In preparing for the upcoming 2020 Solvency II review an important area of focus for life insurers and reinsurers should be a reassessment of asset-liability management (ALM) strategies for long-term liabilities both from the perspective of legislative changes that are under consideration as well as shortcomings in practices that have already been highlighted by regulators. Firms should be assessing these issues for day-to-day solvency, the own risk and solvency assessment (ORSA) and overall risk management needs, bearing in mind the consequences for different types of business and the potential influence on business mix into the future.
In this blog post I
highlight some of the key legislative changes currently under consideration regarding
the treatment of long-term liabilities, including those that may affect each of
the following areas which are important in the context of ALM:
- The methodology and
assumptions underlying the extrapolation of the risk-free rate curves for
varying currencies including the last liquid point (LLP), the rate of
convergence to the ultimate forward rate (UFR) and the level of the UFR itself
- The volatility
- The matching adjustment
also summarise public feedback from the European Insurance and Occupational
Pensions Authority (EIOPA) and national regulators regarding ALM best
guarantee measures under Solvency II
As part of the final set
of rules established prior to the commencement of the Solvency II regime in 2016, a set
of measures was introduced regarding the
treatment of ‘long-term guarantees’ or LTGs. These measures, commonly referred
to as the ‘LTG measures,’ comprised the extrapolation of the risk-free rate, the VA, the MA and the transitional
measures for the risk-free rate and technical provisions (TRFR and TTP).
is well underway towards the review of the LTG measures, as originally envisaged to happen by the end of 2020
under the Omnibus II Directive. EIOPA has been charged with overseeing ongoing experience
with regards to the LTG measures,
publishing an annual report for each of 2016, 2017 and 2018. These annual reports
are intended to be a key input informing the wide-ranging review of Solvency II. Indeed EIOPA
is specifically required to submit an opinion on its assessment of the application of the LTG
measures by the end of 2020.
Additional requests from the European Commission (EC) as part of the review process now make it clear that a point of focus regarding the LTG measures will be a reassessment of their appropriateness, particularly taking into account ALM practices of life (re)insurers.
The Solvency II Directive requires that certain areas must be reviewed by the European Commission by the end of 2020. The Commission has now written to the European Insurance and Occupational Pensions Authority (EIOPA) requesting its advice by 30 June 2020 on items that it has identified as deserving a reassessment. In forming its advice, it’s expected that EIOPA will issue a series of industry consultations addressed to various stakeholders over the coming months. Any proposed changes will be high on the agenda of actuarial functions and risk functions and (re)insurers will need to carry out impact assessments in relation to areas affecting them.
In this briefing note, Milliman’s Karl Murray and Eoin King set out the areas covered by the Commission’s latest request for the 2020 review of the whole Solvency II framework. They also cover a separate request that the Commission has issued to EIOPA related to insurers’ asset and liability management, which is also part of the 2020 review process, as well as providing an update on the latest news in relation to the 2018 interim review of the Solvency II Delegated Regulation.
Solvency II came into force on 1 January 2016. The agreed Pillar 1 quantitative requirements set a market-consistent valuation framework for the valuation of assets and liabilities, as well as sufficient holdings of capital to withstand a combination of so-called ‘1-in-200-year’ Standard Formula (SF) stresses. There is no doubt these fundamental principles are set in stone but nonetheless there have been ongoing changes to the detailed rules since their introduction. This was planned from the outset with certain powers given to the European Insurance and Occupational Pensions Authority (EIOPA) to review methodology and assumptions over time, as well as a specific milestone for the European Commission (EC) to review elements of the Standard Formula in 2018, followed by a more holistic review of the entire rulebook by 2021.
Any changes are intended to reflect developments in the insurance sector and the wider environment. These changes could have significant impacts on individual companies and firms may need to reassess their capital management strategies.
This report by Milliman’s Karl Murray, Eamonn Phelan, and Bridget MacDonnell revisits the rules in specifying the risk-free rate term structure, which forms a fundamental part of the calculation of Technical Provisions (TPs). In particular, they analyse changes to the Ultimate Forward Rate (UFR).
The Volatility Adjustment (VA) is one of the Long-Term Guarantee (LTG) measures under Solvency II which aims to ensure the appropriate treatment of insurance products with long-term guarantees. However, the VA also affords applicability to other types of products with long-term liability cash flows and one of the aims of a recent paper is to reexamine the potential for companies to use the VA for their businesses. In this paper, Milliman’s Karl Murray and Eamonn Phelan examine the features of ongoing risk management with regards to the application of the VA.
Risks relating to conduct of business are attracting increased attention across financial services firms, prompted by the ever-increasing focus of regulators in this area. Senior managers are accountable for conduct risk failings, and accordingly a strong conduct risk framework is an important tool in protecting against such failings. Based on our experience of assisting clients in this area, conduct risk management is still evolving and firms face many challenges. This paper by Milliman’s Karl Murray and Eamonn Phelan looks at recent and ongoing developments from around the globe and discusses actions firms need to take in order to address the changing business and legislative environment with regards to consumer protection.
By 1 January 2018 insurers, banks, asset managers and other investment firms offering packaged retail investment and insurance-based products (PRIIPs) must make a key information document (KID) available for all products offered to customers. On 18 August 2017 the European supervisory authorities (ESAs)—made up of the European Insurance and Occupational Pensions Authority (EIOPA), the European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA)—published an updated questions and answers (Q&A) document on the PRIIPs KID. The first batch of Q&As was published in July.
The ESAs’ publication is aimed at clarifying aspects of the Regulatory Technical Standards (RTS) or ‘Level 2’ rules covering the specific form and content of KIDs. The latest questions addressed by the ESAs include queries on the following:
• Categorisation of a retail investor
• Market risk assessment
• Credit risk assessment
• Summary Risk Indicator (SRI)
• Presentation of costs
The combined set of Q&As, covering the first and second batch of queries, can be found here.
In addition to the latest Q&A document, the ESAs also published a useful flow diagram or decision tree showing how to perform the various calculations for the SRI and performance scenarios. This is a graphical view of the requirements set out in the RTS and a useful summary of the basic calculations. The flow diagram can be found here.
The ESAs stated they will continue to assess whether further guidance is needed based on additional questions received.
Please contact us if you have any questions or comments on PRIIPs. We would be happy to meet with you to discuss ways in which we can help you achieve a successful PRIIPs implementation including gap analysis, KID production, checking overall compliance with the PRIIPs requirements and review of KID elements, including narratives and numerical disclosure tables, etc.