Tag Archives: Gillian Tucker

Regulatory interest in AI: A summary of papers published in the US and the Netherlands

We are seeing an increased interest in the area of artificial intelligence (AI) from regulators recently. In this blog post, I will provide a summary of regulatory papers published in the US and the Netherlands last year. In the US, the Casualty Actuarial and Statistical Task Force (CASTF) published a paper in May 2019 aimed at identifying best practices when reviewing predictive models and analytics filed by insurers with regulators to justify rates, and providing state guidance for review of rate filings based on predictive models. In the Netherlands, the Dutch supervisors Authority for Financial Markets (AFM) and De Nederlandsche Bank (DNB) published two articles in July 2019 discussing the use of AI in the Dutch financial sector and specifically among Dutch insurers.

Regulatory review of predictive models in the US

The CASTF paper begins by defining what a best practice is and discusses whether regulators need best practices to review predictive models. It concludes that best practices will aid regulatory reviewers by raising their level of model understanding. With regard to scorecard models and the model algorithm, there is often not sufficient support for relative weight, parameter values or scores of each variable—best practices can potentially aid in fixing this problem. It notes that best practices are not intended to create standards for filings that include predictive models. Rather, best practices will assist regulators in identifying the model elements they should be looking for in a filing. This should aid the regulator in understanding why the company believes that the filed predictive model improves the company’s rating plan, making that rating plan fairer to all consumers in the marketplace.

The focus of the paper is on generalised linear models (GLMs) used to create private passenger automobile and home insurance rating plans. It is noted, however, that the knowledge needed to review predictive models and the guidance provided may be transferrable when the review involves GLMs applied to other lines of business. The guidance might also be useful when starting to review different types of predictive models.

The paper goes on to provide best practices (or “guidance”) for the regulatory review of predictive models. It advises that the regulator’s review of predictive models should:

  • Ensure that the factors developed based on the model produce rates that are not excessive, inadequate or unfairly discriminatory.
  • Thoroughly review all aspects of the model including the source data, assumptions, adjustments, variables and resulting output.
  • Evaluate how the model interacts with and improves the rating plan.
  • Enable competition and innovation to promote the growth, financial stability and efficiency of the insurance marketplace.

Additional details are provided to give guidance on how to ensure each of these points is met.

The paper identifies the information a regulator might need to review a predictive model used by an insurer to support a filed insurance rating plan. It is a lengthy list, though it is noted that it is not meant to be exhaustive. The information required is rated by level of importance to the regulator’s review. It includes information on:

  • Model input (available data sources; adjustments to data; data organisation; data in the sub-models).
  • Building the model (narratives on how the model was built; information on predictor variables; adjustments to the data; model validation and goodness-of-fit measures; modeller software; and an analysis comparing the old model and new model).
  • The filed rating plan output from the model (general impact of the model on the rating algorithm; relevance of the rating variables and their relationship to the risk of loss; comparison of model outputs to current and selected rating factors; issues with data, credibility and granularity; definitions of the rating variables; data supporting the model output; impacts on consumers; and information on how the model is translated to a rating plan).
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Publication of IFRS 17: Insurance contracts

On 18 May 2017 the International Accounting Standards Board (IASB) published its new International Financial Reporting Standard (IFRS) on accounting for insurance contracts: IFRS 17. IFRS 17 will apply for accounting periods starting on or after 1 January 2021, but prior year comparative figures will be required.1

The Standard is directed at insurance contracts, rather than insurance entities. So it will apply, for example, to equity-release mortgages written by banks, as well as to those listed insurers required to report under the IFRS and to those insurers that adopt the IFRS voluntarily.

The publication was accompanied by webinars conducted by members of the IASB Staff, including Q&A sessions.2 The responses provided by the staff were caveated as being their own views, and not necessarily those of the IASB. Nevertheless, the answers offer some interesting insights, which are briefly summarised in this blog.

Overview
The aim of the Standard is consistent accounting for all insurance contracts, with increased transparency in financial information reported by insurance companies and calculated information based on current estimates. However, the staff acknowledges that the Standard is not directionally convergent with the aims of the Financial Accounting Standards Board (FASB), the standard setter for the United States.

In summary, the principle-based Standard requires an assessment of the profitability of insurance contracts when they are first issued and, if positive, recognition of that value (the Contractual Service Margin or CSM) over the lifetime of the contracts in a manner that reflects the timing of the insurance services provided by the insurer.3

The staff expects firms to incur significant implementation costs.

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EIOPA discussion paper on the review of Solvency II Delegated Regulation

The European Insurance and Occupational Pensions Authority (EIOPA) has launched a review of specific items in the Solvency II Delegated Regulation with a particular focus on the standard formula Solvency Capital Requirement (SCR). In this briefing note, Milliman consultants Aisling Barrett, Gillian Tucker, and John Mulvihill summarise the discussion paper EIOPA has published in order to engage with stakeholders on the topic.