New draft rules could hurt small fixed annuity issuers that want to stick with traditional reserving methods, according to Waylon Peoples.
Peoples, vice president, life actuarial, with Erie Family Life, says the National Association of Insurance Commissioners has promised to free small, strong life and annuity issuers from having to use the complicated principles-based reserving (PBR) approach.
But a proposed update to Valuation Manual-22 has created a tough process for small annuity issuers that want a PBR exemption, Peoples writes in a comment letter on the VM-22 draft update.
"Demonstration of compliance with any of the exclusion tests in VM-22 will likely require a modeling exercise using multiple interest rate scenarios along with supporting documentation that is not meaningfully less than the work and documentation required for those who do not pass an exclusion test," Peoples says.
Principles-Based Reserving Basics
The National Association of Insurance Commissioners is a Kansas City, Missouri-based group for state insurance regulators.
Traditionally, life and annuity issuers have used simple formulas to show they have enough financial resources to meet obligations to insurance policyholders and annuity contract holders.
The NAIC has been working with life insurers and actuarial groups for many years to implement a U.S. life insurance PBR system. The PBR system is supposed to be a framework that life insurance and annuity issuers can set aside reserves based on "statistical modeling," or math-based forecasts, rather than simple formulas.
Many life insurers believe that shifting toward a PBR approach, and away from the traditional, formula-based approach, will help them do a better job of matching resources with obligations and will give them a better understanding of the obligations and the risks they face.
Many small life insurers have argued that meeting the statistical modeling requirements is difficult and expensive and that they should be able to use traditional reserving formulas.
