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Roles and Responsibilities of External Auditors and Actuaries Insurance Industry Workshop 1 2 Novemb

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Title: Roles and Responsibilities of External Auditors and Actuaries Insurance Industry Workshop 1 2 Novemb


1
Roles and Responsibilities of External Auditors
andActuaries Insurance Industry Workshop 1
2 November 2005 Bangkok, Thailand
Kim Norris Managing Director International
Advisory Group www.osfi-bsif.gc.ca
2
Discussion Points
  • External Auditors
  • Roles and responsibilities of the Actuary
  • Roles and responsibilities of an actuary
  • Reporting
  • Dynamic Capital Adequacy Testing (DCAT)
  • Professional Standards and OSFIs role

3
External Auditors
  • An independent audit opinion (required by
    legislation) provides credibility to financial
    statements
  • External auditors are subject to standards with
    respect to qualifications, work and behaviour
  • Professional standards
  • Peer review
  • Statutory requirements
  • Public Oversight Board

4
External Auditors
  • Auditors opinion unqualified or reserved
  • reservation or qualification may be important
    from a supervisory perspective
  • need to understand the reasons for the
    qualification
  • does not necessarily provide assurance on the
    future viability of the institution or the
    effectiveness of management

5
External Auditors
  • OSFI reviews External Auditors work to
  • Help assess the institution
  • enhance supervisors knowledge of the institution
  • identify any prudential concerns raised and hence
    target areas for in-depth reviews

6
Appointed/Consulting Actuaries
  • Roles and responsibilities of an actuary
  • Reporting
  • Dynamic Capital Adequacy Testing (DCAT)
  • Professional Standards and OSFIs role
  • Most jurisdictions now require that a qualified
  • actuary attest to the adequacy and
    appropriateness of the insurers loss reserve

7
Appointed/Consulting Actuaries
  • Roles and responsibilities of an actuary
  • OSFIs expectation for the Appointed Actuary
  • To produce sound, consistent (so that two
    actuaries considering the same fact situation
    arrive at results that are not materially
    different), and appropriate work, monitored by
    the CIA
  • The responsibilities of the actuary are spelled
    out in legislation

8
Appointed/Consulting Actuaries
  • Roles and responsibilities of an actuary
  • The actuary will value
  • 1) the actuarial and other policy liabilities of
    the company as at the end of a financial year
    and
  •  2) any other matter specified by OSFI (e.g. as
    per the AA Memo)
  • The actuary's valuation shall be in accordance
    with generally accepted actuarial principles
    unless otherwise specified by OSFI.

9
Appointed/Consulting Actuaries
  • Roles and responsibilities of an actuary
  • DCAT provision The actuary will meet with the
    directors/audit committee at least once during
    each financial year in order to report, in
    accordance with GAAP and under any other
    specifications by OSFI, on the financial position
    of the company and its expected future financial
    condition.
  • Whistle blowing provision If the actuary comes
    across any matters that have a material adverse
    effect on the financial condition of the company
    and require rectification, the actuary will
    report in writing the CEO, CFO and directors. If
    suitable action is not being taken to rectify the
    matters, the actuary will send a copy of the
    report to OSFI.

10
Appointed/Consulting Actuaries
  • Roles and responsibilities of an actuary
  • Report on the policy liabilities in Annual Return
  • Report to the shareholders and policyholders not
    less than 21 days before the companys annual
    meeting
  • State whether the annual statement fairly states
    the valuation results
  • Meet with and report to the directors or the
    chief agent on the companys future financial
    position (DCAT report)

11
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • Detailed actuarial report submitted to
    regulator
  • Contains the opinion of the actuary concerning
    the fairness and adequacy of the figures for
    policy liabilities included in the insurers
    annual statements
  • Contains detailed commentary and exhibits of data
    and calculations supporting the opinion
  • Filed within 60 days of companys year-end 105
    days for reinsurers

12
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • Purpose
  • To give OSFI a comprehensive report documenting
    the work done by the AA to calculate the policy
    liabilities. OSFI does not release the Report.
    However, companies may release the Report for
    special purposes e.g. to rating agencies or to
    investment bankers

13
Appointed/Consulting Actuaries
  • Contents of the Appointed/Consulting
  • Actuarys Report
  • Introduction and Scope
  • Company, date, author
  • Description of company operations
  • Description of the type of data provided and the
    review and verification procedures
  • Description of the procedures and/or methodology
    to transform data
  • Description of the procedures to ensure the data
    is sufficient, reliable and accurate
  • Disclosure of AAs compensation and bonus
    structure

14
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • Expression of opinion
  • includes the liability figures (both claim and
    premium liabilities) of the AA and that booked by
    the company
  • includes a statement regarding the data
    reliability, sufficiency and consistency
  • may be a qualified opinion

15
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • Comparison of actual experience with expected
    experience in the previous year-end valuation
  • a comparison is provided for 5 years (general
    insurers)
  • A comparison for insurance policy and contract
    liabilities for 3 years (life insurers)

16
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • General Insurers
  • Commentary
  • description of case reserving process
  • any significant changes in assumptions or
    techniques from the previous valuation report
  • the principal characteristics of each line of
    business
  • changes in the companys marketing strategy, mix
    of business, level of retention, reinsurance,
    methods of recording data

17
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • General Insurers
  • Commentary (contd)
  • expected ultimate claims and claim ratios for
    each accident year
  • impact of industry pools
  • impact of inter-company pooling agreements
  • treatment of mass tort and environmental
    liabilities
  • provision for adverse deviation (PfAD)

18
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • General Insurers
  • Database and exhibits
  • exhibits should be provided for each line of
    business on a gross and net basis
  • cumulative paid loss data by (accident year)
  • case reserve by (accident year)
  • reported claim counts by (accident year)
  • open claim counts by (accident year)
  • any other derived exhibits

19
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • General Insurers
  • Other
  • the extent to which the Actuary uses the work of
    the Auditor must be discussed in the Report
  • any reliance on or use of the work of another
    Actuary should be indicated
  • reinsurance amounts recoverable must be stated
  • any known problems in the collection of
    reinsurance should be specified

20
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report General
  • Insurers
  • Review of claims liability data
  • Operational changes and external influences
  • changes in underwriting practice
  • changes in claims handling including case
    estimate practice
  • changes in data processing
  • changes in accounting
  • changes in judicial, regulatory and legislative
    environment
  • economic variables such as inflation

21
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • General Insurers
  • Review of claims liability data
  • Homogeneity and credibility of the data
  • data is usually divided into lines of business to
    increase homogeneity
  • the data set should be large enough to be
    credible otherwise the actuary may use industry
    data to make selections
  • Reinsurance limits
  • Collateral sources e.g. salvage, subrogation,
    loss transfer

22
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • General Insurers
  • Review of claims liability data
  • Different valuation methods
  • most often, the actuary will calculate at least
    two or more methods, compare them and then select
    valuation results from one or a combination of
    methods

23
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • General Insurers
  • Review of premium liability data
  • The claims estimates
  • Premium development
  • The rate level underlying the unearned premium
  • Reinsurance
  • Seasonality of losses
  • Trend factors

24
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • Life Insurers
  • Asset Liability Management (ALM)
  • report on each interest sensitive asset segment
  • report on interest sensitivity of the liabilities
    cash flow

25
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • Life Insurers
  • Sources of earnings
  • analysis of a companys earnings by source in a
    prescribed format

26
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • Life Insurers
  • Participating policies
  • review allocation of investment income and
    expenses
  • transfers to shareholders from participating
    account
  • divided policy

27
Appointed/Consulting Actuaries
  • Appointed/Consulting Actuarys Report
  • Life Insurers
  • Minimum Continuing Capital and Surplus
    Requirement (MCCSR)
  • review cases where actuarial judgement is
    required
  • e.g. negative reserves excess cash value
  • indexlinked policies

28
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing (DCAT)
  • Definition
  • the process of analyzing and projecting the
    trends of a companys capital position under a
    variety of future scenarios, to identify risk and
    threats and to suggest actions to take
  • Purpose
  • to inform management and the Board of Directors
    about the potential threats to the solvency of
    the company

29
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing (DCAT)
  • Usefulness
  • alerting OSFI as to where there are risks of
    insolvency
  • showing the variability of the business plan
  • understand the risk profile of the company
  • OSFI requires the production of the report but
    according to CIA standards
  • The report must be sent OSFI within 30 days of
    presentation to the Board
  • Also applies to companies in runoff
  • The reports are an important component of a
    companys risk management process

30
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing (DCAT)
  • Process of DCAT
  • review of recent operations
  • development of a base scenario
  • examination of the risk categories
  • stress testing of the risks
  • selection of those scenarios requiring further
    analysis
  • The base scenario will usually be the companys
    financial plan

31
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing (DCAT)
  • General Insurers
  • 11 risk categories
  • Frequency and severity
  • Pricing
  • Misestimation of policy liabilities
  • Inflation
  • Interest rate
  • Premium volume

32
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing (DCAT)
  • General Insurers
  • 11 risk categories (contd)
  • Expense
  • Reinsurance
  • Deterioration of asset values
  • Government and political action
  • Off-balance sheet

33
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing
  • (DCAT) Life Insurers
  • 10 risk categories
  • Mortality risks
  • Morbidity risks
  • Persistency risks
  • Cash flow mismatch risk (C-3 risk)
  • Deterioration of asset values (C-1 risk)

34
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing
  • (DCAT) Life Insurers
  • 10 risk categories (contd)
  • New business risks
  • Expense risks
  • Reinsurance risks
  • Government and political action
  • Off-balance-sheet risks

35
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing
  • (DCAT) General Insurers
  • 11 risk categories (contd)
  • (1) Frequency and severity
  • catastrophic loss earthquake, windstorm, flood,
    hail
  • multiple catastrophic losses
  • multiple large losses
  • loss ratio being much higher than usual (about 10
    points)

36
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing
  • (DCAT) General Insurers
  • 11 risk categories (contd)
  • (2) Pricing
  • rate freeze
  • increased competition
  • (3) Misestimation of policy liabilities
  • reserves being at too low a level
  • especially for long-tailed lines there may be
    inflation or court decisions that were not
    factored in originally

37
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing
  • (DCAT) General Insurers
  • 11 risk categories (contd)
  • (4) Inflation
  • at least 3 percentage points over that in the
    base scenario for five consecutive years
  • yield curve shifts up by at least 150 based
    points
  • at least half of all future payments will inflate
    at the higher trend factor

38
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing
  • (DCAT) General Insurers
  • 11 risk categories (contd)
  • (5) Interest rate
  • a parallel shift of 300 bases points in the yield
    curve
  • (6) Premium volume
  • a reduction of up to 30
  • a significant increase in volume

39
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing
  • (DCAT) General Insurers
  • 11 risk categories (contd)
  • (7) Expense
  • low premium volume but fixed expenses
  • technology changes
  • severe inflation
  • court decisions related to market conduct
  • (8) Reinsurance
  • reinsurer insolvency
  • increase in reinsurance rates
  • disputes over policy conditions

40
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing
  • (DCAT) General Insurers
  • 11 risk categories (contd)
  • (9) Deterioration of asset values
  • increase of 150 bases points
  • decline in equities of 25
  • 50 decline in real estate
  • 75 decline in the largest subsidiary
  • (10) Government and political action
  • increase in premium tax
  • increase in assessments
  • entry of new distribution channels
  • (11) Off-balance sheet
  • defaults on letters of credit

41
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing (DCAT)
  • Examination of the risk categories
  • scenarios that are tested should have a 1 to 5
    probability of occurrence
  • Stress testing of the risks
  • how far the risk factor has to change in order to
    drive the companys surplus negative
  • helps to determine sensitivity to certain risks
    and helps fix the scenarios

42
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing
  • (DCAT)
  • Selection of scenarios requiring further analysis
  • at least 3 scenarios must be examined in detail
  • ripple effect and management action must be
    included in scenario testing

43
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing (DCAT)
  • Actuarys opinion
  • Financial condition is satisfactory if throughout
    the forecast period, the company meets all its
    future obligations under the base scenario and
    all plausible adverse scenarios and under the
    base scenario, it meets the minimum regulatory
    capital requirement

44
Appointed/Consulting Actuaries
  • Dynamic Capital Adequacy Testing (DCAT)
  • Actuarys report
  • Must report any plausible adverse scenarios that
    cause the insurer to fall below the minimum
    regulatory capital requirement
  • If the capital is less than the companys target
    level but greater than 100 the actuary must
    comment on the possibility that the regulator
    would exercise its authority to impose
    restrictions which would affect the companys
    ability to successfully execute its business plan

45
Appointed/Consulting Actuaries
  • Principles to keep in mind
  • OSFI relies on the AAs opinion
  • Canadian Institute of actuaries (CIA) develops
    appropriate standards
  • CIA standard of professional conduct applies
  • OSFIs role
  • verify that the actuarys work is reliable and in
    compliance
  • identify concerns with a companys liabilities
  • identify risk and threats
  • take action when necessary

46
Appointed/Consulting Actuaries
  • OSFIs review of DCAT
  • compliance with CIA Standards
  • format of the report
  • appropriateness of adverse scenarios
  • recommendations
  • follow-up on issues previously raised
  • other financial condition, type of business,
    structure of company, effectiveness of management

47
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