Insurance - Life /Annuity

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1 NORTH AMERICA Morgan Stanley & Co. LLC Nigel Dally Hayley Locker, CFA Industry View In-Line Assessing Who is at Risk of Higher Required Life Reserves Under AG38 Regulators are looking at potentially changing reserving requirements for some life insurance policies, which may result in a large increase in reserves for some players. Based on our review, Lincoln, Manulife and Genworth are the companies that appear most at risk. What are the changes? The National Association of Insurance Commissions (NAIC) is in the process of updating the reserving requirements for various secondary guarantee universal life policies that fall under Actuarial Guideline 38. For policies with variable cost of insurance charges, this could result in a substantial increase in the amount of required reserves, especially if the NAIC decides on retrospective application and uses an early look-back date. Reserves at Risk to Potential Changes in AG38 YE 2011 Reserves as % Equity ex-aoci 350 Total Interest-Sensitive 300 Other Interest-Sensitive 250 AG38 Impacted LNC MFC GNW PFG HIG Source: Statutory Filings How much would required reserves increase? The impact on required reserves varies significantly depending on product design, although some industry experts believe the level of reserves could increase as much as two to seven times their current level. Which companies are potentially at risk? Lincoln, Manulife and Genworth are companies that appear to have the most secondary guarantee life insurance policies in force. Principal and Hartford also highlight this as a potential risk in their recent financial statements. Implications: The charge to reserves would be a hit to the statutory capital and negatively impact risk-based capital ratios. Large charges could potentially diminish available capital for other purposes including dividends and stock repurchases. To avoid these charges, we suspect various companies may look to increase the use of captive reinsurance, although as we have discussed in recent research ( Fed Actions Suggest Limited Capital Maneuverability, dated June 28, 2012), the capacity to use these vehicles could be limited. Morgan Stanley does and seeks to do business with companies covered in Morgan Stanley Research. As a result, investors should be aware that the firm may have a conflict of interest that could affect the objectivity of Morgan Stanley Research. Investors should consider Morgan Stanley Research as only a single factor in making their investment decision. For analyst certification and other important disclosures, refer to the Disclosure Section, located at the end of this report.

2 Investment Case Summary & Conclusions We view the proposed changes to reserving for various types of life insurance policies to be a meaningful risk factor that deserves close attention for several companies in the industry. While most domestic US life companies have been downplaying the risk, there is the potential that some of the changes in how reserves are calculated for secondary guarantee universal life policies could have a meaningful impact on capital if the changes were to be applied retroactively. Manulife has already warned this could have a material impact on the statutory capital position of their US subsidiary, John Hancock, while our work suggests other companies including Lincoln and Genworth could also be impacted. Types of Products Could Potentially be Impacted The key issue surrounds the level of reserves that companies are establishing against universal life insurance policies with second guarantees (SGUL see text box for additional explanation). For these products, the amount charged for the insurance coverage (the cost of insurance or COI) can vary depending on factors including the balance of funds in the shadow accounts. In calculating the required reserves, it appears some companies have been using the highest potential COI charges. This results in lower reserves, even though the probability of these higher charges being applied is relatively low. This ultimately leads to significantly lower reserves than if the more conservative charges had been used. While the potential for the use of higher assumed premium charges exists for all products with secondary guarantees that have variable insurance charges, the issue has become increasingly important as various companies have been coming out with products such as Term UL. These products are designed to have little to no cash build up. Many of these policies are being marketed as a direct comparison to traditional term insurance, leading some regulators to be concerned that the only reason they are written on a universal life chassis is to avoid/mitigate various reserving requirements. Essentially by using the higher assumed policy charges in calculating reserves, there is concern among some regulators that companies may be establishing reserves below what was originally intended by the NAIC Valuation of Life Insurance Policies Model Regulation. Accordingly, the Life Actuarial Task Force has been investigating this issue, with the goal of introducing new rules effective January 1, Universal Life Basics How a Regular UL Policy Works: With a regular universal life policy, policyholders pay premiums typically monthly, with the excess of premium payments above the current cost of insurance credited to the cash value of the policy. The cash value is credited each month with interest, and the policy is debited each month by a cost of insurance (COI) charge, as well as any other policy charges and fees, even if no premium payment is made that month. Interest credited to the account is determined by the insurer, but has a contractual minimum rate of between 2% and 4%. The policy lapses if no premiums are paid and the cash value of the policy falls to zero. How a Secondary Guarantee UL Policy Works: Under a non-lapse guarantee policy, as long as certain minimum premium payments are made for a given period, the policy will remain in force for the guarantee period even if the cash value drops to zero. This essentially makes the policy significantly more interest sensitive as the probably of the cash value declining to zero increases as the crediting rate on the cash value declines. What is a Shadow Account? A shadow account is a phantom account value, which is established with more generous assumptions. On some products, there may be multiple shadow accounts related to different policy years. Shadow accounts use unique credited rates, cost of insurance factors and loads. Essentially it is a guarantee to policyholders that regardless of what has happened with their true cash accounts, if their phantom accounts that use more favorable charges and higher crediting balances still have funds, the policy will remain in-force. The issue with multiple Cost of Insurance Charges: With many of the SGUL policies, the cost of insurance charged to the consumer will vary based on the balance of funds in the shadow accounts. This raises the question as to which minimum cost of insurance charges to use in determining the appropriate level of reserves. In many cases, insurers have been using the higher cost of insurance charges, which they believe is in accordance with the rules. However, these rules are likely to be changed, not only for new policies, but also for potentially for various in-force policies depending on the date chosen as the effective look-back effective date. The impact on required reserves could be substantial. Based on a article published by KPMG in the January issue of their Life Actuarial Insights, the required reserves if the insurers are forced to use the lower policy charges could rise by as much as two to seven times. Further, as most of the additional reserves would fall into the deficiency reserve category, which typically is not tax deductable, meaning there would be no tax offset to the higher reserve requirements. 2

3 To date, many of the insurers have downplayed the issue, reflecting their optimism that any proposed rule changes would likely only be applied on a prospective basis, similar to what we have seen on other recently adopted changes in accounting. However, recent developments seem to suggest retrospective adoption is becoming increasingly likely. According to the latest proposals, the regulators now appear to be considering one of three potential look back effective dates January 1, 2003, July 1, 2005, and January 1, It comes as little surprise that companies have been pushing for the latest possible look back date. Lincoln Financial, in a letter dated August 3, 2012, urged regulators to use 2007 as the effective look back date, or 2005 as a reasonable compromise. Based on their comments, they are concerned the earlier look back issue would be very problematic, stating it is a much more significant issue when these assumptions are applied retroactively to existing business that cannot be re-priced. Other regulators, such as the New York State Department of Financial Services, prefer the earlier adoption date of January 1, 2003, as per their comment letter dated August 2, Assessing Who Is Potentially at Risk To assess who is potentially at risk, we have examined exposures both from a qualitative and quantitative perspective. First, from a qualitative perspective, we reviewed the various 10Ks and 10Qs to determine whether universal life reserving practices have been raised as a risk factor. We have also looked to see whether the companies have provided a comment letter to the NAIC, which could also be a sign that the company views the outcome of the rule changes as potentially a risk to their financial position. The results of this first screen are shown in Exhibit 1. Among the various companies we follow, Genworth, Hartford, Lincoln, Manulife and Principal have highlighted the issue as a risk factor in their recent SEC filings. Lincoln, Genworth and Principal also provided comment letters on the proposed changes to the Life and Annuity working committee working on AG38. Further, we followed up with the individual companies to learn more about their reserving practices, in order to determine if they were potentially at risk. What we learned in doing so, was that while several companies do actively write UL policies, their reserving is not based on the use of multiple shadow accounts and they do not use the higher COI assumption when setting their reserves, and therefore they would not expect to be impacted by any changes in the actuarial guidelines. Such companies included MetLife and Prudential. Other companies, including CNO Financial, write more basic universal life policies, which would also not be impacted by any change in the regulations. Exhibit 1 Which Companies have Highlighted AG38 as a Risk Highlighted in Comment 10K and Qs as Risk Lettter to NAIC Aflac Ameriprise CNO Financial Genwort h Hartford Lincoln MetLife Manulife Principal Prudent ial RGA St ancorp Sun Life Financial Torchmark Unum Group Source: Company Data, Morgan Stanley Research Second, we looked to gauge each company s exposure to secondary guarantee universal life policies. The results of our analysis are shown on Exhibit 2. Unfortunately not all companies provide details of their secondary guarantee reserves. Accordingly, we show the break-down between traditional and secondary guarantee interest sensitive reserves where available, and total interest sensitive reserves for those companies who do not provide the split. What we found is that companies with larger balances of secondary guarantee relative to equity (excluding FAS115) include Genworth and Lincoln. While Manulife also has a relatively higher exposure to interest-sensitive individual life insurance reserves, given limited disclosures, it remains unclear what portion is actually falls under AG38. 3

4 Exhibit 2 Interest-Sensitive Individual Life Reserves Exhibit 3 Cumulative UL Sales Since 2003 YE 2011 Reserves as % Equity ex-aoci Total Interest-Sensitive Other Interest-Sensitive AG38 Impacted LNC MFC GNW PFG HIG VUL/ UL Sales ($B) YTD LNC MFC PFG GNW HIG *PFG AG38 impacted estimated based on management comments that 50% of SGUL in-force will potentially be impacted by changes to regulations Source: Statutory Filings, Morgan Stanley Research Last, we also looked at the amount of universal life sales made by each company expected to be impacted since 2003, which is the earliest expected look-back date. As previously discussed, not all universal life insurance will be impacted by the changes. Nonetheless, it provides some perspective into who has written more recent vintage business that potentially could be impacted by the rule changes. The results are shown in Exhibit 3. Among the various companies, Lincoln, Principal and Manulife stand out as having sold a significant amount of UL policies. A significant portion of Lincoln s sales (roughly a third) occurred in the time frame of , which potentially explains why the compact is pushing regulators to chose a later look-back effective date. Based on company disclosures, it appears that roughly 35-40% of these universal life sales contained secondary guarantees, making them more likely to be at risk from any changes in the guidelines. Similarly, we would expect only a portion of the sales of the other companies shown would be impacted if the changes were to be adopted retrospectively. Specifically, Genworth would most likely to see the greatest impact on its term-universal life business, which it began selling in 2010, and through the second quarter of 2012 accounted for $291 million of their total universal life sales. Likewise, Principal only began selling products it expects may be impacted in According to the company, of the roughly $35 billion of secondary-guarantee universal life currently in-force, approximately 50% is reserved using the methodology currently in question. HIG includes whole life sales; Source: Company Data, Morgan Stanley Research In aggregate, the results of our analysis suggest that among the companies we follow, Lincoln, Manulife and Genworth are the company s potentially most at risk from the proposed changes. Genworth in particular has been a large seller of Term UL policies, while Lincoln is one of the larger players in the secondary guarantee universal life space. Lincoln is better positioned to absorb any potential changes to their required reserves, given a robust current RBC ratio of roughly 500%. For Genworth, while their RBC ratio is solid at 405%, the company also has significant long term care exposure, where we remain concerned over reserve adequacy. For Manulife, any charges would not impact their primary Canadian MCCSR ratio, but would likely results in the reallocation of capital from Canada to the US. Implications From our perspective, we see three implications of these pending changes: 1. Increased use of captive insurers: First, we believe insurers will look towards means in which to avoid any charges. This potentially could include greater use of both external and internal captive reinsurance relationships. In a captive reinsurer, reserves are established under a modified GAAP accounting method, and accordingly we do not believe they would be subject to the potential rule changes. The problem, however, is that the ability to rely on these alternatives may be limited. As we discussed in our earlier research piece Fed Actions Suggest Limited Capital Maneuverability, dated June 28, 2012, insurers 4

5 have already been significantly increasing the use of captive insurance relationships, while the capacity of banks and others to finance these relationships through letters of credit has become more restrictive. 2. Statutory capital hits impacting capital management: Second, to the extent the insurers cannot avoid the increased reserve requirement due to the retroactive application of the new rules, they will need to increase current reserves, potentially leading to large hits to their statutory capital positions. Arriving at a precise impact is challenging given the very limited disclosures regarding the exposure of each companies to the various products that could be impacted. That said, any reserve charges would directly impact their statutory surplus and limit their flexibility to make dividends to the parent company, potentially negatively impacting various capital management alternatives, including share repurchases. 3. Changes in future product design: Regardless of whether the changes are prospective or retroactive in nature, the higher reserve requirements will likely spur another round of product redesign and/or price increases. While this would be an industry-wide issue, we could likely see an outsized negative impact on sales prospects for those companies whose recent sales have been dominated by these types of policies, including Lincoln and Genworth. We would expect sales at Manulife to be less impacted given the company has already de-emphasized this product in the US. Accordingly, at a minimum, we believe the issue has emerged as a risk factor that deserves close attention for the industry. While most companies currently have robust capital ratio that suggest ample room to absorb some level of charges, the developments nonetheless add a level of risk around capital management flexibility, depending on the rules ultimately determined by the NAIC and state regulators. 5

6 Exhibit 4 Life Insurance Valuation Summary Price ($) Mkt Cap Operating EPS P/ E Ratio Book Value ex-aoci Price to Book ex-aoci ROE (%) Ticker Rating 14-Aug ($M) E 2013E E 2013E E 2013E E 2013E E 2013E AFL E , AMP E , CNO E , GNW E , NM HIG E , LNC E , MET O , MFC E , NM NM PFG U , PRU O , RGA O , SFG E , SLF E , NM TMK U , UNM E , NM Source: Company Data, Morgan Stanley Research 6

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11 The Americas 1585 Broadway New York, NY United States Tel: +1 (1) Europe 20 Bank Street, Canary Wharf London E14 4AD United Kingdom Tel: +44 (0) Japan Ebisu, Shibuya-ku Tokyo Japan Tel: +81 (0) Asia/Pacific 1 Austin Road West Kowloon Hong Kong Tel: Industry Coverage:Insurance - Life/Annuity Company (Ticker) Rating (as of)price* (08/14/2012) Nigel Dally Aflac (AFL.N) E (05/27/2011) $45.23 Ameriprise Financial, Inc. (AMP.N) E (10/06/2005) $54.34 Genworth Financial, Inc. (GNW.N) E (11/12/2010) $4.89 Hartford Fin. Services Grp. (HIG.N) E (02/08/2012) $17.28 Lincoln National Corp (LNC.N) E (01/28/2011) $23.59 MetLife Inc. (MET.N) O (03/03/2011) $34.98 Principal Financial Group (PFG.N) U (11/09/2011) $26.37 Prudential Financial (PRU.N) O (05/10/2012) $53.54 Reinsurance Group of America O (11/12/2010) $56.05 (RGA.N) StanCorp Financial Group (SFG.N) E (08/09/2012) $30.18 Torchmark Corp. (TMK.N) U (07/13/2006) $50.32 Unum Group (UNM.N) E (02/17/2010) $19.4 Hayley Locker, CFA CNO Financial Group Inc. (CNO.N) E (01/24/2011) $8.81 Manulife Financial Corp. (MFC.TO) E (05/25/2012) C$11.36 Primerica, Inc. (PRI.N) E (09/08/2010) $28.88 Sun Life Financial Inc. (SLF.TO) E (05/25/2012) C$22.53 Stock Ratings are subject to change. Please see latest research for each company. * Historical prices are not split adjusted Morgan Stanley