2012 05 03 Kpmg Solvency Ii Still Fit For Purpose

financial services

Solvency II Programme:

Still fit for purpose?

Highlights from our General insurance survey

April 2012

kpmg.co.uk/solvencyii

http://www.kpmg.co.uk/solvencyii

Foreword

It’s been a rollercoaster ride for all those involved in trying to implement Solvency II, but perhaps some of the greatest uncertainties and challenges have been, and remain to be, around the Solvency II balance sheet, internal model and actuarial function. Hence, we felt the time was right to establish how firms are currently addressing some of these issues that are still prevalent.

Twenty companies participated in this survey and I would like to thank them for taking the time to respond. I hope that the results and the KPMG views expressed will help you address some of the key challenges as you work towards Solvency II compliance and extracting value from the process.

Roger Jackson Partner, Solvency II, Risk Consulting Lead

© 2012 KPMG llP, a UK limited liability partnership, is a subsidiary of KPMG europe llP and a member firm of the KPMG network of independent member firms affiliated with KPMG international cooperative, a swiss entity.

Contents

Executive summary 4

The Strategic view 6

The Operational view 8

The Finance view 10

The Actuarial view 12

Beyond Solvency II 16

Conclusions 19


4 | sOlvency ii PrOGraMMe: still fit for purpose?

Executive summary

for most firms solvency ii projects are entering their final stage, focussing on improving data quality and processes. However, our general insurance survey provides a wake-up call that technical issues remain and that these issues urgently need to be resolved if firms want to see: Boards that are truly engaged; finance functions that are able to manage the business incorporating solvency ii accounting; and actuarial functions that are perceived as vital to the sound management of insurance operations.

The key messages emerging from the survey are:

Demonstrating a level playing field will be key to engaging Boards to truly use internal models in support of strategic business decisions

solvency ii has significantly increased the complexity of technical modelling within firms. However, these models continue to rely on expert judgment and assumptions for which statistical validation is unlikely to ever provide the certainty required by some stakeholders – for instance tail correlations that are intended to reflect how multiple parts of the business will perform following an adverse event.

in the absence of credible statistics, we believe market wide analysis that is able to demonstrate a level playing field for key assumptions is required if Boards are truly to engage and use internal models for business decisions.

Lack of awareness in Finance around technical issues

The technical details within the solvency ii Balance sheet continue to largely be understood within the actuarial rather than finance functions. it is critical that finance functions gain awareness and an understanding of the intricacies of the new accounting basis if a firm is to realise any benefit.

Until this happens, business decisions will continue to be based on current reporting bases, rather than the solvency ii basis. Hence, if any real benefit is to be gained from the new solvency ii basis, and the internal model to which it is aligned, a timely and transparent conversion from one to the other will be necessary. This conversion will also need to consider implications on business planning, ensuring alignment between the planning process and capital reporting requirements.

Little consistency in Governance structures and co-ordination of the Actuarial Function

With no clear regulatory guidance there is little consistency in the Governance structures that firms have implemented around the actuarial function.

The two most prominent Governance models reflect a trade-off between ensuring alignment in the view of risk within the actuarial function (all the actuarial function under one roof) and minimising possible conflicts of interest (capital actuaries’ report to a separate Board member).

Our view is that there are significant benefits to aligning the main actuarial functions under one coordinated function holder, whilst providing a strengthened 3 lines-of-defence validation framework that is transparent and provides sufficient challenge.

Real concern regarding the calculation of the 1-year view and the risk margin

Our survey suggests wide-spread concern regarding the calculation of the 1-year view as well as the risk margin. Whilst more research is required, communication with the finance function will be critical over the coming months if actuaries are to retain a strong presence in managing the business. Transparency, and removing complexity where it cannot be shown to provide additional insight, will be important to ensure success.


Stefan Claus Director, General Insurance Capital Management

sOlvency ii PrOGraMMe: still fit for purpose? | 5

Polarised views on the merits of capital allocation

Our survey highlighted polarised views on the merits of capital allocation and hence whether it is an area to focus resource.

Our view is that provided the process for allocation is aligned to the Board’s risk appetite and a sound, consistent methodology, then capital allocation can facilitate behaviours that are beneficial to the business.

However, this can be very difficult to achieve in practice as it requires the right business culture together with a pragmatic view towards how to allocate capital.

Our survey highlights numerous issues not all of which may be relevant to your firm. However, with at least one further year to implementation, and with the release of the FSA’s new IMAP approach, now is the time to take stock and reflect whether the priorities and the focus of your Solvency II programme continue to be appropriate.Tackling difficult technical issues now will assist Board buy-in and enhance credibility further down the road.

Now is the time to refocus, reprioritise or reaffirm your Solvency II Programme activities!


© 2012 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG Europe LLP and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity.

6 | SoLvENCy II PRoGRAMME: Still fit for purpose?

The Strategic view

…more analysis, including market studies are required to ensure Management Boards gain comfort over the results of their internal model

As Solvency II implementation moves into its final phase, Boards are increasingly focusing on the business implications and appreciating the important role of the internal model in assessing business plan scenarios and determining strategic direction.

The results of our survey show that firms are expecting to increasingly use their internal models as part of the business planning process, see Figure 1 below, by typically providing a more explicit view on the risks

incorporated within a particular plan (the ‘Risk view’). This usually involves assessing the business plan against the Board’s risk appetite, where this has been articulated in terms of a risk distribution from an earnings and/or capital perspective. This information can then be used to inform the decision around the optimal business plan and hence the strategic direction of the firm. Indeed, Figure 1 shows that most firms in our survey are seeing the capital model as a key driver in the planning process and therefore strategy.

Figure 1 – Internal Model influence over the Business Plan

6%

Perc

enta

ge o

f Com

pani

es 100%

80%

60%

40%

20%

–

Now

Not at all

Minor

Post Solvency II

Reasonable Consideration

Key Driver in Planning Process

Source: KPMG LLP (UK) 2012

Before internal models can be properly incorporated into the business planning process several implementation issues will need to be addressed. The business plan will be on a GAAP or IFRS basis reflecting the investor view, in order to get to the ‘Risk view’ a conversion to the Solvency II

accounting basis is necessary. However, this is contrary to the view of some finance functions (the ‘Finance view’), who are struggling to implement the Solvency II accounting basis and view this new basis as purely a regulatory exercise in a similar way to the current FSA Returns.

Paul Merrey Solvency II Strategy

SolvEnCy II PRoGRAMME: Still fit for purpose? | 7

KPMG View

We believe that in order for the internal model to inform the strategic view, Boards of Non-Life firms will need to: • Ensure they are comfortable with

the results of their internal model for the purposes of informing them on risk appetite. More analysis, including market studies, may be required as a result.

• Start viewing Solvency II accounting as a basis for risk management in addition to a regulatory exercise. To do so, Boards will need to be able to quickly switch between the Finance view, through the lens of GAAP/IFRS accounting, and the Risk view, via Solvency II accounting.This is likely to be more challenging for Non- Life firms, as Life firms have had to consider the twin bases of GAAP/IFRS and Embedded value for several years now.

• Develop a clearly articulated Risk Strategy that links corporate strategy, risk appetite and performance management, thereby providing guidance to Divisions, defining the boundaries within which they can take on risk and enhancing the understanding and communication of risk and capital management throughout Divisions and with external stakeholders.



The Operational view

…differing views remain as to the optimum governance structure around the Actuarial Function

increased pressure to embed internal models within the business has resulted in many firms seeking to align Pricing, reserving and capital Modelling actuaries under one executive Officer (see figure 2).

This eases co-ordination & consistency and can help with establishing a single version of risk. However, according to our survey, a significant number of firms are uncomfortable at the increased risk arising from conflicts of interest, preferring instead to ensure that capital actuaries are more closely aligned with the risk function.

Figure 2 – reporting structures for Reserving, Pricing and Capital Modelling actuaries

64% 18% 18%

CFO/CRO CEO/CFO/CRO/Chief Actuary CFO/CEO CRO/COO CFO CRO/CUO

Reserving Pricing Capital Reserving Pricing Capital Reserving Pricing Capital

source: KPMG llP (UK) 2012

…the perfect opportunity to off-shore many Solvency II calculation and reporting aspects

KPMG View

There are significant benefits to aligning the main actuarial functions under one co-ordinated function holder. Particularly as the best in class insurers use pricing models not only to inform management on expected profitability of the in-force portfolio, but also to collate exposure that is used in capital-setting.

avoiding conflicts of interest can be achieved by:

• Ensuring actuarial roles within the actuarial function are confined to the assessment of risk rather than risk taking (for instance, ensuring Pricing actuaries restrict their activities to developing pricing tools and monitoring exposure); and

• Providing a validation framework that is transparent and ensures sufficient challenge.

Mark Winlow Partner, UK Head of General Insurance


At the more granular level the number of actuaries employed has never been higher, and our survey suggests that this is unlikely to fall (see Figure 3). Furthermore, additional and more technical reporting mean that our respondents forecast that actuarial resource will continue to be required at current levels for the foreseeable future. Indeed we are seeing an increase in actuarial support within finance functions that reflects the increased technical nature of the Solvency II balance sheet.

Figure 3 – Resource Adjustment following Solveny II Implementation

21%

11% 68%

Maintain

Reduce Headcount

Increase Headcount

Source: KPMG LLP (UK) 2012


SoLvEnCy II PRoGRAMME: Still fit for purpose? | 9

KPMG View

For those firms who’s management do not perceive any benefit from Solvency II other than achieving regulatory capital, we expect strong challenge of the actuarial cost base. In fact, many Boards may feel the current rigour around establishing robust processes and documenting these processes may provide the perfect opportunity to off-shore many Solvency II calculations and reporting aspects, with the aim to lower overall actuarial expense whilst maintaining the equivalent level of resource and quality.


The Finance view

…black box or overly complex models based solely on theoretical statistics can only harm the credibility of the Solvency II information

Financial reporting

The current focus of the finance function is in the development of stable processes and controls for financial reporting under solvency ii. Typically, firms are identifying necessary data requirements and leveraging newly built models to supply the additional requirements such as risk margins.

KPMG View

Our survey highlighted considerable concern in the industry on the calculation of certain key solvency ii Balance sheet items – such as risk margins (see figure 4). We believe early communication between the actuarial and finance teams on underlying issues and concerns is vital to avoid conflict and tension between these departments later on.

in addition, finance functions will expect credible explanations (for instance reflecting changes in the claims or economic environment) on movements over time – black box or overly complex models based solely on theoretical statistics can only harm the credibility of the solvency ii information with the finance department and senior management in the insurer.

One of the main challenges we are seeing in the market relates to analysing movements in own funds and the scr in sufficient detail to provide decision-useful information to both the management of the company and to external investors. Ultimately the cfO is responsible for this analysis, both in terms of external reporting through the publicly-available solvency ii reports and through management information, and will have a lead role in explaining and reconciling this information.

Figure 4 – Approach to calculating the Risk Margin (Future SCRs)

nies

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of c

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60%

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P – Using a Other full calculation individual risks

or sub risks proportional approach

(say or reserves)


Danny Clark Partner, Solvency II Pillar 3 Lead



Business planning

Business planning in most firms relies on a top-down view driven by the Board as well as a bottom-up assessment supported by actuaries. Whilst lloyd’s requires its syndicates to align these two views, there is no such requirement elsewhere.

Outside of lloyd’s we see a number of firms with one business plan for business steering and target-setting and a different business plan underlying their internal model.

The most common differences arise where firms have excluded extreme events from their business plan used for steering, but have included these events within their internal model, and hence true “best estimate”.

KPMG View

Where insurers have a business plan that is not aligned to the model best estimate, they need to consider the implications now to avoid adverse surprises and increased complexity later on.

To maintain this stance insurers will need to ensure their business planning systems can cater for a set of data to derive targets, whilst a slightly different data set will be used to derive technical provisions on a solvency ii basis.

Where business plans and actuarial estimates are not aligned we believe there will be regulatory pressure to provide transparency as to how firms have bridged this gap – ensuring that explanations for the bridge are credible and monitored regularly over the course of the year.

…one business plan for business steering and target-setting and a different business plan underlying the internal model

Figure 5 – Best Estimate of Profitability under the Model Adjusted to Fit the Business Plan

70%

s

60%

pani

e

50%

age

of c

om 40%

30%

erce

Pnt

20%

10%

– Other scaling of adjusting of scaling of

attritional loss Premium rates reinsurance estimates recoveries




The Actuarial view

1.The 1-Year View & Risk Margin in Financial Statements

Our survey suggests continued concerns on the modelling of the 1-year view and risk margins. The current trend for most of our participants was a move towards more simplified and transparent methodologies. However, two insurers stated that in the medium term they intend to adopt more complex approaches as they and their Board become familiar with the concepts.

Whether this will form part of a wider trend remains to be seen.

firms that stated they had no concerns in the calculation of the 1-year view did so on the basis that the results were not used for any business decisions. in all cases those firms admitted they would be concerned if these results were to be used in any meaningful way. in all cases, the 1-year view has not had any impact on the way any aspects of the general insurance business is managed.

Figure 6 – Which method do you use to establish the 1-year view of risk capital requirements?

nies

50%

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40%

30%

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20%

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10%

P – actuary-in- Other emergence Mertz-

pattern Wutherich the-Box approach


Figure 7 – Have results of the 1-year view been discussed with business?

nies

100%

mpa 80%

of c

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60%

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P – yes no


Figure 8 – Concerns on the calculation of 1-year view?

nies

100%

mpa 80%

of c

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60%

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40%

erce

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20%

P – yes no concerns


Gavin Dunkerley Senior Advisor, General Insurance



Figure 9 – Has the 1-year view requirement changed business management?

nies

100%

ompa 80%

of c 60%

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20%

P – no yes


KPMG View

complex models should only be used if they are sufficiently transparent, sufficiently well understood and can be shown to better reflect the underlying risks. some approaches to the 1-year view frequently fail all three criteria; hence it is not surprising that some in the market are reappraising their methods. We believe this is a positive step, as only by engaging and ensuring other departments buy-in to the changes will actuaries continue to have a strong influence on an insurer’s operations.

2. Capital allocations and risk appetite

Our survey indicates a significant range of return periods and methods for allocating capital. less than a quarter of those surveyed were basing their allocation on the regulatory minimum.

KPMG View

The range of return periods and the fact that several firms are still deciding on return periods indicates either a considerable difference in risk appetites or that firms are still developing their appetite for ruin.

We believe that considerable effort is still required across the industry to ensure that capital allocation methods and assumptions coherently link to a firm’s risk appetite (for instance reflecting the Board’s concerns around earnings rather than capital).

as internal models are embedded and their uses expanded we would expect to see increasing sophistication of methodologies and more granular allocation within a framework of capital adequacy that includes target and perhaps unallocated surplus.

Figure 10 – Return Period used for Capital Allocation when reporting to the Board


32%

47%

1 in 200

21% combination

Other


Figure 11 – Calculating the Diversified Risk Capital Components

nies

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aom

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P – standalone Tvar co-var Other no concerns

risk components



3. Alignment between Pricing and Capital Modelling

firms will need to demonstrate that the internal model changes as their risk profile changes. current best practice amongst the largest firms would suggest this is considered on an annual basis.

However, as our survey shows, a number of firms are also reporting whether the new business written is consistent with their plan figures – thereby highlighting inconsistencies between plan and the actual portfolio. This is typically reported on a monthly or quarterly basis.

KPMG View

in the short term we believe:

• More firms will provide regular monitoring to the Board on the rate adequacy – providing monthly comparison between plan loss ratios and the estimated loss ratio of the current portfolio based on the pricing models; and

• Those firms already reporting these statistics will look to increase the coverage of lines of business reported, and build more transparent feedback loops (setting out in detail as to what is required – impact on pricing and/ or business planning).

in the medium term we expect firms to not only use differences in expected loss ratios, but also to use the exposure information from the actuarial pricing teams to inform and update the capital model.

Figure 12 – Consistency between Underlying Pricing Models and Assumptions in Risk Capital Model

10%

37%

37% no check

explicit: Pricing Models determine the loss Parameters

16% explicit: regular checks on a Portfolio Basis

Other


4. Providing opinions

a significant number of actuaries are awaiting institute Guidance before finalising their approach on what is required to satisfy the solvency ii requirements on actuarial opinions; with some actuaries expressing scepticism over whether it is the actuarial function’s role to opine on

underwriting guidelines. Those actuaries that feel they are well progressed in providing an opinion on underwriting guidelines appear to base this more on good practice in rate adequacy assessments rather than on the underwriting guidelines themselves.



Providing an opinion on U/W guidelines

• Early days • Awaiting further guidance from Professional bodies • Not yet finalised (progress on thinking not shared 37.5% of

in the survey) respondents

• Limited additional effort expected: – involvement in Business Planning process suffices – Provide an option on the sensitivity of products Next 25% of

on the risk capital results respondents

• Rate adequacy reporting: Actual vs Technical – Provide an opinion whether plan is in line with risk appetite

Next 37.5% of – Provide opinion on risks to plan, and achievability of plan respondents – Provide an opinion on U/W models and guidelines

Providing an opinion on Reinsurance arrangements

• Early days • Awaiting further guidance from Professional bodies • Not yet finalised (progress on thinking not shared 25% of

in the survey) respondents

• Limited additional effort expected: – involvement in Business Planning process suffices – Modelling of reinsurance in the risk capital model Next 25% of

suffices (with sensitivity testing) respondents

• Explicit opinion on the appropriateness of the reinsurance programme in place, having consideration of the firm’s risk appetite, reporting findings to the r/i commit tee Next 50% of

• Provide opinion on gaps and efficacy of reinsurance respondents • Financial output for each reinsurance contract: RoRAC,

eva, etc… (no one is planning to asses the reinsurance wordings)

KPMG View

With continued uncertainty as to what is required we expect many actuaries to wait until the second half of 2012 for the expected consultation to provide more details on the requirements of the actuarial function.


Those that are continuing to develop their approach and interpretation will need to consider carefully the key stakeholders of the opinions (and whether business decisions will be impacted), how the opinions are worded, who they can place reliance on and who will ultimately provide sign-off.


Beyond Solvency II

Managing Risk, Finance and Actuarial – bringing them together

firms need to consider how they will evolve their functions to deliver real business value and efficiency whilst satisfying regulatory and market requirements. Traditional risk, actuarial and finance structures included a finance function reporting to the

ceO in a Head Office type role. This function picked up the financial processes namely statutory reporting, financial control, and financial management. a dedicated second line risk function did not really exist and most of what is now known as second line activities were carried out by finance. in recent years firms have adopted different approaches to managing risk with various iterations around the 3 lines of Defence Model in place.

Figure 13 – Evolving functional structures

Traditional Now

Head Office Business Unit Developing Structures

CFO Risk

ActuarialActuarial Management

Actuarial Risk Management

Finance Risk Taking

Finance

CEO CEO

CFO FD COO

AD HoR AFH CRO

Controls based Evolving risk based approach

Future Two Strong Independent Centres with

actuarial competencies embedded

CFO and CRO

Finance Risk Management

Multi disciplinary teams

Actuarial Actuarial

CEO

CFO CRO

Value creation versus controls

regulatory changes such as the Walker review have seen the Head of risk given the same level of authority as the Heads of finance and actuarial.

Moving forward under solvency ii, the chief risk Officer and actuarial function Holder will have increased responsibilities as they will both have involvement in new areas e.g. Orsa, internal Model and the Use Test. as a result we will see the roles of the crO and the chief actuary increasing in proportion to the cfO.

in order to facilitate this, firms are considering how best to become more integrated and share specialised skills regardless of traditional function. These resources would then be aligned against business tasks rather than in functional silos. in the future, organisational design will need to bring functions closer together and encourage more aligned objectives to achieve cross-functional outcomes.

in today’s cost conscious insurance market, these outcomes also need to be delivered at an optimal expense to the business.


Rob Curtis Director, Risk Management & Governance


examples of where we believe firms will benefit from further collaboration between risk, actuarial and finance are:

• Capital Management – work will link around the capital structure of firms, risk appetite / standards and the overall cost of capital to the business

• Performance Management – there will be strong links around operational information, risk parameters, financial measures and an Mi framework to monitor the business closely

• ORSA – the areas of reporting, development of economic capital and regulatory numbers and linking this all into risk management will be a key strategy priority for business under solvency ii.

Optimising the Three Lines of Defence model

clearly firms need to develop their operating models to maximise value for shareholders.

in order to evolve to meet the business needs we feel firms should be developing cross-functional expertise which will make firms more flexible and adaptable. furthermore the three lines of defence model should evolve to devolve responsibility further to the 1st line, thereby allowing the 2nd line to take on a more “value-adding” role within the business. for example:

1st Line: The Actuarial Function supporting the business in evaluating risk

2nd Line: A strong quantitative / qualitative risk function that reviews and provides challenge on the internal model

3rd Line: Internal audit providing oversight and challenge on governance process

To transform the second line, a number of changes should be considered within the business:

First Line

• Greater devolution of responsibilities into the front line increasing which will further increase accountability

• Increased responsibility and involvement in:

– Quality assurance

– Development of policies

– De velopment of Management information

Second Line

• P osition as a “centre of excellence” to the business

• Build multi-functional teams providing insight and value add to group and front line activities

• P rovide insightful challenge and coordinating the activities of the first line e.g. Group Orsa r eporting

Figure 14 – The “3 Lines of Defence” framework

Risk and control

First line: Day-to-day business operations

• An established model control environment • Assessment of model risk

Modelling team • Validation processes and tools

Risk and control

Second line: Oversight

risk function, internal model committee, risk committee

ud

it C

om

tee

d a

nd

Am

it

• Validation policy and procedure setting • Guidance and direction • Monitoring • Technical review

oar • Validation report

BRisk and control

Third line: Independent assurance

• Challenge of model and validation • Process and controls review

internal audit



Figure 15 – Evolving the 2nd line as a centre of excellence

Current state Added value

Operational role strategic role

COE

co-ordination reporting assurance risk Optimisation risk Performance & Management

• Monitoring, • Accounting • Involvement in • Effectiveness • Cultural reporting & actuarial the Orsa & alignment challenge and review of limits

• Aggregation of information

• Internal/ external reporting oversight

• Internal model

• Changing organisational structure

of the risk profile to the business

• Risk selection

• Building measures & incentives • Efficient use

• Planning and forecasting

• Emerging markets &

• New markets, products

of capital • Investor focus

report production

competition • Pricing implications

on KPis • Ratings

• Managing risk implications

appetite

• Emerging risks

Future state

While there will inevitably be challenges for firms to achieve this level of efficiency and performance, we believe the longer term business benefits, whilst ensuring regulatory compliance, will outweigh these.


Conclusions

Our survey highlights open questions and areas where market consensus is still developing.

as solvency ii evolves we expect to see greater alignment and consistency in many areas such as governance around the risk and actuarial functions, the use of internal models within business planning and finance functions, as well as in the more technical areas such as capital allocation and the derivation of the 1-year view.

not all issues will need addressing prior to solvency ii implementation. With many firms suffering from solvency ii fatigue, setting out a clear road map of issues and milestones to address these will help to ensure resources and priorities reflect the right balance between current commercial concerns and ongoing regulatory compliance.



Contact us

For further information regarding any of the topics discussed please contact any one of the authors.

Roger Jackson Partner, Solvency II, Risk Consulting Lead

Tel: 020 7694 5484 [email protected]

Stefan Claus Director, General Insurance Capital Management


Paul Merrey Director, Solvency II Strategy


Mark Winlow Partner, UK Head of General Insurance


Danny Clark Partner, Solvency II Pillar 3 Lead


Gavin Dunkerley Senior Advisor, General Insurance


Rob Curtis Director, Risk Management & Governance


www kpmg.co.uk

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

© 2012 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG Europe LLP and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Printed in the United Kingdom.

The KPMG name, logo and “cutting through complexity” are registered trademarks or trademarks of KPMG International.

RR Donnelley | RRD 268973 | April 2012

http://www.kpmg.co.uk

mailto:[email protected]







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