Professional Documents
Culture Documents
2
Do Insurers Pose Systemic Danger?
The financial crisis helped confirm and its “substitutability” which is its As mentioned, nine insurance groups
the overall resilience and strength of capacity to continue providing services were identified by the FSB as global
the insurance business model. It also (in this case, insurance coverage) systemically important insurers
demonstrated that the systemic relevance following the failure of an entity. (G-SIIs) in July of 2013, based upon
of insurance groups is correlated the IAIS’s definition of sources of
with activities outside the traditional NTNI activities can include leveraging, systemic risk and NTNI activities.
insurance business field.4 As a result, the liquidity or maturity transformation,
International Association of Insurance imperfect credit risk transfers such as Beyond the G-SII designation, the IAIS
Supervisors (IAIS) has taken the initiative “shadow banking” and credit guarantees developed an internationally coherent
of defining the sources of systemic risk, or minimum financial guarantees. Such framework for the supervision of
due mainly to non-traditional insurance activities often involve products that large, complex and global groups.5
and non-insurance (NTNI) activities, are more complex than traditional This framework is not dependent
or as a result of interconnectedness insurance products, thus shifting on whether or not an insurance
(the extent to which an activity and/ financial market risk to insurers. Figure group is systemically important.
or product is linked to the financial 1 below illustrates major traditional
markets. Other considerations include and non-traditional insurance activities
the institution’s size, global activity as well as non-insurance activities.
- Proprietary investment function - Proprietary and derivatives trading - Purely synthetic investment portfolios
(asset liability management - ALM) (non-ALM) - Cascades of repos and securities lending
Investment
and Funding - Hedging for ALM - Property management (as it - Scope and scale of activities beyond
- Funding through equity and debt relates to an investment portfolio) insurance remit
issues, and securities lending
Source: “Insurance and Financial Stability,” International Association of Insurance Supervisors, November 2011. Access at: http://forinsurer.com/files/file00400.pdf
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The New Global Insurance Regulatory Landscape
Figure 2 on the next page illustrates • ComFrame is a set of international capital adequacy component, known
the relationships between the three supervisory requirements focusing as Insurance Capital Standards (ICS),
types of requirements that apply to on the effective group-wide and G-SIIs would have to cope with
insurers depending on their activities, supervision of internationally all quantitative requirements. These
size and systemic importance: the IAIS active insurance groups (IAIGs). include Basic Capital Requirement (BCR),
Insurance Core Principles6 (ICPs), the Higher Loss Absorbency (HLA) and ICS
Common Framework for the Supervision • G-SII policy measures should apply plus the G-SII Policy Measures’ specific
of Internationally Active Insurance only to designated G-SIIs, and should qualitative requirements in addition to
Groups7 (ComFrame), and the Global be appropriate for the risks that the ComFrame and ICP requirements.
Systemically Important Insurers package.8 G-SIIs pose to the financial system.
Note that the IAIS is responsible for
• The ICPs standards and guidance ICPs should apply to all insurers when setting out the criteria and process used
apply to all insurers and insurance capital requirements and other measures by supervisory colleges to identify IAIGs
groups, regardless of size, international vary based on whether an institution is and that the national regulators have
activities or systemic importance. deemed an IAIG or G-SII. IAIGs would discretion to determine whether an
be subject to ComFrame and its insurance group qualifies as an IAIG.9
4
Figure 2. Global regulatory framework affecting insurers, specifically G-SIIs and IAIGs
Type of
requirements
All Insurers
ICPs (Individual/Group)
ComFrame expands on ICPs Qualitative
ComFrame
IAIGs
≈ 50 groups identified
Capital Adequacy ICS
Component of ComFrame
HLA Quantitative
Capital Requirements
for G-SIIs
BCR
G-SIIs
= 9 groups identified
Effective Resolution
G-SII Policy Measures Qualitative
Enhanced Supervision
G-SII Global Systemically Important Insurer BCR Basic Capital Requirement ICS Insurance Capital Standard
IAIG Internationally Active Insurance Group HLA Higher Loss Absorbency ICPs Insurance Core Principles
Source: “10th Annual Insurance Public Policy Summit, Confronting New Challenges in U.S. and International Regulation,” Institute of International Finance, March 12, 2014.
Access at: http://indstate.edu/business/NFI/events/10AIPPS/docs/Insurance%20Portilla%20IIF.pptx
Source: “Frequently Asked Questions for the IAIS Common Framework for the Supervision of Internationally Active
Insurance Groups (ComFrame),” International Association of Insurance Supervisors, Updated December 17, 2014.
Access at: http://iaisweb.org/index.cfm?event=openFile&nodeId=41664
G-SII
IAIG
G-SII Global Systemically Important Insurer BCR Basic Capital Requirement ICS Insurance Capital Standard
IAIG Internationally Active Insurance Group HLA Higher Loss Absorbency ICPs Insurance Core Principles
Source: “10th Annual Insurance Public Policy Summit, Confronting New Challenges in U.S. and International Regulation,” Institute of International Finance, March 12, 2014.
Access at: http://indstate.edu/business/NFI/events/10AIPPS/docs/Insurance%20Portilla%20IIF.pptx
5
Focus on G-SII Qualitative Requirements
The items listed below represent only Effective separation of 3. Separation should not result in
one part of the G-SII requirements, NTNI activities non-regulated financial entities.
but, in our view, they would require The group-wide supervisor may ask the 4. Intra-group transactions or
more attention and a greater G-SII to apply effective separation of commitments with the separated
investment on the part of the affected NTNI activities to help reduce or mitigate entity should be at arm’s length.
institutions in the years to come. systemic risks. The approach should be
defined in the SRMP, and developed 5. Reputational risks that could result
For a complete description of the requirements by the G-SII in collaboration with the in the parent or an affiliate providing
see: “Global Systemically Important Insurers: Policy group supervisors. The question of what financial support to the separated
Measures,” International Association of Insurance
Supervisors, July 18, 2013. Access at: http://iaisweb. constitutes effective separation is a entity should be mitigated.
org/index.cfm?event=openFile&nodeId=34256. critical supervisory policy issue. Whether
or not NTNI activities are effectively The elaboration of Recovery
Systemic Risk Management separated could directly affect the and Resolution Plans (RRPs)
resolvability of this question and may
Plan (SRMP) There should be an ongoing process
affect the calculation of higher loss
G-SIIs should be expected to start work absorption to be applied to the G-SII. As for recovery and resolution planning,
with their group wide supervisor in per the requirement, a G-SII should meet covering, at a minimum, the domestically
developing a SRMP. The SRMP describes the following five regulatory standards, as incorporated firms that could be
how the G-SII would manage, mitigate applied by the group-wide supervisor, in systemically significant or critical if they
and reduce its systemic risk. The SRMP order to be deemed effectively separated: fail. The firm’s senior management would
should include the actions the G-SII be responsible for providing the necessary
will take to either reduce systemic risks 1. An effectively separated entity inputs to the resolution authorities
or to mitigate those risks. It should (subsidiary or affiliate) should be for (i) the assessment of the recovery
also describe the GSII’s enterprise self-sufficient to the degree that plans; and (ii) the preparation by the
risk management framework and the it can operate without the support resolution authority of resolution plans.
control framework that is in place to of the parent or affiliates. The goal of RRPs should be to maintain
effectively mitigate these systemic risks. or restore the business in a sustainable
2. The separated entity’s governance way in the event of financial distress.
framework should ensure the
operational independence
of management (including
risk management).
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Basic Capital Requirement (BCR)
At the moment, a factor-based BCR Ratio = Total Qualifying
approach consisting of 15 risk Capital Resources (for BCR) /
measures is used to calculate BCR.13 Required Capital (for BCR)
This approach helps employ a simple
structure that can be applied to all The approach for calculating required
insurance groups while maintaining capital should take into account
transparency into the 15 risk measures. the risks derived from these five
major activity groupings: an insurer’s
An insurance group’s BCR amount traditional life and non-life insurance
can be identified using its BCR (TL, TNL), non-traditional activities (NT),
Ratio which is defined as: assets (A) and non-insurance (NI).
8
9
Higher Loss Absorbency (HLA)15
Targeted HLA Capacity (step 1) – Group-wide HLA Capacity (step
to the extent the G-SII has demonstrated 2) – whether or not NTNI activities
effective separation of NTNI have been separated, an overall
activities from traditional insurance assessment of group-wide HLA needed
activities, targeted HLA would be should be undertaken and the group-
applied to the separate entities. wide supervisor could determine
whether the HLA capacity held at the
dedicated NTNI entities is sufficient
or needs to be further increased.
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Figure 6. Overview of global capital standards requirements
Objective Serve as a comparable prudential Internalize the costs on the financial Contribute to the stability of the financial
floor, an early warning indicator, system that a G-SII would have system and the protection of consumers
a minimum capital standard in case of a potential failure
Nature Basic (formerly “backstop”) Additional level of capital in relation to a A measure of capital adequacy
capital requirement G-SII’s systemic activities (i.e. G-SIIs will and will constitute the minimum
General
Application Only to G-SIIs and at consolidated Only to G-SIIs and at consolidated All IAIGs (including G-SIIs) and at
group-wide level group-wide level consolidated group-wide level
Inter-linkage The BCR is the foundation for HLA (and The HLA will build on the BCR (The BCR will The ICS is the foundation for HLA,
the BCR calibration may be modified serve as the comparable foundation for HLA. initially the BCR (ICS is the quantitative
depending on the HLA requirements) When the ICS is finalized, it will replace the part of the ComFrame initiative)
BCR in its role as the foundation for HLA)
Links
Articulation Balance sheet (B/S) valuation compatible B/S valuation compatible with S2 and To be confirmed
with Solvency II with Solvency II (S2) (Market-Adjusted resembling S2 Solvency Capital Requirement
Valuation Approach, starting with IFRS or
GAAP, and making adjustments to major
B/S items) factor-based approach similar
to S2 Minimum Capital Requirements
Public/Private Initial phase of annual confidential Transparency with regard to the final results Disclosure of the final results
reporting to group-wide supervisor from
2015-18, public reporting to follow
Scope of risks Main risks (assets, liabilities and off- Drivers of G-SII assessment with All material risks (including non-insurance
B/S exposures) on three components capital uplift on NTNI activities risks and off-B/S activities). It is expected
(insurance, banking, other non-insurance (non-traditional, non-insurance) that a more comprehensive approach will be
Technical details
financial activities not currently subject adopted for ICS development than for BCR
to regulatory capital requirements, with
a further fourth component covering
other material non-financial activities)
Design Simple design and presentation (limits: Pragmatic, practical design (appropriate Appropriate balance between risk sensitivity
no explicit recognition of Asset Liability balance between granularity and simplicity) and simplicity (explicit treatment of
Management (ALM), implicit diversification, diversification and ALM to be explored)
reinsurance to be clarified)
Capital BCR can be covered by core and HLA can be covered by Tiering approach for qualifying
adequacy additional capital (max 50/50) highest quality capital capital resources
First steps Consultation (December 2013 – February 2014) Publication of principles (September 2014) Consultation (October 2013 – December 2013)
Field Test (March 2014 – May 2014) HLA Consultation (December 2014 – Publication of principles (September 2014)
Consultation (July 2014 – August 2014) February 2015) Revised ComFrame draft (September 2014)
Publication of BCR design (October 2014) ICS Consultation (December 2014 –
Endorsement by G20 (November 2014) February 2015)
Next steps As of 2015, reviewing and refining Field Test (March 2015 – September 2015) Field Test (April 2015 – June 2015)
Milestones
of BCR along with first reporting Release of initial HLA consultation ComFrame Consultation (December 2015)
document (mid-2015) Field Test (April 2016 – June 2016)
Confidential reporting (2017-2018)
Source: Accenture analysis of future global capital standards based on publicly available IAIS and FSB documents
11
Effects on Insurers’ Agendas:
Expected Implementation Timeline
The timeline for implementing some It was anticipated that the BCR would The IAIS is committed to develop the ICS
of these measures are both ambitious be applied to G-SIIs as of January by the end of 2016. Full implementation
and uncertain. For example, G-SII 2015. When this happens, it is likely to is scheduled to begin in 2019 after
measures on enhanced supervision influence the development of two other two years of testing and refinement
(including development of the Systemic capital standards planned by the IAIS:17 with supervisors and IAIGs.18
Risk Management Plan) should have
been implemented by now.16 • The HLA, the additional capital Figure 7 below presents a timeline
requirement for G-SIIs, and of when key measures could be
In addition, G-SII measures on effective expected to impact G-SIIs and IAIGs.
resolution (including recovery and • ICS for IAIGs
resolution plans or RRPs) should have
also been developed and agreed by crisis
management groups (CMGs) as they
were expected by the end of 2014.
FT FT FT
Global Insurance Capital Standard (ICS) for IAIGs Full adoption of ComFrame/ICS
IAIG Package
ICS
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12
The Specific Case of Reinsurance Responding to These
The decision to include some reinsurers whether reinsurers could create systemic
New Designations
within the list of G-SIIs has been risk through non-insurance activities such In response to the new
postponed several times. Even if as writing collateralized debt securities or G-SII designation, we have
traditional insurance activities are CDSs is still on the table. At the moment, observed institutions adopt
not considered as either generating or the IAIS has postponed the decision, as the following strategies:
amplifying systemic risk, the question further study and analysis is required.19
1. Exiting strategy with institutions
reshaping their company
structure by carving out parts
of their business, or challenging
Effects on Insurers and How the designation in court.
2. Accommodation strategy with
They Should Respond institutions accepting the higher
capital requirements, policy
measures and committing to
Insurers have taken different positions on NTNI activities, implementing the key
comply with new designation.
new global standards; some are waiting attributes and taking the corrective
for more information before taking a actions called for as part of the ERM 3. Wait and see strategy with
stand, while others have already publicly framework. This, we believe, could institutions awaiting the IAIS’s
criticized the measures.20 They argue that put even more pressure on actuarial, fine-tuning of the rules and
these new measures should be aligned finance and risk resources, and how these will be applied.
with other regimes (Solvency II in the EU) increase the need to foster cooperation
that have required hard, extensive work between internal departments For financial institutions, the
to stabilize. In addition, they say that and the regulatory supervisor. best course of action may
these requirements may have a negative be a combination of these
impact on the insurer’s business model, Finally, the new capital measures may strategies. We suggest they
by requiring additional capital charges require additional capital adequacy field also consider field-testing and
at a time when insurers are already tests, scenario analysis and a comparison actively communicating their
facing difficult market conditions. with other regimes (particularly the perspectives and thoughts
valuation question, maintaining on the G-SII designation
In our view, even if the new capital market consistency versus Generally with their local regulator.
regime is not yet stabilized, some key Accepted Accounting Principles and
aspects of the policy measures should expected adjustments to regulations).
be highlighted—in particular those that
complement the Solvency II regime in These new sets of requirements could,
the EU—including the implementation of in our view, change the playing field
the enhanced supervision and effective and create new opportunities for the
resolution packages for G-SIIs. formation of subsidiaries, mergers and
acquisitions, and for the development
As a first step, insurers should think of new financial and asset liability
about their ability to identify their management strategies, among the
NTNI activities, assess their alignment most-discussed areas. The sooner insurers
with their risk strategy, and enhance review these different requirements, the
their ERM capabilities. Insurers should more able they would be to anticipate
not underestimate the amount of work potential higher capital charges and
needed to implement these measures, adjust their business models accordingly.
especially the steps related to identifying
13
Conclusion
Numerous studies and analysis indicate We believe insurers should keep a
that traditional insurance activities are close eye on the wide package of IAIS
not a major source of systemic risk.21 Such measures. The development of this
risks come mainly from NTNI activities comprehensive framework of reforms
or as a result of interconnectedness involves more than just capital; it is
with other institutions. under way and may affect each insurer—
whether a G-SII, an IAIG, a domestic
Our understanding of the underlying systematically important insurer (D-SII),
intentions of regulators and or one to be. The borders defining these
global leaders is: to discourage the categories are not yet clearly defined
development of NTNI activities and and could change based on current
interconnectedness by applying higher developments. Even an institution’s
capital charges; to minimize the impacts growing activity levels, expanding
of failure by developing effective international footprint and foray into
resolution plans; and to specifically new businesses could make it eligible for
oversee systemic institutions. However a G-SII and, or IAIG designation. We also
the G-SII initiative is only one part of expect important increases in the level of
a global framework with the overall insurance supervision across the globe,
goal of defining an insurance capital thus impacting institutions across regions.
standard which could be applied to
the entire global insurance industry.
14
Notes
1. G-SIFIs are defined by the Financial 6. “Insurance Core Principles, 13. “Basic Capital Requirements forn
Stability Board as “institutions Standards, Guidance and Assessment Global Systemically Important
of such size, market importance, Methodology,” International Association Insurers,” International Association
and global interconnectedness of Insurance Supervisors, October 1, of Insurance Supervisors, October
that their distress or failure would 2011, revised October 19, 2013. Access 23, 2014. Access at: http://j7.agefi.
cause significant dislocation in the at: http://iaisweb.org/modules/icp/ fr/documents/liens/201410/24-
global financial system and adverse assets/files/Insurance_Core_Principles__ YVSQBZCIUQXEXMN.pdf
economic consequences across a Standards__Guidance_and_Assessment_
range of countries.” G-SIIs are one Methodology__October_2011__ 14. Ibid
class of G-SIFIs. For more information revised_October_2013_.pdf.pdf
15. “Global Systemically Important
see “Global Systemically Important
7. “Common Framework for the Insurers: Policy Measures,”
Insurers: Policy Measures,” International
Supervision of Internationally Active International Association of
Association of Insurance Supervisors,
Insurance Groups,” International Insurance Supervisors, July 18, 2013.
July 18, 2013. Access at: http://www.
Association of Insurance Supervisors, Access at: http://iaisweb.org/index.
fsa.go.jp/inter/iai/20130719/04.pdf
Revised DRAFT, September 2014. cfm?event=openFile&nodeId=34256
2. “Global systemically important insurers Access at: http://iaisweb.org/index.
16. “Frequently Asked Questions
(G-SIIs) and the policy measures cfm?event=openFile&nodeId=34519
for IAIS Financial Stability and
that will apply to them,” Financial
8. “10th Annual Insurance Public Macroprudential Policy and Surveillance
Stability Board, July 18, 2013. Access
Policy Summit, Confronting New (MPS) Activities,” International
at: http://www.financialstabilityboard.
Challenges in U.S. and International Association of Insurance Supervisors,
org/wp-content/uploads/r_130718.
Regulation,” Andrés Portilla, Institute Updated December 17, 2014.
pdf?page_moved=1. “2014 update of
of International Finance, March 12, Access at: http://iaisweb.org/index.
list of global systemically important
2014. Access at: http://indstate.edu/ cfm?event=openFile&nodeId=41690
insurers (G-SIIs),” Financial Stability
Board, November 6, 2014. Access at: business/NFI/events/10AIPPS/docs/
17. “Basic Capital Requirements for Global
http://www.financialstabilityboard.org/ Insurance%20Portilla%20IIF.pptx
Systemically Important Insurers,”
wp-content/uploads/r_141106a.pdf International Association of Insurance
9. “Risk-based Global Insurance Capital
Standard,” International Association Supervisors, October 23, 2014.
3. The International Association of
of Insurance Supervisors, Public Access at: http://iaisweb.org/index.
Insurance Supervisors (IAIS) is
Consultation Document, December cfm?event=openFile&nodeId=34540
responsible for developing the
assessment methodology while the 17, 2014. Access at: https://actuary-
18. Ibid
Financial Stability Board FSB is pl.s3.amazonaws.com/Risk-based_
responsible for designating the G-SIIs Global_Insurance_Capital_Standard_ 19. “IAIS Releases Global Systemically
based upon the IAIS methodology. Consultation_Document.pdf1.pdf?AWSA Important Insurers Assessment
ccessKeyId=AKIAIOW3KDG2CZARXGMA Methodology and Policy Measures,
4. “Global Systemically Important Insurers: &Expires=1433383943&Signature=SUF Macroprudential Policy and
Initial Assessment Methodology,” X%2BYpGyQlkTGF3YjAgWwU2Vnw%3D Surveillance Framework,” International
International Association of Association of Insurance Supervisors,
Insurance Supervisors, July 18, 10. Ibid
newsletter. Access at: http://
2013. Access at: https://www.lloyds. newsletter.iaisweb.org/newsletterlink-
11. “Common Framework for the
com/~/media/files/the%20market/ 381?newsid=1087&call=1
Supervision of Internationally Active
operating%20at%20lloyds/regulation/
Insurance Groups,” International
gpa/final_initial_assessment_ 20. “Aviva and Allianz CEOs criticise
Association of Insurance Supervisors,
methodology_18_july_2013.pdf ‘regulatory tsunami’,” Insurance
Revised DRAFT, September 2014.
ERM, February 28, 2014. Access at:
5. “Frequently Asked Questions for the IAIS Access at: http://iaisweb.org/index.
https://www.insuranceerm.com/news-
Common Framework for the Supervision cfm?event=openFile&nodeId=34519
comment/aviva-and-allianz-ceos-
of Internationally Active Insurance criticise-regulatory-tsunami.html
12. “Global Systemically Important
Groups (ComFrame),” International
Insurers: Policy Measures,”
Association of Insurance Supervisors, 21. “Insurance and Financial Stability,”
International Association of
Updated December 17, 2014. International Association of Insurance
Insurance Supervisors, July 18, 2013.
Access at: http://iaisweb.org/index. Supervisors, November 2011. Access at:
Access at: http://iaisweb.org/index.
cfm?event=openFile&nodeId=41664 http://forinsurer.com/files/file00400.pdf
cfm?event=openFile&nodeId=34256
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