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2006 General Meeting

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New Audit Guideline AuG-43. Replaces old guideline AuG-15 ... Admin may 'improvise' for shortcomings in systems. Handling of new products ... – PowerPoint PPT presentation

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Title: 2006 General Meeting


1
Canadian Institute of Actuaries
LInstitut canadien des actuaires
  • 2006 General Meeting
  • Assemblée générale 2006
  • Chicago, Illinois

2
Improving Actuarial Processes Beyond AuG-43
Compliance
  • Jacqueline Friedland, FCAS, FCIA, MAAA KPMG LLP
  • Neville Henderson, FSA, FCIA, MAAA PwC LLP

3
Presentation Outline
  • Introduction
  • Current environment
  • Implications
  • Controls
  • Recomputation
  • Conclusion

4
Introduction New Audit Guideline AuG-43
  • Replaces old guideline AuG-15
  • New guideline includes insurance enterprises
  • Applicable to life insurers, PC insurers,
    reinsurers, and workers compensation boards
  • May also be used for enterprises whose products
    have similar characteristics to insurance
    products
  • Issued December 2005, effective 2006

5
Introduction Why the change?
  • Auditor audits the financial statement as a whole
  • Audit opinions do not (and cannot) express
    reliance on the AAs opinion
  • CIA/CICA Joint Policy Statement provides
    framework
  • Greater consistency with US and UK GAAS
  • Change in audit standards with respect to
    internal controls

6
Introduction Basic Principles
  • AA is responsible for valuing policy liabilities
  • Requirement for independent check on actuarial
    liabilities
  • Requires use of audit support actuary
  • Clarifies that AA cannot provide audit support
    role
  • Requires corroborative evidence for use of AAs
    work

7
Introduction Audit Approach
  • Understand and test internal controls over the
    actuarial valuation (new)
  • Substantive tests
  • Test data used in valuation
  • Review of valuation for reasonableness
  • Testing of calculations, including consideration
    of complex models (new)
  • Extent of testing dependent on
  • Complexity and subjectivity of estimation of
    policy liabilities
  • Availability and reliability of data
  • Nature and extent of assumptions
  • Degree of uncertainty of future events

8
Current Environment Life Insurers
  • Prior to AuG-43 wide variance in practice
  • Dependent on circumstances
  • Little documentation or testing
  • Reliance on post review
  • Controls have not kept pace
  • Poorly documented processes and controls
  • Increasingly complex products
  • AuG-43 forces Actuaries to re-examine processes
    controls

9
Current Environment Property Casualty Insurers
  • Not significant communication between AA and
    audit actuary
  • Review of assumptions, methodology, findings
  • Varying degree of review of calculations

10
Implications Life Insurers
  • AuG-43 provides guidance on reviewing policy
    liabilities
  • Address the risk of material misstatement
  • Identify the risks and how they are mitigated
  • Review the effectiveness of the controls
  • Independent corroborative evidence
  • Recomputation
  • Recomputation is complex for insurers
  • Improve controls to minimize recomputation

11
Implications Property Casualty Insurers
  • Requirement for documentation of internal
    controls and data validation procedures
  • Requirement for more communication with AA
  • Expect closer relationship with AA
  • The audit actuary must test (not do over) the
    AAs calculations
  • Extent of recalculation depends on
  • Nature of policy liabilities
  • Internal control processes
  • Difference of opinion regarding within a
    reasonable range
  • Timing of AA work and audit actuarial specialist

12
Controls General
  • Traditionally more reliance on back-end
  • Increasingly difficult due to tighter timelines
  • Simple trending not enough with complex products
  • More controls on the front-end
  • Quality control rather than correction
  • Limited resources can focus more on analysis
  • Three critical stages to valuation process
  • Collection of data
  • Complex valuation models and calculation systems
  • Other adjustments

13
Controls Data I
  • Issues beyond usual IT controls
  • Quality of data filters handling of rejected
    data
  • Interfaces all data transfer points
  • Data from third parties or specialty admin
    systems
  • Legacy systems and multiple admin platforms
  • Admin may improvise for shortcomings in systems
  • Handling of new products
  • Critical information in comment sections

14
Controls Data II
  • Actuaries need to capture all policy attributes
    that materially affect valuation
  • Is the right information being extracted for
    valuation?
  • Sufficient differentiation for complex products
  • UL min vs max funding
  • Lapse experience dependent on premium features
  • Review use of averages and approximations
  • AuG-43 forces actuaries to review these issues
    and document controls

15
Controls Valuation Models
  • Complex models to value complex products
  • Commercial software vs home-grown models
  • Similar control issues
  • Different approaches to testing
  • Set-up of valuation assumptions
  • Check consistency between assumptions and studies
  • Consider uncertainty in future events
  • Reasonableness in the range

16
Controls Reasonability
  • Complex models combined with complex products
  • How do actuaries get comfort with result?
  • Critical back-end checks and analysis
  • Trending reserve / 1000 face amount
  • Reserve roll-forward or reserve continuity
  • Variance to plan / budget
  • Strain at issue compared to pricing expectations
  • Earnings by source
  • Techniques for analyzing results have evolved but
    documentation may not have

17
Controls Adjustments Outside the Model
  • Adjustments occur throughout the process
  • Several types of adjustments (post model)
  • Handling of financial statement presentation
  • Inclusion of liabilities not modeled
  • Known model deficiencies
  • Significant challenge due to fewer controls
  • Late adjustments
  • Use of spreadsheets

18
Controls Spreadsheets
  • Steps to ensure appropriateness of adjustments
  • Itemize and track changes in adjustments
  • Regular review of need and reasonability
  • Limit who has ability to approve
  • Many adjustments rely on spreadsheets
  • Need same discipline as model
  • Limit authority
  • Version control
  • Establish naming conventions
  • Perform independent checks
  • Document in addition to comments

19
Recomputation
  • Significant effort in case of most life insurance
    products
  • Commercial software vs home-grown models
  • Companies to perform and document self- testing
  • Better controls are demonstrated then need for
    recomputation reduced
  • Always some requirement for testing

20
Conclusion
  • Audit is more robust with improved quality of
    financial statements
  • Greater consistency with other jurisdictions
  • Forcing actuaries to document is not the point
  • Reduce need for recomputation
  • Hopefully identify control gaps and fix
  • Improve processes before a problem occurs

21
Presenters Contact Details
  • Jacqueline Friedland, FCAS, FCIA, MAAA
  • KPMG LLP
  • (416) 777- 8320
  • jfriedland_at_kpmg.ca
  • Neville S. Henderson, FSA, FCIA, MAAA
  • PricewaterhouseCoopers LLP
  • (416) 941-8437
  • neville.s.henderson_at_ca.pwc.com
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