IBOR transition: Impact on Australian insurers - April 2019 - EY
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IBOR transition: Impact on Australian insurers April 2019
Contents
Introduction....................................................................................... 3
Why are the IBORs being phased out?................................................. 4
Current state of play........................................................................... 4
A word on BBSW................................................................................. 5
Key challenges for Australian insurers................................................. 7
1. Developing, issuing and trading new products................................. 7
2. Repapering legacy contracts.......................................................... 7
3. Managing financial risks................................................................ 8
4. Adjusting models and curves......................................................... 9
5. Enhancing systems and data infrastructure..................................... 9
6. Managing tax and accounting outcomes.......................................... 9
Next steps for Australian insurers....................................................... 10
Conclusion......................................................................................... 10
Our Australian IBOR team................................................................... 11
2 | IBOR transition: Impact on Australian insurers
Introduction
Ongoing efforts by global regulators and major banks to phase out the use of interbank offered rates (IBORs)
will have a significant impact on Australian insurers. The IBORs play a critical role in financial markets, acting
as reference rates for cash products and derivative contracts held by a wide array of market participants.
The IBORs are also extensively embedded throughout a range of processes, systems and models across
industries and market segments, including both general and life insurers.
After more than forty years in operation, the end of the London Interbank Offered Rate (LIBOR) after 2021
will be particularly consequential. LIBOR is presently used to price around USD 370 trillion of financial
contracts daily across the globe. It also serves as a critical benchmark rate of performance measurement
for investment securities and as a proxy rate for wholesale funding. Many Australian insurers have exposure
to LIBOR-linked funding or capital instruments. For those with offshore liabilities, LIBOR may additionally
act as an input into discounting, valuation and regulatory cost of capital models. The runway to prepare for
transition is short.
IBOR transition: Impact on Australian insurers | 3
Why are the IBORs being phased out?
Several interrelated factors have led to a fundamental review of the IBORs’ robustness since the global financial crisis:
1. Liquidity has significantly reduced within interbank unsecured funding markets, primarily driven by the
introduction of liquidity standards requiring banks to maintain a stable funding structure more reliant upon
longer-term funding.
2. IBOR panel banks are increasingly reluctant to submit quotes based on expert judgement, rather than
underlying transactions, due to concerns around litigation and allegations of misconduct.
3. Criminal convictions and panel bank fines for misconduct relating to the manipulation of IBORs across
various jurisdictions have further stoked concerns around systemic risks related to the maintenance of these
key financial benchmarks.
Current state of play
Transition governance engaged directly with large financial institutions to ensure
that they are responding with urgency. As IBOR transition
For the abovementioned reasons, regulators and industry
accelerates, banks and insurers should expect further enquiries
bodies globally have undertaken a series of initiatives to restore
from other regulatory bodies in the jurisdictions in which they
confidence in major interest rate benchmarks. These initiatives
operate.
have been led by the Financial Stability Board (FSB) Official
Sector Steering Group (OSSG).
ARR-linked product issuance and
Given unsuccessful initial attempts to reform the IBORs to
be more transaction based, industry efforts are now focused
liquidity
on replacing IBORs with overnight nearly risk-free alternate With the final determination of the ARRs by the central bank
reference rates (ARRs) that conform to the benchmark principles working groups, various government, banking and corporate
put forward by the International Organisation of Securities institutions have started to issue associated debt securities,
Commissions (IOSCO). especially linked to the US and UK ARRs (“SOFR” and “SONIA”
respectively). While some of this activity has been designed
Central bank-coordinated working groups have consequently to promote readiness to accommodate the new benchmarks
been established in all key IBOR jurisdictions to facilitate (systems, processes and approvals), some issuers are proactively
an orderly transition. These working groups have identified seeking first-mover-pricing and reputational advantages.
different ARRs for the major IBOR currencies, and are now
focused on seeking market consensus around term ARRs ARR-linked futures and swaps have also been launched in some
and new contractual “fallback” provisions to minimise markets, again mainly referencing SOFR and SONIA. Liquidity
market disruption in the event of IBOR discontinuations. The in these derivatives markets will be critical for market hedging
International Swaps and Derivatives Association (ISDA) has also purposes. It will also be key to convincing transition participants
played a critical role in this fallback consultation process for that such derivatives can serve as a robust basis for forward-
derivative instruments. looking term ARRs to be potentially set in due course. While
working groups acknowledge the strong demand for term ARRs
for cash markets, debate continues around the most appropriate
Regulatory involvement rate set method (e.g., forward-looking vs. compounded
While ultimately viewed as a voluntary, industry-led initiative, in arrears).
regulators globally have indicated that they view IBOR transition
to be a matter of critical systemic importance. As a result, the Clearing houses have also announced their intention to replace
UK’s Financial Conduct Authority (FCA) announced in 2017 existing overnight index rates with ARRs for calculating
that it would no longer persuade or compel panel banks to price alignment interest (PAI). CME Group (leading global
make LIBOR submissions after the end of 2021. Given panel derivatives market place) has already adopted SOFR for PAI
banks’ concerns around litigation in relation to LIBOR quote and discounting, with LCH (UK and European clearing house
submissions, it is widely accepted that LIBOR will not be reliably organisation) expected to transition from the Federal Funds Rate
published beyond this date. to SOFR for all USD-denominated swaps in the second half of
2020. This development will be a key catalyst to the trading of
Considering the tight timeframe, regulatory authorities in the ARR-linked swaps, especially where existing trades referencing
UK, Switzerland, Singapore and Hong Kong have consequently IBORs are also transitioned.
4 | IBOR transition: Impact on Australian insurers
A word on BBSW
The use of the Bank Bill Swap Rate (BBSW) as a reference rate is widespread across
Australian insurance firms’ investment, funding and derivative product portfolios.
While Australian insurers should prioritise addressing the impacts of IBOR transition in
the first instance, the viability and use of BBSW must also be monitored.
Recent reforms by the Australian Securities Exchange (ASX) and Australian Securities
and Investments Commission (ASIC) have established a firm foundation for BBSW
to comply with the IOSCO Principles for Financial Benchmarks. Under the ASX’s new
waterfall rate set methodology, BBSW is now largely transaction based for the critical
3- and 6-month tenors. ASIC’s financial benchmark reforms, including its Financial
Benchmark Administration Rules and Financial Benchmark Compelled Rules, have
improved BBSW’s robustness and bolstered market confidence in this critical
credit benchmark.
However, despite these changes and the articulated support from the Reserve Bank of
Australia (RBA), we believe that certain market dynamics may challenge the systemic
importance of BBSW over coming years. Cash Rate-linked debt instruments are
expected to be issued by local market participants from 2019. Australian firms looking
to convert future ARR-linked exposures back to AUD may prefer to use cross-currency
interest rate swaps referencing the Cash Rate, to avoid the credit exposure associated
with using BBSW against a risk-free ARR. Illiquidity in certain BBSW tenors (particularly
the 1-month) may encourage users to reference other BBSW tenors or potentially
other benchmarks. All these factors may reduce demand for BBSW-linked cash and
derivative products over time.
The new methodology strengthens BBSW
by anchoring the benchmark to a greater
number of transactions. This should help
to ensure that BBSW remains robust.
Guy Debelle
RBA Deputy Governor
May 2018
IBOR transition: Impact on Australian insurers | 5
Figure 1: Current state overview of key IBORs and their ARRs
As illustrated below, substantial differences exist between working groups’ approaches and progress with respect to ARR
development and consultation on fallback provisions and term ARRs. Market participants face a significant challenge
in developing and executing transition programs based on incomplete information, contingent timelines and divergent
approaches on key variables (e.g., fallback trigger events for cash and derivative instruments).
Jurisdiction
UK US EU Switzerland Japan
IBOR GBP LIBOR USD LIBOR EURO LIBOR EONIA EURIBOR CHF LIBOR JPY LIBOR JPY TIBOR,
EUROYEN
TIBOR
Administrator IBA IBA IBA EMMI EMMI IBA IBA JBATA
Type Term Term Term Overnight Term Term Term Term
Secured/
Unsecured Unsecured Unsecured Unsecured Unsecured Unsecured Unsecured Unsecured
unsecured
Submission vs.
Submission Submission Submission Hybrid Submission Submission Submission Submission
Transaction
To coexist with
ARR
ARRC proposing
Permanent Permanent
pre-cessation
discontinuation discontinuation
Trigger
triggers based
TBD TBD N/A TBD TBD of LIBOR of LIBOR
on Benchmark
announced by announced by
IBORs
Cash products
Discontinuance
the IBA or FCA the IBA or FCA
Events
ARRC proposal
Fallback consultation status
Product types
due Q2 2019
for FRNs, synd.
TBD TBD N/A TBD TBD TBD TBD
loans, bilateral
loans and
securitisations
Index cessation Index cessation Index cessation Index cessation
events as TBD TBD TBD events as events as events as
Trigger
per ISDA Consultation Consultation N/A Consultation per ISDA per ISDA per ISDA
Derivatives (ISDA)
Benchmarks due 1H 2019 due 1H 2019 due 1H 2019 Benchmarks Benchmarks Benchmarks
Supplement Supplement Supplement Supplement
Compounded TBD TBD TBD Compounded Compounded Compounded
Term
setting in Consultation Consultation N/A Consultation setting in setting in setting in
adj.
arrears due 1H 2019 due 1H 2019 due 1H 2019 arrears arrears arrears
TBD TBD TBD
Historical Historical Historical Historical
Credit
adj.
Consultation Consultation N/A Consultation
mean/median mean/median mean/median mean/median
due 1H 2019 due 1H 2019 due 1H 2019
ESTER Reformed
ARR SONIA SOFR SARON TONA
From October 2019 EURIBOR
Administrator BoE FRBNY ECB, FSMA, ESMA EMMI SIX BoJ
Type Overnight Overnight Overnight Term Overnight Overnight
Secured/
Unsecured Secured Unsecured Unsecured Secured Unsecured
unsecured
Submission /
Transaction Transaction Transaction Hybrid Transaction Transaction
ARRs
Transaction
Working group RFRWG ARRC WGERFR NWG CJYIRB
Considering both forward- and
Daily backwards- WG members N/A
presently N/A NWG plans backward-looking rates
Term rate Planning compounded
favour OIS- EURIBOR a backward-
consultation forward-term rate by 1H 2020 EONIA is an
already has
Proposing publication of
quotes-based overnight compounded “prototype rates” by Dec 2020,
status rate Forward rate by different
forward- rate rate and production rates
end-2021 looking rate tenors
by mid-2021
Benchmark administrators Alternate reference rates (ARRs)
BoE Bank of England ESTER Euro Short-Term Rate
BoJ Bank of Japan SARON Swiss average rate overnight
ECB European Central Bank SOFR Secured overnight financing rate
EMMI European Money Markets Institute SONIA Reformed sterling overnight index average
FRBNY Federal Reserve Bank of New York TONA Tokyo overnight average rate
IBA ICE Benchmark Administration Working groups
JBATA Japan Bankers Association TIBOR Administration RFRWG Working Group on Sterling Risk-Free Reference Rates
RFRWG Working Group on Sterling Risk-Free Reference Rates ARRC Alternative Reference Rates Committee
SIX SIX Swiss Exchange WGERFR Working Group on Euro Risk-Free Rates
NWG The National Working Group on Swiss franc Reference Rate
CJYIRB Cross-Industry Committee on Japanese Yen Interest Rate Benchmarks
6 | IBOR transition: Impact on Australian insurersKey challenges for Australian insurers
The discontinuation of the IBORs will present Australian insurance firms with a range of material
challenges across business areas and functions including trading, operations, legal, underwriting,
actuarial, risk and finance.
1. Developing, issuing and trading new To avoid such scenarios, market participants, including
Australian insurers, will need to renegotiate these longer-
products dated legacy IBOR-linked contracts with their clients or
The ability to develop, approve, issue and price new counterparties to either:
ARR-linked products will be critical in meeting client and 1. Change the contractual reference rate to an
investor demands over the coming years, as well as to ARR-linked benchmark
maintaining competitive market share. Crucially, continuing
to issue IBOR-linked products to clients or investors without 2. Amend the fallback language to clarify what should
adequate disclosure of the associated IBOR discontinuation happen if the referenced IBOR ceases to be published.
risks may result in charges of misconduct, and ultimately, The amendment of fallback language is seen to be the most
litigation. achievable of these options in the short term. However,
Insurers will additionally need to ensure they can issue significant commercial and logistical challenges still exist in
and book funding instruments such as floating-rate notes carrying out this task.
(FRNs), as well trade in ARR-linked derivatives, Commercial challenges
so they may adequately fund and risk manage their
Commercially, some value transfer between contractual
operations respectively.
counterparties is likely to occur, either at the time of the
2. Repapering legacy contracts renegotiation itself or in a fallback trigger event. This is
due to two structural features of the ARRs that distinguish
Remediation of the “back book” will likely be an area them from the IBORs:
of significant disruption during IBOR transition. If left
unaddressed by end-2021, legacy investment, funding and 1. The ARRs are overnight rates, unlike the IBOR rates,
derivative instruments linked to IBOR reference rates will which have daily fixings across different tenors.
have to rely on the fallback provisions within their contracts 2. The ARRs are nearly risk-free, and do not contain a
for valuation and fulfillment purposes. This is likely to lead credit risk spread as embedded within the IBORs.
to several challenges, given:
The combination of these factors entails that ARR levels
1. Existing fallback mechanisms were only designed will differ from the IBORs at any given time. While ISDA and
for temporary benchmark publication disruptions. various working groups are establishing methodologies to
Should a reference rate be permanently discontinued, appropriately account for these features (i.e., by including
it is generally understood that initial fallback additional term and credit spread adjustments in the
provisions to “survey” panel banks for an alternative fallbacks), some value transfer is still inevitable.
rate would be unenforceable.
Contractual counterparties may therefore be reluctant
A highly probable outcome in such a circumstance is to renegotiate their contracts even with new proposed
that a floating-rate instrument will effectively convert fallbacks, given the potential for negative revaluations
to fixed, referencing the last-published IBOR mark or contractual triggers coming into play, such as
thereafter. This would have several unfavourable requirements to pledge additional collateral. Where
consequences, including the potential forced sale of clients or counterparties believe that insurers have acted
assets or liabilities. inappropriately throughout the outreach or repapering
2. Existing fallbacks are inconsistent between, and process, they are also likely to litigate.
often within, product types. This would lead to hedge
dislocation, where cash products and their hedging
derivative fallbacks differ.
IBOR transition: Impact on Australian insurers | 7Logistical challenges as Figure 1 illustrates, the Alternative Reference Rate
Committee (ARRC) in the US is proposing pre-cessation
Repapering legacy legal contracts will also present
fallback triggers for cash products, opposed to the
significant logistical challenges. Simply locating relevant
standard cessation fallbacks put forward by ISDA for
contracts and determining any provisions to be amended
derivatives. Different term rate calculation methodologies
will be difficult where documents have not been digitised.
are also being proposed by different working groups, with
IBOR contractual references may be more general in nature
some preferring forward-term fixings based off derivatives
too, such as embedded in inter-company financing terms,
markets, and others leaning towards backwards-
leases or external outsourcing contracts.
compounding calculations.
With respect to impacted financial instruments, repapering
Insurers will have to risk manage these contingencies
derivative contracts is expected to be significantly more
as well as enhance their models and systems to account
straightforward than for cash products. The existing ISDA
for new market features such as cash flows calculated
framework has led to a high degree of standardisation
on a compounded-in-arrears basis. Inconsistent fallback
across derivative contracts. ISDA additionally intends to
rates between legacy cash products and their hedging
publish a protocol to streamline the fallback repapering
derivatives will result in profit or loss should the fallbacks
process across multiple counterparties, though adherence
be triggered. Inconsistent trigger events between
to this protocol will be voluntary and direct outreach
hedging and hedged items (i.e., “cessation” versus “pre-
to some counterparties will likely still be required by
cessation” triggers) will result in timing mismatches and
Australian insurers.
expose counterparties to uncertain periods of fixed-rate
The lack of contract standardisation across cash-based payments from triggered cash products. Renegotiating
products, however, will preclude a protocol-driven solution the contractual reference rate at different times for
in most circumstances. This will make the contractual hedging and hedged items will similarly introduce basis.
renegotiation process significantly more cumbersome, These timing issues are likely to complicate duration
especially where there are multiple counterparties to the management strategies for some insurance firms. This
same transaction. FRN contracts, for example, typically may be particularly significant for insurers with Matching
require unanimous consent of noteholders to amend Adjustment Portfolios under EU Solvency II rules. The
contractual terms. The potential for contract frustration in impacts on insurers’ cash feeder or liquidity funds will also
such scenarios is higher. need to be assessed.
3. Managing financial risks Cross-currency interest rate swap (CCIRS) dynamics will
also need to be considered as a source of financial risk.
As IBOR transition unfolds, Australian insurers, like other Australian insurers typically swap offshore IBOR-linked
market participants, will simultaneously hold both IBOR- investments or funding exposures back to AUD via CCIRS
and ARR-linked positions on their balance sheets. Migrating with LIBOR on one leg versus BBSW on the other. However,
the affected IBOR back book over to ARRs will take time using an ARR-BBSW CCIRS in the future will introduce a
and introduce a host of new financial risks that need to be credit spread differential between the risk-free and credit
managed. benchmark legs respectively. This differential will become
This will be particularly difficult given the various timelines more pronounced during periods of market stress, where
and divergent approaches being adopted for certain the risk-free ARR levels and credit-based benchmarks (such
currency ARRs and between product types. For example, as BBSW) are likely to diverge.
8 | IBOR transition: Impact on Australian insurersWhile this BBSW credit exposure may be managed to These will each have downstream impacts that will need
some extent via basis swaps between BBSW and the RBA to be revised, including cashflow projections, liability
Overnight Cash Rate (Cash Rate), the associated additional discounting, data feed inputs and any new interest
transaction costs and potential capture under uncleared rate risk models. Any operational cross-dependencies
margin and clearing rules may act as a disincentive to (e.g., proprietary vs. vendor systems, links to asset
hedge these additional risks using such instruments. managers) should also be appropriately incorporated in
Australian insurers may opt to mitigate this credit exposure to implementation plans. Early outreach to critical third
in the future by moving away from BBSW-linked CCRIRS parties should be prioritised to allow sufficient time to
and instead hedging such offshore ARR-linked exposures specify and implement required platform enhancements.
using CCIRS linked to the RBA Overnight Cash Rate
(which is risk free). This development alone would require 6. Managing tax and accounting
significant changes to procedures and infrastructure. outcomes
Transitioning to ARRs will pose significant tax and
4. Adjusting models and curves
accounting challenges. Amending cash or derivative
To appropriately price and risk manage new and contracts may entail tax being recognised immediately and
renegotiated positions, Australian insurers will have to payments on realised gains brought forward.
enhance several internal models. Actuarial assumptions
Broader market dynamics may encourage assets and
may have to be revised, as will asset valuation techniques,
liabilities to be transitioned on different timelines,
yield curves, economic scenario generators (ESGs) and
exacerbating existing discrepancies between regulatory
capital projection methodologies. Shifting to ARRs for
and IFRS-reported balance sheets. Such divergence is likely
existing contracts will have an immediate impact on
to impact life insurers particularly, given the longer-term
position valuations, both directly (via the interest rate
nature of this business.
variable), and indirectly for instruments with embedded
optionality (which also depend on interest rate volatility Hedge accounting will be disrupted, with up-front
as a price input). APRA regulatory capital models may assessments of the economic relationship between
additionally need to be rebuilt, redocumented, revalidated hedged items and their hedging instruments becoming
and reapproved by the regulator. more challenging should significant structural basis exist.
Critically, finance teams will need to determine whether
The impact on non-interest rate derivative risk models and
changes in benchmark rates represent a substantial
business models that rely on interest rate ‘feeder’ models
modification of the terms of hedged items. They will have
will also need to be assessed and potentially remediated.
to determine whether a new ARR should be considered
Existing pricing mechanisms and curves will need to be
a permitted ‘hedgeable risk’, and whether a change
maintained in parallel, at least during the transition period,
in hedged risk should trigger a de-designation or re-
for firms to accommodate legacy IBOR-linked positions in a
designation. Hedged items and their hedging derivatives
multi-rate environment.
may need to be booked separately at fair value, resulting in
5. Enhancing systems and data potential net income volatility.
infrastructure Finally, IBOR transition is occurring at a time of significant
change within the insurance industry with accounting
Insurers with significant IBOR exposure will likely need to
standard IFRS 17 Insurance Contracts becoming effective
implement changes to a wide range of proprietary and
for annual periods beginning on or after 1 January 2022.
third-party platforms. Robust historical data sets for ARRs
This may indirectly impact assets and liabilities if Australian
will need to be sourced and integrated into valuation,
insurers use an IBOR-based discount rate.
booking, trading and risk management systems, as well
as collateral management and accounting platforms.
IBOR transition: Impact on Australian insurers | 9Next steps for Australian insurers
The work conducted by the various working groups and ISDA will not be enough to enable transition to ARRs alone.
Australian insurers, like other market participants with IBOR exposures, must be proactive in addressing the challenges
ahead. We recommend that Australian insurers take the following steps during 2019 to best ensure readiness and
mitigate the significant risks associated with this fundamental market transformation.
Identify and nominate a senior executive to be responsible for assessing, planning and coordinating all
1 Transition
IBOR transition activities across the enterprise
Conduct a comprehensive IBOR impact assessment across products, legal contracts, risk exposures,
2 Impact assessment
models, business processes and infrastructure
3 Coordination Mobilise an IBOR transition program office to coordinate transition activities across the enterprise
4 Innovation Prepare to offer new products and financial instruments linked to ARRs
5 Exposure Develop an inventory of legal exposures and contracts that mature after 2021
6 Governance Define an enterprise-wide governance framework for the IBOR transition program
Define a knowledge and education strategy for all internal stakeholders to heighten awareness of
7 Knowledge
transition risks, challenges, and the firm’s transition plan
External Define a communication strategy for all external stakeholders (counterparties, investors and regulatory
8
communication agencies) on the potential impact of IBOR transition on the activities with the firm
Communicate to the board the firm’s exposures to IBOR-linked products and financial instruments,
Internal
9 legal contracts, technology infrastructure; changing risk profile; impact on financial resources and
communication
program governance
Prepare for onsite supervisory examination that assesses the state of readiness to transition from
10 Regulatory
IBORs to ARRs
Conclusion
The impacts of IBOR transition will be felt and divergent approaches across working groups and
internationally. Australian insurers, like other financial product types. Given the complexity of transformation
market participants, must act promptly to assess required, we recommend that Australian insurers
the IBOR dependencies across their products, legal prioritise broad stakeholder engagement. Outreach to
contracts, models and systems. New products must affected clients and counterparties will help refine new
be designed and issued to maintain market share and product strategy and minimise risks of reputational
minimise risks of litigation. New ARR-linked funding damage and contract frustration. Early engagement
sources should be explored and appropriate hedging with regulators will help ensure that potential capital
mechanisms embedded. Legacy IBOR-linked contracts impacts are well understood and that model changes are
maturing beyond end-2021 must be renegotiated approved within an adequate timeframe. Liaison with
with clients and counterparties. Systems and models vendors is similarly critical to specify required platform
must be enhanced to price, book and risk manage new enhancements and shape product pipeline.
ARR-linked exposures. The viability of BBSW must be
Addressing these challenges will require resources and
monitored simultaneously.
expertise be drawn from across all lines of business and
Assessing the impact of transition may itself be enterprise functions. Given the tight timeline and the
a significant undertaking. Where material IBOR risks of inaction, we recommend that Australian insurers
dependencies exist, designing a transition roadmap will mobilise swiftly to address the challenges ahead.
be particularly challenging given contingent timelines
10 | IBOR transition: Impact on Australian insurersOur Australian IBOR team
Grant A Peters
Oceania Insurance Leader
+61 2 9248 4491
grant.peters@au.ey.com
IBOR governance and program management
Damien Jones Andrew Bangura
Partner, Capital Markets Advisory Senior Manager, Capital Markets Advisory
+61 2 9248 5236 +61 2 9276 9235
damien.jones@au.ey.com andrew.bangura@au.ey.com
Hayley Watson Antony Collins
Partner, Financial Accounting Advisory Manager, Capital Markets Advisory
+61 3 8650 7544 +61 2 9248 4862
hayley.watson@au.ey.com antony.collins@au.ey.com
Risk
Warrick Gard Brendan Counsell
Partner, Actuarial Services Partner, Actuarial Services
+61 2 9248 4484 +61 2 9276 9040
warrick.gard@au.ey.com brendan.counsell@au.ey.com
Steven Nagle Michael Seminatore
Partner, Quantitative Risk Senior Manager, Financial Services
+61 2 9276 9010 Risk Management
steve.nagle@au.ey.com +61 2 9276 9295
michael.seminatore@au.ey.com
Legal
Michelle Segaert Dorothy Mioduszewska
Partner, Financial Services Law Director, Financial Services Law
+61 2 9248 4641 +61 2 8295 6080
michelle.segaert@au.ey.com dorothy.mioduszewska@au.ey.com
Technology and data management
Glenn Rogers Tim Brookes
Partner, Financial Services IT Advisory Senior Manager, Financial Services IT Advisory
+61 3 8650 7670 tim.brookes@au.ey.com
glenn.rogers@au.ey.com
IBOR transition: Impact on Australian insurers | 11EY | Assurance | Tax | Transactions | Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organisation, please visit ey.com. © 2019 Ernst & Young, Australia. All Rights Reserved. APAC No. AUNZ00001056 IN1010865 ED None This communication provides general information which is current at the time of production. The information contained in this communication does not constitute advice and should not be relied on as such. Professional advice should be sought prior to any action being taken in reliance on any of the information. Ernst & Young disclaims all responsibility and liability (including, without limitation, for any direct or indirect or consequential costs, loss or damage or loss of profits) arising from anything done or omitted to be done by any party in reliance, whether wholly or partially, on any of the information. Any party that relies on the information does so at its own risk. Liability limited by a scheme approved under Professional Standards Legislation. ey.com
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