current issues in stochastic modeling of segregated fund guarantee products michael bean fcas, fsa,...
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Current Issues in Stochastic Modeling of Segregated Fund Guarantee Products
Michael Bean FCAS, FSA, FCIA
Director, Capital Division
Seminar for the Appointed Actuary
September 22, 2006
Outline of Presentation
• Context• Rationale for review• Key issues
– Summary– Discussion
• Update of hedging guidelines• Conclusion
Context
Context
• Segregated fund guarantee liability and capital requirements currently based on:
– Stochastic framework developed by CIA Task Force on Segregated Fund Investment Guarantees
• OSFI has identified a number of issues with the current framework that need to be addressed
Context
• OSFI document describing key issues recently sent to:
– CIA Actuarial Standards Board– CIA Practice Council
• OSFI has requested that the CIA:– Review the document– Provide initial views on priorities, project
plans and timelines for addressing the issues identified
Context
• Purpose of this presentation:– Highlight the key issues– Initiate discussion of the issues with the
wider actuarial community
Rationale for Review
Rationale for Review
• Over 5 years since the work of the CIA Task Force was completed
• Many significant changes in the industry and marketplace since then
Rationale for Review
• Significant changes:– Demutualization and consolidation– Greater interest in reported financials
and methods used to determine them– Development and growth of new
products– Foreign expansion– Serious interest in implementing
sophisticated hedging strategies
Rationale for Review
• Much experience with segregated fund models has been gained over the past few years
• This experience has revealed a number of potential shortcomings with the current framework
Key Issues
Key Issues: Summary
1. Asset model calibration
2. Premiums allowable as offsets
3. Bond fund and fixed income modeling
4. Modeling of foreign indexes and currency risk in foreign & domestic subsidiaries
Key Issues: Summary
5. Discount rates & assets backing the guarantees
6. Surrenders, resets & fund transfers
7. Contract aging & market-based valuation
8. Contract grouping
Issue #1:Asset Model Calibration
Issue #1: Asset Model Calibration
• Issue:– No calibration requirements for right tail
of asset return distributions
– No calibration of scenarios actually used in the valuation (only model is tested)
– No explicit calibration requirements for indexes of different types (e.g., equity v. bond v. real estate, Canada v. US v. Asia, large v. mid v. small cap)
Issue #1:Asset Model Calibration
• Why this is an issue:– New product designs (e.g., embedded
options of call type)
– Material exposures to foreign equity and bond markets, and currency risk
– Sophisticated hedging strategies
Issue #2:Premiums Allowable as Offsets
Issue #2: Premiums Allowable as Offsets
• Issue:– Amounts of future guarantee premium
allowable as offsets to future benefit payments not defined with sufficient precision
– Possibility of insufficient resources to fund benefit payments as they come due if premiums collected after a benefit payment date are allowed to offset that benefit payment
Issue #2: Premiums Allowable as Offsets
• Why this is an issue:– Sophisticated hedging programs require
the portion of MER considered guarantee premium to be fixed
– Peculiarities of segregated fund contract design
Issue #2: Premiums Allowable as Offsets
• Peculiarities of seg fund products:– Individual contracts can have multiple
benefit payments
– Premium amounts collected after a benefit payment often exceed the size of such a payment (even with discounting)
– Premiums collected over the life of a contract can vary inversely with the level of risk
Issue #2: Premiums Allowable as Offset
• Basic requirement:– At given confidence level, must be
sufficient assets to fund all future benefit payments as they come due
• Applies to:– Individual contracts– Portfolios of contracts with different
maturity-renewal dates
Issue #3:Bond Fund & Fixed Income Modeling
Issue #3: Bond Fund & Fixed Income Modeling
• Issue:– No guidance on stochastic modeling of
bond funds or interest rates
Issue #3: Bond Fund & Fixed Income Modeling
• Why this is an issue:– Material fixed income exposures (e.g.,
Hong Kong Mandatory Provident Fund)
– Dynamic hedging requires interest rate scenarios
– Standard equity models not really appropriate for bonds
Issue #3: Bond Fund & Fixed Income Modeling
• Additional considerations:– Equity-interest rate correlation
– Consistency with yield environment present on valuation date
– Bond funds of different durations consistent with one another
Issue #4:Modeling of Foreign Indexes & Currency Risk in Foreign & Domestic Subs
Issue #4: Foreign Indexes & Currency Risk
• Issue:– Insufficient guidance on modeling of
foreign indexes in either foreign or domestic subs
– Insufficient guidance on modeling of currency risk, whether hedged or unhedged
– Task Force Report silent on currency risk modeling & cost of currency hedging
Issue #4: Foreign Indexes & Currency Risk
• Why this is an issue:– Segregated fund guarantee risk
exposures in foreign (e.g., Asian) subs now material
– Asian markets are different:• Models that work well for Canada &
US may not be appropriate
Issue #4: Foreign Indexes & Currency Risk
• Why this is an issue:– Asian subs have more currency risk:
• Exposure to US markets• Greater fluctuation of US dollar vis-à-
vis yen, euro, etc
– Currency hedging embedded in some products
• Need to model interest rate spreads
Issue #5:Discount Rates & Assets Backing the Guarantees
Issue #5: Discount Rates, etc
• Issue:– Insufficient guidance on discount rates to
be used
– No explicit link between discount rates and assets backing unhedged portion of liabilities and capital, or recognition of asset-liability mismatch
– No explicit link between discount rate and DAC earnings rate (when applicable)
Issue #5: Discount Rates, etc
• Implicit assumptions in liability and capital calculation:– General account assets backing
unhedged portion of liabilities and capital are risk-free
– General account assets able to grow at rates used to discount future benefits and premiums
Issue #5: Discount Rates, etc
• Implicit assumptions cont’d:– General account assets …
• when combined with future premiums and investment income
• are sufficient to fund future benefit payments as they come due
• about 98% of the time
(assumes CTE 95 corresponds to 98th percentile)
Issue #5: Discount Rates, etc
• Implications:– Discount rates consistent with yield
environment on valuation date
– Asset and liability cash flows “matched” (or provision for asset-liability mismatch added to liability and capital)
– Consistency of discount rate and DAC earnings rate when assets backing liabilities and capital “invested” in DAC
Issue #5: Discount Rates, etc
• Comments on asset-liability mismatch:– Current guidance does not preclude a
company from backing a put-type segregated fund guarantee with equities
– Significant mismatch possible even if assets invested in “risk-free” bonds (e.g., 30-year bonds backing 2-year liability)
Issue #6:Surrenders, Resets & Fund Transfers
Issue #6: Surrenders, Resets & Fund Transfers
• Issue:– Insufficient guidance on modeling of
surrenders, resets and fund transfers
– Interrelationships among these options not recognized
– In seg funds, surrender, reset and fund transfer are actually financial options
Issue #6: Surrenders, Resets & Fund Transfers
• Surrender:– Option to avoid making any future
premium payments when value of the embedded guarantee turns out to be low
• Reset:– Option to lock in gains– Equivalently: surrender without penalty
and reinvest in identical contract without sales commission
Issue #6: Surrenders, Resets & Fund Transfers
• Fund transfer:– Option to change risk profile of
underlying assets to the advantage of the policyholder
• Partial surrender:– Option to lock in a portion of gains
without invoking a reset
Issue #6: Surrenders, Resets & Fund Transfers
• Peculiarities of seg fund contracts that make these options valuable:– Premium paid over life of contract, not
up-front
– Premium varies with account balance
– Premium collected varies inversely with risk (put-type guarantees)
– Guarantee applies to account balance, not individual fund balances
Issue #6: Surrenders, Resets & Fund Transfers
• Partial surrender example:– Suppose AV = $200, GV = $100 and
guarantee values adjusted proportionately for withdrawals
– Suppose $80 is withdrawn and put into a risk-free savings account
– Effective guarantee after withdrawal is $140 ($80 + 60% of $100)
Issue #7:Contract Aging & Market-Based Valuation
Issue #7: Contract Aging & Market-Based Valuation
• Issue:– No mechanism to ensure consistency
with market valuation as:
• Contracts move closer to maturity and the embedded options become more similar to market-traded options
• Companies implement sophisticated risk management strategies like dynamic hedging
Issue #7: Contract Aging & Market-Based Valuation
• Background:– Current framework uses real-world
rather than market-based (i.e., risk-neutral) valuation techniques
– Supporting argument:• If a company is not hedging the risk,
what matters is whether it has sufficient assets to fund guarantees in all but the most catastrophic market scenarios
Issue #7: Contract Aging & Market-Based Valuation
• However, what happens when:
– A market for long-dated options emerges?
– The embedded options become short-dated options, comparable to market-traded options?
– Companies implement dynamic hedging, which is based on market valuations?
Issue #7: Contract Aging & Market-Based Valuation
• Areas of particular concern:– Market-based values greater than
current approach (e.g., low risk-free rates, high implied volatilities, etc)
– Risk management strategies that transform a seg fund liability from one form to another and in so doing use actuarial valuation for a security that has an observable market value
Issue #7: Contract Aging & Market-Based Valuation
• Areas of particular concern cont’d:– Inconsistencies between actuarial and
market-based valuation exploited to arbitrage capital requirements
Issue #8:Contract Grouping
Issue #8: Contract Grouping
• Issue:– Insufficient guidance on contract
grouping
– Simple validation tests (e.g., point-in-time matching values) insufficient
– Better grouping algorithms needed for dynamic hedging
Issue #8: Contract Grouping
• Why this is an issue:– Seg fund guarantee liabilities and capital
highly sensitive to changes in account value, interest rates and time to maturity
– Dynamic hedging requires accurate information on sensitivity to AV/GV, interest rates, time to maturity, volatility, etc to determine hedge parameters and implement an effective hedge
Issue #8: Contract Grouping
• Consequence:– Grouping algorithm needs to ensure that
synthetic and seriatim portfolios have similar sensitivities to AV/GV, interest rates, time to maturity, etc
– Small differences in sensitivities can result in large differences in liability and capital values, large tracking errors and ineffective hedges
– Point-in-time value matching insufficient!
Issue #8: Contract Grouping
• Important comment:– Ultimate test of any hedging program is
whether it mitigates the risk in the actual seriatim portfolio, not some synthetic proxy
Update of Hedging Guidelines
Update of Hedging Guidelines
• Until a review of the stochastic modeling framework is completed and any deficiencies addressed, OSFI does not intend to:
– Update its general guidelines for hedging segregated fund guarantee risk
– Consider capital credit for anything other than the simplest hedges
Update of Hedging Guidelines
• Important Note:– Hedging strategies that appear to
mitigate risk within the current framework may introduce additional risk when viewed in true economic terms
– A company implementing such a strategy may be required to hold additional capital, whether or not capital credit for the hedging strategy was requested
Conclusions
Conclusions
• OSFI has identified 8 key issues in the current segregated fund guarantee valuation framework that need to be addressed
• Important that these issues be resolved in a timely fashion
Questions?