Session 9: Panel on Assets Jeffery Yong IAIS Secretariat Regional Training Seminar IAIS-ASSAL San...
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Transcript of Session 9: Panel on Assets Jeffery Yong IAIS Secretariat Regional Training Seminar IAIS-ASSAL San...
Session 9: Panel on AssetsSession 9: Panel on Assets
Jeffery YongIAIS Secretariat
Regional Training Seminar IAIS-ASSAL
San Salvador, 24 November 2010
Session 9: Panel on Assets 224 Nov 2010San Salvador
AgendaAgenda
1. Introduction - lessons from the financial crisis
2. International standards
3. Summary
Session 9: Panel on Assets 324 Nov 2010San Salvador
Lessons from the financial crisis – mainly on Lessons from the financial crisis – mainly on asset side of the balance sheetasset side of the balance sheet
Note : This list is not exhaustive.
Session 9: Panel on Assets 424 Nov 2010San Salvador
Proposed structure of the new ICPsProposed structure of the new ICPs
ICP 18
Risk Assessment and Management
ICP 19
Insurance activity
ICP 20
Liabilities
ICP 21
Investments
ICP 22
Derivatives and similar commitments
ICP 23
Capital adequacy and solvency
ICP 14
Valuation
ICP 15
Investment
ICP 16
Enterprise risk management for
solvency purposes
ICP 17
Capital Adequacy
Standard on valuation
Guidance on valuation
Standard on investments
Guidance on investments
Standard on ERM for solvency
purposes
Guidance on ERM for solvency
purposes
Standard on capital
requirements
Standard on internal
models
Guidance on capital
requirements
Guidance on internal
models
EX
IST
ING
ICP
SN
EW
ICP
ST
RU
CT
UR
E
Session 9: Panel on Assets 524 Nov 2010San Salvador
Total balance sheet approach to recognise Total balance sheet approach to recognise interdependenciesinterdependencies
Supervisory assessment of the financial position
Assets Liabilities and capital requirement
Financial position
Assets Liabilities
Te
chn
ica
l pro
visi
on
s
Best estimate
policy obligations
Risk marginValue of
assets for supervisory
purposes
Capital requirement
Liabilities
Available capital
Public financial reporting
Liabilities
Capital
Session 9: Panel on Assets 624 Nov 2010San Salvador
An example of asset compositionAn example of asset composition
Session 9: Panel on Assets 724 Nov 2010San Salvador
AgendaAgenda
1. Introduction - lessons from the financial crisis
2. International standards
3. Summary
Session 9: Panel on Assets 824 Nov 2010San Salvador
Basis for establishing regulatory investment Basis for establishing regulatory investment requirementsrequirements
• The supervisory regime establishes requirements that are applicable to the investment activities of the insurer.
• The supervisory regime is open and transparent as to the regulatory requirements that apply and is explicit about the objectives of those requirements.
Financial requirements alone not sufficient – need to complement with quantitative/qualitative requirements to limit investment risks by insurer.
Factors to consider when setting requirements:
• Quality of risk management and governance
• Quality of capital resources
• Disclosure framework
• Cost of compliance
• Risk sensitivity of solvency regime Transparency facilitates comparisons across jurisdictions – particularly
important for cross-border insurance groups Explicit objectives can help to identify consistency with other requirements
– regulatory capital requirements, determination of capital resources and valuation of assets and liabilities.
Session 9: Panel on Assets 924 Nov 2010San Salvador
Rules-based vs. Principles-basedRules-based vs. Principles-based
• Limits on asset types
• Form - % of investments; capital charges; deductions from capital resources
• Easy to enforce and explain to court
• Deter insurer from investing in inappropriate assets
• BUT – stifle innovation; disincentivise risk management; one-size does not fit all
• Principles on investment strategy
• More flexibility for insurer to choose strategy that meets its risk profile and objectives
• Less frequent revisions in response to market developments
• BUT – innovative instruments riskier than originally assessed; difficult to enforce actions – open to interpretations
Rules-based Principles-based
Session 9: Panel on Assets 1024 Nov 2010San Salvador
Minimum requirements - security, liquidity and Minimum requirements - security, liquidity and diversificationdiversification
Security
• Restrict investment exposure to high risk investments (default, lost of value, custodianship)
• Limits of using external credit ratings – conduct own due diligence
• Derivatives – assess underlying assets and counterparty risk
Liquidity
• Able to realise/liquidate investments at any point in time
• Insurance groups – due regard to impediments to cross-border transfer of assets particularly in winding up
Diversification
• Diversify within risk category – pooling of same risks (e.g. shares of different companies)
• Diversify between risk categories – uncorrelated investments (e.g. different asset classes, geographical spread etc.)
Session 9: Panel on Assets 1124 Nov 2010San Salvador
Investments should be appropriate to the nature Investments should be appropriate to the nature of liabilitiesof liabilities
ASSETS
Timing of liability
cashflows
Amount of liability
cashflows
Policy guarantees & options
Unit-linked policies
Currency of liabilities
Mismatching risk higher technical provisions and/or capital requirements
Session 9: Panel on Assets 1224 Nov 2010San Salvador
Risk assessibilityRisk assessibility
• The solvency regime requires the insurer to invest only in assets whose risks it can properly assess and manage.
• The solvency regime establishes quantitative and qualitative requirements on the use of more complex/less transparent assets and investments in lightly/non-regulated markets.
Invest only in assets that the insurer can identify, measure, monitor, control and report – including reliable valuation.
Assess maximum loss possible – look through underlying assets.
Particular attention on complex asset classes – implicit obligations of support, increased correlation in times of stress.
E.g.- pre-approval of an insurer’s derivative investment plan – describe controls and test process.
Session 9: Panel on Assets 1324 Nov 2010San Salvador
Requirements on specific financial instrumentsRequirements on specific financial instruments
Off Balance Sheet
Structures
• Consider whether should permit – circumventing requirements?
• Investment strategy of OBS may be different from the insurer’s
• May impact ability to meet policyholder obligations especially in times of stress
StructuredCredit
Products
• Difficult to assess inherent risk underlying the reference instrument – e.g. subprime mortgages
• Impose quantitative/qualitative requirements on investments/originator
• Consider treatment in other financial sector, “skin in the game”, transparency of underlying asset, insurer’s control system
Derivatives
• Obtain information on insurer’s policies and procedures on the use of derivatives – rationale for transactions
• Should be used for risk management and not speculative investment – consider prohibition
• Suitable counterparties and tradability of the derivative
Session 9: Panel on Assets 1424 Nov 2010San Salvador
AgendaAgenda
1. Introduction - lessons from the financial crisis
2. International standards
3. Summary
Session 9: Panel on Assets 1524 Nov 2010San Salvador
Summary of key pointsSummary of key points
• During the recent global financial crisis, insurers were mainly affected due to their investment activities.
• Regulatory and supervisory requirements on investments need to incentivise insurers to have sound investment policies without being too restrictive.
• Sound asset-liability management policies has proven to be a powerful tool to manage risk.
Session 9: Panel on Assets 1624 Nov 2010San Salvador
Some final thoughtsSome final thoughts
• Need to avoid insurers becoming too-big-to-manage or too-complex-to-understand
• Insurers should have better understanding on risk interdependencies
• Avoid mistakes in other sectors
Session 9: Panel on Assets 1724 Nov 2010San Salvador
Thank you for your attention. Any questions/ comments?