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Reserving in Other Countries. Peter A. Royek Toa Reinsurance Company of America Casualty Loss Reserve Seminar Minneapolis, Minnesota September 18, 2000. Why This Session ?. “Affiliate” Membership & “Mutual Recognition” Consolidations / Communication
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Reserving in Other Countries Peter A. Royek Toa Reinsurance Company of America Casualty Loss Reserve Seminar Minneapolis, Minnesota September 18, 2000
Why This Session ? • “Affiliate” Membership & “Mutual Recognition” • Consolidations / Communication • One Actuary’s recent experience - it could happen to you!
Broad Overview of Session • General Discussion of Differences Involving Reserving Among World Markets • Reserving in the United Kingdom • Reserving in Mexico
General Discussion of Differences Involving Reserving Among World Markets • ) Dimensions for Differentiation • ) International Reserving Example
Dimensions for Differentiation • Methods • Reserve Categories • Data • Accounting Rules • Role of the Actuary
Dimensions for DifferentiationMethods • Japan • Strict formula for IBNR calculation • Automobile • Earned Premium for current year X 3% • Personal Accident, Liability, and WC • Earned Premium for current year X 8% • All Other Lines • 0 • Need for change in the future? • Europe (Outside the UK) • Tendency toward a more theoretical, statistical approach
Dimensions for DifferentiationMethods • Others • New IBNR or IBNER requirements or other strict rules for their calculation • Clearly “Standard” Methods are Not Currently Used in these Markets
Dimensions for DifferentiationMethods Rate Inadequacy => Reserve InadequacyTwo Companies Writing the “Same” Risk • Company A - Charges Tariff Rate • Premium = 1,000 • IBNR = 80 (8% x 1,000) • Company B - Deviates Off Tariff Rate • Premium = 700 • IBNR = 56 (8% x 700)
Dimensions for DifferentiationReserve Categories • Premium Deficiency Reserve - Canada • Amount by which UPR is insufficient to cover future loss and expense, liability (if any) must be posted • Appointed Actuary must opine on the adequacy • Similar to Unexpired Risk Reserve in the UK • GAAP adjustment in the US
Dimensions for DifferentiationReserve Categories • Contingency (or Extraordinary Loss) Reserve - Japan • Pre-event loss fund with strict rules for build-up and draw-down • Somewhat similar to Catastrophic Reserve in Mexico • Coming to the US?
Dimensions for DifferentiationReserve Categories • Equalization Reserve - Germany • Can be used for smoothing of results • Like “Topside” or “Corporate” reserves in US companies(?), but these are NOT a separate statutory item • Somewhat like Extraordinary Loss Reserve due to the tax-free feature of these reserves, but NOT the strict rules to build-up or draw-down • Prevision Reserve - Mexico
Dimensions for DifferentiationData • Benchmarks • Not as publicly-available as in the U.S. • AM Best,RAA,etc. • “Private” collections do exist • Consultants • Companies • Canada • Some industry data for Auto • Runoff exhibit in Annual Return NOT by LOB, unlike Schedule P • Japan
Dimensions for DifferentiationData • Other Issues • Not enough data • How to reserve for small or incidental foreign exposure with lack of benchmarks? • Too much data • A “stew” of otherwise-heterogeneous data in a single reserving class • Due to credibility concerns or ceding company reporting?
Dimensions for DifferentiationAccounting Rules • Tax Rates • Basis of Accounting • Different Statutory Statement Items • Fiscal Year/Reporting Frequency • “Combined Ratio”
Dimensions for DifferentiationAccounting RulesTax Rates on Underwriting Income • Japan - 30% • Recent History • 1998 - 34.5% • 1990 through 1997 - 37.5% • 1989 - 40% • United Kingdom - 30%
Dimensions for DifferentiationAccounting RulesTax Rates on Underwriting Income • USA - 35% • Canada - 28% Federal, plus … • Federal Surtax - 1.12%, plus... • Provincial Rates • Ontario - 14.5%, for example, for a combined 43.62% • Federal to lower to 21% by 2005 (excl surtax) • Ontario to lower to 8% by 2005
Dimensions for DifferentiationAccounting RulesBasis of Accounting • Differences when comparing to US Statutory or US GAAP Accounting • Examples in Japan • Valuation of Assets in Japan • Impacts the calculation of “Surplus” • Due to change to “market-based” valuation in 2000/2001 • Consolidation • Companies are making US GAAP Adjustments • Some previously-mentioned items go away • Allows for level comparison of companies
Dimensions for DifferentiationAccounting RulesDifferent Statutory Statement Items • Examples: • Premium Deficiency Reserves • Extraordinary Loss Reserves • Runoff Exhibit in Canadian Annual Return
Dimensions for DifferentiationAccounting RulesFiscal Year / Reporting Frequency • Accounting year-end dates • Japan - 3/31 • Australia - 6/30 • In some markets, results are reported (and IBNR is calculated) only at fiscal year-end
Dimensions for DifferentiationAccounting Rules“Combined Ratio” • Incurred Losses+LAE/EP+Non-Loss Expenses/WP (differs elsewhere) • What does it really tell you about the strength/performance of a company? • Mix of business • Reserve adequacy • Return on equity, revenue, etc. • Potentially leads to bad reserving and underwriting decisions
Dimensions for DifferentiationRole of the Actuary • Canada • Best Estimate • The “minimum” to be carried by the company • Margins above are disclosed • Contrast these with the US • Codification/Best Estimate Reserving coming to the US? • Discounting/PFADs • Discounting only allowed by OSFI for AB • CIA requires reserves be discounted and a Provision for Adverse Deviation (PFAD) be added • Discounted Reserve + PFAD must be >(or =) Company Carried
Dimensions for DifferentiationRole of the Actuary • Canada (continued) • DCAT • Companies operating in Canada now subject • Opining on Premium Liabilities
Dimensions for DifferentiationRole of the Actuary • Japan • Duties of the Actuary listed in “Insurance Business Law” • No Actuarial Judgment in Reserving • Now a Need for Rating Expertise
International Reserving ExampleIntroduction • The “same” piece of business (Treaty/Certificate/Policy) will be run through 4 different scenarios in 3 different jurisdictions • The effects of local reserving rules and tax rates will be run against the same underwriting results
International Reserving Example“Simplifications” • Each company writes only this one account • IBNR thus allocated to this account • Investment Income • Simplified Investment Income calculation, meant only to show that II will vary due to the effect of reserve rules + tax rates on cash available for investment • No variation of investment yield by country • No variation between tax rates on investment income and tax rates on underwriting income
International Reserving Example“Simplifications” • All premium is earned in the first year • No UPR at year end > No “Premium Liability” Issues • Reserve discounting for tax purposes is NOT performed
International Reserving ExampleFramework • LOB = Auto • Premium = 1,000 units • Expenses = 250 units, all paid on 1st day • Expense Ratio = 25% • Investment yield = 5% • Ultimate Loss Ratio = 70% • “Reasonable Range” (for US) is (65%,75%) • Account closed after 5 years • Account history in years 1 through 5 • Payment pattern - 100,100,200,200,100 • Case reserves held at year-ends - 100,100,100,50,0
International Reserving ExampleFramework • Taxes paid at year end on annual underwriting + investment income • Investment income calculated on average cash funds held (oversimplified in this example) • Over- or Under-reserving (where applicable) is adjusted in year 5
International Reserving ExampleFramework • All scenarios will produce an underwriting income of 50 • All scenarios will produce a loss ratio of 70%, an expense ratio of 25%, and a combined ratio of 95% • Net Income and Cash are the items which will vary
International Reserving ExampleScenarios • Japan • IBNR = 30 at Year 1 • Released after Year 1 as all premium is earned • Tax rate = 30%
International Reserving ExampleScenarios • Canada • Company sets loss ratio to the Best Estimate of 70% • IBNR is held to achieve 70% until final settlement • Initial tax rate used is Federal + Ontario provincial rate = 43.62%
International Reserving ExampleScenarios • USA #1 • Company sets loss ratio to the high end of the range - 75% • IBNR is held to achieve 75% until final settlement • Tax rate = 35%
International Reserving ExampleScenarios • USA #2 • Company sets loss ratio to the low end of the range - 65% • IBNR is held to achieve 65% until final settlement • Tax rate = 35%
International Reserving ExampleResults • Japan • IBNR lowest Year 1, then 0 • Takes largest underwriting profit & pays most tax in Year 1. Takes largest U/W losses next 3 years • Overall pays least taxes (lowest rate) • Overall makes least II (while paying overall least taxes, paid a lot in Year 1) • Total Net Income = 60.04
International Reserving ExampleResults • Canada • Sets loss ratio to the “correct”70%, incurs all loss in Year 1 • Earns II between the two US scenarios as it holds reserve level between the two • Overall pays most taxes (highest rate to start) • Total Net Income = 53.66
International Reserving ExampleResults • USA #1 • Company sets high loss ratio 75% • Takes underwriting gain in Year 5 with downward adjustment in loss ratio • Most NI & tax in Year 5 • Overall makes the most II as it holds more reserves longer • Total Net Income = 62.31
International Reserving ExampleResults • USA #2 • Company sets loss ratio - 65% • Takes underwriting loss in Year 5 with upward adjustment • Least NI & tax in Year 5 • II greater only than Japan • Total Net Income = 59.98
International Reserving Example“Conclusion” • The differing reserving rules and tax rates among jurisdictions do impact the results of the “same” account. However: • Factors that were “simplified”or ignored in this example will affect the magnitude and can affect the comparative magnitude of the results • Factors that can vary from those in this example will also affect the magnitude and can also affect the comparative magnitude of the results
Embrace the Differences ! • Know the rules of all the places in which you operate • Operate intelligently (and legally) across your worldwide markets