Solvenz - FINMA

Solvenz - FINMA

Supervisory Framework for Risk Assessment and Risk-based Solvency Philipp Keller, Federal Office of Private Insurance FSI, 28 April 2006 1 Contents Global Regulatory Trends Global Tendencies Regulatory Initiatives Risk Management Risk Based Solvency Models Swiss Solvency Test Internal Model Group Effects Appendix 2 Global Regulatory Tendencies Still some loss making longtail business in the books (life and non-life) Reliance on investment profits Acceptance of negative technical results to obtain cash to invest in market Smaller investment profits Scarce capital Risk management often no issue Explicit requirements on risk management, risk-based capital

requirements, transparency Some fixed rules, limits, prudence Self-regulation Strengthening of supervision Stock market boom Crash Today Rule-based Principle-based Cartels Liberalization Build-up of hidden reserves international expansion time Competition Possibly more volatile results, better ALM, possibly different business models 3 Global Regulatory Tendencies There are costs and risks to a program of action, but they are far less than the long-range risks and costs of comfortable inaction John F. Kennedy In the past, insurance supervisors but also insurance companies were

not sufficiently aware of economic reality The valuation of assets and liabilities were not adequate for an analysis of risk The artificial smoothing of results often made companies and supervisors inclined to comfortable inaction An adequate risk quantification was perceived by some to be too complex and too onerous The financial crisis of 2000/2001 has shown to all that the insurance industry was more exposed than previously thought and both insurers and regulators saw the need for a more adequate, risk based supervisory framework many regulators (UK, NL, CH,) and the EU have started initiatives to develop more risk based supervisory models 4 5 CEIOPS EQIS2 CEIOPS QIS1 CEIOPS Established Impleme 4ntation foBasel II Start of Basel II 1999 Swiss SST UK ICA, NL DST FSA Realistic Balance Sheet

Singapore RBC KPMG Report Sharma Report Start of Solvency 2 Market Riski Amendment 1996 Australia RBC Canada P&C DST 1985 Muller report 1979 1988 Canada Life DST 1973 Basel Accord CBOT SPAN SEC VaR Measure 1980 US Life RBC

1953 1961 Canadian RBC System Banking 1. EU Nonlife Directive 1957 1. EU Life Directive Campagne publishes reports on life and nonlife solvency assessment 1947 Finalnd RBC Regulatory Initiatives 2007 European 1997 2001 2002 2003 2005 2006 International 1992 1998 2000 2004 2005 2006 Contents Global Regulatory Trends Prudential Supervision and Risk Management Risk Management

Prudential Supervision Risk Based Solvency Models Swiss Solvency Test Internal Model Group Effects Appendix 6 Prudential Supervision Prudential Supervision aims to systematically evaluate the risk profile and the risk bearing capacity of the supervised entities. Finnish Financial Supervisory Authority What prudential supervision is about is helping protect other people from the failure of the institution by trying to ensure the institution is adequately run. An adequately-run institution needs to know why its in business. It need s to have a strategy and some idea of where its revenues will come from. It needs to know what kind of risks it faces and, preferably, to try to measure them. It needs to know what kinds of risks it wants to face and take measures to eliminate the rest. And it needs to have some way of telling how much capital it needs to deliver an acceptable risk-adjusted return to shareholders Howard Davis, Chairman, Financial Services Authority, UK Prudential supervision is not only about quantifying insurers risks, but to give incentives so that the companies themselves manage their risks appropriately, i.e. have an adequate risk management and corporate governance 7 Risk Management Wir mssen wissen. Wir werden wissen. Risk management is responsible for identifying, assessing, analyzing, quantifying and then transferring, mitigating or accepting of risk For risk management to be effective, there needs to be a risk culture such that senior management wants to know and risk

management is able to tell the truth about the risks Senior management and the board have to ensure that there is a honest dialog and transparency regarding risks within the company Risk management is not solely about control but about confronting issues and uncomfortable truths openly and honestly David Hilbert A risk based supervisory framework should be such that it fosters a climate in the market where an appropriate risk culture and risk management is rewarded principles instead of rules responsibility with senior management transparency and trust in market and in regulator 8 Risk Management Possible set-up of risk and capital management within an insurance company: many different Equity organizational structures are possible Dividends Capital Senior Hybrid Contingent

Board CFO Capital Management Risk Capacity market, credit risk Risk Appetite Assets Risk and capital management, reinsurance Reserving ALM CRO CIO market, credit risk Liabilitie s Pricing Actuary insurance risk Underwriting Claims Payment Appointed

Actuary credit, insurance risk Sales Reinsurance external Traditional, Finite internal Intra Group Insurance Capital Market Market Portfolio Swaps Securitization, Premium, Future Profit Coinsurance, 9 Risk Management Warren Buffetts three key principles for running a successful insurance business: They accept only those risks that they are able to properly evaluate (staying within their circle of competence) and that, after they have evaluated all relevant factors including remote loss scenarios, carry the expectancy of profit. These insurers ignore market-share considerations and are sanguine about losing business to competitors that are offering foolish prices or policy conditions. They limit the business they accept in a manner that guarantees they will suffer no aggregation of losses from a single event or from related events that will threaten their solvency. They ceaselessly search for possible correlation among seemingly-unrelated risks. They avoid business involving moral risk: No matter what the rate, trying to write good

contracts with bad people doesn't work. While most policyholders and clients are honorable and ethical, doing business with the few exceptions is usually expensive, sometimes extraordinarily so. February 28, 2002, Warren E. Buffett An insurance regulator should set incentives such, that good risk management practices are rewarded: setting transparent requirements putting responsibility to the board and senior management Enforce requirements consistently 10 Prudential Supervision: Pitfalls to Avoid A regulator has to be careful not to give incentives for secondary risk management of supervisors Secondary Risk Management: the preoccupation of risk managers with managing their own risks. This can lead to a culture of risk aversion. Symptoms are that disclaimer paragraphs become longer than the expert opinion, a proliferation of risks which are considered in order to be able to cover all bases, the perception that all risk are unacceptable and a preoccupation with residual, ill-defined risk. (based on The Risk Management of Everything: Rethinking the politics of uncertainty, Michael Power, Demos 2004) Symptoms of secondary risk management in supervision: The insistence on limits on investments and products The fear of transparency, allowing comfortable inaction An obsession with formalities rather than substance The fear and rejection of all things new and unconventional Secondary risk management has to be fought with transparency: of the economic state of the companies but also of the regulatory requirements and a continuing, public engagement of the supervisors with all stakeholders 11 Prudential Supervision: Pitfalls to Avoid Risk management is crucial, however, there are some pitfalls to avoid The Regulation of Everything

Regulation should concentrate on relevant risks Self-regulation and market forces should have their place Limits of Quantification Residual risks (e.g. operational risks) can become blown up all out of proportion Due to lack of data and clear concepts, pseudo-quantifications are used for capital requirements The Myth of Auditability Dangers of Secondary Risk Management Audits should not be used to abrogate responsibility Excessive reflection on risks can lead to the perception that danger lurks everywhere Over-reliance on auditability can lead to check-box mentality both within the industry and the regulator Risk management should deal with a companys risks, not manage their own risk Excessive Internal Control Excessive internal control can lead to a bureaucratic, risk averse company 12 Principles vs Rules for Risk-Based Solvency Principle-based standards describe the objective sought in general

terms and require interpretation according to the circumstance. Companies tailor approach such that clearly stated objective is attained Principle-based Objective can be attained if companies interpret principles faithfully Objective Company specific = risk-based solvency assessment Rule-based Rule based approach does not allow truly company specific risk assessment (or the set of rules becomes huge and Byzantine) Objective Attained result deviates from true company specific solvency requirement, depending on how well rules capture the situation of the insurer 13 Contents Global Regulatory Trends Risk Management Risk Based Solvency Models

Capital Models Risk Based Solvency Frameworks Scope Time Horizon Risk: Definition, Classification, Risk Measures Valuation: Economic, Fair Value vs. Amortized Cost The Market Value Margin Risk Bearing Capital: Risk as Change of RBC Standard Models: Typology Swiss Solvency Test Internal Model Group Effects Appendix 14 Capital Models Most capital models and solvency models consist of two main parts: A valuation V(.) is a mapping from the space of financial instruments (assets and liabilities) in R: V: A * L R, where A * L is the space of all assets and liabilities A risk measure rm(.) of a random variable: rm: G R Necessary capital C for risk is quantified by the risk measure of the change of risk bearing capital over a given time horizon (e.g. 1 year) Risk bearing capital is defined as value of assets V(A) less value of liabilities V(L), where value is generally market value. Let RBC(k)=V(A(k))-V(L(k)) be the risk bearing capital at time k. Then C=rm( RBC(t) RBC(0) ) Risk bearing capital at time

t: random variable The mathematical set up is slightly different for multiperiod models Risk bearing capital at time 0: known 15 Capital Models An economic capital model should be consistent between valuation and risk quantification and between the valuation of assets and valuation of liabilities Often V1(.): A R and V2(l): L R are used i.e. the valuation of assets and liabilities are different functionals, which are not necessarily consistent. Examples: Solvency 1: V1(.) is a mix of market value and book-values, V 2 is basically unspecified (undiscounted, prudent etc.) Solvency 2: V1(.) is market value, V2(.) is discussed to be 90% quantile of the ultimate of the liabilities SST: V1(.) is market value, V2(.) is best estimate + cost for of future regulatory capital Consistency requirement for valuation: If a ~ l, a in A, l in L, then V(a) V(l) Bad example: A pure endowment insurance is close to a ZCB. However, the market value of a ZCB can be far away from its statutory value 16 Risk Based Solvency Frameworks Solvency Framework Valuation Prudent Risk Measurement

1 year Assets Liabilities Observable Multiyear VaR Group Principles Group Risk Consolidated CRTs only CRTs only Market Prices TailVaR others Unobservable Mathematical Framework Market Credit Amortized cost for bonds Undiscounted for P&C Mix of book

value, market value Prudent discountMark to Model MVM rate at time of sale No recognition of derivatives etc. Prudent assumptions Quantile (?) Legal Entity Risk Time Horizon Risks SCR Measure Market Consistent Quantification Scope Assets Liabilities Scope LoB Legal Entity

Group Insurance Standard Models Operational? Internal Models Others? Proxy Scope Type Cost of Capital Quantile? Factor Life Parallel run with standard models Others? RBC P&C Stand-alone run Scenario

Health Mandatory vs facultative RI? 17 Risk Based Solvency Frameworks There are some unique challenges when developing regulatory capital models: They need to be applicable to a wide range of companies They should be flexible in order to allow adaptation to new risks They should be close to companies internal models Their underlying principles should be transparent They should be easily recalibrated if risk factors change (e.g. financial market risk) They should not be so complex as to inhibit use of internal models They should not be so simple as to not allow the use of partial model as a stepping stone for smaller companies to full internal models The art of defining a regulatory capital model is to find an optimal solution fitted to the specific insurance market 18 Scope of Regulatory Models Subsidiaries: Can be in all parts of the world, home country regulator cannot calibrate easily (if at all) a standard model to different risk profiles. Mix of legal entity risk to risks emanating from subsidiaries is widely varying from group to group. Capital flow between subsidiaries and parent is restricted. Risk specific standard model for group is extremely difficult to develop since in addition to legal entity model restrictions on fungibility of Group capital need to be taken into account Subsidiary Subsidiary

Subsidiary Branch Parent Company Branch Risk specific standard model is feasible Branches: Can be in all parts of the world, home country regulator cannot calibrate easily (if at all) a standard model to different risk profile. Mix of parent country risk to risks emanating from branches is widely varying from company to company Parent Company: Standard model can be calibrated using local, country specific statistics and models Legal Entity Branch Branch Risk specific standard model for legal entity is very difficult to develop Capital can flow (nearly) freely between branches and parent company and legal entity can be considered to be one riskentity. Diversification between parent and branches. 19

Time Horizon The time horizon of 1 year used by most internal models and supervisory frameworks is not natural but a compromise: A time horizon of one year is short enough that asset and business strategy need not necessarily be modeled: assume that asset and liability composition at the end of one year is more or less as at the beginning of the year Since solvability requirements (in theory) have to be fulfilled at each point in time a time horizon of one year is short enough so that satisfying the solvency requirement only at the end of each year is a reasonable approximation to a continuous model However, the are also disadvantages to a one year time horizon: Diversification over time is limited During one year many things can happen (strategies can change, assets rebalanced etc. SST requires to do a recalculation if risk situation has changed substantially RBC Forbidden states SCR t=0 t=T 20 Risk Risk: In the abstract, used to indicate a condition of the real world in which there is a possibility of loss; also used by insurance practitioners to indicate the property insured or the peril insured against. IAIS Glossary of Terms Risk is the chance of something happening that will have an impact upon objectives. It is measured in terms of consequences

and likelihood. Australian and New Zealand Standard on Risk Management An investors initial portfolio consists of positions Ai, 1iI, (possibly with some institutional constraints such as the absence of short sales and a congruence for each currency between assets and liabilities). The position Ai provides Ai(T) units of currency i at date T. We call risk the investors future net worth sum ei*Ai(T) (ei denotes the random number of units of currency 1 which one unit currency i buys at time T.) Coherent Measures of Risk, Artzner, Delbaen, Eber, Heath 21 Risk: Regulatory Treatment of Risks Don Dixon AKG Photo Irrelevant for Capital Relevant for Regulatory Requirements Risk Capital Relevant for Reserving 22 Risk: Classification (Example SST) Total Risk Group Risks

Financial Risks Liquidity Risks Operational Risks Insurance Risks quantitatively Market Risks Credit Risks Interest Rates Defaults Equity Migration qualitatively Life P&C Capital Mobility Group Internal Risk Group Behavior Risk Regulatory Risks Shares Real Estate Reinsurers Concentration

Model Spreads Concentration Model Mortality Longevity Alt Invest. FX Biometric Morbidity Premium Risk Small Claims Large Claims Catastrophes Reactivation Policyholder Reserve Risk Lapse Other options 23 Risk Measures: Expected Shortfall vs VaR The Expected Shortfall of a random variable X to the confidence level 1- (ES) is given by ES[X] =1/ E[ max( X- VaRX] =1/ E[X] =1/ E[ max( X- VaR max( X- VaR[X] =1/ E[ max( X- VaRX], 0 )] + VaR[X] =1/ E[ max( X- VaRX] Expected Shortfall is a coherent risk measure

Shareholder: Only default or non-default is relevant not how bad the state of the insurer is in case of default as shareholders have a put-option on the insurer (Merton) Value-at-Risk might be appropriate Policy Holder: In case of default, it matters how much capital is left Expected Shortfall is more appropriate than VAR From the perspective of an insurance regulator, Expected Shortfall has advantages compared to Value at Risk For an insurer, Expected Shortfall has advantage of being coherent: Allocation of risk and risk management of subunits is possible ES is easier to explain to management: - ES1%=average one-in-a-hundred-years loss - VaR1% = the loss that is in 99-out-of-a-100years not exceeded 24 Valuation: The economic view How to measure risks? Accounting risk or economic risk? Reported earnings follow the rules and principles of accounting. The results do not always create measures consistent with underlying economics. However, corporate managements performance is generally measured by accounting income, not underlying economics. Therefore, risk management strategies are directed at accounting, rather than economic performance. Enron in-house risk-management handbook For a risk-based solvency system, risks need to be measured objectively and consistently economic risk rather than accounting risk

Market Consistent Valuation of Assets and Liabilities 25 Valuation: Market Value vs. Amortized Cost Economic Consequences of Amortized Cost: Amortized cost only makes (marginally) sense when bonds are truly held to maturity, but then: investment opportunities vanish if market value of bonds is below amortized cost, any selling of a bond leads to realization of a loss if assets have to be sold, recently bought bonds or equities have to be used to keep realized losses under control if business decreases, cash outflow might have to be served by bonds, leading to a realization of losses In an amortized cost world, companies have an incentive to write loss making business in order not to be forced to sell bonds, exacerbating thereby underwriting cycles, in particular when interest rates rise In addition, the amortized cost framework is difficult if not impossible to extend to derivatives, making it impossible to take into account sophisticated hedging strategies If a company becomes insolvent, the portfolio cannot be sold to second insurer if economic worth of the company is negative under market consistent valuation even if under an amortized cost the valuation looks fine Amortized cost framework for assets gives incentives for perverse risk management: Foreclosing of investment opportunities Cash flow underwriting Downward spiral when business contracts Amortized cost framework

for assets is difficult to extend to derivatives and more complex instruments 26 Valuation: Market Value vs. Amortized Cost Economic Consequences of Amortized Cost (cont.): Under an amortized cost framework, insurance liabilities should be valued consistently Liabilities then cannot depend on (current) interest rates valuation undiscounted or discounted at time of product sale implicit prudence can vanish quickly, e.g. when interest rates decrease discounted using the expected asset return making liability values depend on assets held was called by M. Taylor, Chairman of WM Smith, one of the weirdest emanations of the human mind Use of prudent assumptions (e.g. on mortality, morbidity etc.) again, implicit prudence tends to vanish quickly without anyone realizing it The amortized cost framework generally does not take into account embedded options, giving incentives to add optionalities indiscriminately to increase sales without valuing them Amortized cost framework for liabilities gives incentives to add optionalities without provisioning and implicit prudence vanishes quickly Achieving internal consistency between asset and liability valuation is difficult if not impossible

Amortized cost framework often gives conflicting signals to market consistent view: Hedging is punished Incentives to have huge duration gap rather than proper ALM 27 Market Value Margin Asset valuation: Market consistent Market price if traded Marked to Model if not traded Liability valuation: How to define if liability valuation has to be consistent with asset valuation? Problem: Most liabilities are not actively traded Marked to Model Asset Valuation: Fair Value = the price at which an asset or liability could be exchanged in a current transaction between knowledgeable, unrelated willing parties. The price is an estimate in the absence of an actual exchange (FASB) At what price could an insurance liability be transferred to a willing buyer (e.g. to an insurer)? Definition: The market value margin is the smallest amount which is necessary in addition to the best-estimate of the liabilities, so that a buyer would be willing to take over the portfolio of assets and liabilities. 28

Market Value Margin: Cost of Capital Approx. What is a good proxy for the Market Value Margin? Proposals: Quantile and Cost of Capital Approach Idea: A buyer (or a run-off company) needs to put up regulatory capital during the run-off period of the portfolio of assets and liabilities a potential buyer needs to be compensated for the cost of having to put up regulatory capital Market Value Margin = the present value of future regulatory risk capital costs associated with the portfolio of assets and liabilities Problem: How to determine future regulatory capital requirement during the run-off of the portfolio of assets and liabilities? 29 Market Value Margin: Cost of Capital Approx. Risks considered in the MVM: t=0 t=1 t=2 t=3 Years Risks emanating during year 2 are covered by the cost of setting up SCR(2): CoC*SCR(2) compensates for having to finance SCR(2) during one year Risks emanating during year 1 are covered by the cost of setting up SCR(1): CoC*SCR(1) compensates for having to finance SCR(1) during one year Risks emanating during year 0 are covered by the SCR(0)

Note: This approach for calculation the cost of capital margin assumes that the portfolio transfer occurs at the end of year 0, hence SCR(0) does not enter calculation 30 Market Value Margin: Cost of Capital Approx. MVM= CoC SCR(t) t 1 SCR(0) Premium risk Run-off risk Market and credit risk SCR(1) Market and credit risk assuming asset portfolio corresponds to the optimal replicating portfolio SCR(2) SCR(1) SCR(T) t=0 t=1 t=2 t=3 Years Future SCR entering calculation of MVM at t=0 31

Market Value Margin: Cost of Capital Approx. Calculation of the Cost of Capital Margin: 1. calculate the capital requirement SCR(t) for all years t until the run-off of the portfolio, assuming no new business and assume that asset portfolio equals to optimal replicating portfolio (i.e. only unhedgeable risks remain for SCR(t)). 2. calculate the capital charge, i.e. the cost of holding the required capital, for each projection year as the required amount of capital multiplied by a cost of capital. 3. the cost of capital margin is then determined as the present value of the (discounted) capital charges as projected over the full time horizon of the liabilities Step 1 is the difficult one. In theory, one needs to do a full solvency test for each year until the portfolio has run-off. In practice simplifications can be employed Determine a proxy p(t) for future SCR(t) which is easier to calculate than SCR(t), i.e. the best-estimate of liabilities at time t. Then approximate SCR(t) using the proxy p(t). Show to the supervisor that the proxy is reasonable 32 Market Value Margin: Cost of Capital Approx. Example: Assume that the best estimate of liabilities BE(t) is a good proxy for future SCR(t) Determine SCR(0) without current year risk (premium risk) and assume assets are optimal replicating liabilities only unhedgeable financial market risk needs to be considered. Call this value: SCR(0) SCR(3)=SCR(0)/BE(0)*BE(3)=20/200*7=7 Then set SCR(t)=SCR(0)/BE(0)*BE(t), t=1,,T Year t Proxy: Best Estimate of Liabilities SCR(t) with optimal replicating portfolio 0 1

2 3 4 5 6 200 150 110 70 40 20 10 20.00 15.00 11.00 7.00 4.00 2.00 1.00 0.42 0.92 0.38

0.24 0.89 0.21 0.12 0.86 0.10 0.06 0.84 0.05 Capital Charge (with 6% cost of capital) Discount factor (flat 3% assumed) Discounted Cost Capital (6%)Charge 1.20 1.00 1.20 Cost of Capital Margin 3.45 0.90 0.97 0.87 0.66 0.94 0.62 33

Market Consistent Valuation: Definition Advantages of the Cost of Capital Margin Approach: The CoCM is defined as a proxy for the MVM, therefore it fits into a market consistent valuation framework It can be defined consistently for both life and P&C companies It allows a range of calculation methods, from very sophisticated to simplified It is congruent to the margins used by many companies internally (e.g. for pricing, for EEV,) It forces companies to think about long term risk and capital requirements For supervisors, the CoCM is easy to review 34 Economic Balance Sheet Building blocks: Market consistent (economic) balance sheet Free capital Risk bearing capital Target capital Market value of assets Wherever possible, market-consistent valuation is based on observable market prices (marking to market) If such values are not available, a market-consistent value is determined by examining comparable market values, taking account of liquidity and other product-specific features, or on a model basis (marking to model) Market-consistent means that up to date values are used for all parameters SCR: Required capital for 1-year risk

Market Value Margin Market consistent value of liabilities Best estimate of liabilities 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 with risk-free interest rate 35 Risk as Change of Risk Bearing Capital Building blocks: Year 0 Year 1 Risk bearing capital Market Value Margin Revaluation of liabilities due to new information Probability < 1%

New business during one year Change in market value of assets Market consistent value of liabilities Market value of assets Probability density of the change of risk bearing capital Claims Catastrophes Average value of RBC in the 1% bad cases = Expected Shortfall = SCR Smallest value of RBC in the 1% bad cases = Value at Risk Best estimate of liabilities Economic balance sheet at t=0 (deterministic) Economic balance sheet at t=1 (stochastic) 36 Regulatory Models: Typology

A rough typology Factor Models: Linear combination of volume measures C a1 * v1 a2 * v2 an * v n RBC Models: Risk charges C1,C2, are combined C C1 C22 (C3 C 4 )2 Scenario Based Models: C f ( S1 ,..., S n ) Hybrid Models: A mix of several types of approaches Internal Model based 37 Regulatory Models: Typology Factor Models Basel 1 Solvency 1 Scenario Based RBC GDV SPAN CEA Basel 2 FFSA

CEIOPS Internal Model Based MCT MCCRS RBC (US) RBC (JP) RiskMetrics MCR, APRA Lloyds RDS ICAS DST ECR, FSA SST DCAT 38 Outlook There have been great improvements in risk based solvency frameworks during the last years, many problems however are still unsolved A regulator developing a risk based solvency framework should have in view not only the current knowledge and modeling capabilities but should base the framework on what will be available in a few years time Risk-based solvency systems will co-evolve with insurance market There is not one best risk based solvency system, but mix of rules and principle, level of sophistication etc. depends on the culture of the market One should never forget that the point of a risk based solvency system is not only the calculation of target capital (or SCR) but to

foster a risk awareness in the market (and in the regulator) 39 Contents Global Regulatory Trends Risk Management Risk Based Solvency Models Swiss Solvency Test Principles Standard Models: Financial Market, P&C Cost of Capital Margin Scenarios Experiences from Field Test 2005 Internal Model Group Effects Appendix 40 The SST Concept: Requirements Transparent methodology The model should correspond to the ideas of the users Easy to adjust to changing risk landscape Easy integration of internal models

To give incentives for risk management As simple as possibly, as complex as necessary SST models and all parameters are published and are in the public domain SST is modular, partial modules can easily be changed or improved Calculation is responsibility of management, SST is clear and understandable for management Not a simple factor model but a model which needs to be adapted by each insurer to its specific situation 41 The SST Concept Solvency Framework Valuation Prudent Risk Measurement Market Consistent Liabilities Observable Multiyear VaR

Mix of book value, market value Prudent discountMark to Model MVM rate at time of sale No recognition of derivatives etc. Prudent assumptions Consolidated CRTs only CRTs only Liabilities Scope Legal Entity Group Principles Mathematical Framework Credit Undiscounted for P&C

LoB Group Market Amortized cost for bonds Assets Quantification Group Risk Market Prices TailVaR others Unobservable Quantile (?) Legal Entity Risk Time Horizon Risks SCR Measure 1 year Assets Scope Insurance Standard

Models Operational? Internal Models Others? Proxy Scope Type Cost of Capital Quantile? Factor Life Parallel run with standard models Others? RBC P&C Stand-alone run Scenario Health Mandatory vs facultative

RI? 42 The SST Concept: Principle-Based Core of the Solvency Test Principles Guidelines Definitions Glossary Standard Model The SST is defined not by the Standard Model but by underlying principles Principles define concisely the desired objectives Definition of terms and concepts so that meaning and possible interpretation of principles become clear Guidelines help in interpretation Standard Model allows use of Solvency Test also by small companies Glossary with terms and concepts 43 The SST Concept: Principle-Based 1.All assets and liabilities are valued market consistently 2.Risks considered are market, credit and insurance risks Defines Output

3.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 4.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 5.The market value margin is approximated by the cost of the present value of future required regulatory capital for the runoff of the portfolio of assets and liabilities 6.Under the SST, an insurers capital adequacy is defined if its target capital is less than its risk bearing capital 7.The scope of SST is legal entity and group / conglomerate level domiciled in Switzerland 8.Scenarios defined by the regulator as well as company specific scenarios have to be evaluated and, if relevant, aggregated within the target capital calculation 44 The SST Concept: Principle-Based 9. Defines How-to All relevant probabilistic states have to be modeled probabilistically 10. 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 11. The internal model has to be integrated into the core processes within the company 12. SST Report to supervisor such that a knowledgeable 3rd party can understand the results Transparency Responsibility

13. Disclosure of methodology of internal model such that a knowledgeable 3rd party can get a reasonably good impression on methodology and design decisions 14. Senior Management is responsible for adherence to principles 45 The SST Concept: Standard Models SST Standard Model: Standard Algorithm rather than Standard Formula The standard algorithm is similar to companies internal model: gives incentives for risk management corresponds closely to the thinking of the user of the model (e.g. actuaries, investment specialists, CROs,) Financial market Risk: RiskMetrics type approach (Covariance matrix of market risk factors) Credit Risk: Basel 2 or Credit risk portfolio models, credit risk of reinsurers via scenario P&C Insurance Risk: Distribution based (small, large and cat claims) Life Insurance Risk: Covariance approach for life insurance risk factors Allows easy use of partial internal models allows easy and consistent mapping of reinsurance (business ceded) Companies have to determine sensitivities of assets and liabilities to financial market risk factors Analyze life and P&C insurance risk, determine company specific parameters

Aggregate risk using convolutions etc. 46 The SST Concept: General Framework Market Consistent Data Standard Models or Internal Models SST Concept Credit Risks Insurance Risks Scenarios Financial Risks AssetLiability Model Mix of predefined and company specific scenarios Aggregation Method Target Capital SST Report 47 The SST Concept: Standard Models Financial Market Risk Insurance Risk (Life)

For many companies this is the most For many life companies with important risk (up to 80% of total predominantly savings product, target capital emanating from pure life insurance risk is not too financial market risk) important Most relevant are interest rate risk, Life insurance risk is substantial real estate risk, spread risk, equity risk for companies selling more risk products / disability Financial market risk model does take Model needs to capture into account assets and liabilities simultaneously optionalities and policyholder behavior Interest rate risk is captured not via simple duration but over different (13) Insurance Risk (Nonlife) time buckets Premium-, reserving- and cat risk Credit Risk are important Credit risk is becoming more A broad consensus on modeling important as companies go out of exists among actuaries equity and into corporate bonds Many smaller and mid-sized More information under: companies do not yet have much experience in modeling credit risk www.sav-ausbildung.ch and www.bpv.admin.ch 48

The SST Concept: Cash Flow Based Example: Sensitivity to 2 Year CHF Yield Asset Cash Flows Year Change of present value of net cash flow (assetsliabilities) due to change in the 2 year CHF yield Liability Cash Flows Year Netto Cash Flows A-L 3 Stressed 2Y Yield 2 CHF Yield Curve 1 0 Present Value von Asset - Liabilities 49 Standard Models: Asset-Liability Model Financial market risk often dominates for insurers adequate modeling of interest rate-, equity-,.. risks is key Interest rate risk cannot be captured solely by a duration number Financial instruments have to be segmented sufficiently fine else arbitrage opportunities might be created Modeling should be such that regulatory

requirements shouldnt force companies to disinvest totally from certain investment classes (e.g. shares, private equity) For SST, RiskMetrics type model with given risk factors and associated volatilities and correlation matrix is used + scenarios Scenarios Historical Share crash (1987) Nikkei crash (1990) European FX-crisis (1992) US i.r. crisis (1994) Russia crisis / LTCM (1998) Share crash (2000/2001) Default of Reinsurer Financial Distress Equity drop Lapse = 25% New business = -75% Deflation 50 Standard Models: Nonlife Model Premium risk

Financial market risk For each LoB, moments are derived by parameter- and stochastic risks (coefficients of variation) Large claims Lines of Business Normal claims Method of Moments with prescribed correlation matrix First two moments of premium risk (normal claims) and reserving risk are aggregated using correlation -> two moments defining lognormal For each LoB, Pareto distribution with specified or

company specific parameters Compound Poisson Discounted cash flows Assets: bonds, equity, CF -> i.r. sensitivities Asset Model: Covariance/Riskmetrics approach Normal Reserving Risk Method of Moments with prescribed correlation matrix Lognormal Aggregation by Convolution Aggregation

by Convolution Further aggregation with scenarios 51 The SST Concept: Market Value Margin For the SST, liabilities have to be valued market consistently, defined as the Best Estimate + Market Value Margin The MVM is approximated using the cost of capital approach The Cost of Capital Margin (CoCM) consists of two components: a first part depending on insurance risk and unhedgable market risk a second part depending on the illiquidity of the assets of the insurer Reasoning for the first component: The insurer setting up the market value margin should not be penalized if, after the transfer, the insurer taking over the portfolio does not minimize the regulatory risk capital requirements as fast as possible. Reasoning for the second component: The insurer taking over the portfolio of assets and liabilities should be compensated if the insurer setting up the market value margin invested in an illiquid asset portfolio. Assume that initial asset portfolio is rebalanced such that it matches optimally the liabilities. The speed of the rebalancing is constrained by liquidity of assets (it

takes longer to liquidate for real estate than for government bonds). The duration for achieving the optimal replicating asset portfolio depends on the asset mix. 52 The SST Concept: Market Value Margin MVM= CoC SCR(t) CoC: 6% over risk free t 1 ES at t=0 does not enter calculation of the market value margin necessary at t=0 risks taken into account for 1-year risk capital and market value margin are completely disjoint and there is no double-counting SCR with portfolio converging from actual to replicating portfolio taking into account illiquidity of assets Sequence of Achievable Replicating Portfolios SCR with optimally replicating asset portfolio Achievable Replicating Portfolio has converged to Replicating Portfolio t=0 t=1 t=2 SCR: 1-Period (e.g. 1 year) risk capital = Expected Shortfall of risk-bearing capital t=3 Years Future SCR entering calculation of MVM at t=0 53

SST Concept: Cost of Capital Margin For the SST, the risk margin is defined as the market value margin which can be approximated by the cost of capital approach The cost of capital margin can be simplified using the following proxies: Best Estimate as proxy for residual (unhedgeable) financial market risk Best Estimate as proxy for credit risk Best Estimate for nonlife insurance risk Best Estimate for savings products (for life) Square Root of Best Estimate for stochastic risk (for life and P&C) Sum at Risk or PV of future claims for mortality and disability risk Incremental effect of scenarios: proportional to approximated SCR(t) Companies need to show that the proxies for the different components of SCR are reasonable 54 SST Concept: Cost of Capital Margin Year 0 1 2 3 4 5 6 200 1000 100 200

150 800 70 150 110 600 50 110 70 400 40 70 40 200 30 40 20 100 20 20 10 0 10 10 2.00 1.73 1.48 1.18

0.89 0.63 0.45 15.00 12.00 Proxies Best Sum Best Best Estimate Insured Estimate Estimate Stochastic Risk Savings Products Risk Products Market Risk SCR Components SCRstoch SCRsav SCRrisk SCRmarket Aggregation Risk + Saving assume full dependence + Stoch assume independence + Market assume independence SCR without scenarios Scenarios

Final SCR with scenarios Discounting Discounted SCR 9.00 6.00 3.00 1.50 0.00 5.00 3.50 2.50 2.00 1.50 1.00 0.50 10.00 7.50 5.50 3.50 2.00

1.00 0.50 20.00 20.10 22.45 22.45 15.50 15.60 17.31 17.31 11.50 11.60 12.83 12.83 8.00 8.09 8.81 8.81 4.50 4.59 5.00 5.00 2.50 2.58 2.77 2.77 0.50 0.67 0.84 0.84

2.00 1.54 1.14 0.79 0.45 0.25 0.07 24.45 18.85 13.98 9.60 5.45 3.01 0.91 0.94 0.92 0.89 0.86 0.84 24.45 18.30 13.17 8.78

4.84 2.60 0.76 1.00 0.97 55 The SST Concept: Scenarios Ersatz experience is a better guide to the future than the real past and present, Hermann Kahn in On Thermonuclear War Scenarios can be seen as thought experiments about possible future states of the world. Scenarios are not forecasts, in that they need not predict the future development, but rather should illuminate possible but perhaps extreme situations. Scenarios are also different from sensitivity analysis where the impact of a (small) change of a single variable is evaluated. Alternate states of the world Current state of the world 56 The SST Concept: Scenarios

The formulation and evaluation of the scenario should not be a compliance exercise but will entail a detailed and comprehensive discussion not only of primary but also of secondary and tertiary effects. Example: A scenario Earthquake in Tokyo should not only specify the financial impact due to loss of life and to the collapse of buildings, but also discuss the implication on the financial markets (e.g. the collapse of the global financial market for a given duration, the effect on global markets of Japan having to rebuild the infrastructure, etc.). Example: A scenario Dirty Bomb in European City should not only specify the financial impact due loss of life but should in addition discuss the impact on real estate prices, airline travel, financial markets, consumer confidence, long term effects on mortality and morbidity, The formulation of the scenario should comprise a) the event occurring during the following year b) the effects of the scenario in the future 57 The SST Concept: Scenarios Historical Scenarios: Stock Market Crash 1987, Nikkei Crash 1989, European Currency Crisis 1992, US Interest Rates 1994, Russia / LTCM 1998, Stock Market Crash 2000 Default of Reinsurer: Reinsurer to which most business has been ceded defaults Financial Distress: Increase of i.r., lapse, no new business, downgrading of company,

Personal Accident: large accident during company outing or mass panic in soccer stadium Deflation: decrease of i.r. Anti-selection for Health Insurers: all insured with age < 45 lapse Pandemic: Flu Pandemic with given parameters (e.g. number of death, sick-days, etc.) Industrial Accident: Accident at chemical plant Collapse of a dam (Swiss specific) Terrorism Longevity Global Scenarios (for groups&reinsurers) Reserving: Provisions have to be increased by 10% Property Cats (earthquake, windstorm) Hail (Swiss specific): Given footprints Special Line Cats: Aviation (2 planes collide, marine event, energy event, credit&surety event 58 Standard Models: Calculations Company specific calculations necessary for the SST are: Market consistent valuation of assets and liabilities with valuation of

relevant options and guarantee The cash flows of assets and liabilities Sensitivities to different risk factors Financial market risks Biometric risks and Option Exercise Estimation of reserving risk Estimation of stochastic risk for current and previous year risk Estimation of parameter risk for certain LoBs Probability distributions of large claims for different lines of business Aggregation (using correlations, convolutions etc.) Evaluation of pre-specified scenarios and definition and evaluation of company specific scenarios Company-specific parameters have to be used if the values supplied by the regulator do not reflect the company situation, e.g. equity volatilities. 59 Experiences from Field Test 2005 The SST is not simple but was perceived by most participating in the field test 2006 to be doable. Many commented that a simplification would make the results less relevant. The SST was done by 45 companies, ranging from very small insurers to large groups. Skandia assesses the adequacy of its available economic capital annually by carrying out an analysis of its main risk exposures and resulting required capital levels according to the Swiss Solvency Test. Skandia, Annual Report 2005 For our risk and investment strategy we need to be able to quantify the cash flow structure and the risk bearing capacity of our portfolios. For this the SST is a good (although in many aspects still to be modified and enhanced) basis. In addition, we can use the SST to test capital requirements for alternative investment strategies. As we have not yet an equally well suited internal model, the SST is

for us of great benefit. We see it as an integral part within our ALM process. Comment by Ren Bhler from the National Versicherung, a mid-sized insurance group. Wir haben diesen Sommer viel gelernt ber unser Versicherungsgeschft und ber die Bedeutung von einzelnen Zahlen. Es gab viele Diskussionen ber Kennziffern usw. welche zu einem Wissensaufbau in unserer Geschftsfhrung fhrten und dazu beitragen werden, dass wir die Gesellschaft mit noch besseren Entscheidungsgrundlagen fhren knnen. Die Ergebnisse aus dem SST-Testlauf nutzen wir auch fr Diskussionen mit dem Verwaltungsrat (es gibt eine zustzliche Sicht auf den Vermgensstand und den Geschftsverlauf). Ich bin berzeugt, dass der SST die Fhrung von unserer Gesellschaft zuknftig untersttzen wird. Die Aufsicht lieferte uns dementsprechend ein weit ausgebautes Fhrungshilfsmittel. Comment by Martin Rastetter from the Metzgerversicherung a small-to-midsized nonlife company with approx CHF 160Mio tech. provisions 60 Results of the Field Tests: Hidden Reserves In most cases, market consistent valuation releases substantial 1.4 1.4 amounts of hidden reserves to risk bearing capital Nonlife Statutory Assets

1.2 (=100%) Statutory Reserves 1.2 (=100%) 1 1 0.8 0.8 0.6 0.6 0.4 0.4 0.2 0.2 0 0 0.2 0.4 0.6

0.8 1 1.2 1.4 1.6 Market Consistent Valued Assets 1.8 0 Life 100% 02 0.2 0.4 0.6 0.8 1 1.2 1.4 1.6

1.8 Market Consistent Reserves (discounted best estimate + market value margin) 61 Results of the Field Tests: Solvency Ratios The Statutory Solvency Ratio is only a weak predictor for the SST Solvency Ratio For nonlife companies, Spearmans Rank Correlation is approx 0 and for life companies Spearmans Rank Correlation is approx 0. 5 Nonlife Life 62 Results of the Field Tests: MVM Market Value Margin / Best Estimate vs Market Value Margin / ES[RBC], based on provisional data of Field Test 2005 0.7 X-axis: MVM divided by best estimate of liabilities Y-axis: MVM divided by 1-year risk capital (SCR) MVM / Best Estimate vs MVM / 1-Year Risk Capital Nonlife Life 0.6

Life companies writing predominately risk products 0.5 0.4 0.3 0.2 Life companies writing predominately savings products 0.1 0 0 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08

Market Value Margin / Best Estimate 63 Contents Global Regulatory Trends Risk Management Risk Based Solvency Models Swiss Solvency Test Internal Model Challenges for Supervision Definition Internal Models: Acceptable vs Unacceptable Review Transparency Group Effects Appendix 64 Internal Models: Definition A model is a framework to discuss economic capital The point of the model is not (solely) the calculation of economic capital but to have a common framework for discussion of risks, of dependencies, of links between different areas of the business etc. It consists of : Methodology: Assumptions, models, mathematics, mapping of the real world to a conceptual framework, Parameters: estimates, mortality

tables, claim size estimates, Data: Position data, data on financial instruments, insurance policies, Implementation: Software code, IT platforms, data warehouses, Processes: Testing, back-testing, falsification, plausibilisation, estimation, Some supervisors show reluctance for the use of internal models. However, internal models have been used since the beginning of insurance for valuing technical provision. The difference of calculating provisions to an internal model used for economic capital calculation is only that the former is often done without a formalized algorithmic process. 65 Internal Models: Challenge When allowing internal models for target capital calculation, the problems a regulator faces are: Internal models for the SST have to be used by: How to ensure that the results are comparable between different companies How to ensure, that a company is not punished if it models risks more conscientiously than its peers

How to be able to distinguish between acceptable and not acceptable models How to be certain that a model is deeply embedded within a company Captives (those which have to do the SST) (~10-15) Reinsurers (~20) Groups and conglomerates (10-15) Legal entities with substantial amount of business written by foreign branches (~10-15) Insurers, for which the SST standard model is not applicable (?) Life insurers writing substantial options and guarantees linked to financial market (in discussion) (~5-10) Some small and mid-sized companies already indicated that they will develop partial- and full internal models in order for the SST calculations to be better integrated within the companies processes In addition, the determination of technical provisions is done via a internal model 66 Internal Models: Challenge For some type of insurers, models are often assumption driven: Up to 90% of the economic capital requirement due to insurance risks emanates from assumptions and only 10% from historical data: models can often not be back-tested; The review has to rely less on formalized requirements as for VaR market risk engines; The assessment of models has to rely more on experience, comparison with similar models and embedding of the model within the company

The regulatory review of models will rely heavily on discussions with quants and actuaries, assessment of companys know-how of the model and its limitations and public transparency There are limits on what a regulator can demand from internal models of insurers and reinsurers: Model verification is impossible Falsification is in many cases unpractical The scientific method cannot be formalized. There can be no set of guidelines codifying the model approval process We need to accept that some properties of a model cannot be proven statistically (e.g. some dependency structures, some parameters) Models can, however, be persuasive 67 Acceptable and Unacceptable Models Acceptable Models Clearly stated and understood assumptions Clear on idealizations and simplifications Transparent on which effects are neglected All relevant risk factors are taken into account The model relies not purely on historical data but aims to model the future risks using theory, scenarios, expert opinion etc. The model is tested

Unacceptable Models Theory is misapplied Pure statistics, no explanation Hidden and unclear assumptions Too many simplifications The model is not tested against the real world Inappropriate or stale parameters The model is not sufficiently understood within the company The model is regularly challenged, and compared against industry best-practice 68 Internal Models: Review Even worse than having a bad model is having any kind of model good or bad and not understanding it If internal models are used for regulatory purposes, it will be unacceptable if the model is not understood within the company Senior management is responsible for internal models and the review process. The review of internal modes will be based on 4 pillars There needs to be Internal Review; deep and detailed knowledge by the persons tasked with the upkeep and improvement of the model

External Review; Review by the Supervisor; Public Transparency. Knowledge on the underlying assumptions, methodology and limitations by the CRO, appointed actuary etc. The regulator is responsible for ascertaining that the review process is appropriate Sufficient knowledge to be able to interpret the results and awareness of the limitations by senior management and the board Companies using internal models have to disclose publicly the methodology, valuation framework, embedding in the risk management processes etc. 69 Internal Models: Public Transparency A little light dispels a lot of darkness. Rabbi Schneur Zalman The public disclosure requirements on internal models should be principles based. The amount of information to be disclosed should be based on the principle that a knowledgeable person can get a reasonably good impression on the basic methodology of the internal models as well as on the major design decisions. In particular a description of the following main features should be provided: valuation methods (for assets and liabilities); risk measure; criteria for the choice of parameters and distribution functions; major scenarios and risk factors and the assumptions on their dependencies;

aggregation methods; embedding into the company's risk management processes; scope of the model and which relevant risks are not quantified. 70 Internal Models Further Development of Internal Capital Models: Modeling of intra-group risk and capital transfer instruments, allowing analysis of group structure on capital requirement of group and legal entities True multi-year models, taking into account business and asset allocation strategy Modeling of underlying, relevant risk factors on assets and liabilities, dependency structure will emerge naturally via dependency between risk factors rather than via correlation matrices between risk types Set-up to allow more flexibility to analyze results for sub-portfolios (e.g. lines of business, risk types, legal entities, management units, sub-groups,) 71 Contents Global Regulatory Trends Risk Management Risk Based Solvency Models Swiss Solvency Test Internal Model Group Effects Group Level Diversification Consolidated View Group vs. Solo Requirements Group: Unconsolidated

Appendix 72 Group Effects Increasing Organizational Level Different levels of diversification: Group Level Diversification benefit similar as for branches but reduced fungibility of capital has to be taken into account Diversification benefit between different branches: geographical diversification but interdependencies due to cats, economic drivers and financial risks Diversification benefit between different LoBs: due to independence of losses but interdependencies due to common economic drivers, common claim events Diversification benefit within portfolios: driven predominantly by the law of large numbers Subsidiaries Legal Entity Level Branches Company Level Lines of Business Portfolio Level Single Risks

Product Level Increasing relative diversification benefits 73 Group Effects What is diversification? Consider two portfolios A and B. Let R(A) and R(B) be the risk capital necessary for portfolio A and B respectively. Assume R(.) is a risk measure. Then, if R(A+B) < R(A)+R(B), i.e. if the necessary risk capital for the combined portfolio is less than the sum of the risk capitals necessary for portfolio A and B, there is diversification between portfolio A and B Note that diversification depends not only on the portfolios A and B but also on the risk measure R(.) For groups, diversification relates to the fact that the sum of the solvency requirement of all subsidiaries of the group (considered as stand-alone companies) is higher than the total group capital (if the group is considered consolidated) Capital requirements of legal entities of the group Diversification Effects Capital requirement of the group reduced due to diversification benefits Capital requirements for subunits reduced by allocated diversification benefit

To allocate this diversification benefit to the subsidiaries is questionable: A consolidated group capital requirement is not necessarily a realistic requirement, and the allocation method needs to be specified 74 Group Effects: Consolidated Approach With the consolidated approach, all asset and liability portfolios of all legal entities of a group are (conceptually) merged. Capital of LE2 Implicit assumptions: If a legal entity LE1 of the group has a financial loss, the rest of the group (LE2,,LEn) transfers capital Capital of LE1 Capital which flows from LEk to LE1 is assumed to be proportional, i.e. CapitalFlow(LEk)=Loss(LE1)/(Capital(LE1)++Capital(LEn)) Legal Entity 1 This occurs irrespective of the existence of a legally binding instrument (e.g. a guarantee or retrocession) between LE1 and LEk. Logically, if LEk has to do a solo-solvency test, the possibility of capital flow away from LEk has to be taken into account group risk for LEk Capital of LE n Legal Entity k Capital of LE2 Capital of LE n

Capital of LE1 Legal Entity 1 Legal Entity k 75 Group vs. Solo Supervision Two Methodologically Consistent Frameworks for Group and Solo Requirements: Group Supervision: Assume unlimited capital transfer between the legal entities of the group even if no formal risk and capital transfer instruments are in place consolidated calculation Solo Supervision: Assume unlimited capital transfer in case of financial problems in the rest of the group even if no formal risk and capital transfer instruments are in place group risk Group Supervision: Assume capital transfer only via formal risk and capital transfer instruments Solo Supervision: Assume capital transfer only via formal risk and capital transfer instruments Formal risk and capital transfer instruments Assumed unlimited capital transfer 76 Group: Unconsolidated A group is defined not only by its legal structure but also by its web of intra-group capital and risk transfer instruments

Intra-group risk and capital transfer instruments allow group-level diversification to be realized and allocated to legal entities Intra-group retrocession, contingent capital issued and received, etc. Fungible capital Legal Entity 3 Limited fungibility of capital due to regulatory restrictions have to be considered Intra-Group Capital and Risk Transfer Instruments: Intra-group Retrocession Guarantees Participations Dividends Loans Parent Company Market Value Margin Legal Entity 1 Group securitization of future cash flows / earnings

Issuance of sale / liquidation surplus notes of a business Legal Entity 2 Intra Group Capital and Risk Transfer Instruments can only be considered if they are legally binding and acceptable to the regulators involved 77 Group Supervision Risk based capital systems in different territories will accelerate the need for a harmonization of group supervision In order for groups to allow consistent models on both group and legal entity level, harmonized methodological requirements and a review framework needs to be in place Differing methodological requirements between group- and legal entity levels and between different jurisdictions will lead to legal entity level models which will be used solely for regulatory purposes and which will not be integrated in companies process, making them effectively useless for companies and supervisors FOPI aims to have a framework for group-level SCR, which is acceptable internationally, in particular for Solvency 2 FOPI strongly supports the concept of a lead supervisor to ensure the consistency of the review and approval processes 78 Contents Global Regulatory Trends Risk Management Risk Based Solvency Models Swiss Solvency Test

Internal Model Group Effects Appendix IAIS Cornerstones CRO Forum Principles for Financial Risk Mitigation CRO Forum Principles for the Use of Internal Models Definition of Market Consistent Valuation 79 Cornerstones IAIS Cornerstone I: the solvency regime addresses the robustness of the insurer to meet its liabilities both short term and over a longer time span. Cornerstone II: the solvency regime is sensitive to risk, and is explicit as to which risks, individually and in combination, lead to a regulatory financial requirement and how they are reflected in the requirement. Cornerstone III: the solvency regime is explicit on how, for each of the risks that attract a financial requirement, individually and in combination, prudence is reflected in these requirements. Cornerstone IV: the solvency regime requires a valuation methodology which makes optimal use of and is consistent with information provided by the financial markets and generally available data on insurance technical risks. Towards a common structure and common standards for the assessment of insurer solvency, IAIS, Draft Version, Oct. 2005 80 Cornerstones IAIS Cornerstone V: the solvency regime includes the definition of technical provisions. Technical provisions have to be prudent, reliable, and objective and allow comparison across insurers worldwide. Technical

provisions include an explicit risk margin. Cornerstone VI: the solvency regime requires the determination of a best estimate of the costs of meeting the obligations arising from the insurance portfolio, taking into account the time value of money, determined by reference to the relevant risk free interest rates on the financial markets Cornerstone VII: the solvency regime establishes a range of solvency control levels and the supervisory instruments associated with each of the control levels. Cornerstone VIII: the solvency regime allows a set of standardised and more advanced approaches to determine the solvency requirements, and includes the use of internal models if appropriate. Towards a common structure and common standards for the assessment of insurer solvency, IAIS, Draft Version, Oct. 2005 81 Risk Mitigation: CRO Forum Principles Principle 1: Provide the right incentives Solvency II should provide incentives for sound risk mitigation strategies. Principle 2: Sound risk management framework is a precondition A precondition for the use of financial instruments for risk mitigation is a sound risk management framework for the company. Principle 3: Focus on the process, not the instrument The admissibility of financial instruments for risk mitigation should be based upon the soundness of the risk hedging process. Restrictions on the use of financial instruments for risk mitigation cannot follow a one size fits all approach (e.g. a list of admissible and inadmissible financial instruments). Principle 4: Equal yardsticks for qualifying financial instruments Qualifying financial instruments used for risk mitigation purposes should receive full and unrestricted capital credit under Pillar I of Solvency II. The credit given for financial instruments used for risk mitigation under Pillar I, should be based on the documented and evaluated economic effect on both the valuation of assets and liabilities and the determination of the MCR and SCR. Financial Risk Mitigation in Insurance - Time for Change, The Chief Risk Officer Forum, Risk Mitigation Working Group 82

Risk Mitigation: CRO Forum Principles Principle 5: Supersede legacy rules Determination of capital requirements for solvency purposes under Pillar I of Solvency II or under Solvency I should be based entirely on economic principles if the insurance company can demonstrate that it has a sound risk management framework (Principle 2) and that it is using financial instruments for risk mitigation satisfying the requirements of Principles 3 and 4. Principle 6: Consistent treatment in statutory accounting Under the statutory accounting regime, the asset valuation rules in respect of financial instruments used for risk mitigation purposes must be consistent with the valuation rules in respect of the liabilities they are designed to hedge. Financial Risk Mitigation in Insurance - Time for Change, The Chief Risk Officer Forum, Risk Mitigation Working Group 83 Internal Models: CRO Forum Principles A set of principles which according to the CROF internal models need to satisfy to be acceptable for regulators for use of regulatory capital calculation. Principle 1: SCR should be set to ensure a standardised likelihood of economic loss to policyholders. 1.1 SCR should be based on the economic value of liabilities and the insurers risk profile, and should be independent of accounting liabilities. 1.2 The level at which the MCR is set should not interfere with the operation of the SCR, and should strike a balance between being linked to the economic value of liabilities and their risk in a transparent manner, and allowing for continuous monitoring and the need for a legally certain trigger for intervention. Principle 2: Internal models need to be based on the adverse movement in the Economic Value of (Assets Liabilities), calibrated to a target annualised 99.5% probability of solvency. 2.1 Economic Value defined as The present value of future cash flows, valued in such a way as to be consistent with current market prices where these are available and reliable for unhedgeable, undiversifiable risks, a market value margin (MVM) should be applied to the best estimate cash flows in order to obtain the price that a willing, rational and welldiversified counterparty would charge for taking on the risk. 2.2 Modelling approaches based on longer time horizons or alternative risk measures (e.g. TailVaR) should be admissible, as long as the calibration approach used is consistent with

an annualised 0.5% probability of economic insolvency. Chief Risk Officer Forum Principles for Regulatory Admissibility of Internal Models, June 2005 84 Internal Models: CRO Forum Principles Principle 3: All material risks that can affect the balance sheet should be explicitly modelled. 3.1 All sources of market risk need to be modelled probabilistically with embedded options and guarantees, management actions and policyholder behaviour explicitly modelled where material through simulation modelling, and inter-risk dependencies explicitly modelled and parameterised. 3.2 All sources of credit risk (investment credit risk, reinsurer / derivative counterparty risk, credit insurance risk) must be modelled probabilistically and aligned with the principles of Basel II, taking account of default risk, migration risk and spread risk. 3.3 Insurance risk modelling approaches should be tailored to the type and magnitude of the risk: Life and health risks should include parameter (level and trend), process and calamity risk, the modelling of which should take into account scientific analysis, expert opinion and analysis of historical experience. Non-Life risk should cover both premium risks and reserve risks modelling should be appropriate for the nature of the risk under consideration e.g. frequency-severity methodologies for large losses and perils and the modelling of non-proportional reinsurance, scientific / expert-opinion driven scenarios for weather, geological and environmental risks etc. 3.4 Operational risk to be incorporated in a manner aligned with the principles of Basel II 3.5 Risk aggregation to explicitly account of inter-risk dependencies, estimated based on tail dependencies Chief Risk Officer Forum Principles for Regulatory Admissibility of Internal Models, June 2005 85 Internal Models: CRO Forum Principles Principle 4: Implementation of the internal risk model must be such that it is used as part of business as usual 4.1 Full risk calculations with the risk model itself assessed and refined at least on an annual basis, with calculation updates computed at least quarterly 4.2 Comprehensive documentation, formal internal sign-off and regulatory sign-off

processes in place 4.3 The internal risk model must be used for capital allocation and as an input into performance measurement, and consequently management compensation 4.4 Validation and reconciliation of data carried out by independent 3rd party Chief Risk Officer Forum Principles for Regulatory Admissibility of Internal Models, June 2005 86 Market Consistent Valuation: Definition The valuation of a company's (or person's) financial claims and obligations is said to be market consistent, if it is based on and is consistent with the public financial markets participants' assessment of value and risk, which is derived directly or indirectly from the observed prices at which instruments are traded in these public financial markets. The understanding of some elements is key to the definition: The prices that underlie the assessments are those that are achieved in public markets. The public aspect is critical in order to get close to an "efficient arbitrage free market". In particular the market participants must have the opportunity to exploit any price inefficiencies at any time. The price observed might not directly imply the required value: obviously transaction and other costs have to be considered, but also the price observed represents the instrument's value for the seller and a purchaser, which might differ for a third party, because some risks, rights or obligations impact the third party differently. Assume, for example, a bond investor's claim on a bond issuer. The bond investor will value the credit risk of the issuer, because she considers the possibility that the issuer fails on its obligation. The corresponding default option is held by the owner of the institution that issued the bond. Consequently, the bond issuing debtor will have to add the value of its own credit risk to the market value of the bond, when valuing this obligation for its own balance sheet. (A good test is the accounting principle that double entries have to match; in other words, accounting itself cannot create value.) 87 Market Consistent Valuation: Definition Consistency means that a knowledgeable person, knowing how to assess financial claims and obligations, would transact her assets and liabilities neither at higher nor lower prices than those achievable in the public financial markets. The knowledge that might be needed comprises the ability to discern the various risks that might or might not be valued by the

public financial markets. Assessment in the definition refers to all quantitative and qualitative methods known to analyse financial market prices. If the public financial market does not value a claim or an obligation or a part / component of it then the value assigned to it will be intrinsic, i.e. depending on legal entity specific factors. The above is the definition of market consistency and some explanation for how to interpret it. It will be the accountant's or actuary's task to apply the definitions to the valuation of the various assets and liabilities that are found in a financial institution. The most prominent example for an insurance company is of course an insurance contract. The result of such an analysis would reveal that an insurance contract's value consists of the "risk neutral" expected value of the conditionally expected cashflows, conditional on all future financial market prices. The cashflows to consider comprise all "inflows" and "outflows", i.e. all contractually agreed premium income, all claims payments and expenses, fees and costs for any resources required to manage and administer the contractual obligations. In particular, among the costs are those for the resource used to buffer risk. Whereas the conditionally expected cashflows can be replicated for the difference between the actual cashflows and the conditionally expected cashflows one needs risk capital, the cost of which has to be recognized in the valuation. Definition by Hans Peter Wrmli 88

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