IFRS insurance project Implementation issues for U.S. property/ casualty insurers. Ralph Blanchard

Transcription

1 IFRS insurance project Implementation issues for U.S. property/ casualty insurers Ralph Blanchard 1

2 Outline Current situation Accounting standard setters Accounting rules Market environment Experience with Fair value Discounting Future US GAAP closing the books Future US Statutory 2

3 Current situation U.S. Accounting Standard setters US GAAP Set by FASB Overlaid by SEC rules (SEC registrants only) Disclosure somewhat generic, free-form Focus is on investors US Statutory (regulator accounting) Set by state regulators (jointly NAIC) Overlaid by state laws (legislators) NAIC considers for adoption all FASB changes Extensive public disclosure Focus is on solvency 3

4 Current situation U.S. Insurance Accounting rules-1 For insurance contracts, US GAAP virtually identical to US Statutory few exceptions Pre-claims earned premium approach also known as unearned premium approach 4

5 Current situation U.S. Insurance Accounting rules-2 Post-claims (i.e., claim liability) undiscounted unbiased supposedly expected value (conceptual mean) current estimates Limited exceptions (e.g., tabular claims) 5

6 Current situation U.S. Insurance Accounting rules-3 Due to extensive disclosure, many (stock analysts, rating agencies) make their own adjustments for: Possible bias Time value, Market value (at least for rating agencies) 6

7 U.S. Market Environment-1 Very diverse insurance orgs. (2,402 cos.) 60% stock, 33% mutual, 7% other (e.g., reciprocals) Large companies and small companies 1 with over US$48B in annual premium 156 with between US$10K and $100K annual premium Countrywide cos. and regional cos. Personal lines vs. Commercial lines vs. Specialty vs. Reinsurance (few write all lines). Data sources: year-end 2008 data from Bests Aggregates & Averages and SNL Financial 7

8 U.S. Market Environment-2 Very diverse products Some very short tail, Some very long tail Auto (Motor) Physical Damage Loss reserves 8% of 2008 NWP Products Liability Occurrence Loss reserves over 6 times 2008 NWP Little market concentration for most products Personal Auto Liability biggest has 19% share 157 orgs over US$15M (2008 NWP) Comm l Auto Liability biggest has 9% share 129 orgs over US$10M (2008 NWP) 8

9 U.S. experience - fair value claim liabilities - 1 Two places where fair value has to be estimated: 1. Purchase accounting under US GAAP 2. Tax accounting for transactions with (overseas) affiliates Both involve fair value estimates at one point in time, not subsequent re-measurement Purchase Accounting diff. between fair value and normal value is amortized not clear if anyone uses this information. Tax Accounting fair value only the transaction price, not the subsequent balance sheet. 9

10 U.S. experience - fair value claim liabilities - 2 Purchase Accounting unit of account Have to calculate by reporting segment Probably want to calculate one level below No need to calculate at more detailed level Top side calculation? Both may be estimated using Cost of Capital approaches 10

11 U.S. experience - discounted claim liabilities - 1 US Statutory Tabular Tabular reserves are indemnity reserves that are calculated using discounts determined with reference to actuarial tables which incorporate interest and contingencies such as mortality, remarriage, inflation or recovery from disability applied to a reasonably determinable payment stream. Tabular reserves shall not include medical loss reserves or loss adjustment expense reserves. Essentially, only annuity-like liabilities Fixed interest rate (not current rates) Non-tabular Rare reversed for RBC requirements Most common Financial Guaranty 11

12 U.S. experience - discounted claim liabilities - 2 US GAAP (SEC) Fixed and determinable payments Plus, whatever Statutory accounting allows Fixed interest rate if you change the rate, you must restate Even if rule is to use current rates COULDN T SWITCH TO MARKET YIELDS WITHOUT SEC RULE CHANGE. 12

13 Future US GAAP Prop/Cas insurance Pre-claims Earned Premium approach Post-claims Discounted, probably with risk adjustment Acquisition costs? (if not allowed, GAAP=Stat.) Only change might be in claim liabilities (and maybe presentation) 13

14 Future US GAAP Closing the Books-1 Time frames are tight Announce earnings usually within 30 days Report due within 35 days (qtr-end) to 60 days (yr-end) Liabilities built up from many pieces Can be over 1,000 review lines big firm Even small firm can have dozens of lines Only have about 7 days to close the books Not enough time for in-depth analysis. Must rely on lock-ins, roll-forwards 14

15 Future US GAAP Closing the Books-2 Discounting has 3 pieces 1. How much Roll forward prior estimate. Review some pieces quarterly, some annually 2. When Estimate payment pattern separately from how much Change infrequently a soft lock-in? 3. Time value of money Least difficult task is US yield curve Update each quarter 15

16 Future US GAAP Closing the Books-3 Risk Adjustment Not observable, not runoff testable Highly judgmental Easiest approach may be using pricing models IRR pricing models already have Amount of capital assumption Cost of capital assumption Whatever approach likely lock-in Need to justify any change to external auditors (& SEC) How can you justify a change to what you couldn t see in the first place? 16

17 Future US GAAP Closing the Books-4 Unit of account for discount and risk adjustment One level below reporting segment? May not need to do at a lower level May be able to do as a top-side adjustment BUT IS IT ALL WORTH IT? Maybe not. Definitely not for short tail. Maybe for long tail. 17

18 Future US Statutory US regulators (NAIC) looking at Solvency II, IFRS, FASB proposals Strong anti-discount sentiment for P&C liabilities below state insurance commissioner level (not universal). Possible that US Statutory will not change If so, no impact on many mutuals, non-stocks. 18

19 Contact details Ralph S. Blanchard, III FCAS, MAAA The Travelers Companies, Inc. One Tower Square Hartford, CT