Here we review recent GC Capital Ideas posts examining the benefits to (re)insurers adopting Own Risk and Solvency Assessment (ORSA) standards.
Posts Tagged ‘ORSA’
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Addressing Own Risk and Solvency Assessment/Enterprise Risk Management and Insurance Capital Standard Globally
In accordance with the objectives of the National Association of Insurance Commissioners (NAIC) and European Insurance and Occupational Pension Authority (EIOPA), Own Risk and Solvency Assessment (ORSA) is “people and risk-centric,” primarily employing a principles-based approach, as opposed to a rules-based approach. This means that decisions on matters related to risks are largely based on the judgment of individuals relying on underlying facts, as opposed to decisions being made mostly by following intricate sets of rules. This is similar to the principles-based approach taken by International Financial Reporting Standards (IFRS). Although the calculation of the Solvency Capital Requirements (SCR) under Solvency II is rules based, like Insurance Capital Standard (ICS), Solvency II can be a “one size fits all” rules-based approach to capital, especially if the standard formula is used. (Re)insurers will need to find a way to incorporate ICS into their ORSA processes and the vehicle to accomplish this may be through the internal model.
(Re)insurers that are required to implement Own Risk and Solvency Assessment (ORSA), or a similar framework such as Internal Capital Adequacy Assessment Process (ICAAP), may benefit by adopting a strong ORSA/enterprise risk management (ERM) framework. One such framework that could work on a global basis is illustrated below.
Own Risk and Solvency Assessment (ORSA) was first introduced as a regulatory requirement as a result of Solvency II. (Re)insurers would be wise to take note of the many similarities between Solvency II and the National Association of Insurance Commissioners’ (NAIC) ORSA and, where possible, avoid reinventing the wheel when trying to implement them. Now, and especially with the introduction of the Insurance Capital Standard (ICS), it is increasingly important for (re)insurers to avoid unnecessary, redundant and duplicative activity in the attainment of regulatory satisfaction by striving for a uniform framework to establish risk management and controls, corporate governance, transparency and disclosures across borders. In so doing, (re)insurers will gain optimum value from their ORSA.
There is very little doubt that (re)insurers face and will continue to face growing regulation and scrutiny both domestically and internationally. Therefore, (re)insurers should seek the most effective and efficient way to meet the growing demands of increased global regulation. What follows below is a brief discussion of the overlap of some of these new global regulatory requirements and thoughts on how (re)insurers might go about approaching them.
Other countries, such as the Philippines and Indonesia, have instituted rules that may, conversely, impede the development of a healthy, profitable insurance market. The Indonesian regulator’s recent steps to reduce capital outflows, with a focus on reinsurance premiums ceded to international reinsurers, remain highly debated and will be explored in greater detail later. The Philippines, in addition to a risk-based capital (RBC) framework, has instituted a minimum paid-up capital requirement (starting in 2006 and revised in 2013) that increases every two years and will result in a PHP2 billion (approximately USD44 million) minimum threshold in 2020. This will put minimum capital levels in the Philippines well above those of more developed markets, including Australia, Japan and Singapore. The policy applies uniformly across the industry regardless of premium volume, line of business or geographic scope and therefore its impact is more strongly felt by smaller carriers that will most likely be forced out of the market or into the arms of larger players. The Philippines Insurer and Reinsurer Association (PIRA) has been outspoken against the minimum capital requirement and stated a preference for a standalone RBC metric.
Asia Pacific is a diverse mix of countries encompassing nearly one-third of the earth’s landmass and more than one half of its population. Given the broad spectrum of economic and regulatory sophistication across the region, the approach to insurance regulation has varied on a country-by-country basis as each regime adapts solvency principles to their own needs and political realities.
The National Association of Insurance Commissioners (NAIC) has stipulated that “the solvency framework of the U.S. system of state-based Insurance regulation has included a review of the holding company system for decades, with an emphasis placed on each insurance legal entity. In light of the 2008 financial crisis and the globalization of insurance business models, as discussed in this report, U.S. insurance regulators have begun to modify their group supervisory framework and have been increasingly involved in developing an international group supervisory framework (1).”
The Own Risk and Solvency Assessment (ORSA) requirements are the key element of the Pillar 2 qualitative risk management requirements. The purpose of an “own risk assessment” by each company is to prove the appropriateness of the standard formula or internal model results if the company has applied for a certified internal model. While the Pillar 1 solvency capital requirement is calculated on a one-year basis to show that a company has enough capital to avoid insolvency through the end of the year in a 1-in-200 year event, the focus in Pillar 2 ORSA is the forward-looking assessment of solvency capital adequacy. Companies need to provide a projection of the risk and capital position for the entire planning period (at least three years), which has to be consistent with the business case balance sheet and profit and loss projection. The aim of ORSA is to demonstrate that there is an adequate level of capital available to support the business plan for a longer period. Based on this planning projection of the risk and capital position, (re)insurers need to define meaningful stress tests and scenarios to show they would be adequately capitalized in adverse scenarios as well. If a company would face solvency issues in certain stress scenarios, it needs to show it has countermeasures in place in order to reach the strategic targets of the corporate and risk strategy again.