Proposal to Modify Existing Statutory Regulation for In-Force Synthetic GIC Business
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1 Proposal to Modify Existing Statutory Regulation for In-Force Synthetic GIC Business Tina Kennedy, FSA, MAAA Member, American Academy of Actuaries Annuity Reserves Work Group Chairperson, Deposit Fund Subgroup of ARWG November 27-28, 2012 All Rights Reserved.
2 What is a Synthetic GIC? Participating contract designed to transfer most risk to plan participants through the crediting rate formula The product was developed in the mid-1990s in response to plan sponsor concerns regarding ownership of assets Synthetic GIC is a group annuity contract or other agreement that establishes the insurer s obligations by reference to a segregated portfolio of assets that is not owned by the insurer Investment guidelines typically control the types, allocations, maturities/durations, and quality of assets allowed in the segregated portfolio The insurer provides a book value withdrawal guarantee for most participantinitiated payments Claims occur only after all the market value of the segregated portfolio is exhausted Typically an evergreen contract with no stated maturity date; however, the segregated portfolio of assets is generally managed to a target duration All Rights Reserved. 2
3 Existing Regulation and Issues Existing Statutory Regulation NAIC Synthetic Guaranteed Investment Contract Model Regulation Reserve equals excess, if any, of (1) PV of guaranteed benefits using spot rate supportable by the expected return from segregated portfolio but not greater than 105% of the treasury spot rate over (2) market value of assets less deductions Partial reproduction in Appendix A-695 of the NAIC APPM NY Regulation 128 CT Regulation 38a-459 Some states have a percentage of premium accumulation as the reserve Issues Reserves increased significantly at year-end 2008 due to low Treasury rates and high spreads on investment grade corporate bonds Temporary relief granted by some states Need for a permanent solution within the statutory framework All Rights Reserved. 3
4 Synthetic GIC Proposed Changes to Statutory Valuation Methodology Determination of the Discount Rate Substitute 50% Treasury-based spot rate plus 50% corporate bond index spot rate for 105% of the Treasury spot rate Corporate bond index combines two indices Barclays Short Term Corporate Index (less than 1 year to maturity) Barclays U.S. Corporate Investment Grade Bond Index (greater than 1 year to maturity) Deduction to the market value of assets Eliminate the deduction provided Asset default risk borne by the plan participants Transfer of risk reflected in contractual provisions No change to the deduction if: Asset default risk borne by the insurance company All Rights Reserved. 4
5 Selection of Corporate Bond Index Selection of Corporate Bond Index Corporate Bond Index Requirements Should be widely used in practice Investment grade corporate bonds; no treasuries Barclays US Corporate Bond Index Widely used in portfolio management Commonly used as a component of the benchmark for the asset portfolio supporting Synthetic GICs Provides more reference rates across maturity spectrum than alternative indices Barclays also offers a short-term index; important since corporate bond indices have a minimum one-year-to-maturity requirement All Rights Reserved. 5
6 Blending of Corporate Bond Index and Treasury Rates Blending of Corporate Bond Index and Treasury rates Principles from general account valuation Consider plan type and guarantee duration Barclays historical spread decomposition for the U.S. Corporate Investment Grade Bond Index Components of investment spread include default cost, risk premium and liquidity cost For the period Jan 2007 through May 2012, the average default cost as a percent of the total investment spread is 46% (Barclays) Review of historical Treasury rates and bond index rates All Rights Reserved. 6
7 Historical Comparison of 50/50 Blend and 105% Treasury The 50/50 blend accommodates historical and recent financial market environments All Rights Reserved. 7
8 Impact to Reserve Based on Sample Contract and Assumptions Proposal lowers reserves on historical valuation dates when Treasury rates are low and credit spreads are relatively wide Due to PV of guaranteed contract benefits responding to changes in market conditions to a greater degree than in existing regulation Proposal generates similar reserve patterns with respect to assumptions; reserves increase as MV/BV ratio deteriorates Current crediting rates increase Duration shortens (lower discounting rate, shorter discounting time) All Rights Reserved. 8
9 Key Aspects of Synthetic GIC Proposal Retains consistency with solvency focus of statutory regulation Objective Conservative Allows for a more consistent liability valuation with the underlying assets Recognizes that most risks are retained by the plan participants Aligns asset deductions with AVR requirements for separate accounts All Rights Reserved. 9
10 Questions? ARWG, Deposit Fund Subgroup Chair - Tina Kennedy, FSA, MAAA Or Contact John Meetz, Life Policy Analyst, American Academy of Actuaries (meetz@actuary.org) All Rights Reserved. 10
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