South African Insurance Outlook 2021 - Navigating the insurance - Deloitte

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South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
South African
Insurance Outlook 2021
Navigating the insurance
landscape                  1
South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
S A INSUR A NCE OUTLOOK | PER SPEC TI V E S ON THE INSUR A NCE L A NDSC A PE

                                                                               Introduction

Contents                                                                       Overview of the 2020 financial
                                                                               and EV results

                                                                               COVID-19 – Once bitten, twice shy.
                                                                               A pandemic’s impact on stress
                                                                               testing frameworks

                                                                               Optimising the life insurance
                                                                               regulatory balance sheet

                                                                               Artificial intelligence and
                                                                               machine learning

                                                                               Using technology to combat
                                                                               insurance fraud

                                                                               Proactively managing conduct risk

                                                                               Understanding a more complete
                                                                               IFRS 17 picture

                                                                               IFRS 17: Controls and financial
                                                                               reporting under the new standard

                                                                               VAT: Closing the compliance gap

                                                                                                                2
South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
S A INSUR A NCE OUTLOOK | INTRODUC TION

                                                                                                                                                                                        Introduction

Introduction                                                                                                                                                                            Overview of the 2020 financial
                                                                                                                                                                                        and EV results

                                                                                                                                                                                        COVID-19 – Once bitten, twice shy.
Our South African Insurance Outlook 2021 publication             The past year has shown that capital coverage of the           We hope you enjoy reading our publication and look
                                                                                                                                                                                        A pandemic’s impact on stress
reflects on the past year, and shares some of our thoughts       insurance industry has not been affected as much as might      forward to hearing any thoughts or comments that you    testing frameworks
on trends that will shape the industry in years to come.         have been feared at the start of the pandemic. However,        may have on any of the articles.
Inside is a collection of articles that were penned by           it has highlighted the importance of a robust capital
Deloitte professionals who provide services to the South         management and capital optimisation strategy.                                                                          Optimising the life insurance
African insurance industry.                                      Our team unpacks some options available to embed
                                                                                                                                Authors                                                 regulatory balance sheet
                                                                 capital optimisation into your business operations.                                   Andrew Warren
Our focus, this time, is on business, capital, governance                                                                                              Director, Actuarial and
                                                                                                                                                                                        Artificial intelligence and
and financial reporting priorities in the local insurance        The pandemic has prompted change in a sector that                                     Insurance Solutions, Insurance
                                                                                                                                                                                        machine learning
industry.                                                        was already dealing with systemic challenges. The                                     Sector Advisory Leader,
                                                                                                                                                       Deloitte Africa
                                                                 silver lining, though, was the industry’s response that
                                                                                                                                                       anwarren@deloitte.co.za
Not surprisingly, many of the articles comment on the            led to unexpected improvements in some areas such                                     +27 (011) 202 7423               Using technology to combat
impact of COVID-19 on the industry. The impact of the            as customer satisfaction and communication. In this                                                                    insurance fraud
pandemic and the lockdown response was a key driver              publication we discuss how artificial intelligence (AI)
of the 2020 financial results of insurers, and we have           continues to infiltrate every corner of the world, and how                            Gerdus Dixon                     Proactively managing conduct risk
unpacked the themes that have emerged in the results             insurers are implementing machine learning methods that                               Partner, Audit and Assurance,
released recently by the listed insurers. The article explores   underpin AI.                                                                          Insurance Sector Audit Leader,
both the IFRS and embedded value consequences of the                                                                                                   Deloitte Africa                  Understanding a more complete
increased (and decreased) claims rates and the impact of         It would be remiss in 2021 for a publication like ours not                            gdixon@deloitte.co.za            IFRS 17 picture
                                                                                                                                                       +27 (021) 427 5574
sales volumes and policy retention.                              to comment on IFRS 17. This financial reporting standard
                                                                 will become mandatory for all insurers with financial years
While it is only natural to want to put the pandemic in the      commencing on or after 1 January 2023. We comment on                                                                   IFRS 17: Controls and financial
rear view mirror, as an industry we should take on board         how insurers can manage their businesses using insights                                                                reporting under the new standard
learnings from the pandemic. The Deloitte team have              gained from IFRS 17, rather than merely seeing the financial
brought insights to the question of how frequently we can        reporting standard as a matter of compliance. And we
                                                                                                                                                                                        VAT: Closing the compliance gap
expect an event like COVID-19 to occur when compared             know that the standard will bring changes to the financial
to the calibration of selected modules within the SAM            control environment at insurers, and our team highlighted
regulatory regime.                                               where management and audit committees should expect
                                                                 change.
                                                                                                                                                                                                                         3
South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
S A INSUR A NCE OUTLOOK | OV ERV IE W OF THE 2 02 0 FIN A NCI A L A ND EMBEDDED VA LUE R E SULT S OF THE L A RGE S T FI V E LI S TED INSUR A NCE GROUP S IN SOUTH A FR IC A

                                                                                                                                                                              Introduction

Overview of the 2020 financial and embedded                                                                                                                                   Overview of the 2020 financial
                                                                                                                                                                              and EV results

value results of the largest five listed insurance                                                                                                                            COVID-19 – Once bitten, twice shy.
                                                                                                                                                                              A pandemic’s impact on stress

groups in South Africa
                                                                                                                                                                              testing frameworks

                                                                                                                                                                              Optimising the life insurance
                                                                                                                                                                              regulatory balance sheet
The completion of the 31 December 2020 financial reporting cycle by the listed
insurance groups in South Africa offers an opportunity for reflection. Their
                                                                                                                                                                              Artificial intelligence and
results, achieved against the backdrop of a global pandemic, are scattered with
                                                                                                                                                                              machine learning
references to muted new business volumes, increased claims and short-term
COVID-19 related provisions for poorer expected persistency and mortality.
                                                                                                                                                                              Using technology to combat
While these features were an unavoidable reality for the 12-month reporting                                                                                                   insurance fraud
period ended 31 December 2020, the same results also point to an industry
that delivered for its policyholders and the broader economy in uncertain times.
                                                                                                                                                                              Proactively managing conduct risk
The results show the impact of premium holidays and reductions, significant
business interruption (BI) claims and interim relief payments to policyholders.
These customer relief measures, coupled with the wider assistance offered by                                                                                                  Understanding a more complete
the industry in the form of relief funds, had a positive impact in South Africa, as                                                                                           IFRS 17 picture
well as the other countries where the groups have a foothold.

In this article we comment on themes evident in the International Financial                                                                                                   IFRS 17: Controls and financial
Reporting Standards (IFRS) results, regulatory capital position and embedded                                                                                                  reporting under the new standard
value (EV) results of the largest five insurance groups that collectively represent
more than 80% of the local industry’s premiums and assets. We analysed the
                                                                                                                                                                              VAT: Closing the compliance gap
results in aggregate to form an industry view, rather than comment on the
results of the individual insurance groups.

                                                                                                                                                                                                              4
South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
S A INSUR A NCE OUTLOOK | OV ERV IE W OF THE 2 02 0 FIN A NCI A L A ND EMBEDDED VA LUE R E SULT S OF THE L A RGE S T FI V E LI S TED INSUR A NCE GROUP S IN SOUTH A FR IC A

                                                                                                                                                                              Introduction
IFRS results and regulatory capital position               Consolidated results of the five large listed insurance groups in South Africa
Three of the five insurance groups referenced in this      as at and for the 12 months ended 31 December 2020                                                                 Overview of the 2020 financial
article have 31 December year ends, and two of the                                                                                                                            and EV results
groups have 30 June year ends. For the two groups
that have 30 June year ends we used their 2020 interim                                                                                          Momentum                      COVID-19 – Once bitten, twice shy.
results and historic announcements to calculate                                                                                                 Metropolitan                  A pandemic’s impact on stress
pro forma results for a 12-month period ended 31                                                                                                                              testing frameworks
December 2020. The adjacent table summarises the
IFRS results for the five insurance groups, on the
basis described. Where the article refers to “total” or
                                                                                                                                                                              Optimising the life insurance
                                                                                                                                                                              regulatory balance sheet
“aggregated” it is the sum of the five insurance groups.

Despite the local equity markets drop in value in March
                                                                                                                                                                              Artificial intelligence and
2020 the markets recovered during the remainder of                                                                                                                            machine learning
the year to end relatively unchanged compared to the
start of 2020 (using SWIX as a reference). That recovery
allowed insurance groups, on an aggregated basis, to                                                                                                                          Using technology to combat
report a respectable 3.8% increase in assets. Insurance                                                                                                                       insurance fraud
groups are also impacted by the value of assets
throughout the year though. Old Mutual points out in
                                                                                                                                                                              Proactively managing conduct risk
their results commentary that the average market levels
during 2020 were 6.7% lower than the prior year, which
negatively impacted asset-based fees for insurance                                                                                                                            Understanding a more complete
groups that manage and administer customer assets.                                                                                                                            IFRS 17 picture

The aggregated equity for the insurance groups
decreased by R15.6 billion, or 6.0%. The lower equity is                                                                                                                      IFRS 17: Controls and financial
mostly a function of the aggregated loss after tax of                                                                                                                         reporting under the new standard
R4.7 billion reported by the insurance groups as well
as ordinary dividends paid of R12.7 billion (2019: R16.2                                                                                                                      VAT: Closing the compliance gap
billion). The dividend declarations during 2020 and
into 2021 were a mixed bag ranging from some groups
withholding dividends to maintaining past dividend
policies, but with a downward adjustment for                                                                                                                                                                  5
specific uncertainties.
South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
S A INSUR A NCE OUTLOOK | OV ERV IE W OF THE 2 02 0 FIN A NCI A L A ND EMBEDDED VA LUE R E SULT S OF THE L A RGE S T FI V E LI S TED INSUR A NCE GROUP S IN SOUTH A FR IC A

                                                                                                                                                                                                                                   Introduction
  Despite the reduction in equity the insurance groups still                                   contracted by 7% in 2020, and more severely in some                 For example, Santam as the largest short-term insurer in
  reported relatively healthy regulatory Solvency Cover                                        other African countries.                                            the country established a claims provision of R3 billion,
                                                                                                                                                                                                                                   Overview of the 2020 financial
  Ratios (SCRs). Refer to the graph below illustrating some of                                                                                                     net of reinsurance for its BI exposure. The industry’s          and EV results
                                                                                               On an aggregated basis the insurance groups’ profit
  the insurance group’s SCR ratios:                                                                                                                                accounting for BI claims at 31 December 2020 followed
                                                                                               before tax of R48.3 billion reported in 2019 reduced to
                                                                                                                                                                   the rulings in both South Africa and the United Kingdom
                                                                                               R4.3 billion in 2020 (-91%). The financial results reflect the                                                                      COVID-19 – Once bitten, twice shy.
                                     SCR Cover Ratios                                                                                                              courts that addressed the uncertainty around the
                                                                                               impact of:                                                                                                                          A pandemic’s impact on stress
                                                                                                                                                                   application of BI clauses. These proceedings confirmed
              260%
                                                                                               • Lower new business volumes as adviser productivity, in the                                                                        testing frameworks
                                                                                                                                                                   that cover should be provided for BI losses caused by the
                                                                              211%
              210%
                     199%                                                                        absence of face-to-face sales, was significantly impacted         government enforced national lockdown, provided there
                            181%          189% 185%                                  191%
                                                          180%
                                                                                                 during the initial lock down period                               was an instance of COVID-19 within the defined radius of        Optimising the life insurance
                                                                 162%
              160%                                                                                                                                                 the policyholder’s business. Insurers have accepted the         regulatory balance sheet
                                                                                               • COVID-19 customer support mechanisms, such as premium
Cover ratio

                                                                                                 holidays, and other direct financial support                      decisions of the courts, although further legal processes
              110%
                                                                                                                                                                   afoot to confirm the length of the indemnity period that
                                                                                               • Increased death claims – the Association for Savings and                                                                          Artificial intelligence and
                                                                                                                                                                   applies.
              60%                                                                                Investment South Africa (ASISA) noted that the South            								                                                          machine learning
                                                                                                 African life assurance industry recorded 116 774 more           A key feature of many of the results announcements is
              10%
                                                                                                 death claims in 2020 than it did in 2019, an increase 		        the short-term provisions created for the anticipated
                                                          Momentum
                       Liberty             Old Mutual
                                                          Metropolitan
                                                                                 Sanlam
                                                                                                 of 37%                                                          impacts of worsening mortality, morbidity and persistency         Using technology to combat
              -40%
                                                                                                                                                                 experience related to COVID-19. The provisions for those
                                                                                                                                                                                                                                   insurance fraud
                     SCR Cover Ratios as at 31 Dec 2019   SCR Cover Ratios as at 31 Dec 2020   • Poorer persistency for life insurance policies – while most
                                                                                                 insurers commented that the actual lapse experience in          groups that disclosed them explicitly total more than
                                                                                                 the current year tracked favourably against expectations        R10 billion at 31 December 2020. Some groups noted that           Proactively managing conduct risk
  It is not always easy to make direct comparisons between
                                                                                                 as policyholders opted to hold onto their insurance             their provisions needed to be bolstered in the second
  the IFRS results of the individual insurance groups as their
                                                                                                 policies in uncertain times, the assumptions for short-         part of 2020 as the actual experience was more severe
  accounting policies for the recognition of negative reserves                                                                                                                                                                     Understanding a more complete
                                                                                                 term future terminations have been bolstered                    than their initial modelling, or additional information had
  and revenue are often not consistent, and the level of                                                                                                                                                                           IFRS 17 picture
                                                                                                                                                                 become available. For example, Momentum Metropolitan
  prudence applied in setting policyholder liabilities varies.                                 • Significantly lower investment returns on shareholder           Holdings note in their interim results announcement:
  For example, in the current year Sanlam reported that it                                       assets coupled with a reduction in asset-based fees on          “Mortality data from the South African Medical Research
  had previously created a pandemic reserve of                                                   customer assets (following on from lower assets under                                                                             IFRS 17: Controls and financial
                                                                                                                                                                 Council, indicates that recorded Covid-19 deaths are
  R760 million that was now to be utilised. By contrast,                                         management during the year)                                                                                                       reporting under the new standard
                                                                                                                                                                 understating the full mortality impact of the pandemic. In line
  most other insurers did not previously hold any such
                                                                                               • Improved non-life personal lines underwriting results – lower   with the SAMRC data, our mortality claims experience to date
  reserve. Suffice to say that even if pandemic reserves were
                                                                                                 personal lines claims volumes, particularly for motor           has been more severe than our initial modelling. We therefore     VAT: Closing the compliance gap
  commonplace these reserves would unlikely have been
                                                                                                 vehicles, in the first half of the year during the extended     increased our COVID-19 provision…”.
  sufficient to absorb all that 2020 brought to bear.
                                                                                                 national lockdown enforced by government                        The short-term provisions generally allow for increased
  The current year’s results were achieved against the                                                                                                            mortality claims, higher terminations, reduced return-to-
                                                                                               • Relief payments to clients in the hospitality and leisure
  backdrop of muted economic activity in Africa, even before                                                                                                                                                                                                       6
                                                                                                 sector coupled with significant liabilities created to settle BI work experience on disability income claims in payment,
  the pandemic hit. South Africa’s Gross Domestic Product                                                                                                         as well as BI claims.
                                                                                                 claims.
South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
S A INSUR A NCE OUTLOOK | OV ERV IE W OF THE 2 02 0 FIN A NCI A L A ND EMBEDDED VA LUE R E SULT S OF THE L A RGE S T FI V E LI S TED INSUR A NCE GROUP S IN SOUTH A FR IC A

                                                                                                                                                                                                                                                                                                                     Introduction
Embedded Value results                                                                                                                                 The slowdown in the economy and the pressure on household incomes further added to
The impact of these short-term COVID-19 assumptions and provisions is also evident in                                                                  lower new business volumes, although arguably the increased need for life and disability                                                                      Overview of the 2020 financial
the disclosed embedded value results, as can be seen in the graph below under the                                                                      insurance during a pandemic may have had an offsetting impact. Several insurers indicated                                                                     and EV results
‘Operating assumption and model changes’. The graph presents the aggregated position for                                                               marked increases in the sale of conventional annuity business.
the insurance groups. The negative impact was observed in both the adjusted net worth
                                                                                                                                                       VNB margins also decreased, with most insurers indicating higher per policy expenses                                                                          COVID-19 – Once bitten, twice shy.
(as described in the paragraphs above) and value of in-force business (VIF).
                                                                                                                                                                                                                                                                                                                     A pandemic’s impact on stress
                                                                                                                                                       being the key driver. Insurers with fixed distributions costs (e.g. workforce agents)
                                                                                                                                                                                                                                                                                                                     testing frameworks
The aggregated EV decreased from R274.9 billion to R258.4 billion, or 6.0%. In addition to                                                             were harder hit due to their inability to reduce these costs as sales volumes reduced.
the impact of the short-term COVID-19 assumptions, economic/investment variances had                                                                   Some insurance groups observed a shift towards more affordable products, as well as
a significant impact on reducing the aggregate VIF and therefore EV.                                                                                   policyholders reducing their cover or benefits, generally resulting in lower margins for new                                                                  Optimising the life insurance
                                                                                                                                                       and exciting policies.                                                                                                                                        regulatory balance sheet
Aggregated change in EV for the 12 months ending 31 Dec 2020
R’millions                                                                                                                                             While there is largely consistency in how insurance groups went about setting up their
                                                                                                                                                       short-term COVID-19 provisions/reserves, it is unclear to what extent it pulls through to                                                                     Artificial intelligence and
320 000                                                                                                                                                                                                                                                                                                              machine learning
                                                                                                                                                       the VNB assumptions. For example, there are limited disclosures on the extent to which
                                                                                                                                                       insurance groups allowed for changes in future mortality and persistency experiences,
300 000
                                                                                                                                                       related to COVID-19, in the VNB numbers.                                                                                                                      Using technology to combat
                                                                                                                                                                                                                                                                                                                     insurance fraud
                                                                                                                                                       Value of New Business and VNB Margins
280 000
          274 876                                                                                                                                      for the 12 months ended 31 December 2020 and 2019
                                                                                                                                                                                                                                                                                                                     Proactively managing conduct risk
                                                                                                                                                                      3 000                                                                                                                                 3.50%
                                                                                                                                          258 449
260 000
                                                                                                                                                                      2 500                                                                                         2.98%                                   3.00%    Understanding a more complete
                                                                                                                                                                                                                   2.58%                                            2.58%
                                                                                                                                                                                                                                                                                                                     IFRS 17 picture
                                                                                                                                                                                                                                                                                                            2.50%
                                                                                                                                                                      2 000
240 000

                                                                                                                                                    Rands (million)
                           Expected    Operating Operational Economic Investment Extraordinary Foreign            Other Capital                                                                                                                                                                             2.00%
          EV Start   VNB                                                                                Dividends                 Other   EV End
                           earnings   assumption experience assumption experience expenses / currency
                                      and model               changes             development movements
                                                                                                                   flows and
                                                                                                                    transfers                                         1 500                                                                                                                                          IFRS 17: Controls and financial
                                        changes                                      costs                                                                                                                                                                                                                  1.50%    reporting under the new standard
                                                                                                                                                                      1 000
                                                                                                                                                                                                                   1.08%
                                                                                                                                                                                                                                                                                                            1.00%
The Value of New Business (VNB) made a smaller contribution to the aggregate VIF                                                                                                             0.90%
                                                                                                                                                                                                                                             0.84%

                                                                                                                                                                       500
                                                                                                                                                                                                                                             0.69%                                                                   VAT: Closing the compliance gap
compared to previous years, with most insurance groups suffering a decrease in VNB,                                                                                                                                                                                                                         0.50%

some significantly so.                                                                                                                                                                       0.10%
                                                                                                                                                                         0                                                                                                                                  0.00%
                                                                                                                                                                                        Liberty              Old Mutual            Momentum                    Sanlam                 Discovery*
New business volumes deteriorated as traditional face-to-face distribution channels                                                                                                                                                Metropolitan

took strain in generating sales, with mixed success in transitioning to digital channels.
                                                                                                                                                                              VNB 12 months to 31 Dec 2019    VNB 12 months to 31 Dec 2020      New Business Margin Dec 2020     New Business Margin Dec 2019                                        7
                                                                                                                                                                                                                                                                        *Discovery group VNB margin not disclosed.
South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
S A INSUR A NCE OUTLOOK | OV ERV IE W OF THE 2 02 0 FIN A NCI A L A ND EMBEDDED VA LUE R E SULT S OF THE L A RGE S T FI V E LI S TED INSUR A NCE GROUP S IN SOUTH A FR IC A

                                                                                                                                                                              Introduction
In summary
The record books may show 2020 as a year in which reported                                                                                                                    Overview of the 2020 financial
financial results were well below expectations, it is by no means                                                                                                             and EV results
the full story. It was a year where the industry again showed its
resilience, while at the same time positively impacting the lives
                                                                                                                                                                              COVID-19 – Once bitten, twice shy.
of its customers at a time of great financial need. Perhaps less
                                                                                                                                                                              A pandemic’s impact on stress
obvious, it was also a year where the industry made meaningful                                                                                                                testing frameworks
strides in changing its operating model through introducing
digital capabilities that will transform the industry for many years
to come. While it might be somewhat difficult for the authors
                                                                                                                                                                              Optimising the life insurance
                                                                                                                                                                              regulatory balance sheet
of this article to say, being an accountant and an actuary, but
perhaps 2020 is a year in which we need to look beyond just the
numbers to see the full picture.
                                                                                                                                                                              Artificial intelligence and
                                                                                                                                                                              machine learning

Authors
                                                                                                                                                                              Using technology to combat
                          Gerdus Dixon                                                                                                                                        insurance fraud
                          Partner, Audit and Assurance,
                          Insurance Sector Audit Leader,
                          Deloitte Africa                                                                                                                                     Proactively managing conduct risk
                          gdixon@deloitte.co.za
                          +27 (021) 427 5574
                                                                                                                                                                              Understanding a more complete
                                                                                                                                                                              IFRS 17 picture

                          Carike Nel
                          Director, Actuarial and                                                                                                                             IFRS 17: Controls and financial
                          Insurance Solutions,                                                                                                                                reporting under the new standard
                          Deloitte Africa
                          canel@deloitte.co.za
                          +27 (021) 427 5358                                                                                                                                  VAT: Closing the compliance gap

                                                                                                                                                                                                              8
South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
S A INSUR A NCE OUTLOOK | COV ID -19 – ONCE BIT TEN, T W ICE SH Y

                                                                                                                                                                                                              Introduction

COVID-19 – Once bitten, twice shy                                                                                                                                                                             Overview of the 2020 financial
                                                                                                                                                                                                              and EV results

A pandemic’s impact on stress testing frameworks                                                                                                                                                              COVID-19 – Once bitten, twice shy.
                                                                                                                                                                                                              A pandemic’s impact on stress
Introduction                                                    were imposed, social distancing was the new norm and              from its pre-crash high in December 2019 to its lowest 		                   testing frameworks
As we reflect on 2020 that seems to have gone by in a           both fist bumps and elbow shakes were gaining traction.           point in March 2020, which was a significant fall of 34%.
flash, we have seen the remarkable ability of the human         At the time many felt like Henny Penny and were thinking          But even this movement translates to only a 1-in-100 year                   Optimising the life insurance
race to adapt and innovate, with the insurance market           that the sky was falling. But was it really a 1-in-200 year       event according to the Standardised Formula 		                              regulatory balance sheet
being no different. Remote working was set up with near         event when compared to the underlying calibrations of the         calibrations.
perfect transition, that saw insurers adapting to change        Standardised Formula?
and the use of technology on a level never seen before in                                                                         With equities comprising only 14% of non-life insurers’                     Artificial intelligence and
the insurance sector. However, the negative impact of the       In answering this question, we look at the key risks that are     investment portfolios on average1, the impact of the
                                                                                                                                                                                                              machine learning
COVID-19 pandemic left its mark – from the tragic loss of       captured by the Standardised Formula SCR, namely market           falling equity market was not as significant as might
life to the significant economic and societal impacts and, of   risk, life underwriting risk, non-life underwriting risk and      have been expected. In contrast, life insurers were
                                                                                                                                                                                                              Using technology to combat
course, the specific effects on the insurance sector.           operational risk, and assess how the emergence of those           more exposed with equities representing on average 		                       insurance fraud
                                                                risks under COVID-19 impacted on insurers’ solvency.              43% of their overall investment portfolio2. Despite this,
With the promulgation of the Solvency Assessment and            				                                                              however, most of these equity investments relate to
Management (SAM) regulatory framework on 1 July 2018,           Market Risk                                                       investments made on behalf of policyholders through 		                      Proactively managing conduct risk
insurers have increasingly asked the question of what a         In the market risk module we saw that equity risk, interest       with-profits policies and linked business. With this
“1-in-200 year” event would actually look like. This paper      rate risk and currency risk were the risks within the             risk passed on to the policyholders, most SCR ratios of
                                                                                                                                                                                                              Understanding a more complete
aims to explore how frequently we can expect an event like      Standardised Formula that were most significantly affected        life insurers were largely unaffected. Insurers who offer
                                                                                                                                                                                                              IFRS 17 picture
COVID-19 to occur when compared to the calibration of           by COVID-19.                                                      downside protection on their equity-backed policies
selected modules within the SAM Standardised Formula.                                                                             saw a significant increase in their investment guarantee
It further goes on to recognise potential areas where           • Equity Risk                                                     reserves, with the fall in the markets also resulting in an                 IFRS 17: Controls and financial
COVID-19 has highlighted shortfalls in the Solvency Capital       According to the calibrations of the Standardised 		            increase in the volatility of equity markets, with some of                  reporting under the new standard
Requirement (SCR) for consideration in insurers’ economic         Formula, which consider annual movements of an 		               this offset by the hedging strategies that were
capital modelling and broader Own Risk and Solvency               insurer’s overall equity exposure, the MSCI World Index         employed.
Assessment (ORSA).                                                saw a 1-in-9 year event for the 12 months ending March                                                                                      VAT: Closing the compliance gap
                                                                  2020 (13% fall from March 2019 to March 2020) while
The journey thus far                                              the JSE All Share Index experienced a 1-in-10 year event      Reference:
If we look back to March 2020 we can remember that                over the same period (21% fall). However, we could also       1. Prudential Authority – Non-life industry experience 2018
                                                                                                                                2. Prudential Authority – An overview of the experience of life insurers in                                    9
equity markets were in freefall, worldwide lockdowns              consider the intra-year drop in the JSE All Share Index          South Africa for 2018
South African Insurance Outlook 2021 - Navigating the insurance - Deloitte
S A INSUR A NCE OUTLOOK | COV ID -19 – ONCE BIT TEN, T W ICE SH Y

                                                                                                                                                                                        Introduction

  Observation                                                    Observation                                                 Observation
                                                                                                                                                                                        Overview of the 2020 financial
  It is imperative that insurers are well prepared for           Insurers need to understand the level of                    Insurers with long-dated liabilities need to assess        and EV results
  these extreme market movements, with a clearly                 diversification assumed in the calibrations of the          their exposure to non-parallel movements in the yield
  defined approach for investment decisions under                Standardised Formula to identify areas where                curve, e.g. tilts and changes in shape, as these are not
  such conditions, allowing careful and objective                economic capital requirements might need to                 considered within the Standardised Formula. This is        COVID-19 – Once bitten, twice shy.
  consideration when markets are in free fall, reducing          deviate from the Standardised Formula. While                especially important where asset-liability matching
                                                                                                                                                                                        A pandemic’s impact on stress
                                                                                                                                                                                        testing frameworks
  the risk of knee jerk-reactions. This should include a         the Standardised Formula does not allow for                 is not based on matching cash flows, but rather
  focus on the hedging of investment guarantees, and             diversification between different currencies, the past      based on matching duration or overall movements in
  stress testing the effectiveness of those hedges under         year has made it clear that the volatility of the Rand is   liabilities. This shortfall in the Standardised Formula    Optimising the life insurance
  extreme market movement scenarios.                             not the same for all foreign currencies, e.g. the USD/      was noted during SAM’s development and insurers’           regulatory balance sheet
                                                                 ZAR exchange rate tends to be more volatile than            risk management functions could benefit from
                                                                 other exchange rates.                                       revisiting the relevant position papers and discussion
                                                                                                                                                                                        Artificial intelligence and
• Currency Risk                                                                                                              documents to understand the shortcomings of the
                                                                                                                                                                                        machine learning
  Similar to equity risk, the Standardised Formula                                                                           Standardised Formula, not only for interest rate risk,
  calibrations (considering annual movements) suggest        • Interest Rate Risk                                            but also for other risk modules.
  that the GBP/ZAR movement for the twelve months              Interest rate risk was the most severely affected market                                                                 Using technology to combat
  to April 2020 equates to a 1-in-10 year event (19% 		        risk module, with nominal yields reducing by up to 40%                                                                   insurance fraud
  depreciation). For the USD/ZAR, we saw a 1-in-17 year        at short durations (equivalent to a 1-in-100 year event)
                                                                                                                             Observation
  event over this same period (12% depreciation). 		           and increasing by up to 80% at longer durations (which is
                                                                                                                             Many insurers have defaulted to using the PA’s risk        Proactively managing conduct risk
  However, as with equity risk, we could also consider the     much more severe than a 1-in-200 year event).
                                                                                                                             free curve for other calculation bases, e.g. IFRS and
  intra-year movement from the most recent strongest           Subsequent to this volatility, the PA had updated the
                                                                                                                             Embedded Value reporting, but, after the volatility
  position of the ZAR against the USD, in December 2019,       constituent bonds used to derive the risk-free curve. 		                                                                 Understanding a more complete
                                                                                                                             experienced during 2020, insurers were urgently
  to the weakest position in April 2020, over which a 27%      This update had very little impact at short durations, but                                                               IFRS 17 picture
                                                                                                                             considering alternative curves. With a variety of risk-
  depreciation was experienced. Even this only translates      significantly reduced the impacts at longer durations.
                                                                                                                             free curves available, it’s important for insurers to
  to a roughly 1-in-30 year event when compared against        Had the new bond constituents been used throughout
                                                                                                                             have a sufficiently deep understanding of any yield
  the Standardised Formula calibrations.                       2020 the impacts at long durations would be 			                                                                          IFRS 17: Controls and financial
                                                                                                                             curve that is used, for example an understanding of
                                                               somewhere between a 1-in-20 and a 1-in-50 year event,                                                                    reporting under the new standard
                                                                                                                             the curve construction methodology (interpolation
 The average life and non-life insurer have limited 		         depending on the duration. This less severe impact
                                                                                                                             and extrapolation), selection of bond constituents and
 foreign exposures and hence the impact of the ZAR             is also more in line with the observed movements in
                                                                                                                             whether historically the curve has displayed desirable     VAT: Closing the compliance gap
 deterioration had an insignificant effect on most 		          government bond yields.
                                                                                                                             behaviour, especially during times of market stress.
 insurers’ SCR ratios over the last year.

                                                                                                                                                                                                                        10
S A INSUR A NCE OUTLOOK | COV ID -19 – ONCE BIT TEN, T W ICE SH Y

                                                                                                                                                                                                                      Introduction
                                                              Further to this there are also longer-term mortality               recession caused between 2.2 and 3.0 million
  Observation                                                 impacts from both lockdown and the associated economic             job losses6 and 7, well in excess of the 1 million jobs lost 		                      Overview of the 2020 financial
  Insurers can improve economic capital models                recession, which have been estimated to be multiples of            during the 2008 Global Financial Crisis8. Retrenchment                               and EV results
  by recalibrating many of the market risk modules,           the direct excess deaths, with this impact being spread            risk might be negligible at an industry level9, but there are
  using more recent and larger data sets than those           over the next 10 years5. These longer-term impacts are             a number of insurers with significant exposure thereto,
  underlying the Standardised Formula. A typical                                                                                                                                                                      COVID-19 – Once bitten, twice shy.
                                                              expected to be concentrated in lower income families               leading to such insurers recognising large retrenchment
  example is interest rate risk, where there is significant
                                                                                                                                                                                                                      A pandemic’s impact on stress
                                                              where poverty induced deaths are likely to occur. However,         losses. This is the second round of such losses in less 		                           testing frameworks
  experience available beyond the data set that was           higher income families are also expected to be subject to          than 15 years, illustrating that retrenchment experience
  used to calibrate the Standardised Formula. Re-             increased risk from at least a few factors, including delayed      is highly volatile, but also that it behaves more like a
  calibrating using more recent data could also better        cancer diagnoses, emotional impacts from lockdown and              short-lived catastrophe and less like the long-term
                                                                                                                                                                                                                      Optimising the life insurance
  reflect changes in market behaviour, like the impact of                                                                                                                                                             regulatory balance sheet
                                                              potential long-term COVID-19 symptoms. To the extent               upward stress included in the Standardised Formula.
  technology and automated trading on equity markets.         that these deaths occur in the most impoverished of                This is especially relevant for business with shorter
                                                              communities the impact on the insurance industry would             contract boundaries, where the impact of such a short-
                                                                                                                                                                                                                      Artificial intelligence and
                                                              be limited, but the loss of human life remains equally tragic.     lived catastrophe might not be captured sufficiently by                              machine learning
Life Underwriting Risk                                        When including the impact of these longer-term deaths the          the Standardised Formula.
While pandemics have always been a classical stress test      severity of the COVID-19 pandemic becomes undoubtably
for life insurers, COVID-19’s far reaching complexity could   more severe than the 1-in-200 year event envisioned by the                                                                                              Using technology to combat
not have been captured in the simplicity of a theoretical                                                                         Observation
                                                              Standardised Formula.                                                                                                                                   insurance fraud
stress test.                                                                                                                      Insurers with any material retrenchment risk need
                                                              • Morbidity Risk                                                    to take great care in ensuring their economic capital
• Mortality Catastrophe Risk                                    Life insurers were also subject to other claim variances,         and ORSA stresses make an appropriate allowance                                     Proactively managing conduct risk
  COVID-19’s mortality impact has taken much longer             including increases in temporary disability claims due to         for the true nature of retrenchment risk. In light
  to materialise than the three months assumed in the 		        severe COVID-19 conditions, where waiting periods could           of its volatility and potentially large and relatively
  Standardised Formula. With vaccines now available                                                                               frequent losses, risk appetite policies also need to be                             Understanding a more complete
                                                                be very short, as well as additional hospital cash claims
  there is renewed hope that we can start estimating 		                                                                                                                                                               IFRS 17 picture
                                                                due to COVID-19 submissions, although this is expected            reassessed to ensure there are appropriate risk limits
  the pandemic’s ultimate impact. In this regard our 		         to be more than offset by a reduction in submissions 		           in place for retrenchment risk.
  analysis is based on the estimated impact of a third          arising from elective procedures. There could also be 		                                                                                              IFRS 17: Controls and financial
  wave, without any fourth wave impact and after netting        lockdown related impacts on morbidity claims, e.g. 		          Reference:                                                                             reporting under the new standard
  off other lockdown related impacts like limited deaths 		     from temporary changes in lifestyle activities and alcohol
                                                                                                                               3. Extrapolated from SAMRC Excess Deaths data
                                                                                                                               4. Swiss Re – Pandemic influenza: A 21st century model for mortality shocks
  due to influenza and lower accidental deaths. The 		          availability.                                                  5. Business Tech – ‘Real and dire possibilities’ facing South Africa after lockdown:
  excess deaths within the South African population is 		                                                                         Dawie Roodt                                                                         VAT: Closing the compliance gap
                                                                                                                               6. Statistics South Africa – Quarterly Labour Force Survey,
  then estimated to reach anywhere between 180 000 and        • Retrenchment Risk                                                 Quarter 2: 2020
  250 000 by the end of 20213. According to the 		              The lockdown induced recession is the worst economic           7. NIDS-CRAM – Overview and Findings, NIDS-CRAM Synthesis
                                                                                                                                  Report Wave 1
  Standardised Formula calibrations this could be expected      contraction our country has faced, at least since 1960         8. Business Tech – South Africa lost 1 million jobs because of the
                                                                when economic growth data became available. This 		               2008 recession – here’s why this one could be even worse
  to happen once every 250 to 370 years4.                                                                                                                                                                                                             11
                                                                                                                               9. Prudential Authority – An overview of the experience of life insurers in
                                                                                                                                  South Africa for 2018
S A INSUR A NCE OUTLOOK | COV ID -19 – ONCE BIT TEN, T W ICE SH Y

                                                                                                                                                                                              Introduction
• Lapse Risk and New Business Volumes                            As such, the below are short-term observations that were
  The life insurance industry’s lapse experience is always       observed across the non-life insurance market for the            Observation
                                                                                                                                                                                              Overview of the 2020 financial
  fascinating to observe and 2020 was no different.              average insurer:                                                 One would expect that with new work-from-home               and EV results
  Despite severe and unprecedented economic hardship                                                                              protocols, increased stress environments and
                                                                 • Significant business interruption claims paid and
  there were no massive increases in industry level lapses10,                                                                     stretched resource capacity following the pandemic,
                                                                   reserved for                                                                                                               COVID-19 – Once bitten, twice shy.
  definitely nothing that suggests we had a mass lapse 		                                                                         operational risk would increase. However, the
                                                                 • Reduced loss ratios of the motor line of business owing        Standardised Formula doesn’t accurately capture this
                                                                                                                                                                                              A pandemic’s impact on stress
  event on our hands. In fact, some insurers experienced                                                                                                                                      testing frameworks
                                                                   to the lockdown                                                effect. Insurers that use the Standardised Formula
  an improvement in lapse rates. This emphasises that any
  experience item, like lapses, that depends on 		               • Cash backs paid to policyholders to share in this              as a proxy for economic capital as part of their ORSA
  policyholder behaviour is notoriously difficult to predict       improved motor experience                                      process need to critically assess the appropriateness       Optimising the life insurance
                                                                                                                                  of the operational risk modules in light of the current     regulatory balance sheet
  under extreme conditions, as it might behave 		                • Reduced cover from comprehensive to third party, fire
  counterintuitively.                                              and theft                                                      environment.

                                                                 • Increased claims on accident and health, travel and                                                                        Artificial intelligence and
 New business volumes showed large reductions10, as 		             property contents lines of business                                                                                        machine learning
 disposable income came under pressure and advisor
                                                                 • Increased expenses following work-from-home protocols
 networks were restrained from travelling, placing at least
                                                                   adopted
 some upward pressure on per policy expenses.                                                                                                                                                 Using technology to combat
                                                                                                                                                                                              insurance fraud
                                                                   Observation
  Observation                                                      With the observation that there was very limited
  ORSA scenarios representing extreme conditions                                                                                                                                              Proactively managing conduct risk
                                                                   impact on non-life insurers’ Standardised Formula
  need to consider the possibility of policyholders                SCRs, non-life insurers that use the Standardised
  behaving in unexpected and counterintuitive ways,                Formula as a proxy for economic capital as part                                                                            Understanding a more complete
  as this is not only plausible but could also notably             of their ORSA process need to critically assess the                                                                        IFRS 17 picture
  change the outcomes of such scenarios.                           appropriateness of the non-life underwriting risk
                                                                   modules in light of the current environment, both
                                                                   from a claims and expenses perspective.                                                                                    IFRS 17: Controls and financial
Non-Life Underwriting Risk                                                                                                                                                                    reporting under the new standard
With roughly 80% of non-life premiums being attributed to
the motor, property and liability lines of business11, we have   Operational Risk
seen that, on the surface, there appears to be a limited         As the Standardised Formula allowance for operational risk                                                                   VAT: Closing the compliance gap
impact of the pandemic on non-life underwriting risk for         is largely a premium and reserve exposure-based
the average non-life insurer, as the risk modules do not         calculation, we have seen that, on average, the operational
specifically cater for the direct impacts of the COVID-19        risk allowance for insurers decreased relative to
                                                                                                                               Reference:
pandemic.                                                        expectations, in line with lower than expected business       10. Prudential Authority – Summary of QRT data                                                 12
                                                                 volumes.                                                      11. Prudential Authority – Non-life industry experience 2018
S A INSUR A NCE OUTLOOK | COV ID -19 – ONCE BIT TEN, T W ICE SH Y

                                                                                                                                                                          Introduction
Looking Forward
With the pandemic not yet over, we have listed below some
                                                              Last year may have felt like more than a 1-in-200 event
                                                              across the risks the industry faced. But it is safe to say
                                                                                                                                Authors
                                                                                                                                                                          Overview of the 2020 financial
items insurers should consider when assessing their top       that, bar the remaining uncertainty surrounding business                    Lafras Eksteen                  and EV results
and emerging risks within the ORSA process. These items       interruptions claims, the industry’s capital position was                   Senior Manager, Actuarial and
                                                                                                                                          Insurance Solutions,
should also be considered as part of the post-stress profit   more than adequate to absorb the severe impact, showing
                                                                                                                                          Deloitte Africa                 COVID-19 – Once bitten, twice shy.
assessment for their Loss Absorbing Capacity of Deferred      the resilience of the balance sheets under the new capital                  leksteen@deloitte.co.za         A pandemic’s impact on stress
Taxes calculation.                                            regime. What our analysis has confirmed, however, is that                   +27 (011) 209 8109              testing frameworks
                                                              not all of the risks and interrelationships of the risks can be
• Increased lapses and lower new business volumes owing       catered for in a one-size-fits all standardised formula. It is
  to suppressed economic growth and retrenchments             important that insurers feed the insights and data gained
                                                                                                                                                                          Optimising the life insurance
                                                                                                                                                                          regulatory balance sheet
• Increased risk of defaults and widening of credit spreads   during the pandemic into other elements of their risk                       Ricardo Govender
                                                              management framework, in particular their ORSAs. In this                    Senior Manager, Actuarial and
  as the economy remains fragile
                                                              way they will be better informed about the effectiveness                    Insurance Solutions, Deloitte
                                                                                                                                          Africa                          Artificial intelligence and
• Impact on the property market and property investments      of various elements of their risk management strategies as
                                                                                                                                          rgovender@deloitte.co.za        machine learning
  of a permanent shift towards remote working and             they adapt and thrive in the increasingly uncertain world.                  +27 (011) 304 5953
  e-commerce                                                  As Albert Einstein so eloquently put it: “In the middle of
• Fiscal and monetary policy impacts on the economic          difficulty lies opportunity”.                                                                               Using technology to combat
                                                                                                                                                                          insurance fraud
  environment and wider financial markets

• Longer-term mortality impacts which are still highly
  uncertain                                                                                                                                                               Proactively managing conduct risk

• Impact on trade credit and credit life business over the
  next few years following the economic impact of the                                                                                                                     Understanding a more complete
  pandemic                                                                                                                                                                IFRS 17 picture

• Potential delays in transformation and other large-scale
  programmes, including IFRS 17 implementation                                                                                                                            IFRS 17: Controls and financial
                                                                                                                                                                          reporting under the new standard
• Potential long-term implications on staff skillsets
  following prolonged remote working, school and
  university disruption and the related implications for                                                                                                                  VAT: Closing the compliance gap
  operational risk and scarce skills

• Changes in cyber and security risk related to prolonged
  remote working and e-commerce.
                                                                                                                                                                                                          13
S A INSUR A NCE OUTLOOK | THE S A M DUS T H A S SE T TLED, TIME TO OP TIMI SE THE LIFE INSUR A NCE BA L A NCE SHEE T

                                                                                                                                                                                                                         Introduction

The SAM dust has settled, time to optimise the                                                                                                                                                                           Overview of the 2020 financial
                                                                                                                                                                                                                         and EV results

life insurance balance sheet                                                                                                                                                                                             COVID-19 – Once bitten, twice shy.
                                                                                                                                                                                                                         A pandemic’s impact on stress
                                                                                                                                                                                                                         testing frameworks
Easy wins to improve life insurers’ regulatory capital positions
                                                                                                                                                                                                                         Optimising the life insurance
                                                                                                                                                                                                                         regulatory balance sheet
Introduction                                                                              Priorities                                                 The clearly defined boundaries of the risk-based Standardised
We are about two years into reporting under                                                                                                          Formula SCR provide a good starting point to optimising
the new Solvency Assessment and Management                                                                                                           insurers’ capital consumption. Since capital optimisation is not    Artificial intelligence and
(SAM) framework, and with the dust of                                                     Regulatory                                                 a once-off exercise, we also introduce a framework to embed
                                                                                           solvency
                                                                                                                                                                                                                         machine learning
implementation having settled many life insurers                                             ratio                                                   capital optimisation across an organisation that considers the
are finding a steady rhythm of submitting the                          Economic                              Economic                                stakeholders and trade-offs mentioned here.
new regulatory returns. They have a more                               de-risking                            solvency                                                                                                    Using technology to combat
                                                                                                               ratio
                                                                                                                                                                                                                         insurance fraud

                                                                                                                               Performance metrics
hands-on understanding of the processes                                                                                                              Optical Capital Optimisation, or Optimal Capital
                                                    Stakeholders

needed to produce, in particular, the new capital                                                                                                    Consumption
measures, and have a better view of how these                                                                                                        With the implementation of Solvency II leading South Africa’s       Proactively managing conduct risk
                                                                                          Optimal
measures describe the risks of their businesses.                                          solution                                                   implementation of SAM by a couple of years, we can leverage
                                                                       Tax                                        Earnings
We are seeing investments made to improve the                      efficiency                                     volatility
                                                                                                                                                     various learnings from Europe. A particular aspect in this regard
reporting processes needed, but there is also an                                                                                                     has been the approach to optimising regulatory capital without      Understanding a more complete
opportunity to use the deeper understanding to                                                                                                       any economic substance behind the optimisation.                     IFRS 17 picture
improve the performance of the business with
respect to capital consumption.                                                  IFRS and             Liquidity                                      Similar to certain tax shelters, this has been perceived as
                                                                                EV earnings           and cash                                                                                                           IFRS 17: Controls and financial
                                                                                                     generation                                      “gaming” the system. Our view, however, is that a deep
                                                                                                                                                                                                                         reporting under the new standard
Capital optimisation requires trade-offs between                                                                                                     understanding of capital optimisation is essential to understand
the different aspects summarised in the adjacent                                                                                                     underlying risk drivers, which enables better risk management
diagram. The optimal solution considers all these                         Capital optimisation considerations                                        and should thus be considered as part of an insurer’s Own Risk      VAT: Closing the compliance gap
aspects across the different stakeholders, taking                                                                                                    and Solvency Assessment. Better solvency ratios, based on a
into account their performance metrics and the                                                                                                       sound understanding of risks assumed, also enables insurers
                                                      In this article we focus on the various options available to
business priorities.                                                                                                                                 to offer more affordable products while still providing the
                                                      optimise regulatory capital ratios under SAM, also referred to as
                                                                                                                                                     appropriate risk-adjusted return to shareholders.                                                 14
                                                      solvency ratios or Solvency Capital Requirement (SCR) covers.
S A INSUR A NCE OUTLOOK | THE S A M DUS T H A S SE T TLED, TIME TO OP TIMI SE THE LIFE INSUR A NCE BA L A NCE SHEE T

                                                                                                                                                                                                        Introduction
Which Levers Should Insurers Focus on?
The SAM standardised formula SCR is a complex                Cost/Effort Modelling Optionality                       Reinsurance and Risk Transfer             Balance Sheet Management and
                                                                                                                                                                                                        Overview of the 2020 financial
                                                             Required                                                                                          Capital Structuring
calculation with many components underlying the                                                                                                                                                         and EV results
Market Risk, Life Underwriting Risk and Operational Risk     Easy wins       • Remove conservatism          • Reduction of insurance liabilities                • Composition of assets considering
calculations. Furthermore, diversification of components                                                      and/or SCR through traditional                      concentration and default risk
                                                                             • Allowance for existing                                                                                                   COVID-19 – Once bitten, twice shy.
has a dramatic impact of the resulting solvency ratio.                          management action framework   reinsurance                                       • SAM specific ALM strategy (positive   A pandemic’s impact on stress
There are thus many levers insurers can pull to influence                                                   • Reinsurer credit rating, parent                     and negative liabilities)             testing frameworks
                                                                             • Interpretation of contract
their solvency ratio, within which we acknowledge two                                                         guarantee, reinsurance collateral
                                                                                boundary                                                                        • Minimise regulatory deductions
broad types of capital optimisation. The first type does                                                                                                          from Own Funds in FSI 2.3 Section
                                                                             • Illiquidity premium applied to        • Concentration risk – use multiple                                                Optimising the life insurance
not affect an insurer’s risk exposures per se, but rather                                                              reinsurers                                 8*
                                                                                yield curve                                                                                                             regulatory balance sheet
results in risk capital being modelled more accurately,
                                                                                                                     • Consider counterparty default
and we term this “Modelling Optionality”. The second
                                                                                                                       relaxations in FSI 2.2 Att. 3(b) *
type changes an insurers’ actual risk exposures, either
                                                                                                                                                                                                        Artificial intelligence and
through risk transfer or risk reduction, and we have         Moderate        • Iterative risk margin (IRM)           • Catastrophe risk reinsurance             • Letters of guarantee                  machine learning
split this type into two categories, being those solutions   effort          • External rating model for             • Mortality swap reinsurance               • Use of Tier 2/3 Basic Own Funds or
relating to “Reinsurance and Risk Transfer” and those        required          company/counterparty CQS                                                           Ancillary Own Funds, as opposed
relating to “Balance Sheet Management and Capital                                                                    • Mass lapse reinsurance                                                           Using technology to combat
                                                                               mapping                                                                            to just Tier 1 Basic Own Funds
Structuring”.                                                                                                                                                                                           insurance fraud
                                                                                                                     • “VIF” reinsurance solutions –
                                                                             • Improved tax modelling,                                                          • Updates to management action
                                                                                                                       reduce cashflows uncertainty               framework
Each of these categories are further grouped into:                              particularly maximising LACDT
                                                                                                                                                                                                        Proactively managing conduct risk
• easy wins                                                  Honourable • Swap curve                                 • Consider capital efficiency of           • Company structures, subordinated
• those requiring moderate effort                            mentions                                                  reinsurance agreements                     debt, contingent loans
                                                                        • Internal model
                                                                                                                                                                                                        Understanding a more complete
• those requiring considerable investment, which we                                                                  • Alternative risk transfer         • Product design and contract
                                                                                                                                                                                                        IFRS 17 picture
  refer to as honourable mentions.                                                                                     agreements, e.g. insurance linked   wording, e.g. new product offering
                                                                                                                       bonds                             • Capital efficient mergers/
These options are widely documented, so in this article                                                                                                    acquisitions                                 IFRS 17: Controls and financial
we do not describe them in detail, but rather assess the
                                                                                                                                                                                                        reporting under the new standard
impacts of the various options on capital optimisation.
                                                             *Any use of “FSI” refers to the Financial Soundness Standards for Insurers, as published by the Prudential Authority

                                                             With a small- to medium-sized life insurer in mind, we determined the potential effect of selected solutions on the solvency
                                                                                                                                                                                                        VAT: Closing the compliance gap
                                                             ratio, relative to the cost/effort and expertise required to implement those solutions. This was done through analysis
                                                             and judgement, as well as incorporating learnings from the European Solvency II regime. These results must be carefully
                                                             considered, as they depend on both an insurer’s specific business, as well as the skills, expertise and operational capabilities
                                                                                                                                                                                                                                      15
                                                             available within the company.
S A INSUR A NCE OUTLOOK | THE S A M DUS T H A S SE T TLED, TIME TO OP TIMI SE THE LIFE INSUR A NCE BA L A NCE SHEE T

                                                                                                                                                                                                                                        Introduction
Our resultant findings for selected capital optimisation solutions are summarised in this diagram.
                                                                                                                                                                                                                                        Overview of the 2020 financial
The potential impact on solvency ratio relative to cost/effort and internal expertise required                                                                                                                                          and EV results

                                                                                                                                                                                                                                        COVID-19 – Once bitten, twice shy.
                                                                                                  More cost/effort required                                                                                                             A pandemic’s impact on stress
                                                                                                                                                                                                                                        testing frameworks
                                                                                                                                                Honourable mentions
                                              Bubble size represents the potential impact of each
                                    5
                                                         option on the solvency ratio.                                                                                              Internal model
                                                                                                                                                                                                                                        Optimising the life insurance
                                                                                                                                                                                                                                        regulatory balance sheet

                                                                                                                                                            Tier 2 or 3 own funds

                                                                                                                                                                                                     More internal expertise required
                                                                                                                     Product design and                                                                                                 Artificial intelligence and
      Internal Expertise Required

                                    4
                                                                                                                      contract wording
                                                                                                                                                                                                                                        machine learning

                                            Easy wins
                                                                                                                                                                                                                                        Using technology to combat
                                    3
                                                                                      LACDT
                                                                                                                                                                                                                                        insurance fraud
                                                    Management action                                                      VIF solutions        Iterative risk margin
                                                    (contract boundary)
                                                                                                                                                                                                                                        Proactively managing conduct risk
                                    2
                                                                                                                          Mortality swap
                                            Counterparty default
                                             (CQS conservation)           Illiquidity premium
                                                                                                                                                                 Mass lapse reinsurance
                                                                                                                                                                                                                                        Understanding a more complete
                                                                                                                 Asset liability matching                                                                                               IFRS 17 picture
                                    1                                     Asset diversification
                                                                          (concentration risk)          Traditional reinsurance
                                                                                                                                            Moderate effort                                                                             IFRS 17: Controls and financial
                                                            Remove conservatism                                                                                                                                                         reporting under the new standard
                                                                (modelling)
                                    0
                                        0                           1                               2                             3                          4                             5                                            VAT: Closing the compliance gap
                                                                                                               Cost / Effort Required

                                    As cost/effort and internal expertise increase we move towards the top right-hand corner of the graph. The size of each bubble gives an indication of the possible
                                    improvement in solvency ratio relative to other initiatives. For example, implementing an internal regulatory capital model requires significant cost/effort and internal
                                                                                                                                                                                                                                                                      16
                                    expertise, but the potentially significant improvement in the solvency ratio might be worth the effort.
S A INSUR A NCE OUTLOOK | THE S A M DUS T H A S SE T TLED, TIME TO OP TIMI SE THE LIFE INSUR A NCE BA L A NCE SHEE T

                                                                                                                                                                                                Introduction
Easy Wins                                                         insurers, is to fully understand the interplay between         risk margin (IRM). As the name suggests, the IRM
Easy wins are summarised in the bottom left-hand                  assets held and components of the Market Risk module.          calculates the risk margin and SCR iteratively. While this     Overview of the 2020 financial
corner of the graph, as these are initiatives that can be         Small tweaks, for example spreading cash assets across         entails upfront effort, it has been proven to be cost-         and EV results
implemented with relatively limited internal expertise            multiple major banks, reduces concentration risk and can       effective in the long term and can introduce significant
and minimal cost/effort. Many of the easy wins relate to          significantly decrease the Market Risk capital requirement.    solvency ratio improvements, particularly where there
                                                                                                                                                                                                COVID-19 – Once bitten, twice shy.
modelling initiatives. This can be understood with the                                                                           are large negative reserves. While the IRM modelling
                                                                                                                                                                                                A pandemic’s impact on stress
context of where insurers’ capital thinking was grounded,         Moderate Effort                                                sophistication is not directly comparable to the actual risk   testing frameworks
the Financial Soundness Valuation (FSV) framework. In the         In the middle of the graph there are several classic risk      transfer achieved through mass lapse reinsurance, both
FSV world conservatism in modelling was not only required         management tools, for example, asset liability matching        tools achieve similar outcomes in reducing the lapse risk
but was also common practice. Under SAM the liabilities           that has long been used by insurers. This ranges from          component of the SCR. Insurers could thus consider these
                                                                                                                                                                                                Optimising the life insurance
                                                                                                                                                                                                regulatory balance sheet
should be measured on a best estimate basis, however              simple durational matching that can be done with less          tools as alternatives to one another by comparing upfront
both implicit and sometimes explicit conservatism remains         cost and expertise, all the way to complicated hedging         cost/effort of the IRM approach, including regulatory
within some actuarial models and assumptions. Actuaries           strategies. These provide protection against a wide variety    application cost/effort, against the long-term cost of mass    Artificial intelligence and
tend to include conservatism to allow for the uncertainty         of movements in various financial variables.                   lapse reinsurance premiums.                                    machine learning
in assumptions, model risk and data. Actuaries should do
more to ensure their numbers reflect a best estimate view.        Reinsurance is a similarly well-established risk               Honourable Mentions
Conservatism is particularly included in the valuation of         transfer tool, starting with the transfer of mortality         One of the biggest bubbles on the graph relates to the use     Using technology to combat
new contracts.                                                    and morbidity risk through traditional reinsurance.            of Tier 2 and tier 3 own funds, particularly the use of        insurance fraud
                                                                  Similarly, mortality swaps are an effective way to reduce      Ancillary Own Funds in the form of subordinated debt and
Furthermore, some insurers choose more conservative               longevity risk on annuity books and at the same time           parental letters of guarantee. A parental guarantee can
                                                                                                                                                                                                Proactively managing conduct risk
Credit Quality Steps than can be justified. Similarly, insurers   reduce cash flow volatility to better enable asset liability   significantly improve the solvency ratio without requiring
might not be shortening contract boundaries for loss-             matching. Reinsurance can also provide financing, like         a capital injection. When applying a parental guarantee
making contracts, i.e. not allowing for the fact that such        VIF solutions which entail transferring large portions of      in the SCR calculations an allowance for default risk is       Understanding a more complete
contracts can be assumed to be repriced at the expected           premium to a reinsurer, thereby reducing Own Funds,            required, however this allowance is generally small relative   IFRS 17 picture
repricing date, hence reducing capitalisation of long-term        but also significantly reducing most life underwriting risk    to the maximum allowable increase in Own Funds, being
future losses.                                                    components, including lapse risk. The net effect of such a     say 50% of SCR for Tier 2 Own Funds.
                                                                  solution could well be an improved solvency ratio.                                                                            IFRS 17: Controls and financial
A key modelling requirement under SAM is the loss                 One of the youngest additions to the reinsurers’ toolkit is    Related to this are regulatory deductions from Own Funds,      reporting under the new standard
absorbing capacity of deferred taxes which, with                  mass lapse reinsurance, which transfers a part of the          including investments in an insurer’s own shares, in its
a moderate level of effort, could reduce the SCR by up            loss arising from a mass lapse event. This is particularly     holding company, cash and deposits at a bank within the        VAT: Closing the compliance gap
to 28%. SAM also provides insurers with the option to             beneficial for risk business with long contract boundaries     same financial conglomerate, participation in financial and
increase the discount rate by an illiquidity premium,             where the mass lapse SCR is sizeable.                          credit institutions and net deferred tax assets. Minimising
which can significantly reduce reserves for annuity                                                                              these deductions will improve the solvency ratio.
business, albeit with a marginal increase in SCR.                 In South Africa insurers also have access to a
                                                                                                                                                                                                                              17
Another easy win, particularly at small/medium sized              fundamentally different tool, application of an iterative
S A INSUR A NCE OUTLOOK | THE S A M DUS T H A S SE T TLED, TIME TO OP TIMI SE THE LIFE INSUR A NCE BA L A NCE SHEE T

                                                                                                                                                                Introduction
In the top right-hand corner of the graph is use of an
internal model for regulatory capital. An internal SAM                                Sponsorship                                   Constraints                 Overview of the 2020 financial
                                                                           Executive Sponsor/Business Owners                Resources/Budget/Timescales
capital model requires significant cost/effort and internal                                                                                                     and EV results
expertise to implement, but could lead to significant
improvement in the solvency ratio. These models are not                1       Agree objectives                                                                 COVID-19 – Once bitten, twice shy.
very common in South Africa, especially the life insurance
                                                                                                                                                                A pandemic’s impact on stress
space. Historically it has been very difficult to get approval                                                                                                  testing frameworks
                                                                                         2    Maintain ‘long-list’
for use of an internal model from the Prudential Authority.

Finally, the impact of new products and features should                                                  3      Prioritised ‘short-list’                        Optimising the life insurance
                                                                                                                                                                regulatory balance sheet
be fully understood before launch, including the impact
on diversification benefits of SCR components. In fact, by                                                                  4         Execution
launching products that target certain SCR components an
                                                                                                                                                                Artificial intelligence and
insurer can sell more policies without materially impacting                          Process                                                                    machine learning
                                                                                                                                     Control
its capital requirements, and thus improve Return on Equity.                Communication and Stakeholder
                                                                                                                                    Governance
                                                                                   Management

Ideas are cheap, execution is everything                                                                                                                        Using technology to combat
With so many capital optimisation tools available it is                                                                                                         insurance fraud
                                                                 A key aspect of such a framework is investigating various optimisation
far too easy for insurers to shoot from the hip, resulting
                                                                 options and documenting these options succinctly in a log or an “ideas
in capital optimisation becoming a series of ad hoc and
                                                                 hopper”. An ideas hopper would summarise key features of an optimisation                       Proactively managing conduct risk
sporadic decisions. This could result in sub-optimal
                                                                 option, its impact on key metrics, as well as barriers to implementation
outcomes and/or unintended consequences for other
                                                                 if any. The inclusion of barriers allows insurers to easily identify when
aspects of the business, which are costly to reverse after                                                                                                      Understanding a more complete
                                                                 previously unviable options become viable.
implementation. Truly effective capital optimisation, on the                                                                                                    IFRS 17 picture
other hand, entails embedding it throughout the business
by establishing a capital optimisation framework which has                        Maintain the ‘ideas hopper’

buy-in from senior management, clearly defined objectives,                                                                                                      IFRS 17: Controls and financial
appropriate controls, and well debated priorities and                             Capital    Earnings   Liquidity   Volatility Timescale Resource
                                                                                                                                                    Execution   reporting under the new standard
                                                                                                                                                       risk
processes that allow for efficient execution.
                                                                 Option 1          +ve         -ve        n/a         +ve       3 months   low         low

                                                                 Option 2
                                                                                                                                                                VAT: Closing the compliance gap
Embedding capital optimisation should reach into the heart
of an organisation by touching its culture and making capital    ...

optimisation a key factor in every business decision. Also,      ...
capital optimisation should not just focus on maintaining a                                                                                                                                   18
certain solvency ratio, but also on stability of such ratios.
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