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With APRA’s engagement with industry around AASB 17 ramping up, the 2021 calendar year will be key for insurers and reinsurers to shape how AASB 17 requirements will interact with APRA’s financial reporting and LAGIC solvency calculations. This period also presents an opportunity for the industry to consult APRA on areas that reduce operational impacts of the change.
This blog outlines the key changes and implications for General Insurers from updates to APRA’s prudential framework as a result of AASB 17 with a focus on potential changes in capital calculations.
Below are the top five capital/solvency proposed changes that General Insurers need to be aware of:
1. Capital Base Adjustments: APRA is proposing additional regulatory adjustments to the capital base to minimise impact from AASB 17 changes on the capital base as follows:
These will impact the LAGIC capital base calculation processes and the effects need to be understood for the specific GI product groups.
2. Reviewing limits for Asset Concentration Risk Charge (ACRC)
APRA is reviewing the dollar value exposure limits built into LAGIC such as those relating to ACRC (GPS 117). APRA is proposing to factor in inflation and introduce an indexation mechanism to the dollar exposure limits to futureproof the requirement. This is a sensible proposal and will benefit insurers who regularly reach the ACRC dollar limits merely through inflationary growth in their asset concentrations.
Since the introduction of LAGIC in 2013, RBA’s inflation calculator on a representative basket of goods estimates a 14% increase in costs (up until end of 2019). This change is expected to be higher allowing for elapsed time until the new prudential standards are introduced. General Insurers may wish to consider discussions with APRA around the inflation mechanism for ACRC limits and the factors that will flow into this mechanism by class of business (e.g. CPI vs. AWE vs. Other).
3. Internal Capital Models option to be removed for regulatory capital purposes
APRA is proposing to require all insurers to use the standard method and will remove the option to use an Internal Capital Model (ICM) for calculating regulatory capital.
We note that a range of insurers have continued to develop and use economic capital modelling for a variety of business uses (pricing, reinsurance design, Asset-Liability Matching etc) but not for APRA solvency calculations perspective.
APRA has indicated that in the majority of cases, costs of using an ICM outweighed the benefit of adopting it for APRA LAGIC purposes in terms of management time and prescribed capital amounts saved. Whilst this reduces options available to insurers, it won’t in our view, change management outcomes in terms of managing to both economic and regulatory capital views for a variety of business and regulatory purposes.
4. Fair value requirement for measurement of assets
APRA is proposing to explicitly require General Insurers to deduct the difference between fair value and reported value of assets, for the purposes of determining the capital base.
Currently under GPS 114, APRA requires that the stress tests informing the asset risk charge should be applied to the fair value of assets. However, this is not explicitly reflected in GPS 112 (Measurement of Capital).
This change may not have significant impacts on General Insurers who already use fair value of assets when determining LAGIC elements, however, APRA is seeking feedback on where there are situations where General Insurers are not using fair value.
5. Operational Risk Charge for whole of account quota share arrangements
APRA is reviewing whether the current risk charges are appropriate, and what the potential alternatives could be. We view that this could impact General Insurers who have high levels of reinsurance support such as whole of account quota shares and where the operational risk charge can be a prominent element of the PCA (given that operational risk charge is calculated on the gross position).
General Insurers may benefit from consultation with APRA around this area of the risk charges, particularly as operational risk is generally more effectively dealt with via appropriate and robust preventative governance and controls frameworks rather than holding capital.
Kaise is a Partner in Consulting and advises general insurers and reinsurers on a range of matters covering Board and Management insurance reserving advice, corporate strategy, reinsurance programs, claims and capital management, pricing advice on large/complex deals and Appointed Actuary and External Peer Reviewing roles. Kaise’s international experience covers the Australian, New Zealand, South East Asian and European insurance markets.
Anne has worked in the General Insurance Industry in Australia and the UK for more than 30 years and joined Deloitte in 2020 as Partner and Global IFRS 17 General Insurance Leader. Anne is a member of the International Accounting Standards Board Transition Resource Group (TRG), appointed in November 2017, and is Chair of the Australian Accounting Standards Board TRG, actively driving discussion and debate to support Australian implementation of IFRS 17. Anne has experience leading a global IFRS 17 implementation project through impact assessment, deep dive analysis of critical issues, policy development, practical application and design and managing senior stakeholders through this process. With a foundation in global financial reporting processes and delivery, establishing and running a global finance policy function and developing a robust finance control environment for a multinational national insurance company, Anne has a track record of implementing, streamlining and enhancing business systems and supporting reporting processes. Based in Australia, Anne is working with clients globally to deal with the challenge of implementing IFRS 17.