New Way Of Determining Capital Stirs Some Concern Among Insurers

December 31, 2006 at 02:00 PM
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The third phase of a new way of determining capital that would apply to all in-force life insurance is a dramatic shift from the way that insurers currently determine capital set aside and requires companies to start looking at the issue now, according to discussions held during the winter meeting of the National Association of Insurance Commissioners here.

If all goes as planned, the C-3 Phase III project would take effect at year-end 2008. It is the third leg of a multi-year capital assessment project that regulators, with the help of the American Academy of Actuaries, Washington, are developing. C-3 Phase I applies to general account, fixed annuity business. C-3 Phase II applies to capital requirements for variable annuities with guarantees such as death and living benefits. C-3 Phase III assesses interest rate and market risk.

As part of the effort to establish the C-3 Phase III of the project, Peter Boyko, chair of the Academy's Life Capital Working Group, described elements of the project to members of the Life Risk-based Capital working group. Among the current recommendations is to include single premium life business in the C-3 Phase III component of the project and to remove it from C-3 Phase I, as well as to eliminate the current C1 required capital on expense allowance for variable products.

According to the presentation, projections would reflect prudent best estimate assumptions, and asset projections would reflect a company's reinvestment and disinvestment policies. Treatment of hedges, according to the presentation, would be directly reflected in the C3P3 calculation based on a C-3 Phase II framework.

During his presentation, Boyko presented calculations designed to illustrate that "for older policies, some of the reserves could be available to dampen capital."

In response to the presentation, John Bruins, a life actuary representing the American Academy of Life Insurers, Washington, said the "proposal is very broad in scope," and "from an application standpoint, it exponentially increases the work of companies." Bruins cautioned that the change in measuring capital could cause some companies to be put into insolvency because the bar measuring solvency is being moved. Not only could C3-Phase III affect solvency, but it could also impact ratings from rating agencies, he added. "There is a lot going on here. We don't take solvency lightly and we shouldn't be looking at [C-3 Phase III] lightly."

Mark Birdsall of Security National Life, representing the National Alliance of Life Companies, Sarasota, Fla., said there is an "enormous cost" associated with setting these assumptions and urged that simplicity be considered as the project progresses.

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