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Life Health > Annuities

Private Asset Graders Might Be Easy Graders

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What You Need to Know

  • Securities with private letter ratings made up about 4.1% of insurer assets in 2023.
  • The percentage of assets with private ratings has increased from 2.5% in 2020.
  • The ratings from the private issuers are about 2.7 notches higher than the ratings from an NAIC valuation office.

Insurance investment analysts are wondering whether some of the assets going into the life insurance and annuity pie crusts are overrated.

The analysts work for the Capital Markets Bureau, a National Association of Insurance Commissioners team that helps state insurance regulators understand insurance companies’ investments.

The analysts have noted in a new report that “private letter ratings,” or custom assessments of securities by credit rating providers, seem to be a lot higher than the grades the same securities would get from the NAIC’s own Securities Valuation Office.

Because the private letter ratings are so much higher than SVO ratings, using them without any adjustments can “potentially lead to the undercapitalization of insurance companies,” the analysts warn.

What it means: Grade inflation could make your clients’ life insurance policies and annuity contracts a little less secure than they look.

The pies: Life insurance policies and annuity contracts are, in effect, pie crusts made out of legal contracts. In the United States, the fillings traditionally have consisted mainly of high-grade corporate bonds, mortgages, mortgage-backed securities and a smattering of other types of assets, such as private debt, private equity stakes and securities backed by everything from automobile loans to credit card debts.

The ratings: The United States leaves regulation of the business of insurance to state insurance regulators. The NAIC is a Kansas City, Missouri-based group that helps states share regulatory resources.

States gauge insurance companies’ financial health by asking them to calculate “risk-based capital ratios.”

When an insurer adds assets to the capital total used in the RBC ratio math, the insurer is supposed to adjust for each asset’s level of risk by applying a value reduction, or “charge,” that reflects what the NAIC believes to be the asset’s level of risk.

In some cases, for big, widely distributed batches of securities, insurers can use public ratings from “nationally recognized statistical ratings organizations,” or credit rating providers, to figure out what risk charge to use.

In other cases, the issuers and insurers get risk-level designations from the NAIC’s own Securities Valuation Office or private letter ratings from outside rating providers.

Crediting rating providers note that they must use highly regulated credit assessment processes and they say that competition increases credit rating quality, by pushing regulators, insurers and the providers themselves to compare the performance of the different approaches used and see what works.

In the past, smaller rating providers and others have suggested that the Securities Valuation Office and big rating providers may have a financial incentive to reduce the level of competition in the credit rating market.

Assets with private letter ratings: U.S. insurers ended 2023 with $352 billion of their assets, or about 4.1% of their $8.5 trillion in cash and invested assets, invested in securities with private letter ratings.

That was up from $190 billion in assets with private letter ratings, or 2.5% of $7.5 trillion in total cash and invested assets, in 2020.

The grades: The NAIC’s Capital Markets Bureau has been trying to measure the toughness or easiness of the private letter rating providers by looking at what happens when issuers migrate from getting Securities Valuation Office designations to getting private letter ratings from outside credit rating providers.

The bureau analysts think of the grades in terms of “notches.”

If, for example, the top rating an issuer gives is AAA and the next grade down is AAA-, the analysts call the difference between those two grades a “notch.”

In 2023, about 97% of the 109 securities that moved to a private letter rating from a Securities Valuation Office designation ended up with a higher risk grade, the bureau analysts found.

NAIC risk-level designations based on the private letter ratings ended up being 2.74 notches higher than the designations that the same securities received from the NAIC’s own Securities Valuation Office.

In 2020, the average difference between designations based on private letter ratings and designations based on the Securities Valuation Office designations was just 2.375 notches.

Under the current rules, the bureau analysts note, the NAIC and the insurance industry must treat any particular credit rating as being the equivalent of any other rating of the same level no matter what firm provided the rating.

But the analysts say the NAIC has observed securities rating toughness differences.

“They could have an adverse impact on capital requirements under the current RBC framework,” the analysts say.

Credit: PeskyMonkey/iStock


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