Fall 2015 Flashcards
Question 21 - SAO (2 points)
Management of an insurance company has decided to replace its Appointed Actuary because of disagreements over substantive wording in the Statement of Actuarial Opinion (SAO).
The 2014 SAO Instructions require specific steps be taken as a result of this change in Appointed Actuary. Describe four of these steps.
Step 1:
* The company must notify the domiciliary commissioner of the change in appointed actuary and that the newly appointed actuary meets the qualification standards
* The company must notify the DOI within 5 days
Step 2:
* The company must inform the commissioner of any disagreements related to the substantive wording of the SAO and provide a description of the disagreements and how they were resolved within 10 days.
Step 3:
* The company must request that the former actuary provide a letter stating whether he/she agrees with the statements in the Company’s letter
Step 4:
* The company’s Board of Directors must appoint a new Appointed Actuary by the 2014 year end so they can opine on the 2014 SAO
1) Notify , 2) Inform on disagreements, 3) Request comment, 4) Appoint New
Question 22a - SAO (0.75 points)
OPINION
In my opinion, the amounts carried in Exhibit A on account of the items identified:
* A. Meet the requirements of the applicable insurance laws
* B. Are computed in accordance with accepted actuarial standards and principles
* C. Are less than the minimum amount I consider necessary to be within a range of reasonable estimates of the unpaid loss obligations of the Company under the terms of its contracts and agreements
Identify three errors in the wording of the OPINION section of the SAO.
- Needs to specify the insurance laws of (State of Domicile) OR missing the State
- The actuary should disclose the minimum amount that they believe is reasonable OR The amount by which the recorded reserve differs from the minimum amount the actuary believes is reasonable should be disclosed
- Need specify the opinion is on “loss and loss adjustment expense” as opposed to just “loss”
Question 24a - SAO (0.5 points)
Describe the concept of materiality as it relates to an actuarial work product.
One of the following:
* An omission, understatement, or overstatement in a work product is material if it is likely to affect the intended user’s decision making process or reasonable expectation
* An amount is material if including or excluding from disclosure would impact user’s decision
* Material if it would influence the decisions of regulators, investors, or business partners
The candidate was expected to know the meaning of materiality but was not expected to quote a definition verbatim. Common errors included:
* Only providing a description of possible metrics for determining materiality.
* Not mentioning that materiality depends on the user/audience – it was not sufficient to state that it would change/affect the actuarial opinion with no mention of the impact to the user.
* Simply saying it was something that needed to be disclosed.
* Attempting to define material adverse deviation rather than defining the concept of materiality.
Question 24b - SAO (0.5 points)
Briefly describe one reason why it may not be feasible to accurately determine a range of all possible outcomes when establishing a reserve range. Identify an example for the reason.
One of the following:
* Future liability yet to be identified is not reliably estimable, such as courts ordering payments of insurance claims where perils are explicitly excluded (for example, Asbestos/Product liability).
* There could be an unforeseeable event that the insurer did not consider being liable for – or the extent to which it was liable. A good example of this is asbestos reserves which have caused many insurer’s losses to develop more adversely than anticipated.
Extra Examples:
* Historical events are the usual basis for determining possible outcomes, but an event could occur that wasn’t accounted for. For example, very high inflation on medical WC costs.
* Some possibilities are so far remote that quantification and identification is very challenging. i.e.: Proliferation of lawsuits that would affect line of business. There is no way the actuary can foresee this, but it could happen.
Question 24c - SAO (1.5 points)
For each type of insurance below, describe how the two indicated risk factors could interact and influence the Appointed Actuary’s conclusion of whether there are significant risks and uncertainties that could result in material adverse deviation.
Type of Insurance & Risk Factors
(1) Coastal Homeowners
* Growth in a soft market
* Lack of available experience
(2) Mortgage
* Change in sustained unemployment rate
* Change in home prices
(3) Automobile
* Currency exchange rate
* Availability of repair parts
(1) Coastal Homeowners
* The growth may impact/distort some standard actuarial methods, unless they can be accurately accounted for. The lack of experience will also make accurate reserve estimates very difficult, especially given the CAT nature of the coastal area. This will likely increase the possibility that RMAD exists.
(2) Mortgage
* If the unemployment rate increases and home prices decrease, there will be a much higher rate of default and banks will not be able to recover the outstanding balance due to the home price decrease. This would increase the RMAD.
(3) Automobile
* A stronger dollar in US coupled with an increase in availability of repair parts could lead to cheaper rates to fix cars. This could lead to less uncertainty and less chance of RMAD.
* If car parts for foreign made vehicles become scarce at the same time that the dollar weakens, then severities for auto physical damage could significantly increase, leading to a risk of material adverse deviation.
Question 25a - SAO (1 points)
Identify four items that the Appointed Actuary should disclose in the SCOPE paragraph of the Statement of Actuarial Opinion (SAO).
Any four of the following:
- Date of Review
- Source of data (name, affiliation)
- Evaluation date
- Reconciliation to Schedule P
- Are you opining on UEPR or long duration contracts?
- Reviewed methods/assumptions used in determining reserves listed in Exhibit A
- Reviewed data for reasonableness/consistency
- If there are any reserve amounts the actuary is not opining on
- Reflect Disclosure Items Exhibit B
Question 25b - SAO (1 points)
A company discounts its workers’ compensation reserves. Identify four items that an actuary should disclose related to the discounting of reserves in an actuarial communication.
Any four of the following:
- Whether a Risk Margin is used, and basis for risk margin
- Amount of reserve discount
- Amount of tabular discount
- Amount of non-tabular discount
- Discount table used/description of tabular discount/basis & assumptions for tabular discount
- Determination/basis/selection method/methodology of discount rate (also source)
- Description of tabular discount
- Material changes in discounting methods
- Specific risks/uncertainties with regard to timing of future payments
- Accounting date
- Valuation date
- Review date
- If any assumption/method was prescribed by applicable law (permission granted)
- If a range is specified, basis for the range
- Significant limitations that constrained actuaries analysis
- Materially differs from ASOP 20
- Selection of Tabular discount rate
- Selection of Non Tabular discount rate
Question 26b - SAO (0.5 points)
Briefly describe the requirements for a contract to qualify for reinsurance accounting treatment under GAAP.
To qualify for reinsurance accounting under GAAP the following criteria must be met:
- Significant insurance risk; Transfers both underwriting and timing risk (i.e. uncertainty in the timing of and amount of payments.)
- It’s reasonably possible for reinsurer to incur a significant loss (exception in cases where substantially all of the risk is transferred)
Extra:
Requirements for GAAP/SAP:
- if SAP recognizes then GAAP will too.
- No strict rules for GAP but industry standard is ERD>1% or 10-10 Rule, which says risk transfer exists if >10% chance that reinsurer incurs >10% loss.
Common errors included providing an incomplete answer, such as referencing the 10-10 or 1% ERD rule without discussing how it relates to the GAAP requirements. Many candidates confused the idea of underwriting risk with a chance of significant loss.
Question 26c - SAO (0.5 points)
Briefly explain the rationale for whether each of the following should be included in risk transfer analysis:
- Maintenance fee
- Profit commission
Maintenance Fee
- Yes, it’s a cash flow between insurer and reinsurer
- Yes, cedant must pay this to reinsurer to prevent commutation
- Yes should be included because it is a payment between insurer and reinsurer and could eliminate coverage if not paid
- Yes, it would change the reinsurer’s calculated profit or loss
Profit Commission
- No, risk transfer analysis focuses on loss scenario, which will have no profit commission
- No, profit commission impacts cedent’s results which should not be considered in risk transfer analysis
- No, any indirect economic impact is already accounted for in premium
- No, including would have potential for manipulation
This question required a deeper understanding of risk transfer than part b. Common errors included assuming that a maintenance fee is not a cash flow between insurer and reinsurer, and that not including profit commission would lead to manipulation.
Question 1a - Credit Scores (1 points)
According to McCarty, identify the two age groups where insureds are disparately impacted by the use of credit scoring and briefly describe the reasoning.
The elderly and young adults. Young adults typically have not had the time to build a good credit score or credit history. The elderly typically use less credit, which too has an adverse impact on the credit score. If credit scoring is used to determine rates, these groups will be at a disadvantage.
Question 1b - Credit Scores (0.5 points)
Other than age groups, identify one group of insureds that McCarty claims is disparately impacted by the use of credit scoring and briefly describe the reasoning.
Any one of the following:
- People of lower socioeconomic class / low income / poorer people – may have lower score due to lack of available lines of credit b/c of their income, for example. This drives up premiums for something that is beyond their control.
- Certain religious faiths which don’t support the use of credit / usury / interest, so they wouldn’t have fair credit scores – doesn’t tell about driving ability.
- Race / minorities - McCarty claims credit scores are a proxy for race and socioeconomic status. Poorer minorities are more likely to have a low credit score and insurance companies are effectively increasing their rates
Question 1c - Credit Scores (0.75 points)
Empirical studies have shown that those with different credit scores have an observed difference in total insurance losses.
Identify a key metric and describe how the metric could be driving these loss differences.
Frequency of claims / percent of accidents reported / willingness to file a claim / risk absorbing:
* People with high credit scores may pay for smaller claims out of pocket while low credit scores may file a claim with insurance company. Therefore those with high scores will have lower total losses since they are paying for some claims themselves.
Question 2a - Porter Ch.5 - (1 points)
Identify four reasons why a state might disapprove a rate or form filing.
- Contrary to public interest or Rate is unaffordable to insureds
- Illegal or Rate violates law/statue
- Excessive or Rate too high
- Filing did not meet filing deadline
- Insufficient supporting documentation:
Errors in documentation provided in filing or,
Did not comply with all the state’s filing requirements - The following item is not allowed/approved by regulator or specific item is required to be
used:
Rating variable/assumption/methodology/model
Many candidates did well listing reasons for state disapproval of a rate or form filing. Common errors included simply stating discrimination without qualifying their answer by stating ‘unfairly’ discriminatory or discriminate against ‘protected’ classes. Other candidates made the error of repeating similar answers, such as the rate is excessive and the rate is too high.
Question 2b - Porter Ch.5 - (0.5 points)
Describe one argument in favor of having a no-file law in every U.S. state.
- Market competition keeps insurance pricing fair
- Will reduce the costs of filings for insurers (and these costs get passed down to policyholders). Competition will naturally ensure rates are fair.
- It would reduce costs to both insurers and regulators as insurers would not need to spend money on filings and regulators could use time/budget on other matters concerning insurance regulation (e.g. solvency)
This question was open to interpretation and allowed for many different reasonable answers. A common error made by candidates was that they were able to provide an impact of the No-File law system (i.e. cost/labor reduction, time efficiency, etc.) but did not provide a specific reason for favoring the no-file law (e.g., the cost savings would be passed down to insureds or open competition would lead to fair insurance pricing).
Question 2c - Porter Ch.5 - (1 points)
A personal lines insurer files rates with the state department of insurance 45 days after it begins to use them. The insurer is not in compliance with the state’s rate filing requirements.
Identify two types of rate filing laws that could exist in this state, and briefly describe how the insurer’s filing activity would not comply with each.
Any two of the following:
Prior-Approval
* Insurer must file rates and receive approval notice from the state DOI before using rates, can’t use until approval is received. Rates must be approved BEFORE use
File-and-Use
* The insurer must file for rate changes but allowed to use the rates immediately or after a short waiting period. The insurer files rates 45 days after use. Hence it is not in compliance because rates must be filed first with state before use
Extra
Use-and-File
* Insurer may use the rates as they want and file within a specified period after the rates are put in use. The specified period may be shorter than 45 days, say 30 days. Thus the insurer is not in compliance.
Flex Rating
* Did not comply because insurer’s rates are outside of acceptable change and they used them anyway without prior approval.
State-Mandated Rates
* Insurer cannot do business legally in state if the insurer used a rate in their filing that is not the mandated rate.
The question required application of the specific rate filing laws chosen to the situation presented in the question, specifically the violation/lack of compliance of the rate law. Common errors included omitting or incorrectly stating a rate filing law. There were some candidates who made the error of switching a violation of the Use-and-File law with File-and-Use. Others simply stated a definition of the rate law that did not demonstrate how the insurer was not in compliance with the type of rate filing law specified.
Question 3a - NAIC Solvency/Dearie - (1 points)
Briefly describe one distinct rationale for each of the following elements in a state insurance solvency regulatory system:
* Minimum capital requirements
* A state guaranty fund
* Reinsurance transactions require regulatory approval
* Insurers must submit annual financial statements
Any one of the following bullets for each element:
Minimum capital requirements
* Ensure that company has enough surplus to remain solvent
* Ensure that adequate capital is on hand to fulfill policyholder obligations
* Barrier to entry into state for prospective insurance companies, keeps riskier undercapitalized carriers from entering market
* Helps identify troubled insurers by seeing which insurers are below or near their minimum capital levels
* Allows regulators to take regulatory action against troubled insurers
State guaranty fund
* Protect policyholders when an insurer goes insolvent by paying the claims and/or a portion of the unearned premium of the policyholder; may be subject to limitations/caps
Reinsurance transactions require regulatory approval
* To verify there is risk transfer in the reinsurance contract
* Review to ensure insurer is not using reinsurance to artificially inflate surplus / mask financial issues
* Most reinsurers are outside of the U.S and they are not regulated by the U.S. regulatory system
* Reinsurance coverage may be covering or exposed to large losses or catastrophic risks. This requires regulatory attention
Insurers must submit annual financial statements
* These financial statements allow the regulator to continually monitor insurers
* Statements are used by regulators to assess the insurer’s risk and financial condition
* Encourage market discipline / competition since publically available
* Standardized format allows regulators to compare companies
* Reports feed into offsite monitoring analysis / tools such as RBC and IRIS
Candidates were expected to produce one rationale for each element in a state insurance solvency system. Common errors included:
Minimum capital requirements
* Mentioning that it provides protection if premiums charged are not enough to cover losses
* Stating that it provides protection/additional funding in case an insurer becomes insolvent
State guaranty fund
* Mentioning that funds are available in case of insurer insolvency, without including the uses for the funds
* Mentioning that it provides protection against insolvency, without including what/who is protected
* Describing an assigned risk plan rather than a state guaranty fund
* Mentioning that it helps companies remain solvent during adverse scenarios by helping them pay claims
Reinsurance transactions require regulatory approval
* Referring to assessing the reinsurer’s strength without referencing the transaction or the impact on the ceding company
Question 3b - NAIC Solvency/Dearie - (0.5 points)
Briefly describe two reasons for the development of the Reinsurance Regulatory Modernization Framework of 2008.
Any two of the following:
- Needed to reduce penalties associated with unauthorized but strong reinsurers
- Better reflect the globalization of insurance by recognizing foreign reinsurers
- Allow reinsurers to receive collateral reductions when they meet certain standards
- Promote competition in the reinsurance market
- Standardize treatment/streamline regulation for domestic & alien reinsurers
Candidates were asked to demonstrate knowledge of the reinsurance framework, but this proved challenging. Common errors included:
- Confusing the framework with the provisions of other acts such as the Non-Admitted and Reinsurance Reform Act
- Asserting the framework applied to all reinsurer types
- Stating that too many reinsurer insolvencies prompted action for more stringent regulation
- Mentioning that lessons learned from the recent financial crisis prompted action
- Stating that it ensures that reinsurance transactions actually transfer risk
Question 3c - NAIC Solvency/Dearie - (1 points)
Describe two provisions of the Nonadmitted and Reinsurance Reform Act (NRRA)
Any two of the following bullets:
Reinsurance
- If the insurer’s domiciled state is NAIC accredited and the domiciled state recognized the reinsurance credit, NRRA prohibits other states from denying credit
- The reinsurer’s domiciliary state has sole responsibility of the financial solvency of reinsurer
- Allow states to continue reinsurance collateral reform on individual basis if they are accredited by NAIC
Non-admitted
- Premium taxes for non-admitted insurance transactions are only paid in the home state of the insured
- Placement of non-admitted insurance is only to be regulated by the home state of insured
- Non-admitted /Surplus line brokers only need to be licensed in home state of the insured
The question asked for two provisions in the Non-admitted and Reinsurance Reform Act. Since the question asked candidates to ‘Describe’, this means that full credit answers contained the provision as well as some other supporting/additional verbiage. Common errors included:
Omitting key elements of responses
- Example: Only home state can collect tax
No reference to insured’s home state
No reference to non-admitted business
No reference to premium tax - Example: If home state gives credit, then no other state can deny credit
No reference to ceding insurer’s home state
No reference to reinsurance credit
No specification of home state being NAIC accredited or similar standard - Example: Elimination of the due diligence search
No reference to exempt commercial purchaser / sophisticated purchaser
No reference to actions that must be taken prior to being waived - Stating that it allowed an insurer/reinsurer to be licensed in one state and conduct business in all states
- Interchanging the terms licensing & regulating
- Interchanging the terms broker & insurer
- Referring to ‘certified’ reinsurers
Question 5a - Rating Agencies - (0.5 points)
Describe an A.M. Best interactive rating.
Any one of the following:
- This is when an insurer pays for their rating, which allows them to have more control over their rating by having discussions with the rating agency, providing helpful proprietary data, and answering inquiries from the agency.
- Insurer’s senior management has an interactive meeting with rating analysts, so analysts can understand the company’s business strategy, experience with adverse conditions and integrity. Insurer also submits proprietary info to rating analysts. Analysts determine rating based on findings from meeting, background research and proprietary info.
- Rating agency requires insurers to give proprietary information in a high level interactive meeting to give the right rating. Information can include: U/W, pricing, reserving and investment, etc.
Candidates should provide multiple facts in the answer to demonstrate knowledge of what an interactive rating entailed. General statements about BCAR or financial solvency were not sufficient to receive full credit; an interactive rating includes more than just the calculation of capital requirements.
Question 5b - Rating Agencies - (1 points)
Briefly describe two advantages and two disadvantages for a mid-size mutual insurance company to obtain an interactive rating from A.M. Best.
Advantages (any two of the following):
- Insurer has some control over information reviewed
- Easier to obtain credit for the company
- Fewer chances of error
- Third parties often rely on the assessment
- It is less expensive to pay for a rating than to demonstrate financial strength individually to others
- Agents may be wary of insurers without an interactive rating
- Unrated reinsurers may not be considered as viable by primary insurers placing business
- Certain lines of business can’t easily be sold by companies w/o high ratings (for example: reinsurance, surety, structured settlements, homeowners, and specialty lines)
- Individual and corporate policyholders want to be sure the insurer will be able to pay their claims
- Rating process can give management insight into areas that need improvement
- Ability to purchase reinsurance may be easier if they have an interactive rating
Disadvantages (any two of the following):
- It has a cost, the company must pay for interactive rating
- It requires time, effort, and personnel
- It is intrusive
A common mistake for disadvantages was to state that the interactive rating may result in a poor rating; these answers focused on the rating outcome and not on advantages/disadvantages of an interactive rating as requested.
Question 5c - Rating Agencies - (1.5 points)
Fully describe one argument in favor of and one argument against the following statement:
“A.M. Best is, effectively, a regulator of the insurance industry.”
In favor:
- Since ratings play such an important part in the insurance industry (agents may use rating for placement, insurer may require a certain rating of their reinsurers, etc.) AM Best can bring pressure on companies to provide strong incentive for them to take corrective action, much like a regulator.
- It can have huge impact on insurers as consumers, and agents with limited information on the company rely heavily on financial strength ratings.
Against:
- However, AM Best does not have regulatory authority. It can’t reject filings, approve/reject rate changes, respond to consumer complaints, etc. It can’t force the company to act as a regulator could, it can only exert pressure. Nor can AM Best take control of the company in case of financial difficulty as a regulator could.
- Realistically, all AM Best can do is adjust its ratings. It does not have the regulatory power to control or prohibit insurers to take certain actions.
Candidates had some difficulty with this part, with many candidates not fully explaining their answers.
- For instance in the Against section, several candidates just said that AM Best does not have real regulatory or legal power, without describing some of the regulatory powers that regulators do have.
- Others in the For section mentioned that insurance companies needed a good rating to write a particular line of business, without any further information. The question asked to fully describe, which requires more explanation than a question asking for a brief description
Question 6a - Porter Ch. 4 - (0.75 points)
Briefly describe three key goals of insurance regulation.
Any three of the following:
- Promote fair and equitable treatment of insurance
consumers - Ensure financial stability of insurers
- Ensure insurer solvency
- Ensure availability of insurance in the market
- Prevent unfair discrimination towards consumers
- Ensure availability of coverage
- Promote a competitive market
- Ensure that insurance companies have enough surplus
The most common mistake was to repeat the same answer. For example, stating that regulation should ensure fair and equitable treatment of policyholders, as well as stating that regulation should protect consumers.
Question 6b - Porter Ch. 4 - (1 points)
As part of its modernization plan, the NAIC has undertaken (or plans to undertake) several initiatives to improve state-based insurance regulation. Describe two of these initiatives.
Any two of the following:
- ORSA - own risk and solvency assessment. Companies self-assess their own risk and provide valuable qualitative insight to regulators
- Improve RBC calculation – operational risk charge and improve the square root formula
- Review IFRS accounting standards and improve uniformity in global insurance market while improving assessment of short & long term profitability of insurers
- Solvency maintenance – create document laying out US insurance structure, look for ways to use int’l developments in insurance regulation in US and apply lessons from global financial crisis
- IMF FSAP – financial sector assessment programs is an international in-depth look at regulation, especially on group comparisons
This part was more challenging. The most common mistake was to list current functions of the NAIC that are not related to current initiatives in the NAIC modernization process.
Question 6c - Porter Ch. 4 - (1.5 points)
Describe one argument in favor of and two arguments against the following statement:
“The financial crisis of 2007-2008 demonstrated that insurance should be regulated at the federal level.”
“For” federal regulation (any one of the following):
- Need one national voice in dealing with global insurance topics
- Since insurance is a critical element of society, federal regulation would help avoid a massive insurer failure
- A single authority would allow ease of monitoring so that business transactions in all states can be monitored together, as opposed to state by state
“Against” federal regulation (any two of the following):
- Insurance companies were the least hit by the crisis, which showed that current rules and regulations at the state level are effective in keeping insurance companies afloat and ongoing
- Duplication, peer review, and diversity of opinions among state regulators more likely to catch failing companies
- The low amount of problems in state-regulated insurers relative to federally-regulated banks shows that state regulation is an effective process
Common mistakes included stating that the federal government should regulate insurance because insurance needs federal regulation, or stating that the financial crisis proved state regulation is too expensive.
Question 9a - Porter Ch.12 - (0.5 points)
Describe how a guaranty fund provides services to policyholders.
- Handles claims of insolvent insurer OR Pays claims and returns unearned premium of insolvent insurer
- Provides temporary coverage in case of insolvency
The candidate was expected to know that the guaranty fund continues insurance coverage until policyholders find new insurers and that the guaranty fund handles claims and refunds unearned premium for policyholders of an insolvent insurer.
Most candidates were able to state that the guaranty funds pay the claims of insolvent insurers. Fewer candidates also knew that they provided temporary coverage. The most common errors were restating the question as an answer and rewording the same answer in two different ways.