in critical areas that communicate to policy-makers the role casualty actuaries should play in the Federal Regulatory Structure
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Federal Charters Task Force
The charter we are using is the following: “The P&C Federal Charters Task Force will inform casualty actuaries of
the issues in this area, solicit views from casualty actuaries on these issues, and develop a viewpoint and position on the principal legislative proposals with respect to how such proposals would affect the role of casualty actuaries in P&C risk transfer mechanisms such as insurance companies, self-insurance plans, and similar mechanisms.
This Work Group anticipates that its efforts will form part of a larger Academy effort and so its audience will include the casualty actuarial profession, other Academy committees and work groups and
regulatory and legislative decision makers.”
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MAJOR EFFECT OF FEDERAL REGULATION ON CASUALTY ACTUARIES
Traditional rate regulation will be eliminatedSolvency focus and the need for methods
and techniques to support solvency will be even stronger than today
Many of the technical skills that actuaries have offered to companies will no longer be as valuable under a Federal regulatory structure
Actuarial Skills will be in demand but will be challenged by other disciplines.
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Position Papers
The task force has developed eight position papers to focus thought on key issues where casualty actuaries have a unique expertise
These position papers have been forwarded to the AAA Committee charged with coordinating the involved disciplines (casualty, life, and health) and writing a monograph
Members will have an opportunity to comment on these positions
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Eight Position Papers
Staffing of Federal Regulatory Structure The agency should have a chief casualty actuary.
Rate Standards No need for rate standards
Loss Reserve Opinion: KEEP IT RBC and Related Solvency Measures: KEEP THEM Cash Flow Testing: DEVELOP AND MAKE TOOL AVAILABLE Role of Statistical Agents
Recognize need in the legislation Permit advisory rates
Basis of Accounting No actuarial need for statutory Coordinate with accountants
Definition of Insurance For Regulatory Purposes
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Next Steps And How You Fit In
We expect the federal charter legislation to be actively considered in 2003
Our work has been forwarded to the Coordinating Group
The P&C Task Force will actively participate in the writing of a monograph and position papers that will be used in how the Academy responds to and testifies on legislation
You can be heard by conveying your thoughts to me or to any committee member or to Greg Vass who is the Academy staff supporting us.
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ACADEMY WEB SITE ON FEDERAL CHARTERS
The website contains the major pieces of federal legislation and related material.
It contains the position papers and the minutes of the teleconferences so you can see how the task force reached consensus on the position papers.
The web site address is available from Greg Vass of the Academy staff at 202-223-8196.
CAGNY November Meeting
Speaker Contact Information:Charles Bryan
PresidentCAB Consulting, LLC
600 South High StreetColumbus, Ohio
Phone 614-221-1919Fax 614-221-2881
E-mail: [email protected]