Title: RiskBased Solvency Requirements
1Risk-Based Solvency Requirements
- Hansjörg Furrer, Swiss LifeConference in Recent
Developments in Financial and Insurance
Mathematics and the Interplay with the Industry - Oberwolfach, 18-24 February 2007
2Agenda - Overview
- 1. From Solvency 0 to Solvency II
- Standard models and internal models
- Risk measurement in a multi-period framework
- Conclusions
3Agenda - Overview
- 1. From Solvency 0 to Solvency II
- Standard models and internal models
- Risk measurement in a multi-period framework
- Conclusions
4What is Solvency?
- Solvency
- the ability of an insurer to fullfil its
obligations under all insurance contracts under
all reasonable foreseeable circumstances - How to meet this requirement?
- insurers establish over and above the technical
provisions a buffer of freely available capital
against adverse business fluctuations to meet
their underwriting liabilities - Question size of the buffer? time horizon?
5Solvency in Europe Solvency 0
- 1973 / 1979 publication of the first non-life
and life directives of the EEC (European Economic
Community) - mainly based on the work by Campagne 5
- Campagne recognizes that
- Investment risk is the most important risk for a
life company - Technical provisions are the most important
invested amount - Solvency margin as a percentage of the technical
provisions - the more prudent a company is, the more it has
to pay for the solvency
6Required solvency margin
- Required solvency margin for life companies (EEC,
1979) - 1st Result 4 of the mathematical reserves (?
investment risk)2nd Result 3 capital at risk
(? technical risk) - Early warning signal, based on fixed ratios
(wind-up barrier guarantee fund ? 1/3 of the
solvency requirement) - Rationale for the 4 solvency margin figure?
7Pearson type-IV distribution
The Solvency I capital requirement (required
solvency margin) is defined via the ?-quantile
(one-year VaR) of the loss ratio distribution,
where the loss ratio X is defined as
Here L denotes the one-year loss and R the
technical provisions. Campagne 5 assumed that X
has a Pearson type-IV distribution
The required solvency margin qa is thus given by
Density function of the Pearson type-IV
distribution with parameters
For the data that were used, this led to qa 4
(a 95).
8Solvency in Europe Solvency I
- 1992 2nd and later 3rd directive solvency
margins left unchanged - 1994 Insurance Committee asks the European
supervisory authorities (from 2004 CEIOPS) to
establish a working group to investigate solvency
issues - Chair of the group Helmut Müller (BAV,
Bundesaufsichtsamt für das Versicherungswesen) - 1997 presentation of the Müller Report 8
- current solvency margin structure satisfactory
- amount of the minimum guarantee fund needs to be
increased (inflation) - identification of three risk groups (technical,
investment, non-technical) - 2000 Based on the Müller Report and further
preparatory work, new life and non-life
directives were proposed - 2002 New life and non-life directives were
adopted by the European Parliament
Solvency I directives
9The Solvency I Life Directive
- Approved in March 2002
- Set into force as of Jan 2004
Timeline
- Available solvency margin covering the technical
provisions must be of good quality - Guarantee fund may not be less than a minimum of
EUR 3m - Solvency requirements for unit-linked contracts
Requirements
- Simple, robust
- easy to understand and use
- inexpensive to administer
- rule-based, and not explicitly risk-based (e.g.
differences between asset and liability profiles
are neglected)
Characteristics
- have worked well over the years
- have significantly increased the protection of
the policyholders - BUT Since the creation of these rules,
significant changes have taken place in the
insurance industry need to adapt the rules
Experience
10Life insurance environment since the 90ies
In 1980 the life insurance industry was 150
years old, in 2000 it was 20 years old
- Equity markets experienced a strong bull run from
1996-2000 - severe underwriting losses could be disguised
- Equity and corporate bond markets suffered falls
in 2001-2002 - Interest rates stabilized on a low level
- problems with (high) guaranteed returns
- Increasing life expectancy / costs
- More frequent extremes / catastrophes (e.g.
09/11, Tsunami)
11Solvency in Europe towards Solvency II
- 1999 At a meeting of the Insurance Committee
(IC) it was agreed that a more fundamental review
of the overall financial position of an insurance
company should be done. This review should
include previously neglected risk classes (e.g.
ALM risk, OpRisk,) - 1999 Solvency II project was named for the first
time in a paper entitled The Review of the
Overall Financial Position of an Insurance
Undertaking (Solvency II Review). Aspects
mentioned - Technical provisions (non-life) - Reinsurance
- Asset / investment risk - Solvency margins
(reflecting the true risks) - ALM - Accounting systems
- 2001 Launch of the Solvency II project by the
European Commission (EC) - CEIOPS was asked to provide input and
recommendations
12The three phases of the Solvency II project
13Phase 1
KPMG Report, Sharma Report
- KPMG Report 7 criticizes that even though
assets, provisions and solvency margins are
connected, firm-specific risks are not explicitly
taken into account - CEIOPS set up a working group of insurance
supervisors, known as LWG (London Working Group)
as it was chaired by Paul Sharma from the FSA - 2002 Publication of the Sharma Report 10
- Risk classification and causal chain mapping
- Survey on actual failures and near misses from
1996-2001 - Discussion of 21 case studies in 17 European
countries - in each case, the causal chain began with
underlying internal causes (e.g. incompetence,
operating outside area of expertise, inadequate
internal controls etc.)
14Current Status of the Solvency II Project
- February 2007 Solvency II Framework Directive at
a drafting phase - to be published in July 2007
- Based on the various answers on the Calls for
Advice that took place between 2004-2006 - During the same time period, CEIOPS Quantitative
Impact Studies QIS (three so far, more to come?)
provided insight mainly into the Pillar 1
standards - July 2007 Publication of the draft Solvency II
Directive - Political decision making process commences in
the European Parliament and European Council of
Ministers
15Objective of Solvency II
Securing the benefits of the policyholders
- Note this does not necessarily require the
continued existence of a company. Zero-failure
will not be the aim of prudential supervisory
systems. In a free market, failures will occur!
16Agenda - Overview
- 1. From Solvency 0 to Solvency II
- Standard models and internal models
- Risk measurement in a multi-period framework
- Conclusions
17European standard models (1/2)
From formula to spreadsheet solutions
- Major risk categories
- Market - Credit
- Insurance - Operational
- Most of these main risks can be subdivided
- into sub-risks (e.g. insurance risk into
- u/w risk, mortality risk, sickness risk,
- surrender or lapse risk, and expense risk)
- Notation Capital requirement for each risk
category - Market, insurance and credit risk are measured in
the following way - For OpRisk, the Basel II Standardized Approach is
being used
18European standard models (2/2)
From formula to spreadsheet solutions
- Depending on the correlations used (usually 1 for
high correlation and 0 for low correlation),
the solvency capital requirements result in
factor-based formulae like the following - Quantitative impact studies (QIS) serve to
calibrate data from different countries
Insurance risk
Credit risk
19The Swiss Solvency Test
- Definition The SST is a principle-based
framework aiming to assess an insurance companys
financial soundness in order to ensure the
fulfillment of its (long-term) obligations
towards the policyholders by taking into account
the true risks the company is exposed to - Risks entering the capital requirement
- market
- insurance
- credit
- emanating during a one-year time horizon
- Note OpRisk does not enter the SST capital
requirement!
20Timeline of the SST development
Market crash, deterioration of insurers solvency
H Lüthy becomes new director of FOPI,
reorientation to prudential supervision
2003
Start of Swiss Solvency Test project Mai 2003
with participation of industry, actuarial and
insurance association, consulting companies and
others, conceptual work finished end of 2003
2004
Field test 2004 with 10 insurers, supported by
consulting companies
2005
Further development underway on requirements on
internal models, group effects and intervention
levels
Field test 2005 with 45 insurers covering
approximately 90 of the market
2006
- Insurance supervision act implemented 01/01/2006
Field test 2006, mandatory for all large life
nonlife companies
Small companies, reinsurers and groups prepare
for full SST calculations in 2008
2007
Field test 2007, mandatory for all large life
nonlife companies
2008
As of 2008 all companies have to implement the
SST, and as of 201, target capital requirement
will be in force
21SST and Solvency II timelines in comparison
SST
- Phase III
- Implementing phase
- New insurance supervision act AVO set into force
on 01/01/2006 - SST for groups and financial conglomerates
- Phase II
- Two field test runs
- Calibration of the model, parameters
- Phase I
- Conceptual work
- Establishment of a standard model
Solvency II
- Phase III
- Implementing phase
- Modeling, standard models, calibration of models
and parameters - Implementation in national law
- Phase II
- Development of detailed rules
- Three waves of Calls for Advice giving structure
of the framework - QIS1, QIS2, Impact assessments,
- Phase I
- Gathering knowledge
- General design of the system (e.g. 3-pillar
approach) - KPMG report, Sharma report, .
22The SST principles
- All assets and liabilities are valued market
consistently - Risks considered are market, credit and insurance
risks - Risk-bearing capital is defined as the difference
of the market consistent value of assets less the
market consistent value of liabilities, plus the
market value margin - Target capital is defined as the sum of the
Expected Shortfall of change of risk-bearing
capital within one year at the 99 confidence
level plus the market value margin - The market value margin is approximated by the
cost of the present value of future required
regulatory capital for the run-off of the
portfolio of assets and liabilities - Under the SST, an insurers capital adequacy is
defined if its target capital is less than its
risk bearing capital - The scope of SST is legal entity and group /
conglomerate level domiciled in Switzerland - Scenarios defined by the regulator as well as
company specific scenarios have to be evaluated
and, if relevant, aggregated within the target
capital calculation - All relevant probabilistic states have to be
modeled probabilistically - Partial and full internal models can and should
be used. If the SST standard model is not
applicable, then a partial or full internal model
has to be used - The internal model has to be integrated into the
core processes within the company - SST Report to supervisor such that a
knowledgeable 3rd party can understand the
results - Disclosure of methodology of internal model such
that a knowledgeable 3rd party can get a
reasonably good impression on methodology and
design decisions - Senior Management is responsible for adherence to
principles
23The revised insurance supervision act
Old act
New act
- Rule based
- Product and tariff approval
- Restrictions on products, investments and
pricing - Solely Solvency I capital requirements, no
explicit consideration of investment risk - Consequences
- Overexposure to risky assets
- Under-priced long-term guarantees
- Accounting and regulatory arbitrage
- Compliance culture
- Often underdeveloped risk management
- No link between regulatory requirements and
companies internal risk measurements
- Principle based
- Review of provisions
- No restrictions on products (with the exception
of mandatory group life and health insurance
products) - Less restrictions on investments
- Solvency I and risk-based capital requirements
24The SST concept economic balance sheet
Valuation reserves
Free capital
Credit risk capt
Risk bearing capital
Market insurance risk capt (incl. scen)
Target capital
Statutoryassets
Market Value Margin
Market value of assets
Best-estimate Expected value of liabilities,
taking into account all up to date information
from financial market and from insurance. All
relevant options and guarantees have to be
valued No explicit or implicit margins Discounting
at the risk-free interest rate
Best- estimate liabilities
Market value of liabilities
25The SST standard model
- Mixture between factor- and scenario-based model
- One-year time horizon for SCR, Cost-of-capital
approach for MVM - Major risk categories
- Market - Credit - Insurance
- Probabilistic approach the model output shall be
a probability distribution function from where
risk measures can be derived thereof - Variance-covariance approach for market and life
insurance risk - Non-life different probability distributions for
reserve risk and current year risk. The current
year risk is further subdivided into a large
claims risk and a small claims regime) - SST already implemented in the law (Revised
Insurance Supervision Act, set into force on
01/01/2006)
26Risk measurement framework
Risk models
Scenarios
Valuation models
Market risk
Market value assets
Insurance risk
Best estimate liabilities
Credit risk
Market Value Margin
Output of analytical model (probability
distribution)
Results from analytical model combined with
weighted average of scenario impacts
Target capital and Risk-bearing capital
27Risk measurement in the SST
Average Value-at-Risk (Tail Value-at-Risk) as
risk measure
Probability distribution of the change in risk
bearing capital RBC1-RBC0
RBC1(?)
MVM1(?)
RBC0
Change in market value of assets
MVM0
BEL0
BEL1(?)
Capital requirement
Claims
Calamity
Target capital
Economic balance sheet at the valuation date t 0
Realization of theeconomic balance sheet at
time t 1
28Market value margin MVM
- Rationale A buyer needs to put up regulatory
capital aside during the run-off period of the
portfolio of assets and liabilities - The buyer needs to be compensated for the cost of
having to put aside regulatory capital - Market value Margin present value of future
regulatory risk capital costs associated with the
portfolio of assets and liabilitieswhere
is the annually-compounded
yield-to-maturity and the cost of capital - In practice, a proxy such as the best-estimate of
future liabilities can be used to calculate the
future one-year risk capitals
29SST standard model for market risk (1/2)
- The SST standard market risk model is a
RiskMetrics type model with given risk factors
Zi such as e.g. - interest rates - exchange rates -
- equity prices - implied volatilities
- commodity prices - credit spreads
- Assumptions
- The risk factor changes X(t) Z(t) Z(t 1)
are assumed to have a multivariate normal
distribution with covariance matrix ? - The change in risk bearing capital is a linear
function of the risk factor changes - The change in risk-bearing capital is univariate
normally distributed
RBC(t) f (Z(t))
30SST standard model for market risk (2/2)
- 73 Risk Factors
- 413 interest rate
- 1 Credit spread
- 4 FX
- 6 Shares
- 4 Real Estate
- 1 Hedge Fund
- 1 Private equity
- 1 Participations
- 3 Implied vola
Interest rate time buckets 1,,10, 15,20,30
years
CHF
EUR
USD
GBP
FX
Equity
- Shares
- CHF
- EUR
- USD
- GPB
- Japan
- Asia ex Japan
- EMU SmallCap
- Real Estate
- IAZI
- Commercial
- Rüd Blass
- WUPIX A
- Hedge Funds
- Private Equity
- Participations
31SST standard model for life risk (1/2)
- Analytical model with the following risk factors
- Mortality - Recovery - Expenses
- Longevity - Surrender / Lapse
- Morbidity - Capital option exercise
- Assumptions
- Risk factor changes are multivariate normally
distributed with mean zero and covariance
structure ? (based on expert opinion) - Biometric risks are assumed to be independent
from market risk factors - Scenarios
- Pandemic (Spanish flu 1918 translated to the
present) - Disability scenario (short term increase
systemic increase) - Mortality long term changes (to take into
account of systemic over- or underestimation),
32SST standard model for life risk (2/2)
33SST standard model for credit risk
- Definition of credit risk within the SST
- risk of default or change in the credit quality
of issuers of securities to whom the company has
an exposure - Distinction between
- default risk
- downgrade or migration risk
- Quantification
- Basel II (standardized) approach
- Internal models
- Basel II IRB
- Credit risk portfolio models provided that they
capture the credit migration riskCreditRisk
would not be permissible since only the default
risk is modeled
34SST standard model for scenarios (1/3)
- Motivation during normal years, the market and
insurance risk capital is determined on the basis
of a variance-covariance type model, i.e. - the risk factor changes are assumed to follow a
multivariate normal distributionwith mean 0 and
covariance matrix ? - The change in risk bearing capital is a linear
function of the risk factor changes (1st order
approximation) - Poor description of extreme tail
events(distribution of risk factor changes have
more extreme events than would be predicted by
the normal law)
35SST standard model for scenarios (2/3)
36SST standard model for scenarios (3/3)
- The impact of a number of scenarios (both
pre-specified and company specific) on the risk
bearing capital has to be assessed - Assumptions scenario i, i 1,,m occurs with
probability pi and causes an additional loss of
ci (cilt0) - The probability of a normal year is
- The probability distribution of the change in
risk bearing capital during one year with
aggregated scenarios is
37Scenario aggregation an illustrative example
? 10 ? 40 c1 - 50 c2 - 150 p1 0.04 p2
0.05 p0 1 (p1 p2)
38Pros and cons of standard models
Pros
Cons
- Easy to implement in a spreadsheet
- Allows for fast calculations
- Easy to amend / extend
- Suitable for management purposes
- Easy to verify for the supervising
authorities/auditors
- Too simplistic
- Hidden model assumptions
- Possibly inconsistent
- Model mixtures (stochastic ? volume-based)
- Valuation and risk measurement
- Aggregation of risk classes
- Expert opinion required at various levels
- Subjective parameter estimates such as
correlation coefficients between the four main
risk categories - Incomplete
- Options and guarantees not priced
39Characteristics of a good risk model
- An economic capital model should be consistent
- between the valuation of assets and liabilities
- between the valuation and the risk measurement
- between the risk assessments of different time
periods in a multi-period setup - With an internal model, one should be able to
determine a level of capital that closely
reflects the actual risks borne by the company in
terms of - Exposure to non-linearities, in particular
(embedded) options and guarantees - Volatilities of securities
- Underwriting results
- An economic capital model should be
- clearly and comprehensively documented
- integrated into the regular risk reporting
process (i.e. no ad-hoc solutions for external
parties such as regulators) - equipped with clear responsibilities, reviewed by
internal and external parties
40The demand for internal models
- Regulatory perspective In October 2006, the
Swiss regulator (FOPI) sent out a letter to all
Swiss life insurance companies asking them to
abstain from simplified economic capital models
(such as variance-covariance type models) for SST
purposes. Rather, companies should develop and
use internal models. Companies have until 31
March 2007 to present a project plan to the FOPI
regarding the implementation of such a model.
Rationale - standard model not appropriate for large
companies, re-insurers, insurance groups and
financial conglomerates - large volumes of the business may be written
outside of Switzerland - there may be substantial amounts of embedded
options and guarantees, i.e. non-linearities - Rating agencies SP rewards innovation within
their ERM assessments
41What makes a good model?
Internal model requirements
Technical
Process related
Corporate governance
- Consistency (all levels)
- Appropriate modeling of non-linearities, in
particular (embedded) options and guarantees - Multi-period stochastic simulation approach
- No ad-hoc solutions (e.g. models must be
integrated into internal risk management
reporting) - Comprehensive documentation
- Regulatory assessment / review
?
42Modeling and implementation issues
- Time discretization (continuous daily, monthly,
quarterly, ?) - In a parametric framework model choice, i.e.
tractability versus correctness (Example
dependency structures) - Granularity of the asset and liability universe /
number of model points - Number of simulated sample paths / scenarios
efficiency versus statistical significance of the
output. Confidence intervals, rare event
simulation, . - Calibration
- One-period versus multi-period approach?
- Choice of risk measure
Complicated models will always be based on
subjective esti-mates which make the outputs at
best difficult to verify or compare across the
industry
43Agenda - Overview
- 1. From Solvency 0 to Solvency II
- Standard models and internal models
- Risk measurement in a multi-period framework
- Conclusions
44Motivation
- Belgian life insurance companies are given
exemption fromthe strengthening of their
reserves if they can demonstratethat they have
an excellent asset-liability management in place.
In this regard, the Belgian control authority
CBFA recently released a document including the
following request - Lentreprise dassurances fournit la Value at
Risk (VaR) et la Tail Value at Risk (TailVaR) à
un horizon de 1 an, de 5 ans et de 10 ans, ainsi
que la probabilité de ruine sur ces même horizons
de temps. - Is this a well-posed problem?
45One-period vs multi-period risk measurement
Risk evolving over several periods of uncertainty
?? one-period risk
Multi-period
One-period
- Availability of information
- Possibility of taking intermediate actions
(willingly or unwillingly) - rebalancing the portfolio according to a
predetermined investment strategy - Bonus policy
- Raising capital
- Selling off subsidiaries (legal structure)
- Exercising embedded options
- Appropriate risk measure choice
- To be applied to the terminal values or the
entire stochastic process? - Properties such as time-consistency
- Object of interest financial position X at the
end of the period under consideration - Absence of inflow of information
- Buy and hold strategy, i.e. no intermediate
actions are permissible
46Time-consistent dynamic risk measures
cf Delbaen et. al.
- Key question how are the risk assessments of
financial positions interrelated in different
periods of time? - Definition a dynamic convex risk measure
is called time consistent iffor all
financial positions X, Y ? L? and t 0, 1, ,
T-1 - Interpretation acceptability tomorrow in any
state of the world ensures acceptability
today. Put another way, capital requirements
should not contradict each other as time evolves.
47Tail-VaR is not time-consistent
- One can show that Tail-VaR is not time
consistent! - More general risk measures that solely depend on
the law of the terminal value can not be
time-consistent - The Belgian control authority should be careful
when asking for multi-period Tail-VaRs this can
lead to contradictory capital requirements.
Assuming a holding strategy, then, - at time 0, the regulator may accept a companys
risk capital - at time 1, however, the regulator might be forced
to refuse! - Different (investment) strategies lead to
different capital requirements (regulatory vs
internal view)
48Future challenges
- and the role of academia
- Modeling of group and cross-sectoral issues (no
longer on solo level), in particular - Risk aggregation / diversification
- Legal structure
- Appropriate modeling of all the CRTIs (capital
and risk transfer instruments such as
reinsurance, guarantees, ) - Fungibility of capital
49Agenda - Overview
- 1. From Solvency 0 to Solvency II
- Standard models and internal models
- Risk measurement in a multi-period framework
- Conclusions
50Conclusions (1/2)
- Rapid changes in the design of insurance
supervisory frameworks in the wake of the stock
market crash at the beginning of the noughties - Key driver towards model choice as simple as
possible, but not simpler - Standard models often not appropriate to capture
all the risks taken by a company (too simple) - Standard models rather designed for small
companies than large ones - Development of internal risk models very costly
- Any financial model is a simplified and thus
imperfect representation of the economic world
and the ways in which managers perform
(financing) decisions, investment, or trading.
That is, be aware of the model risk! - Alignment of the different capital requirements
(regulators, rating agencies)
51Conclusions (2/2)
- Complicated models always be based on subjective
(parameter) estimates. - At best estimates difficult to verify (by
investors / auditors) or compare across the
industry - At worst manipulation of models to flatter the
bottom line - Multi-period risk model approaches desirable, but
leave the company with a myriad of decisions /
assumptions to be taken - Lack of capacity for regulators / auditors to
verify, validate and approve the companies
internal risk-calculation models - Lack of convergence among regulatory regimes.
Large and internationally active insurance
companies may be faced with the problem that some
of their (overseas) subsidiaries will be
regulated by other, often cruder measures (A
battle over Basel II. The Economist, 4 November
2006)
52References
- Basel Committee on Banking Supervision. (2005).
International Convergence of Capital Measurement
and Capital Standards. A Revised Framework (Basel
II). Bank for International Settlements (BIS),
Basel. www.bis.org/publ/bcbs118.pdf - Bundesamt für Privatversicherungen (2004).
Weissbuch des Schweizer Solvenztests.
www.bpv.admin.ch/themen/00506/00552/index.html?lan
gde - Bundesamt für Privatversicherungen. (2005).
Verordnung über die Beaufsichtigung von privaten
Versicherungsunternehmen. Aufsichtsverordnung,
AVO, 961.011. BPV Bern. Available under
www.admin.ch/ch/d/sr/9/961.011.de.pdf - Bundesamt für Privatversicherungen (2006).
Organizational Requirements for Model Use in SST.
BPV Bern, 12 January 2006. www.bpv.admin.ch/themen
/00506/00530/index.html?langde
53References (contd)
- Campagne, C. (1961). Standard minimum de
solvabilité applicable aux entreprises
dassurances. Report of the OECE (Organisation
Européenne de Cooperation Economique). - International Actuarial Association (IAA).
(2004). A Global Framework for Insurer Solvency
Assessment. Research Report of the Insurer
Solvency Assessment Working Party. Available at
www.actuaries.org/LIBRARY/Papers/Global_Framework_
Insurer_Solvency_Assessment-public.pdf - KPMG (2002). Study into the methodologies to
assess the overall financial position of an
insurance undertaking from the perspective of
prudential supervision.
54References (contd)
- Müller, H. et al. (1997). Report of the Working
Group Solvency of Insurance Undertakings. Set
up by the Conference of the European Union Member
States. Available under www.ceiops.org - Sandström, A. (2005). Solvency. Models,
Assessment and Regulation. Chapman Hall. - Sharma, P. (2002). Prudential Supervision of
Insurance Undertakings. Paper presented at the
Conference of Insurance Supervisory Services of
the Member States of the European Union (now
CEIOPS) http//europa.eu.int/comm/internal_market/
insurance/docs/solvency/solvency2-conference-repor
t_en.pdf