Solvency II Flashcards
Pillar 3
- Disclosure and Supervisory reporting regime
- Defined reports sent to regulator and public
- Regular Supervisory Report (RSR) produced annually and sent to regulator
- RSR is private report
- RSR contains:
a. Solvency calculation results
b. ORSA details
c. Risk management process details
d. Qualitative information
e. Quantitative Reporting Templates (QRT)
- a subset of QRT to support MCR calculation will be required quarterly - Sometimes a summary of the RSR may be produced with only material changes detailed
- Solvency and Financial Condition Report (SFCR) produced annually
- SFCR is publicly disclosed report
- Contains subset of QRT and qualitative information from RSR
- Some items can be omitted if demonstrated to be confidential
Differences to Solvency I
- More extensive disclosures
- Increased transparency
Pillar 2
- Supervisory review process
- Supervisor may decide a capital add-on is needed to cover risks that haven’t been modelled at all or adequately in pillar 1
- ORSA required
- ORSA is to:
a. Identify all risks to which exposed
b. Identify risk management and controls in place
c. Quantify ongoing ability to meet MCR/SCR - You can split Pillar 2 into governence requirements and ORSA
Governence
- Sets out requirements and responsibilityies of key functions
- Board have overall responsbilitiy for ongoing SII compliance
- All insurers must have
a. Risk management/
b. actuarial/
c. compliance/
d. internal audit functions - Clear segregation of responsibilities needed - Pillar 2 defined minimum levels
ORSA
1. In addition to SCR/MCR
2 Identify ALL risks to which subject and risk management/controls related
3. Not all risks covered in MCR/SCR e.g. reputational risk
4. Quantify ability to meet MCR/SCR over business planning horizon (3-5 years) - allow for new business
5. Confidence level not prescribed - should be level company feels appropriate
6. e.g. own risk appetite level or to achieve AAA rating
7. Considered by supervisor when deciding if capital add-on needed
8. Evidence required ORSA used by S.management and impact on ORSA considered when making strategic decisions
Pillar 1 in general, include main PIlar 1 discussion areas/headings
- Calculation of the min cap requirements for firms
- Methodologies for valuation of A&L (tech prov)
- Market consistent basis
- 2 capital requirements - SCR/MCR
- SCR calculated using:
a. Prescribed standard formula
b. IM approved by regulator
c. A mixture of a. and b. - MCR and SCR are capital required to be held above TP
Discussion areas are:
- Charts including the risk chart for standard formula
- Valuation of A
- Valuation of TP
a. BEL
b. Risk margin - Capital requirements
a. SCR - overview/SF including risk chart/IM
b. MCR
c. Supervisory intervention - Quality of capital
- Data quality
What does the standard formula risk chart look like
Top=SCR Middle = Loss absorbing adjustment/BSCR/Ops risk Bottom = 1. Market 2. Counterparty Default 3. Life 4. Intangible 5. Health 6. Non-life
Market Risk sub-modules:
- Equity (rcm)
- Property (rcm)
- Int rate (rcm)
- Credit spread (rcm)
- Currency
- Concentration
- Illiquidity
Counterparty Default:
- Type 1 - rated counterparty, undiversified
- Type 2 = unrated counterparty, diversified
Life insurance risk:
- Mortality
- Longevity
- Disable/morbidity
- Lapse (rcm)
- Expenses
- Revision
- CAT e.g. pandemic
Explain the standard formula calculation of SCR
- Different risk modules and sub-modules analysed as per chart
- First calculate SCR for each risk sub-module
- Then run through correlation matrix and matrix multiplication to get overall SCR for that risk
- Then run each risk module SCR through correlation matrix and matrix multiplication to get combined BSCR
- Make an adjustment for loss absorbing capacity of technical provisions including ability to adjust discretionary benefits
- Make an adjustment for Ops risk based on % of premiums and TP
Extras:
- SCR calculated using change in NAV (assets-BEL) ie. stressed NAV-base NAV (if stressed NAV decreases by 20 then 20 is your SCR)
- Example stresses are property down 25%, mortality up 15%
- Ops risk in SF is uncorrelated/undiversified with other risks
- The stresses come from detailed rules from supervisor
Valuation of Assets in SII, differences from Solvency I?
- MC valn - assets xchanged at arms length, 2 willing party
- i.e. MV
- If no accurate MV then mark to model
Differences to now:
- Most of europe = bv
- Reinsurance recovery is asset not liab
- Reinsurance asset adjusted for default risk.
SII valuation of TP in general (3 points)
- TP=BEL+RM
2, MC approach - Amount insurer has to pay to transfer BEL to another insurer
BEL methodolody
- MC valuation
- PV of future expected cashflows discounted at risk free
- BE assumptions used, no prudence/MADs
- Assumptions allow for all decrements and policyholder actions including lapses
- All relevant past/present data internal/external taken into account for assumption setting
- Premiums allowed up to contract boundary
- Expenses and expense inflation allowed for
- No closure reserve
- WP discretionary benefits allowed for
- Dynamic management/policyholder actions allowed
- Stochastic techniques with 1000’s of sims likely
- Policy by policy projection appropriate, grouping allowed
- If financial options/guarantees stochastic techniques, though closed form solution may be allowed
- Risk free rate is gilts or swaps + credit risk adjustment
- Adjustment for illiquidty premium on risk free rate too (compensation for holding illiquid asset)
Possible illiquidity adjustments: - QIS 5 was proportion of illiquidity premiums
- Countercyclical premium = adjustment to discount rate in times of financial stress
- Matching adjustment = adjustment for companies with predictable long term liabs and hold to maturity assets
- UL unit res and non-unit res unbundled
Explain the internal model methodology including 6 tests
- Must be approved by regulator
- Full or partial model possible
- Useful is risk profile different to standard formula
- May already have EC model going
- Capital requirements will be different than SF
- Regulator can force company to do it if SF not appropriate
- SCR must still cover all SF risks and 99.5th percentile VAR over 1 year calibration
- 6 tests to be passed before approved
- Use test is most challenging - to prove embedded in company and used for decisions/risk man/governence
- Data quality and assumptions also a problem
- Limited extreme event data
- Likely industry concensus will happen e.g. equity down 20%
- Will allow for company specific features e.g. more volatile equity holdings
- Allow for correlations changing in extreme situations
- If tests passed, IM structure up to company
- e.g. could use stochastic modelling not stresses
- IMAP is the UK process
- IM is costly
- Self-assessment template completed and sent to regulator
- It includes how the use-test has been passed etc.
The 6 tests:
- Use test - embedded in company, used in decisions/rm/gov
- Statistical quality - min quality standards met covering data/assumps/aggregation
- Validation - fully validated by company
- Calibration - SCR is equivalent to 99.5th percentile over 1 year
- Documentation - design/operation well documented
- Profit/loss attribution - demonstrate risk category attribution of p/l
Explain MCR
- Factor based linear formula
- 85th percentile VAR over 1 year
- 0.25xSCR<0.45xSCR
- Most will be on the limits
- Factors based on type of product (wp/ul/without p) and the tech provision level
- If fall below, regulator remove authorisation to sell NB
Explain the importance of good quality data in SII
- more complete/correct=more consistent/accurate calcs
- wider range of methods to calculate BE possible
- Validation more reliable
- Credible conclusions made
- Comparisons over time of results more effective
- Understanding of business and results better
- More likely to be able to use IM
Other effects of SII on an insurer
- Will be a group SCR accounting for diversification
- Each subsidiary must cover own SCR
- Group SCR>Sum of individual MCR’s
- Optimal product mix may change
- Optimal asset mix may change
- Some assets lead to lower capital requirements
- M&A activity increase for diversification benefits
- MI changes related to SII
- External disclosures to increased and change
- Share price/credit rating may change