The Impact of IFRS and Solvency II on Asset-Liability Management and Asset Management in Insurance Companies
A new study jointly produced by EDHEC-Risk Institute and the EDHEC Financial Analysis and Accounting Research Centre reveals the contradictions inherent in the current Solvency II and IFRS provisions for insurance companies. The report shows notably that the numerous provisions proposed by the IFRS are at odds with the good risk management practices put forward by Solvency II.
The profound changes in the risk management of insurance companies, brought about by the increasing complexity and variety of risks over the last two decades, have made it necessary to revise prudential regulations (Solvency II) and to adapt the international accounting standards (IFRS).
The objective of the new accounting standards is to offer a better view of all companies, particularly with regard to the risks they run. However, our study shows that the definition of these regulations and their application to insurance companies are often at odds with their initial objectives: those who adopt good asset management or asset-liability management (ALM) practices in order to reduce their exposure to risk are often heavily penalised. These standards result in additional volatility in pure accounting terms, the extent of which does not correspond to economic reality.
With regard to Solvency II, we feel that the latest CEIOPS proposal, contained in the QIS 21, is inapplicable as it stands due to the inadequacy of its risk calibration. While Solvency II highlights the issue of taking extreme risks into account and aims to create an incentive for companies to measure and manage these risks, this calibration is an incentive to engage more in opportunistic arbitrage than in the improvement of risk management. In an effort to demonstrate the inadequacy, and even contradictions, which one may find between certain IFRS definitions and Solvency II proposals on the one hand, and the aim to make insurance companies accountable for their risk management approaches on the other, EDHEC has published this major report. The first part of this report provides an analysis of the IFRS and the Solvency II provisions, in light of the asset management and ALM issues facing insurance companies. The second part examines state-of-the-art techniques in these areas, with particular focus on their suitability and relevance with regard to the requirements for insurance companies to better manage their risks. The third section goes on to provide details of the limits placed by the new IFRS environment on insurance companies in terms of asset management solutions in the presence of liabilities, thereby highlighting the additional volatility constraints on income statements and shareholders’ equity brought about by these new accounting standards.
The objectives of the IFRS and Solvency II require the implementation of more sophisticated risk management techniques
The first stage of the profound changes taking place in the risk management practices of insurance companies — phase I of the IFRS — has been operational since 2005 and for the moment only concerns companies that take savings from the general public. This is the phase that causes the least disruption, as it mainly involves the implementation of the ‘fair value’ principle for all assets, a practice that is already widely used by the financial markets. However, we will see that the secondary effects are far from negligible and that the volatility generated in income statements and/or shareholders’ equity is such that it will impose new constraints on insurance companies, particularly because of the need to implement advanced asset management and ALM techniques.
Phase II of the IFRS is expected for 2008 and will extend the integration of risk to liabilities. Provisioning calculations or even approaches and the explicit inclusion of options and guarantees will then have to be completely revised; this should bring about new constraints for insurance companies, which appear to be showing greater levels of interest than in phase I2.
Finally, the third phase — Solvency II — which, unlike the IFRS, will concern all European insurance companies, is expected by around 2010. Our study shows, however, that the impact on asset management and ALM, and in particular the questions related to the integration of risk, will be visible as soon as the broad outline is given for the standard capital requirement formula (around 2007). Solvency II reinforces requirements for the evaluation and management of risk, the notion of which has been widened not only in terms of its scope (financial market risk, ALM, lending, underwriting and operational risk) but also its modelling (distribution law, correlation, study of extreme risks), evaluation and risk management (derivatives, reinsurance, securitisation and diversification). EDHEC believes that while the IFRS tend to add additional and unfortunate financial management constraints, Solvency II may bring about more structural changes to asset management and ALM.
Now, a major step in the development of Solvency II has just been completed with the publication of the QIS 2, which aims to use the responses given by insurance professionals to provide a quantitative estimate of the global impact of the new solvency system. On this particular point, EDHEC believes that while the initial proposals respond quite well to the required balance between sensitivity to the primary risk factors faced by insurance companies, on the one hand, and the complexity and soundness of the different approaches tested, on the other, the calibration of the proposed standard formula’s parameters is totally inadequate in light of the economic capital requirements it engenders. These requirements reach a level that is between two and four times that provided for by Solvency I, depending on the associated risks and activities, while the regulatory authorities consider insurance companies today to be well capitalised. It would appear that the CEIOPS suggests measuring risk using a VaR of 99.5%, but that the calibration of risk model factors has no bearing on this figure. This report therefore highlights certain errors in relation to the treatment of the volatility of certain risk factors in various areas:
- In general insurance, the historical volatility of the combined ratio does not appear to be an appropriate measure of risk, as it supplants any optimal management between the technical result (insurance operations) and financial result. It therefore constitutes a hindrance to the implementation of techniques for managing risks which in order to be hedged involve a volatility that will require additional capital.
- Stress scenarios require excessive capital needs, in particular volatility of 40% for stock markets over one year, which, as in the case of life insurance companies in the US, could completely discourage the holding of stocks. When the stress scenarios are compared in terms of historical data, it is also interesting to note that the volatility figure used for stocks has no bearing on that used for the yield curve.
- The treatment of options and the explicit absence of any consideration for dynamic asset allocation or hedging strategies are at odds with the objectives of Solvency II3.
To conclude our analysis of the new prudential and accounting provisions, we believe that the ‘financialisation’ and sophistication of asset management and ALM techniques over the last few years should continue to grow. It should lead to an optimisation of the management of economic capital, through better asset-liability adequacy and more dynamic management of the differentials in duration and convexity between the assets and liabilities (more structured and sophisticated interest rate products, caps, floors, swaptions, CDS, etc.). It will also result in a transfer of some of the risks of mass insurance (securitisation of automobile and residential portfolios) and large risks (natural catastrophe, mortality and life expectancy bonds) towards the financial markets. Finally, it will privilege better management of the extreme risks of financial assets, as well as the optimisation of diversification, even though it is still early for evaluating the degree to which it could boost and broaden asset allocation towards alternative investments, private equity, structured credits, etc.; this will depend on how those assets are treated in the standard formula, which we hope will be different to that proposed by the QIS 2.
To respond to these issues, part II of the EDHEC study provides a look at the state-of-the-art asset management techniques in the presence of insurance liabilities, as developed over the last thirty years, both in the academic and professional spheres. In particular, we show how techniques for dynamic asset management in the presence of such liabilities can be implemented using different supports (long-term bonds, derivatives, mutual funds, structures or a combination of these supports), with the dual objective4 of managing liability risk exposure (‘liability-matching portfolio’) and effectively managing asset performance. However, part III shows that depending on the strategy used, the accounting methods for treating the variation of the ‘fair value’ of each asset, as well as hedging operations, lead to greater or lesser volatility in the income statement and in shareholders’ equity and therefore result in an accounting bias in terms of strategic financial choices that we feel is completely at odds with the reality of economic volatility.
The IFRS bring about an additional volatility constraint (which clouds actual risk exposure) both with regard to hedging solutions for liability risk…
The hedging of liability risks can generally be done using three strategies: by constituting a bond portfolio, by using derivatives or by a combination of these two approaches.
The use of a bond portfolio to hedge liability risks immediately involves several challenges in purely financial terms: one must find bonds with appropriate maturity in relation to that of the liabilities, manage the hidden options in the insurance liabilities (which is almost impossible with bonds) and endure insufficient financial profitability. From now on, the accounting treatment of bonds and insurance contract liabilities where the risk is placed on the insurance company will generate volatility in the income statement (particularly with regard to immunisation techniques that require dynamic management of the bond portfolio) or in shareholders' equity (and therefore in the solvency margin). While much of the bond portfolio is acquired with a view to securing returns paid to policyholders, as well as insurance liabilities, and as a result is generally held until maturity, the IFRS demand that the variations in quarterly or half-yearly unrealised bond profits (classified as AFS) be included in shareholders’ equity, while the corresponding entry in liabilities remains part of historical costs. This volatility is completely artificial and in no way reflects either the value of an insurance company (dissymmetry in the treatment of the impact of an interest rate variation on assets and on liabilities) or the actual risk being run by an insurance company. The IFRS thereby reduce the financial management of liability risk hedging over several years, or even decades, to a scenario whereby assets are immediately liquidated (with no adjustment of liabilities).
Mindful of the excessive nature of this approach, the IASB suggested the implementation of a new asset category during the transition phase — HTM (held-to-maturity) — so as to correct this accounting mismatch (assets being valued at historical cost as with insurance liabilities). However, the accounting consequences for a HTM bond that is sold are so harsh as to have effectively dissuaded most insurance companies from using this asset category5 (in fact, some have no asset classified as HTM).
The second solution for hedging liabilities, involving the use of derivative instruments (swaps, swaptions, etc.) should allow the establishment of improved financial management solutions by allowing customisation through on the one hand the implementation of better cash flow matching and, on the other, the management of non-linear risks that are included in the liabilities’ hidden options. However, the appropriate treatment of derivatives requires either an overhaul of the IFRS or profound changes in the culture of financial markets. Today, the variation in value of the hedge performed using derivatives is fully included in the income statement, while, as we have seen, its corresponding entry, which is constituted by the change in value of the liabilities, has no accounting status.
This mismatch can result in such volatility in the income statement that the IASB established exceedingly cumbersome concepts referred to as ‘hedge accounting’, ‘shadow accounting’ and the ‘fair value option’. Again, however, the conditions required for the application of hedge accounting are so demanding (in particular proof of the effectiveness of the hedge) that insurance companies have made little use of it. The second problem for which, unlike in the banking world, there is no favourable and simple solution6 is that of macro hedging. In practice, the last half-yearly publications of 2006 have shown that these two issues alone are sufficient to bring about very high volatility in the income statement, a volatility which is not always understood by the financial markets, which in such cases do not hesitate to penalise the stocks of the company concerned.
The third solution for hedging liabilities is the creation of a bond portfolio that is complemented by derivative instruments (fixed-to-floated swaps, forward-start swaps) which, depending on the strategy used, make it possible to shorten or extend the duration of the bond portfolio. From an accounting point of view, this solution naturally combines the two mismatches mentioned for each of the last two strategies.
In practice, insurance companies maintain their mixed (bond-derivative) strategy at the cost of major efforts in communication (not without certain incidents, as seen with the last half-yearly publications): the financial community is not always inclined to delve into the depths of derivatives accounting and prefers to penalise those companies whose high volatility is accompanied by an explanation that is too complex or too opaque.
… and effective performance management
As developed in our analysis of state-of-the-art asset management techniques, the second component of good financial management practices in an insurance company, based on the separation theorem, is the search for high-quality performance from the asset portfolio. EDHEC suggest the use of the core-satellite approach to manage performance. The issue of optimising management and defining the asset risks is tackled in the core portfolio. A company can go about this in two ways: by employing risk diversification techniques to determine the optimal asset allocation decisions, on the one hand, and, on the other, by employing insurance portfolio techniques whereby risk hedging is performed using derivative instruments or, equally, dynamic asset allocation strategies, generating nonlinear returns (convex payoffs) that will ensure tight control of the risk of loss or underperformance.
The first strategy, consisting of risk management on the basis of an optimal asset allocation decision (for example, where a certain percentage of stocks and bonds is defined as the optimal reference), requires frequent transactions as prices fluctuate to ensure that the asset portfolio is constantly adjusted so as to match the reference percentages at least7. Using simulations, we demonstrate the superiority of this strategy when compared to a buy-and-hold strategy, in terms of its capacity to reduce the volatility and/or the (C)VaR (extreme risks) of the portfolio performance. Generally, this strategy used to be implemented by mutual funds, which had the advantage of not being consolidated, meaning they caused no volatility in the income statement. Now, with the IFRS, major mutual fund holdings are usually consolidated. Furthermore, variations in minority mutual fund shareholdings are considered to be variations in liabilities and are recognised in the income statement. Such accounting constraints penalise this optimal allocation strategy, which is particularly effective in financial terms, bring about high volatility in the income statement and/or shareholders’ equity and necessarily impact heavily on the solvency margin.
The second risk management strategy is to consider optimal hedging with a view to generating non-linear returns as a protection against the risk of losses or underperformance. This strategy can be put in place using derivative instruments (an out-of-the-money put option, for example), structured products or even a dynamic asset allocation strategy (for which we have already mentioned the associated accounting problems). From an IFRS standpoint, the harsh constraint in derivatives handling of having to demonstrate and document the effectiveness of the hedge means that insurance companies must endure high volatility in the income statement, linked to the variation in the derivatives position with no corresponding variation in the underlyings. With regard to the treatment of structured products, the IFRS consider them as hybrid instruments made up of a host contract (the underlying) and one or more derivatives. Generally, the accounting treatment of these two components is done separately, which brings us back to the volatility and mismatch problems that are specific to derivatives.
Concrete numeric example of accounting volatility in risk management based on optimal asset allocation
Various numeric simulations were performed throughout this study to support our findings. One of the simplest, but no less informative, is a comparison between the accounting results of a buy-and-hold strategy, which consists of a direct investment in the global DJ Euro Stoxx index where the position then remains unchanged, and those of a strategy designed to determine the optimal allocation of the different sector indices that make up the DJ Euro Stoxx (with dynamic readjustments making it possible to return at regular intervals to the defined optimal allocation level) so as to minimise the portfolio’s extreme risk (CVaR) with no expected constraint on profitability. This simulation was performed for a period of 13 years (January 1993 to December 2005).
As shown in the table below, dynamic management (PF Min CVaR) makes it possible to considerably reduce volatility and extreme risks in relation to the buy-and-hold strategy, i.e. where one invests in the DJ Euro Stoxx and waits 13 years without making a single transaction.
However, the accounting treatment under the IFRS favours the buy-and-hold strategy, because it is possible to classify stock portfolios as AFS (Available For Sale). Quarterly or half-yearly variation in the market value8 of the DJ Euro Stoxx index will have no impact on the income statement but will only affect shareholders’ equity.
By contrast, with the dynamic asset allocation strategy, which makes it possible to reduce financial volatility and extreme risks, the quarterly and half-yearly variations in the market value of the portfolio made up of stocks from the DJ Euro Stoxx sector indices will be directly visible in the income statement. The volatility of the income statement under this management approach will be almost 17% (as against 0% under the buy-and-hold strategy, even though the latter results in greater financial volatility), with a maximum drawdown of 48% (as against 0% under the buy-and-hold strategy, which in reality results in a maximum drawdown of 63%). Finally, it is worth mentioning that this accounting impact on the income statement is in no way a reflection of shareholders’ equity (after integrating the results), as this equity varies as shown in the above table, with greater volatility, maximum drawdown, VaR and CVaR under the buy-and-hold strategy.
The IFRS represent a harsh restriction on good financial management practices in European insurance companies
With regard to the application of the IFRS to insurance companies, EDHEC believes that neither the method chosen (two-phase approach) nor the adaptational decisions made are satisfactory; above all, they are at odds with the intentions of the body for international accounting standards:
- While the concept of fair value is at the heart of the IFRS structure, and in view of the importance of defining a consistent representation of a company’s financial situation, the exclusion, on the one hand, of an insurance company’s liabilities on the pretext that they are too difficult to evaluate because they are not traded on the market is not consistent with the decision, on the other, to treat derivatives and structured products at fair value, even though they may be just as untradable and difficult to value. This inconsistency is one of the principal sources of volatility in the income statements of insurance companies. At a time when prudential regulators — mainly through Solvency II — and the body for international accounting standards (via the LAT) are promoting internal models for the evaluation of asset-liability adequacy, the idea of excluding the majority of an insurance company’s liabilities from an actuarial analysis appears to be contradictory.
- EDHEC feels that the implementation of the IFRS undermines the very notion that financial accounts are a reflection of the value and risks of an insurance company. They impose constraints in terms of the volatility of the income statement and shareholders’ equity that appear to be completely at odds with the objective of the IFRS to make insurance companies accountable for the management of their risks. While Solvency II encourages insurance companies to improve the measurement of the extreme risks of their assets and liabilities so as to better manage them, the accounting result of good practice in the management of extreme risks is most often a financial situation that appears to be more risky than if the insurance company had done nothing at all.
- Finally, a more conceptual and fundamental contradiction comes of this analysis. While insurance companies strive to improve the management of their long-term risks (liabilities often have a lifetime of several decades), this management approach is handled in accounting terms by an analysis of the quarterly or half-yearly variation in the market value (which generally reflects short-term risk premia) of assets, liabilities and their associated hedges. Such an approach leads to insurance companies being considered as liquidating their assets and liabilities on an ongoing basis, whereas, in fact, they employ long-term management techniques to protect their liabilities, an approach which justifies a policy of allocating to risky assets that are partly non-liquid.
It is likely that the failure to sufficiently distinguish between the role of accounting and that of financial analysis, a phenomenon that has been heightened in recent years by the prominence in accounting of the true and fair view principle, has led to the inconsistencies highlighted in this study.
Instead of simply recording a company’s operations and possibly providing a discounted value of its worth, the IFRS, by also claiming to provide a consistent and universal framework for the analysis of a company’s value and its risks, reveal an ambition that is in our opinion disproportionate and dangerous.
Conclusion: From a Fair Value-based to an ALM-based approach to the evaluation of risks and solvency of insurance companies
While nobody would dispute the value of having a real view of the impact of the primary financial and actuarial risk factors on an insurance company’s accounts, we feel it is regrettable not only for the insurance sector but for the economy as a whole that the fair value of assets and liabilities be a basis for analysing the financial soundness and solvency of insurance companies. For most of their activities, insurance companies have long-term or even very long-term liabilities that in turn justify long-term allocation. Measuring their solvency on the basis of short-term values is not only incompatible with the need for investment in assets that, while risky, yield very positive average long-term returns, but also means that any genuine asset-liability management is an illusion, even though the regulators actually hope to promote ALM.
Similarly, EDHEC feels it is contradictory to favour the implementation of internal risk analysis models within the scope of the new prudential provisions (Solvency II), while at the same time basing the ultimate assessment of a company’s solvency on ratios taken from accounting values.
EDHEC believes that the only basis for analysts and regulatory authorities to assess the financial soundness and durability of an insurance company should be an analysis of the consistency between the liability risks and asset risks and an evaluation of the consistency and robustness of the asset-liability management models used.
This ALM-based approach to financial analysis presupposes that there is precise documentation of the company’s ALM allocation policy and the robustness tests that have been performed. This information should serve to support the LAT tests, which are planned for the transitory phase of the application of the IFRS to the insurance sector.
EDHEC believes that neither the solutions put forward by the IASB to circumvent or diminish the short-term nature of the IFRS nor the transitory provisions are satisfactory. They ultimately render accounts more complex, arbitrary and unclear, and they increase accounting risk without offering any real solutions to facilitate good financial ALM management practices in insurance companies. On the contrary, we have shown in this study that good ALM, risk and asset management practices remain heavily penalised by the accounting provisions.
EDHEC hopes that European regulators and financial analysts will take full stock of the consequences of the new ‘financial’ approach to prudential regulation, Solvency II. This means abandoning all references to external and accounting approaches to solvency evaluation in favour of an evaluation of risk measurement and risk management procedures, internal models and the choice of risk parameters that underpin asset allocation and liability management decisions. In light of this, EDHEC regrets the approach chosen by the CEIOPS, as put forward in the QIS 2. Not only does it not correspond to the state of the art in global and optimal management of risk and insurance capital, but furthermore, and more importantly, in cases such as the treatment of options or the explicit absence of consideration for dynamic allocation strategies, it is at odds with the objective set out by Solvency II to control financial risks.
In conclusion, EDHEC feels that the particular nature of long-term investors’ liabilities, be they insurance companies or pension funds, is such that both regulators and financial analysts need to attach greater importance to the ongoing concern principle (which is an accounting principle), rather than suppose that the notion of fair value will transcend the whole of the accounting doctrine. It is only by finding this necessary balance that the invaluable contribution of the IFRS to the transparency of risk, particularly market risk, will not be undermined by the legitimate aim of allowing institutional investors, and insurance companies in particular, to continue to operate as long-term investors and perform their invaluable role of constant liquidity providers for the market and the economy at large.
This study was sponsored by AXA Investment Managers.
1 Quantitative Impact Studies 2, produced by the CEIOPS (Committee of European Insurance and Occupational Pensions Supervisors).
2 It should be noted that this problem is already raised in phase I by the LAT (Liability Adequacy Test) on the one hand, and by the development of European Embedded Value on the other.
3 "No consideration should be given to management actions or active trading strategies." (QIS 2)
4 The authors of the study present a general analysis of the separation theorem from modern portfolio theory in the context of asset-liability management, as formalised by L. Martellini in ‘The Theory of Liability Driven Investments’, Life & Pensions Magazine, 2, 5, pp.39–44, 2006. This general analysis places LDI solutions in an innovative and consistent theoretical context.
5 More generally, the HTM category makes both dynamic management of interest rate risk and active management of credit risk impossible, which in turn means that the bond portfolio cannot be well managed in financial terms.
6 The report provides an analysis of the limits and inadequacy of the shadow accounting solution proposed in phase I of the implementation of the IFRS.
7 Fixed mix strategy. One can also adjust in line with variations in the risk parameters, leading to rebalancing in order to preserve optimal allocation with respect to the new estimated values of these parameters.
8 According to the company’s chosen frequency for accounting publications.
"The Impact of IFRS and Solvency II on Asset-Liability Management and Asset Management in Insurance Companies"; Noël Amenc, Lionel Martellini, Philippe Foulquier, Samuel Sender; November 2006
"QIS 2: Modelling that is at odds with the prudential objectives of Solvency II"; Philippe Foulquier, Samuel Sender; 2006
"CP20: Significant improvements in the Solvency II framework but grave incoherencies remain: EDHEC response to Consultation Paper n° 20"; Philippe Foulquier, Samuel Sender; January 2007
"QIS3: meaningful progress towards the implementation of Solvency II, but ground remains to be covered"