osfi update november 19, 2009 bernard dupont director, capital division

OSFI Update

November 19, 2009

Bernard DupontDirector, Capital Division

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Agenda

MCCSR Overall direction

IFRS modifications

Segregated Funds Requirements

Market and Credit risks QIS

Mortality improvement

Others

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MCCSR overall direction

Pressure from everywhere to redesign capital requirements

Redesign the current MCCSR standardized test to use new and more risk based techniques

Allow the use of internal models for determining regulatory capital

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Implementation of IFRS

General principle:

- Reduce MCCSR modifications to a minimum until phase II

- When the company is given the option to retain the current accounting methodology, retain current MCCSR treatment.

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OSFI will require life insurance companies to continue to use the current practice for CALM valuation as the basis for establishing relevant MCCSR capital available and capital required.

Balance sheet capital under IFRS will be adjusted to reflect any differences between CALM and IFRS valuations.

A secondary option being considered is to allow IFRS valuations using IAS 39 for non-insurance contracts and non-insurance components bifurcated from insurance contracts into capital.

Insurance Contracts

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Lessons learned in the recent financial turmoil showed that certain securitization structures did not transfer the risk as expected.

Assets which are not derecognized or which are not exempted from consolidation should be included in the capital available and capital required calculations.

Securitization and Off Balance Sheet Structures

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Most impacts for insurers are expected to occur within the following areas:

Consolidated Mutual Funds:• Where Insurers control mutual funds through

direct ownership of mutual fund units and IFRS requires consolidation, Asset risk capital charges will apply.

Consolidated Segregated Funds:• Risk based capital requirements already exist for

segregated funds and OSFI will continue with the current treatment. Although segregated funds will appear on the balance sheet, they would not attract asset specific capital charges outside of the existing Segregated Fund Risk charge.

Securitization and Off Balance Sheet Structures

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Own-use Property:Unrealized revaluation gains and losses would not be included in capital.

These unrealized gains do not represent capital freely available to absorb losses because own property is not easily sold in a stress environment and without disrupting operations.

Impact at time of adoption of fair value and valuations changes going forward will both be excluded from regulatory capital.

MCCSR / TAAM returns will be adjusted accordingly.

Real Estate

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Real Estate

Investment Property: OSFI will require that any fair value gains or losses upon transition and subsequent revaluation gains and losses be recognized in regulatory capital.

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Net impact of IFRS 1 changes:

Net impact from IFRS 1 (other than own-use property) should be reflected in retained earnings.

OSFI recognizes that impact of some changes have been flagged by industry as potentially material and adverse (e.g. IAS 19, Employee Benefits ).

On confirmation of systemically material net impacts, OSFI will execute a transition mechanism. (ex. a phase-in could amortize the hit to capital over four quarters).

Progress reports need to substantiate overall material impact of changes if OSFI is to provide transitioning.

IFRS 1 – Transition to IFRSs

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MCCSR Standardized Approach

Std Approach Working Group created:

participants: OSFI, AMF, Assuris

Start modifying the MCCSR current elements being more impacted by IFRS Phase II

Market and credit risk

Calibrate the elements once the results from QIS are available (fall 2009)

Recalibrate the elements once the results from modelling are available

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MCCSR Standardized approach

Framework Paper issued October 2008

Market risk paper issued October 2008

Modifications expected to be in place for 2012

Work on other MCCSR elements after phase I developments if necessary

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Segregated Funds

Current regulatory capital requirements for segregated fund guarantees are based on a modeling approach developed by the Canadian Institute of Actuaries (CIA) in 2000

Traditionally, OSFI has worked with the CIA when developing capital requirements and, for the most part, this approach has worked well

The market for segregated fund guarantee products has continued to evolve, with companies introducing new and increasingly complex products (e.g., guarantee minimum withdrawal benefit)

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Capital Requirements – Historical Perspective

OSFI has, for some time, had concerns about the risks in segregated fund guarantee products and the extent to which the modeling approach developed by the CIA captures these risks

As a result of these concerns, in 2006, OSFI asked the CIA to conduct a comprehensive review of the modeling approach for segregated fund guarantees to ensure that it was still appropriate

The events of the past 18 months have reinforced OSFI’s concerns and suggest that current risk evaluation may have underestimated the risks in segregated fund guarantee products

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Capital Requirements – Historical Perspective

Segregated fund guarantee risk is not like traditional insurance risk

Traditional insurance risk is diversifiable through the law of large numbers

The equity market risks, which form a major part of segregated fund guarantee risk, are not diversifiable

When equity markets decline, obligations on all policies increase at the same time

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Recent Developments

OSFI is undertaking a comprehensive review of segregated fund guarantee requirements

Review has several components:Comparison of the models and assumptions used by different companies to determine capital requirementsComparison of the amounts determined by different companies for identical risksConsideration of alternative methods for determining capital requirementsAdvice of an external consultant on different methods and amounts to be determined by this review

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Recent Developments

Segregated fund guarantee requirements are expected to increase as a result of this review

Review will confirm whether and by how much requirements should increase and the methods used to determine requirements going forward

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Recent Developments

Preliminary results of the review suggest that:there is a wide range of practice with respect to the setting of assumptions, e.g., for equity returns, discount rates and policyholder behaviour anddifferent companies could be holding materially different amounts for the same risk.

Differences could be the result of some companies being more conservative than necessary

No evidence that companies are not following CIA standards of practice

Increased disclosure of assumptions to the public may be appropriate.

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Recent Developments

Industry consultation on possible changes to the requirements for segregated fund guarantees would take place during 2010

Implementation expected to occur as soon as practicable, subject to appropriate grandfathering and/or transitioning/implementation arrangements

CIA has recently established a new task force to look at segregated fund guarantee risk modeling and requirements

OSFI is monitoring the work of this task force as OSFI completes its review

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Mortality Improvement

CIA Standard expected to be in place in 2010 allowing mortality improvement to be taken into account

OSFI will reverse the impact in capital until the capital requirements have been assess appropriately, likely including a QIS in 2010

New capital requirement might be in place in 2012

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Other issues

Assessing the appropriateness of the current Capital Metric for Holding companies, including the associated disclosure requirements and leverage ratio.

Minor changes for MCCSR 2010 Updated to reflect the introduction of Part XIII.

Hedging rules clarified