COPLFR (excl 7-8) Flashcards
What should the opening paragraph state?
Actuary’s Name and Title
Who made the appointment (BOD)
Affirmation of qualifications
Relationship w/ the company (Employee or consultant?)
Date of appointment
statement that the qualification documentation was provided to the board
Appointment of AA
Initial Appointment:
By BOD before 12/31 year opining on (notify dom com within 5 days with )
- Name and title
- manner of appointment
- person meets requirements of a qualified actuary (or was approved by dom com, presented to BOD)
after no further notice is needed unless change!
3 types of “Board of Directors”
can include designated BOD, its equivalent, or an appropriate committee directly reporting to the BOD
Identification Illustrative Language
I, Name of AA [designations], am associated with ABC insurance. I was appointed by the BOD of ABC insurance on xx/xx/xxxx to render this opinion. I meet the def of a QA per the NAIC annual statement instructions - P&C, AO. I have provided my qualification documentation to the BOD directly.
Def of Qualified Actuary
meets basic education, experience, CE reqs of SQS for SAO, NAIC P&C AS as set forth in QS for actuaries issuing SAO in the U.S, promulgated by the AAA and…..
obtained and maintains an AAD
and….
is member of professional act organization that.
-adheres to code of conduct of Academy
-reqs adherence to U.S QS
-ABCD participation while actuaries are practicing in the US
exception to qualified actuary
-evaluated by Academy’s CPC and determined to be a QA for some LOBs and business activities (provides exemption for all QA reqs except for member of org that does the 3 things)
- approved by dom com
What must company do if AA is a QA by the exception?
company must attach, each year, approval letter and reference in the ID paragraph
U.S QS
Basic ed: ACAS/FCAS/EA/MAAA
exp: 3 yrs responsible
U.S specific knowledge: law and practices
subject area knowl:
30 hours relevant CE
- 6 + hours organized activities
- 3 + professionalism
- 1 +bias
- <=3 general business
+
one of…
fellowship (SOA/CAS) AND completed relevant education
min of 1yr responsible exp under review of QA
OR
min 3 years responsible exp under review of QA
U.S SQS
Basic ed: exams from academy/soa/cas on
policy forms & coverages, UW, marketing, ratemaking, insurance accounting, reinsurance OR
obtained signed statement from QA familiar with your background
exp: 3 yrs responsible
CE: 15 hours +, 6+ organized activities
NAIC standards for QA
US SQS
AAD
member of org that does the 3 things
state reqs vary
What should the qualification documentation contain?
-brief bio of actuary
-description of how def of QA is met for that year (CE)
-describe relevant experience to SAO
At what level should the review of the qualification documentation take place?
level within holding company structure that is responsible for overseeing insurance operations
-can be a parent board if a subsidiary (note in meeting minutes the name of the lead entity that reviewed the documentation or by attaching a copy of the parent boards meeting minutes reflecting their review)
Is the qualification documentation sent to the commissioner?
It is considered workpapers and available for inspection upon regulator request or during a financial exam
same confidentiality as the AR
Where can qualification documentation be reviewed if a single AR is used for multiple companies (in intercompany pooling for example)?
may be reviewed at level other than statutory entity defined as “responsible for overseeing insurance operations”
What constitutes an AAD?
designation meeting or exceeding NAIC P&C educational standards for AAs
examples:
FCAS & 6U
ACAS & 6U & 7
FSA (GI track)
exceptions can be made for 6U for example, can override with experience
How should actuaries (subject to US QS) document CE?
maintain timely records as evidence, should be for 6 + years
include
dates
hours
brief desc
whether it applies to a SQS and which one
is it an organized activity?
Procedure for changing an AA
Within five days of the action, the company must advise the relevant domiciliary insurance department in writing of the change.
Within 10 days of the notification, the company must write to the domiciliary Commissioner stating whether in the 24 months preceding the change (any disagreements on important things, list them and state whether they were resolved, nature of resolution(s))
The letter must be accompanied by a response from the former Appointed Actuary addressed to the company “stating whether the Appointed Actuary agrees with the statements contained in the Insurer’s letter and, if not, stating the reasons for which he or she does not agree
What reserve items may be included in the scope?
- Loss and LAE reserves;
- Retroactive reinsurance assumed reserves;
- Unearned premium reserves for P&C long-duration contracts;
- Unearned premium reserves for extended reporting endorsements (>= 1st schedule P interrogatory amt)
- Other reserve items for which the Appointed Actuary is providing an opinion
Language for examining actuarial methods and assumptions
I have examined the actuarial assumptions and methods used in determining the reserves listed in Exhibit A, as shown in the Annual Statement of the Company as prepared for filing with state regulatory officials, as of December 31, 2022.
Examples of “stated basis of representation” for reserve items in scope
-discounted for TVM?; items discounted
-explicit risk margin?
-gross or net of specified recoverables?
-is potential for uncollectible recoverables considered?
-types of LAE included
-is it only for portion of reserves in Exhibit A?
-misc
What must a 0% participant of an intercompany pooling arrangement do?
-speak on risks/uncertainties relevant to the lead entity
-A,B include their data
-attach A,B of lead entity
What must be disclosed for intercompany pooling?
-lead entity, description of the pool
-pooling %s, state of domicile, names of those involved
Do the requirements of intercompany pooling apply to 100% qs agreements?
No, for example dont mention this or attach any other companies SAO exhibits (also goes for AOS)
Review date def
“the date (subsequent to the valuation date) through which material information known to the actuary is included in forming the reserve opinion.
Language for data source
“In forming my opinion on the loss and loss adjustment
expense reserves, I relied upon data prepared by
___________ (officer name and title at the Company). I
evaluated that data for reasonableness and consistency. I
also reconciled that data to Schedule P, Part 1 of the
Company’s current Annual Statement. In other respects, my
examination included such review of the actuarial
assumptions and methods used and such tests of the
calculations as I considered necessary
Can the appointed actuary themselves be “responsible for the data provided” instead of an officer?
Yes, can also be a TPA, however regulators expect this to be an officer
When are “letters of representation” used in SAOs?
For consultant appointed actuaries sometimes which can include:
company-provided comprehensive data
info on events subsequent (to valuation date)
basis of reserves
changes in company methodology
any LDCs?
pools
reinsurance
What should the actuary do if the data is unreasonable or inconsistent to a significant degree? and the problem was not resolved satisfactorily
Do not rely on the data in question: If, in the Appointed Actuary’s judgment, this causes a significant increase in the uncertainty inherent in the Appointed Actuary’s opinion on the reserves, then the situation is typically described in the Statement of Actuarial Opinion and elaborated upon in the Actuarial Report,
or
– Conclude that an actuarial opinion cannot be formed based on the available data
What does the schedule P reconciliation include?
-should be gross and net, if not discuss in AR
-significant data types reconciled to Part 1 (A => R);
paid loss, incurred, paid LAE, sal/sub, claim counts, EP
-reconcile paid for either cumulative, or current CY, same for case reserves
-if differences deemed immaterial, discuss in AR
-aggregate up / down to minimum necessary level
What are some factors that can cause schedule P reconciliation issues?
-may use additional data not in Schedule P (exposure, policy lims)
-not aggregated with the same basis
What should the actuary do if unexplained differences remain between their data and Sched.P?
confirm the persons responsible for the data are aware
recommend company inform its auditors
discuss in SAO and elaborate in AR (explain any material differences)
Illustrative language for Schedule P reconciliation
I also reconciled that data to Schedule P – Part 1 of the Company’s current Annual Statement. The data generally reconciled with one exception: The total amount of Company XXX’s paid loss differs by $21,000. This difference results from rounding and is not material.
Data testing requirements
actuary typically writes a letter to company management (cc the company’s financial statement auditor(s)) identifying any significant data items for testing
auditor has discretion on what to test specifically
not required to write a letter, its just good for documentation reasons
ASOP 21 - responding to / assisting auditors can help
Evaluated methods and assumptions language if they did examine them
I have examined the actuarial assumptions and methods used in determining reserves listed in Exhibit A, as shown in the Annual Statement of the Company as prepared for filing with state regulatory officials, as of December 31, 2022, and reviewed information provided to me through XX/XX/2022 …my examination included such review of the actuarial assumptions and methods used and such tests of the calculations as I considered necessary.
Evaluated methods and assumptions language if they did NOT examine them and performed independent tests
I have examined the reserves listed in Exhibit A, as shown in the Annual Statement of the Company as prepared for filing with state regulatory officials, as of December 31, 2022, and reviewed information provided to me through XX/XX/2022…my examination included the use of such actuarial assumptions and methods and such tests of the calculations as I considered necessary
What does “meets the insurance laws of state X” mean?
generally interpreted as statutory accounting requirements.
Thus, to comply with insurance laws, reserves ordinarily represent management’s best estimate.
Language for when actuary reviewed methods and assumptions used in setting the recorded reserves (OPINION)
Are computed in accordance with accepted actuarial standards.
Language for when actuary performed an independent analysis of recorded reserves (OPINION)
Are consistent with reserves computed in accordance with
accepted actuarial standards.
Reasonable provision language
Make a reasonable provision for all unpaid loss and loss
adjustment expense obligations of the Company under the terms
of its contracts and agreements.
reasonable net, redundant / deficient gross language
Make a reasonable provision for all net unpaid loss and loss
adjustment expense obligations of the Company under the
terms of its contracts and agreements, but a deficient [or
redundant] provision on a gross of reinsurance basis. The
provision for all gross unpaid losses and loss adjustment
expenses is $X less than [or greater than] the minimum [or
maximum] amount I consider necessary to be within the range
of reasonable estimates.
What should a qualified opinion include?
items to which qualifications relate
amounts qualified
reasons for qualification
an opinion on the remaining reserves
2 examples where an opinion is not qualified even if the actuary doesnt review a segment
-that segment is not material to total reserves
-actuary reviews anothers analysis on material reserves and determines that it produces reasonable result (no independent analysis)
- should disclose whether they reviewed and the extent of the
review