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Assurance & Advisory Business Services
May 20, 20051
FRS 104 Insurance ContractsFRS 104 Insurance Contracts
Singapore Actuarial Society Forum
4 March 2005
Singapore Actuarial Society ForumSingapore Actuarial Society Forum
4 March 20054 March 2005
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AgendaBackground
Product Classification
Insurance Contracts and Contracts with DPF – Accounting Treatment
Disclosure Requirements
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Background on IFRS Insurance ProjectBackground on IFRS Insurance Project
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BackgroundIASB developing a single set of global accounting standards
Many countries committed to the objective of global “harmonisation”
Cross-border capital flows highlight the need for consistent, understandable financial information
Drivers for fair valueHistorical cost accounting models lack relevance
Solvency-based approaches don’t provide an accurate picture
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Phased approach for insurance
There is now a phased approach to insurance contracts.
The Board’s objective for Phase I is to implement some components of the insurance project by 2005, without delay to Phase II
IFRSINSURANCE
PROJECT
IFRSINSURANCE
PROJECT
Phase I – Implemented 1/1/2005Phase I – Implemented 1/1/2005
Phase II – Implement Fair Value by 2007 / 8 (?)Phase II – Implement Fair Value by 2007 / 8 (?)
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2005 requirements
All European Listed companies and Australian reporting entities are required to report under International Financial Reporting Standards by 2005
Singapore FRS based on IFRS
CCDG has adopted FRS 104 for Singapore to be effective 1 Jan 2005
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Key standards for insurersVariousFRS 39 EquityInvestments:
EquitiesFixed Income
MortgagesLoans
FRS 104Insurance Liabilities & Investment
contracts with discretionary participation
features
FRS 16/25Property
FRS 18InvestmentContract DAC
FRS 39Insurance Liabilities –
Phase I
Investmentcontract liabilities
FRS 104
Other assetsOther
liabilities
Insurance DAC
FRS 104PVIF VariousVarious
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Product ClassificationProduct Classification
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Product classification- Why is it important?Product Classification defines accounting treatment
Contracts with Discretionary
Participation Features
Phase I
Investment contractsInsurance contractsExisting
Accounting*Existing
Accounting*
*Subject to certain modifications+Subject to exposure draft
ExistingAccounting*
ExistingAccounting*
Amortised Cost-or-
Fair Value +
Amortised Cost-or-
Fair Value +FRS 104
FRS 104 FRS 39
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Classification flowchartAre any elements of
the benefit driven by discretionaryparticipation
Deposit component
Insurance and depositcomponents of contract must, ifnot recognised, be unbundled
and valued separately
Yes
No
Yes
No
Product is an InvestmentContract with discretionary
participation features
Classified as aninvestment contract
Product is an InvestmentContract without discretionary
participation features
Is there significantinsurance risk present
in the contract?
Insurancecomponent
Is there adeposit component to the
contract? If so, is the deposit componentindependent of the insurance
cash flows?
Insurancefeatures present
in contract
Yes
Product is anInsurance ContractNo
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Definition of insurance“A contract under which one party (the insurer) accepts significant insurance risk from another party (the policyholder) by agreeing to compensate the policyholder if a specified uncertain future event (the insured event) adversely affects the policyholder.”
Significant Insurance Risk
InsurerInsurerPolicyholderPolicyholder $
on occurrence of insured event
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Significant insurance risk‘Significant if, and only if, an insured event could cause an insurer to pay significant additional benefits in any scenario, excluding scenarios that lack commercial substance.’
Additional benefits must be for pre-existing risk and do not include:
Charges that would be made on cancellation or surrenderLoss of ability to charge policyholder for future servicesPossible reinsurance recoveries (these are classified separately)
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Change in level ofinsurance risk
Once insurance, always insurance, but can go from investment to insuranceInvestment may change to insurance through:
Changes in regulation, lawSwitch between funds, first fund has no insurance risk – second fund has insurance risk.Previously underestimated risks in investment contracts
INVESTMENT INSURANCE
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Comparison to US GAAP
US GAAP Classification FRS Classification
SFAS 60, SFAS 97 Limited Payment, SFAS 120 Insurance
SFAS 97 Universal Life Insurance
Insurance or Investment(depending on significance of insurance risk)SFAS 91, SFAS 97 Investment
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Unbundling
Are any elements ofthe benefit driven by discretionary
participation
Deposit component
Insurance and depositcomponents of contract must, ifnot recognised, be unbundled
and valued separately
Yes
No
Yes
No
Is there significantinsurance risk present
in the contract?
Is there adeposit component to the
contract? If so, is the deposit componentindependent of the insurance
cash flows?
Insurancefeatures present
in contract
Product is an InvestmentContract with discretionary
participation features
Classified as aninvestment contract
Product is an InvestmentContract without discretionary
participation features
InsurancecomponentYes
Product is anInsurance ContractNo
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When do you unbundle?
Unbundling is required when:The insurer’s existing accounting policies do not require recognition of the deposit component, and
The insurer can independently measure the deposit component from the insurance component
Unbundling is allowed but not required when the insurer can independently measure the deposit component from the insurance component
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Discretionary participationFeatures (DPF)
Are any elements ofthe benefit driven by discretionary
participation
Deposit component
Insurance and depositcomponents of contract must, ifnot recognised, be unbundled
and valued separately
Yes
No
Yes
No
Is there significantinsurance risk present
in the contract?
Is there adeposit component to the
contract? If so, is the deposit componentindependent of the insurance
cash flows?
Insurancefeatures present
in contract
Product is an InvestmentContract with discretionary
participation features
Classified as aninvestment contract
Product is an InvestmentContract without discretionary
participation features
Yes
No
Insurancecomponent
Product is anInsurance Contract
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Definition of DPF
Contractual right to additional payments as a supplement to guaranteed minimum payments
Likely to be a significant portion of the total contractual payments.
Amount or timing is contractually at the discretion of the issuer
Contractually based onPerformance of a specified pool of contracts or a specified type of contract
Realised and/or unrealised investment returns on a specified pool of assets held by the issuer
Profit or loss of the company, fund or other entity that issues the contract
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Insurance Contracts and Contracts with DPF – Accounting TreatmentInsurance Contracts and Contracts with DPF – Accounting Treatment
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Insurance Contracts
During Phase I, existing accounting policies apply with certain modifications
Prohibited – certain accounting policies are prohibited as they do not meet the FRS framework
Mandated – certain accounting policies must be implemented if they are notalready in the existing accounting policies
Allowed to continue, but not start – certain accounting policies that do not meet the FRS framework can continue, but cannot be implemented.
Can be started – certain accounting policies can be introduced.
Existing accounting policies are those in the primary financial statements
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Prohibited policies
The following accounting policies are prohibited
Setting up catastrophe provisions
Setting up claims equalisation provisions
Offsetting of reinsurance assets and direct liabilities
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Mandated policies
The following accounting policies are mandated if they are not already present
Liability adequacy testing
Impairment of reinsurance assets
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Liability adequacy testCurrent liability adequacy test applies if
Test at each reporting date using current estimates of future cashflows(including cashflows from embedded guarantees and options)
If these are > current liability, liability is increased and deficiency flows through P&L
Otherwise Liability Adequacy Test under FRS 37
Best-estimate of the payments required to settle the obligations
Expected PV of cashflows using realistic assumptions with margins for risk
FV like calculations
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Impairment of reinsurance assets
Reinsurance asset is reduced and reduction flows through income statement if it is impaired
Reinsurance asset is impaired if:
Objective evidence of an event after initial recognition that the cedant may not receive all amounts due to it
The impact of the event can be reliably measured
Impairment may be reversed
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Policies that may continue
The following accounting policies may continue but companies may not adopt them where they are not already applied
Measuring insurance liabilities on an undiscounted basis
Using non-uniform accounting policies for subsidiaries
Using excessive prudence in the valuation of liabilities
Measuring contractual rights to future investment management fees at > their FV as implied by fees charged by others for comparable services
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Phase I measurement concerns
Liabilities and backing assets may not move together
Liabilities are fixed or at amortised cost, but
Assets are classified as AFS, with changes in fair value in equity
Assets are classified as Trading, with changes in fair value in profit and loss account
Therefore some policies are allowed to start
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Policies that may be started
The following accounting policies can be started
Use of current market discount rates
Use of shadow accounting
Use of asset-based discount rates (subject to certain restrictions)
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Current market interest rates
Measure designated insurance liabilities using current market interest rates
Current market interest rates
Can include investment spreads only if already included
Otherwise risk free rates
Can move to using current assumptions at the same time
Can be performed for any designated liabilities
Must be consistently applied to designated liabilities until they are extinguished
All changes in liabilities must flow through income statement
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Shadow accounting
Shadow accounting
Applicable if the measurement of an insurance liability is driven directly by realised gains & losses on assets held
Permits all recognised gains and losses (whether realised or unrealised) on assets to affect the measurement of insurance liabilities in the same way
If unrealised gains and losses flow through income statement resulting change in insurance liabilities recognised in income statement
If unrealised gains and losses flow through equity resulting change in insurance liabilities recognised in equity
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Asset-based discount rates
Measure liabilities using discount rates based on asset returns
Can continue if already in use
Rebuttable presumption that financial statements will become less relevant and reliable if move towards use of asset-based discount rate
Only as part of move to a new accounting policy system which is more relevant and reliable
Must be applied consistently to all insurance contracts
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Insurance contracts with DPF
Distributable surplus must be classified as liability or equity
Disclosure of movement in statement of equity if any distributable surplus classified as equity
Distributable surplus classified as liability taken into account in liability adequacy test
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Investment contracts with DPF
Like insurance contracts, continue existing accounting with additional modifications:
Premiums can still be recognised as revenue
If distributable surplus is classified as equity
Minimum liability for investment contracts is IAS 39 liability for guaranteed benefits
If distributable surplus is all classified as liability, need to include this in the liability adequacy testing
Fair value disclosure under FRS 32 still applies
If impracticable – disclose this fact, nature of the risks and range in which the fair value is likely to sit
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Business combinations -insurance phase I
Subsequently test for liability
adequacy
Intangible Asset Insurance
Liability(based on original
accounting policies)Net Fair Value
Closed Book Basis
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Business combinations -insurance phase I
Can be presented as net liabilities
Intangible asset = Insurance liabilities – FV of Insurance liabilities(based on existing a/cg policies) (at purchase date)
Amortised over the estimated life of the contract
Considered a component of insurance liabilities and subject to liability adequacy testing
Outside the scope of IAS 36 and IAS 38
Prior acquisitions – continue existing accounting policies
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Key Learning Points
Catastrophe and equalisation reserves prohibited
Liabilities adequacy testing and impairment of reinsurance assets mandated
Gross presentation – reinsurance shown separately
Investment contracts with discretionary participation features temporarily under FRS 104 – subject to disclosure requirements of FRS 32
Business Combinations allow separate presentation of intangible asset
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Phase I – Disclosure RequirementsPhase I – Disclosure Requirements
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Insurance disclosurerequirementsFRS 104 Two high level principles:
Principle 1 – Explanation of recognised amountsPrinciple 1 – Explanation of recognised amounts
Principle 2 –Amount, timing and uncertainty of cash flowsPrinciple 2 –Amount, timing and uncertainty of cash flows
Fair Value Disclosure for insurance contract assets and liabilities
Implementation guidance - runs to 61 paragraphs – but does not create additionalrequirements!
Fair Value Disclosure for insurance contract assets and liabilities
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THANK YOU…THANK YOU…