The Appointed Actuary's Role

In the most general sense, solvency is the ability of an entity to honour its financial obligations. From the accounting viewpoint, solvency requires that assets equal or exceed liabilities, and, therefore, that total equity is non-negative. This is ascertained as of a specific date by the preparation of a balance sheet.

Even though a balance sheet may show a corporate entity to be technically insolvent by this definition, legal insolvency is really only determined through court or regulatory action to terminate the operations of that company. In contrast, the appointed actuary's concept of solvency of an insurance company extends beyond the balance sheet at a specific date to the continued vitality of the organization.

Accordingly, in considering the solvency of insurance operations, the amount of, and expected trends in, surplus and other forms of available capital over the near future are of vital importance, especially in terms of the risk profile of the company itself. It is necessary to consider the purposes of and needs for that capital in relation to anticipated and possible events occurring after the statement date.

Dynamic capital adequacy testing is the process of analyzing and projecting the trends of a company's capital position given its current circumstances, its recent past, and its intended business plans, under a variety of future scenarios. It allows the appointed actuary to inform company management on the likely implications of the business plan on capital and to provide guidance on the significant risks to which it will be exposed.

The principal goal of this process is to help prevent insolvency by arming the company with the best information on the course of events which may lead to capital depletion, and the relative effectiveness of alternative corrective actions. Furthermore, knowing the sources of threat, the appointed actuary can strengthen the monitoring systems where the company is most vulnerable, and, thus, provide timely advice on a continuous and ongoing basis.

It is fundamental to this process and the proper interpretation of the results to understand that the projected capital position under various scenarios may well be inadequate after five years of adversity, especially if company actions have not been assumed to be adjusted on a timely basis as results emerge. This is not in itself an indication of current or anticipated difficulties. It is the specific degree and timing of capital depletion that indicate the risks to which the company is particularly sensitive. This, together with the results under the base scenario, should guide the company as to the necessity of revising the business plans, or preparing for contingencies.

The process described utilizes the regulatory formula for both required and available capital as the capital adequacy standard under the base scenario, and does not require the appointed actuary to develop, validate, or give an opinion on such formula.

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As the standard indicates, the DCAT process is to include the running of a base scenario and several adverse scenarios. It lists ten risk categories which the appointed actuary is to examine for possible threats to capital adequacy. Section III of this educational note elaborates more fully on each of these ten risk categories. The standard goes on to state that the risk areas posing most significant threats be examined in detail, including "ripple effects," and that at least three such risk areas be examined. Finally, the standard includes a model opinion that can be signed where, throughout the forecast period, the minimum applicable regulatory capital requirement is met under the base scenario and surplus remains positive under plausible adverse scenarios.

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The general process to be followed in carrying out this analysis may vary considerably from one company to another, but the existence of the required opinion presumes some degree of uniformity in the standard of plausibility of scenarios and approaches taken towards testing.

One acceptable approach would consist of the following:

• Development of the base scenario - As stated in the standard, this would normally, but not always, be consistent with the company's business plan.
• Examination of the ten risk categories, and identification of those which need no analysis whatsoever due to the circumstances of the company versus those that are relevant to company circumstances.
• For each of the relevant scenarios, "stress-testing" of the risk category in question - In this first stage testing, it is suggested that only limited reflection of the "ripple effects" discussed in Section III be carried out. Stress-testing means a determination of just how far the risk factor in question has to be changed in order to drive the company's surplus negative during the forecast period, and then evaluating if that degree of change is plausible or not.

• Selection of those scenarios requiring further analysis - At least the three risk categories showing the greatest surplus sensitivity should be examined in further detail, including more detailed reflection of the associated ripple effects. Clearly, any risk category under which a plausible scenario results in a negative surplus position in the forecast period should be subject to this further examination and reporting. Again, the stress-testing approach, but now taking fuller account of ripple effects, can be used to assess plausibility.
• Reporting on the base scenario, and then on all ten risk categories, but in different levels of detail:
• for those considered irrelevant, a cursory explanation of why (this should be documented, but could be excluded from the formal report);
• for the relevant but less sensitive categories, a brief description of the approach taken and results; and
• for the most sensitive categories, a more detailed description of the risk category, circumstances in which a negative scenario could arrive, what kinds of ripple effects could take place and how they have been taken into account, what management action if any has been assumed, and plausibility of the results.

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As stated in the standard, the company's financial condition is deemed satisfactory if, throughout the forecast period, under the base scenario, the minimum regulatory capital requirement is met and, under all plausible adverse scenarios, a positive surplus position is maintained. Otherwise, the company's financial condition is deemed unsatisfactory, and an unsatisfactory opinion is to be reported. Above, plausibility means having a probability of at least 1%. For purposes of this standard, the minimum regulatory capital requirement for a Canadian life insurance company is currently an MCCSR ratio of 120%, and for a foreign insurer, a TAAM ratio of 120%.

Assessing probabilities of the order of 1% will not always be easy. In some risk categories for some companies, it will take an obviously implausible event (for example, for most life insurers, a 10-fold increase in mortality would be implausible) to drive surplus negative. In other situations, it will be equally clear that an adverse scenario is more than just 1% probable (for example, interest rates falling 200 basis points over the next five years). In such a case, an unsatisfactory opinion is required. Others will be more difficult to assess. Where there is some uncertainty as to whether an adverse scenario which results in an unsatisfactory financial condition has less than a 1% probability, but the appointed actuary is of a reasonably strong view that it is less, that scenario and the appointed actuary's rationale should be disclosed in the report, but there is no need to give an unsatisfactory opinion based on this scenario alone.

The appointed actuary should also report any plausible adverse scenarios which cause the insurer to fall below the minimum regulatory capital requirement. Even though the appointed actuary may have signed a satisfactory financial condition opinion, the report should make it clear to the board that the company would be prevented from writing new business by the regulators under these scenarios in the absence of capital enhancements.

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In this subsection, "satisfactory financial position " means a financial position which avoids special regulatory scrutiny (i.e., which keeps an insurer off its regulator's "watch list.") "Strong financial position" means a financial position which is significantly better than satisfactory.

A strong financial position is not a substitute for an investigation, not only because plausible adversity deteriorates financial position, but also because an investigation reveals the timing of deterioration in an adverse scenario, and, thus, reveals how much lead time the insurer needs, or can expect, to deal with the adversity. Similarly, a strong financial position is not a substitute for annual performance of the investigation. It is appropriate, however, for the scope of an investigation to take account of the stability, both historical and expected, of the insurer's environment and operations. The continuing relevance of the results of prior investigations should be considered.

A prior investigation remains relevant if the insurer's:

• Products to be sold during the current forecast period are similar to those sold in the prior investigation, or the insurer is closed to new sales.
• Current environment, operations, and business plan are those of the prior investigation.
• Actual experience has been comparable to that in the prior investigation's base scenario forecast.

A relatively refined forecast and relatively comprehensive adverse scenarios would be appropriate unless the insurer:

• has a strong financial position which is virtually certain to remain satisfactory in the face of adversity during the forecast period; or
• has a satisfactory financial position and stable historical and expected environment and operations, and a prior investigation with a relatively refined forecast and relatively comprehensive adverse scenarios remains relevant.

In those conditions, a less refined forecast would be appropriate if in accordance with CIA standards on approximation. However, use of such more approximate forecasts would not be appropriate for any company with material volumes of new business.

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There will be some situations where capital enhancements are a basic part of a company's business plan. Examples of such capital enhancements could include private equity from financial investors, public equity, subordinated debt, injection of funds into the Canadian branch of a foreign insurer, etc. This will be true particularly in the case of fast-growing insurers that are either subsidiaries of larger organizations, either Canadian or foreign, or foreign insurers that are present in Canada on a branch basis.

The fact that the business plan and the base DCAT scenario calls for such capital injections should not be cause for the appointed actuary to not be able to sign the usual DCAT opinion. However, the appointed actuary should be satisfied that, in fact, such capital injections are, indeed, the intent of the entity making the injection, and that such injections are within the means of that entity.

A similar circumstance can arise in the case of an insurer without a parent organization, that is intending a major initiative in a new sphere of operations, and is intending to raise capital externally in support of that venture. The base scenario will show the need for such capital, but, again, should not be cause for not signing a satisfactory opinion.

A more difficult question arises in the case of the adverse scenarios. Obviously, it would be inappropriate to assume away any negative outcomes merely by an assumed capital injection.

The prequisite for a satisfactory opinion is that the insurer will remain solvent under all plausible scenarios (which has been interpreted to mean scenarios with more than a 1% probability). This would seem to presume that the appropriate level of capitalization for the insurer, from a solvency perspective, would be such that, under plausible scenarios, it would remain solvent. For testing adverse scenarios essentially out of the control of management, it is appropriate, then, not to assume any additional capital from outside beyond that called for in the business plan and base scenario. For scenarios where the "adverse" factors are more under management's control (in particular a scenario of much higher sales than planned), capital injections above and beyond those anticipated in the base scenario are appropriate.

In order not to present a misleading picture to management, the board, the parent organization, or the regulator, clear reporting of assumptions made on capital injections is essential. This is the case for those intended under the base scenario, as well as the limited occasions of any additional injections deemed appropriate under an adverse scenario. In such adverse scenarios, reporting of DCAT results with and without the assumed additional injections is recommended.

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Similarly to the situation with capital injections, there will be some situations where management action in response to adverse scenarios should be assumed to occur. An example would be deteriorating mortality or morbidity experience on group insurance written on a one-year-term renewable basis. This is not to say that all the adversity in poor claims should be assumed away through rate increases, but to assume no management action whatsoever in the form of premium rate increases, tightening up of underwriting, modification of benefit definitions, etc., would appear implausible (this is clearly different from long-term individual life insurance policies with fully guaranteed rates and provisions).

In order not to present a misleading picture, clear reporting of assumed management action is essential. It may be helpful under adverse scenarios to report on DCAT results with and without the assumed management action.

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The appointed actuary is expected to develop an understanding of the sensitivity of the insurer's financial condition under each major risk category which is material to the company. This section outlines major risk categories which could be considered, and possible adverse trends and ripple effects for each. These should not necessarily be considered all-encompassing for every company. The Society of Actuaries' Dynamic Financial Condition Analysis Handbook is a good supplemental reference for risk areas and adverse scenarios that may be relevant for a given company, beyond those covered below.

Adverse scenarios could include:

• Gradual changes in experience which may or may not be detected for some time
• Shock changes to experience
• Incorrect estimates of expected experience

Recent industry and company historical experience and outlook for the future should be considered to determine the range in experience that should be considered.

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There are a variety of scenarios that could lead to significant adverse mortality experience relative to that assumed in pricing and/or valuation. A company with a significant block of life insurance or annuity policies should test the effect of this potential adverse mortality experience. This testing should be done separately for each of these lines of business.

For insurance business, adverse mortality may arise from a variety of causes, some of which include:

• an absolute increase in mortality rates, probably for a specific period of years, potentially arising from an epidemic or other catastrophe;
• a steady and continued deterioration in mortality, arising potentially from antiselective lapse experience as new and more competitive products are offered or due to a weakening in underwriting standards; and
• a misestimation of expected experience due potentially to a lack of complete experience data.

For annuity business, adverse mortality may arise from causes such as:

• a steady and continued decrease in mortality rates, arising potentially from improvement in medical treatment and/or changes in annuitant lifestyles, at a faster pace than that assumed; and
• a misestimation of expected experience due potentially to a lack of complete experience data.

The appointed actuary should consider whether the adverse mortality will be permanent or temporary in nature. Where appropriate, the impact should be reflected through a re-valuation of reserves.

The appointed actuary should consider ripple effects such as the following:

• Is the adverse mortality experience on products with adjustable premiums or benefits? To what extent and how quickly is management able and willing to adjust products? This will depend on the nature of the adverse mortality experience, whether temporary or permanent, and whether unique to the company or industry wide. Some delay should be considered before management action is taken and some consideration should be given to only a partial adjustment for the adverse mortality experience.
• Will management adjust pricing for new business, and how quickly? This will also depend on the nature of the adverse mortality experience, whether it is considered to be temporary or permanent and whether it is unique to the company or industry wide, but some delay should be considered before management action is taken.
• Will sales levels and/or persistency be impacted if any pricing or benefit adjustments are made that potentially alter the company's competitive position in the marketplace?

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Adverse morbidity includes:

• Increase in incidence rates for disability, medical, dental, critical illness, and other coverages
• Decrease in rates of claim termination

These may arise from a variety of causes, some of which include:

• Prolonged high unemployment recessionary environment leading to both sharply increased incidence and low termination rates for disability
• An epidemic which increases incidence rates without increasing death rates
• Improved treatment for diseases, such as AIDS, that decrease both recovery rates and death rates for disabled lives
• Aggravation of "entitlement" ethic as a result of court practices
• Retrenchment of government social security programs
• Escalation in dental and medical costs

The appointed actuary should consider ripple effects such as:

• Price increases in new business, and rate increases for inforce renewable business and attendant impact on lapses and new business
• Constraints to price increases as industry reacts slowly in implementing renewal rate increases
• Rate guarantees that limit or delay required rate increases
• Increase in antiselective lapse that may dampen - or nullify - the intended effect of rate increases
• Increased expenses and litigation resulting from more active claim management

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Policy persistency can pose a significant risk to the capital adequacy of an insurer.

Generally, persistency risk can be divided into two distinct categories:

· Whenever the cash value exceeds the reserve, the risk is that lapses or surrenders (hereinafter referred to as "lapses") will exceed those assumed in the statutory valuation assumptions.

· Whenever the reserve exceeds the cash value, the risk is that lapses will be less than those assumed in the statutory valuation assumptions.

For the first category, the impact on the insurer's books can best be illustrated by examining the effect of lapses for a block of business. For the sake of simplicity, assume that, for every policy in the block of business, the cash value exceeds the reserve (this would include policies where the cash value is zero and the reserve is negative). In this case, the "loss on lapse" actually experienced would equal the sum, for all lapsed policies in the block, of the cash value less the reserve. At the same time, the change in reserve during the accounting period will include an expected "loss on lapse." The insurer's earnings will be negatively impacted only to the extent that the experienced loss on lapse exceeds the expected loss on lapse.

The situation is analogous for the second of the two categories (i.e., where the reserve exceeds the cash value). Such blocks of business are often referred to as "lapse supported."

In examining the persistency risk, it is prudent to assume that, because of antiselection, both these adversities may well happen concurrently.

Ripple effects for persistency risk include:

• Worsened mortality
• Worsened morbidity
• Mismatch of asset and liability cash flows
• Increased unit expenses
• Liquidity risk

Causes of adverse of persistency include:

• Premium increases
• Divided reductions
• Changes in distribution system
• A new product introduced to the market by a competitor
• Lowering of premium rates in the market

One special case of the liquidity risk which the appointed actuary may wish to examine is the "run-on-the-bank" scenario, described as follows. In addition to what follows, the appointed actuary should also consider the guidance on this scenario in the educational note on Liquidity Risk Measurement. The purpose of this scenario is to project the effect on the company of a major lapse/liquidity problem. In this scenario, only the company in isolation and its subsidiaries are affected, and this scenario does not apply to the industry in total.

The scenario could be instigated by a sudden lack of confidence in the company as perceived by the outside market. An example could be a sudden downgrade by external rating agencies, combined with extensive publicity. The perception of a problem could be self-fulfilling. None of the assumptions for interest rates or inflation would be affected. But, in addition to the obvious impact on lapses, this scenario would affect the company's new business while, at the same time, it could not proportionately reduce expenses.

The company could not borrow any external capital or debt, such as any commercial paper, preferred shares, etc. Any existing borrowings could not be renewed at maturity. Assumptions with respect to selling non-liquid assets would be very conservative.

The company would experience a sudden virtual stoppage in new annuity business. Roll-overs at maturity would be minimal. The appropriate level of lapses would be assessed for each product line. There would be high levels of surrenders, even with the existence of market value adjustments or surrender changes.

The company would experience much higher lapses in its individual insurance blocks. Again, the appropriate level of lapses should be assessed for each product line. The mortality experience of the remaining policies should be assumed to be worse due to antiselection.

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Adverse scenarios related to C-3 risks could result from:

• Mismatches between the cash flow pattern of assets and liabilities
• Variability in the cash flow pattern of assets and liabilities
• Changes in future rates of interest

The appointed actuary should test the impact on surplus across all lines of business in aggregate of potential adverse scenarios, but the potential management actions will depend on the nature and characteristics of the various blocks of assets and liabilities. Changes in future rates of interest will also impact the market value and earnings of surplus assets.

When there is a mismatch between the cash flow pattern of assets and liabilities, there will be a need to reinvest positive cash flow, or borrow, or liquidate assets to fund negative cash flow. Future rates of interest can vary substantially and can adversely impact surplus. The value of derivatives will also be impacted. Where they are used as hedges, they will help mitigate adverse impacts. Where they are used to take mismatch positions, they will add financial exposures.

In assessing the impact of changes in interest rates, the appointed actuary should consider both the current mismatch position as well as the potential for mismatch in the future. These will depend on the maximum position allowed by the company's investment policy and the most aggressive position that has been taken in the past.

Parallel and nonparallel shifts in the yield curve, both on a sudden and on a gradual basis, should be considered. Stochastic modelling as well as deterministic scenarios should be considered. As well as specific scenarios, the appointed actuary should also stress test the C-3 risk by determining what scenario of future interest rates could result in insolvency.

Changes in future interest rates will impact not only future rates of reinvestment and market values, but also the pattern of the cash flows, for example on asset-backed securities and callable bonds and on surrenderable policies.

Future interest rate levels will also impact the level and mix of new business for guaranteed fund and segregated fund products. Likewise, interest rate levels will impact the level of surrenders and transfers between funds and movements to and from portfolio average versus new money products. The movement and financial exposure will depend on surrender charges and market value adjustments embedded in products. Particular consideration should be given to assessing the impact of a "run on the bank" scenario.

Future interest rates may also impact the achievable spread for new business and fixed interest business where rate resets are being made.

Sustained low levels of interest rates could also impact the company's ability to support minimum long-term guarantees embedded in both insurance and annuity products.

For participating insurance, universal life, and adjustable premium business, considerations would include:

• The impact of the proportion of fixed income assets backing participating business and the duration of those assets, and that of key competitors
• Dividend actions of competitors
• The ability and willingness of management to maintain or change dividend scales
• Related policyholder actions such as surrender levels and potential litigation
• Impact on level of new sales

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Adverse scenarios in respect of C-1 risk (deterioration of asset values) may come from a variety of sources, including:

• Increases in losses from defaults on debt securities
• Poor returns and/or declines in value of equities
• Poor returns and /or declines in value of real estate
• Counter-party defaults on derivatives
• Loss or significant decline of value for other major asset categories
• Concentration risks, including geography (e.g., impact of natural disasters), asset class, industrial sector, subsidiaries, individuals
• Fluctuations in currency values

The actuary should consider what is the appropriate recognition in reserves and expected pricing actions. The ripple effects could vary depending on whether the C-1 results are company specific or industry wide.

The following are possible ripple effects:

• Exposed risk positions as a result of counterparty default (example C-3 risk)
• Decreased policy owner dividends which could lead to higher surrenders
• A ratings down-grade which could, in turn, have many shock waves such as decreased sales and increased surrenders
• A liquidity crisis caused by large, sustained default losses

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One of the uncertainties facing an insurance company is the volume of new business that it will be able to write in future. Volumes significantly different from those assumed can result in a capital position quite different from that expected, with negative outcomes.

There are several categories of events that could have considerable impact on the amount and type of business written by an insurance company:

• A financial rating downgrade, of either the company itself or of an affiliated company (particularly the parent), or some other event similarly damaging a company's reputation
• A change in law or regulation directly affecting an important product line.

Examples would include:

• a change in tax law affecting the position of the policyholder purchasing a particular kind of product
• a change in capital or reserving requirements putting a particular type of product at a competitive disadvantage relative to products provided by other financial institutions or even other insurance providers not affected in the same fashion
• Entry by government into an insurance area previously within the domain of the private sector
• Entry of a new and strong competitor into an area where competition was previously weak
• Loss of a key distributor or even an entire distribution channel previously responsible for the production of a significant portion of a company's business
• Loss of a key client, for example, a very significant group client representing a significant portion of an insurance company's group portfolio
• Unexpected success in a new product area or in beating previously stronger competition

Most of these categories of events would lead to lower sales than expected. The clear first-order impact would be on coverage of expenses, particularly where there is a large element of overhead and fixed expense associated with the marketing and sales function. Examination of this first-order impact would be of most importance in any scenario testing. Second-order impacts could include:

• Higher lapse rates on existing business (which could be significant, depending upon the event causing the fall in new business)
• The resulting poorer claims experience on that remaining business
• The resulting poorer coverage of maintenance expenses (resulting from both lower sales now and higher lapse of existing business)
• Possibly ripple effects on other lines of business with some connection to the one initially affected (say, a distribution channel primarily involved in one line of business which leads to significant sales later in another line)

Management action here could include items such as:

• Diversification into more than one line of business
• Control over non-variable expense levels
• Maintaining contingency action plans to be implemented in case of one of these events, etc.

The last category of event in the first list above, leading to larger sales than expected, could result in severe capital strain for a company. Other ripple effects could include problems with management control over policy issue, underwriting, field expenses, financial reporting, etc., due to rapid growth, leading to later problems in claims and expenses as eventually competition catches up and volume levels return to normal.

Possible management actions would include:

• Putting capital-raising plans in place with any parent company or with external sources of capital
• Contingency plans to be able to handle increased volumes of business
• Increasing use of reinsurance to mitigate need for additional capital, etc.

Normally, the baseline scenario would incorporate the new business projections of the company business plan and the associated expense levels. Alternate scenarios would be heavily company-dependent, varying in particular with the kind of market the company serves and the distribution channel employed to reach it, but any alternate scenario would be expected to reflect not only the change in new business levels, but also the impact on expense coverage and any other likely second-order impacts.

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Expense assumptions are a major consideration in the projected financial positions of every insurer. This assumption is unique in that, to some degree, company management has a greater level of influence on expenses than on other assumptions. Even insurers who have historically managed their expenses aggressively to budgeted targets, however, may face major expense issues in the event of unexpected variations in business growth or litigation, for example. The extent of demonstrated effective actions towards managing expenses should influence the appointed actuary's decision in how closely to relate expense levels to future targets versus current experience in the base scenario. Companies practicing strict management of budgets to meet expense levels included in product pricing may have different results from companies that manage budgets to other measures.

Adverse expense scenarios and related ripple effects to which an insurer's financial condition may be sensitive include:

• Inflation - A severe inflationary environment may cause a rapid increase in absolute expenses and in unit costs. A high inflation scenario would normally be assumed to accompany a high interest scenario, and the two should logically be linked.
• Low sales - Low sales can precipitate an increase in unit costs where a portion of expenses are considered to be fixed. This will place adverse pressures on the profitability of new business and on unit maintenance expenses on inforce business.
• High terminations - High terminations of business can precipitate an increase in unit costs. They can increase absolute levels of termination expenses, and can increase unit maintenance expenses on the remaining policies inforce.
• Technological obsolescence - New technologies may be developed which deliver significant cost, delivery, or service benefits to those who can achieve economies of scale. For companies that do not make use of new technologies, expenses may rise relative to the competition. Such a scenario should also include the sales and termination impacts of technological obsolescence.
• Court awarded damages - Potential high costs can result from court awarded damages to plaintiffs relating to such matters as market conduct. Ripple effects resulting from damage to reputation can include ratings downgrades, lower sales and higher terminations.
• CompCorp assessments - Further industry failures can precipitate higher assessments to companies in the industry. Ripple effects from such failures can include damaged industry reputation, flight to quality, lower sales and higher terminations in some instances.
• Company structure - Holding company expenses may be allocated to subsidiary companies based on historical or anticipated relative profits. This could lead to a major change in the level of expense allocated to the insurer based on the performance of one of the other companies in the enterprise. Within a single insurer, methods of allocating overhead expenses to different business units may produce changing expense levels over time. In an enterprise which has several insurance companies or business units that provide services to one another, the impact of cross-billing should be considered.

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Reinsurance terms on most individual life cessions tend to be guaranteed for the life of the underlying policy. The principal risks for a ceding company are outlined below.

The first would be the insolvency of a reinsurer. The appointed actuary should calculate the exposure to the principal reinsurers of the insurance company, assuming liquidation of the reinsurer. The impact should reflect an assumed "realization percentage" of assets to liabilities of the failed reinsurer, and any different treatment of various types of amounts owing from the reinsurer to the direct writer. The impact may well be mitigated by right of offset of amounts owing under all treaties between the two companies, the preferred position insurers will have relative to other creditors of a failed reinsurer, the right of recapture in the event of failure, and any amounts on deposit or in trust with the insurance company, or letters of credit in respect of an unlicensed reinsurer. It would normally be appropriate to assume under this scenario that the business previously ceded to the failing reinsurer could be successfully reinsured elsewhere (but possibly on less favourable terms), unless there is something unique about the business involved that would make securing such replacement reinsurance difficult.

Another risk would be increases in reinsurance rates on future new business. Where reinsurer action is similar across insurers operating in similar markets, such action by a reinsurer or reinsurers would not necessarily pose competitive issues, as many could be faced with similar changes in terms, requiring repricing in the entire marketplace. However, where reinsurer action is targeted to one company because of poor experience, necessary repricing could impact the level of sales.

A third risk would be reduction in reinsurance capacity available for the financing of new business, and the resulting increase in reinsurance costs or constraint on the growth of the company.

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When the government makes changes in its policies or regulations, implementation usually takes a long time. This allows time to analyze the impact and take the appropriate actions. But some changes can occur in a very short period of time and cannot be foreseen. Others can even be effective retroactively.

Examples of adverse events are:

• An increase in premium tax rates
• An increase in taxation rates for corporations (income tax or capital gains tax)
• A prolongation of temporary taxes (e.g., the additional Part VI temporary capital tax for insurance companies should end in December, 1998, but the government could decide to prolong this temporary measure or make it a permanent one)
• New restrictions on RRSPs or RRIFs which would have a direct impact on the level of new business for those products
• The possible entry of other financial institutions into the life insurance industry (e.g., due to revisions to the Bank Act) which would impact the amount of new business and could lower profit margins due to increased competition.
• Possible new restrictions on the investment practices of life insurance companies (e.g., a restriction on the use of derivative products for speculation or hedging)
• The introduction of new or modified public healthcare policy which could decrease new sales or in-force business (e.g., the introduction of pharma-care)
• A change in regulatory solvency standards which could increase the capital requirements for life insurers (e.g., the introduction of a lapse component to the MCCSR)
• A reduction in the government's need to borrow funds which could impact the level of government bonds available to the market
• Political instability which could lead to confiscation of assets, closure for new business, exchange controls, etc., particularly in foreign jurisdictions

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There are numerous off-balance-sheet items which may place an insurer at risk. Often these off-balance-sheet items arise from new or evolving industry practices which, in future years, do get recognized on the balance sheet by the CICA, the CIA or regulators. Therefore, the appointed actuary needs to develop awareness of any emerging risks which may be relevant to the insurer during the forecast period and assess their potential threat to solvency.

Discussed below are examples of common off-balance-sheet items and their related risks that may be relevant to the insurer:

• Operating lease obligations - The lessor is exposed to the credit risk associated with the lessee's inability to meet its lease obligations.
• Derivative instruments - The risks associated with derivatives include market risk, default risk, management risk and legal risk:
• Market risk includes marketability risk and basis risk. The marketability risk is the risk of not being able to cancel or unwind one's contract when desired or at a favourable price. Basis risk is the risk that the derivative's price behaviour does not act as expected, undoing the intended hedging benefits. The price behaviour of the instruments can change adversely when market conditions change. Market risk is best evaluated on a security basis and on a portfolio basis since some risks may not net against each other.
• Default (or credit) risk is the risk that a loss will be incurred due to default in making the full payments when due, in accordance with the terms of the contract.
• Management risk is the potential for incurring material, unexpected losses on derivatives due to inadequate management supervision and understanding, systems, controls, procedures, accounting and reporting.
• Legal risk is the risk that the derivative agreement is not binding as intended.
• Contingent liabilities or losses - There are a variety of contingent liabilities to which a company may be exposed, such as tax, litigation, etc. The appointed actuary should consider the financial impact of adverse outcomes.
• Letters of credit and pledged assets - The insurer may be exposed to the risk that a lending institution defaults on payment under, for example, a letter of credit, or a call on assets pledged.
• Capital maintenance agreements - An insurer could be exposed to capital maintenance agreements it must honor for its subsidiaries.

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Modelling will normally be required to test the capital adequacy of the insurer under the base scenario and adverse scenarios for the DCAT standard. Asset, liability and surplus (capital) modelling are required. Within any one company, there may be a variety of different types of models for the various lines of business and jurisdictions. The modelling capability needs to be flexible enough to enable the appointed actuary to assess risks within each risk category.

Unless the model results resemble the company's, the scenario testing will have no credibility. The model must respond in the same direction and in about the same magnitude as the company in reality will respond to events.

In considering whether a model is depictive, the main focus is on the base scenario. There should be no major discontinuities from the last actual year to the first projected year. The numbers should generally flow fairly smoothly from one year to the next.

A good way to check the depictiveness of a model is to use, as input for the model, the data prior to the most recent actual year, and use the experience of the last year to set the parameters. The result from the model could then be compared to the actual results. If the results between actual and projected are found to be sufficiently close, the model can be accepted. The appointed actuary should make up in advance acceptable differences in assets, liabilities, surplus, premium, investment income and net income. There is also a retrospective check on depictiveness that can be made. Each year after the actual results have been determined, differences between actual and base scenario model results should be justified.

There are two aspects to checking the validity of the model. The first relates to accounting balances (i.e., verification of the mechanical accuracy and consistency among the various parts of the model) and the second to reasonableness.

The reasonableness of a model concerns all the scenarios, but it is probably best assessed by looking at the difference between the results of two scenarios. Do the differences seem reasonable?

The objective in designing the structure of the model is to facilitate the projection of the company's operations under a number of different scenarios.

The company being modelled operates within an industry that is itself influenced by, and operates within, a geographic and economic environment. The company will have its own legal structure, and, within that, a management structure around which it will plan and monitor its financial results. In organizing the model, it is necessary to reflect this structure and determine where constraints apply and at which level within the hierarchical structure of the model parameters are best set.

Economic parameters, such as interest rate levels, inflation, capital appreciation and unemployment levels are illustrative of assumptions that need to be established at the highest level as they must be applied throughout the model.

There are demographic parameters which need to be established at the highest level as well, such as an overall deterioration in mortality or morbidity; however, these may best be handled as indicators to modify an assumption at a product level. A good illustration may be the approach used for the required scenarios regarding improvement or deterioration in the underlying mortality levels or lapse rates. Distinctive tables would be expected to be applied to annuities and life insurance, for example, but the corresponding changes from expected levels should be consistent.

In designing the structure for the model, the size and complexity of the organization will dominate. At a corporate level, capital infusions, shareholder dividend payments, income taxes, required surplus, investment of surplus, and corporate expenses, such as head office lease and overhead costs, have to be modelled. In a single product line company, these may be combined with the product projection.

In the more complex organization, while similar issues arise as in the single product line company, the need to segment the model arises. This may be driven by size, or certain products may be more efficiently modelled using different language or techniques. Alternatively, there may be a desire to analyze specific units separately.

• Management

• Product

• Investment

The interrelationship of product cash flows feeding the asset model are critical. Cash available needs to be established before investment decisions can be implemented.

It may be desirable that calculation of taxes and required surplus be done at a divisional level of the model on a stand-alone basis. However, when results are consolidated these will have to be redone on a consolidated, basis. This implies that such data as necessary must be transferred to the corporate model to facilitate these calculations.

Models constructed for purposes of solvency testing will have to be run repeatedly under many different scenarios of possible future experience. Variations in experience levels apply not only to the usual factors such as deaths, withdrawals, expenses, and interest rates, but also to items which can be thought of as company policies. These include investment strategies, valuation assumptions, and marketing and new sales.

It follows that any models which are to be used for capital adequacy testing purposes must be flexible and allow for changes to be made in the underlying assumptions which form the various scenarios.

Another aspect of flexibility involves the ability of the model to focus on a particular line of business, division of the company, fund, or territory. Since it is likely that models constructed for solvency testing purposes will also be used for corporate planning, the model should be sufficiently flexible to reflect any reasonable changes in company operations which it might be desired to test. Of course, these same changes might very well be the subject of additional scenarios in the solvency testing process.

(Return to index)

Significant time and effort will be required to develop the capabilities to perform and to execute the projection and analysis. The preparation of a clear and complete report on the results and implications of this work is an important component in the entire process.

The audience for this report is company management as well as the board of directors and the regulator.

The appointed actuary should report all plausible adverse scenarios which have a material impact on the financial condition of the insurer during the forecast period. In addition, any adverse scenarios which result in non-positive surplus during the forecast period or a base scenario which results in failing the minimum applicable regulatory capital requirement during the projection period would require an unsatisfactory opinion in the report.

A sample report outline follows:

1. Executive Summary

• summary of the base and adverse scenario results (MCCSR ratios, earnings, assets, liabilities, surplus)
• highlighting of the most significant solvency risks
• DCAT Opinion

2. Introduction to DCAT

• purpose, scope, process, method

3. Capital Adequacy Measurement

• description and summary of the current position (e.g., MCCSR ratio)
• definitions of CIA DCAT standard of capital adequacy for base scenario and adverse scenarios

4. Base Scenario

• description of scenario, assumptions, results
• discussion of consistency with business plan

5. Adverse Scenarios

• description of scenarios, assumptions, assumed management action, results
• recommendations on what actions management could take to mitigate adversity

6. Analysis of Risks by Line of Business

• discussion of risks and scenario results

7. Conclusions and Recommendations

• summary and future developments

8. Appendices

• key corporate objectives / initiatives
• capital enhancement activities
• key assumptions and other considerations (rating agencies, taxation, valuation/accounting issues)