In the second episode of a two-part series, FCIAs Sati MacLean and Houston Cheng return to talk about financial condition testing, key performance indicators and other aspects of IFRS 17 that P&C actuaries need to think about before the end of the year.
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Fievoli: Welcome to Seeing Beyond Risk, a podcast series from the Canadian Institute of Actuaries. I’m Chris Fievoli, Staff Actuary, Communications and Public Affairs, at the CIA.
This is the second in a series of two podcasts addressing IFRS 17 implementation for P&C actuaries. Last time, we talked about the Transition Readiness Test and the role of the Appointed Actuary, and today we’re going to dive into items such as financial condition testing and key performance indicators.
Again, we’re joined by CIA members Sati MacLean and Houston Cheng.
Thank you once more for joining us on the podcast.
MacLean: Thanks, Chris. It’s great to be back.
Cheng: Same here. Thanks for the invite.
Fievoli: Well, let’s start off talking about FCT – financial condition testing. What changes are happening for IFRS 17?
Cheng: There’s been a quite a bit of work, and we kind of started out earlier this summer knowing that it would be a lot of work, but we’ve spent a couple of months now updating our current FCT model.
And we realized there are a few things – some are hard, some are easier and other things are just, we’ll have to do some shortcuts on them, at least for now, right?
As an example, one of the hardest things to model LRC is just that it’s much more granular now. There are a lot more pieces and floating parts in there compared to in the past. Where UPR is fairly straightforward, the LRC is much more, I wouldn’t say onerous, but it’s a lot more work to put that together.
But on the onerous portion, there’s especially more work on the onerous contracts, if they are onerous, and a similar comparison to an IFRS 4 onerous contract would be premium liabilities.
It was quite a bit more straightforward to model that, whereas now, with onerous contract, we’ve had to put a lot of thinking behind it and how to model it to a level of detail that’s sufficient for the FCT but not necessarily at the same level of detail that’s for financial reporting.
And that’s especially true if we are allowing for multi-year contracts. So some of these things we’ve either currently scoped out or have a reduced capacity for.
Another area that we’ve had to put a bit quite a bit more work on this portion of modelling is the reinsurance. So the view of the reinsurance is quite different under IFRS 17 versus 4.
So we used to model on a gross and net basis, whereas now we’ve switched our model to gross and ceded just because of the enhanced focus on reinsurance contracts as standalone contracts.
And I would say the last piece on this is the work on the LIC. Even though most of the discounting PfAD can be converted to discounting and risk adjustment is fairly straightforward, or you can make it fairly straightforward, there is some work required to come up with the insurance finance expense and insurance service expense split. Even though, from my perspective, the split doesn’t really impact capital, it is a big portion of IFRS 17.
So we have put some thinking and resources around splitting the incurred claim to finance expense and service expense, but that does create quite a bit more work.
I’ll leave it at that and open for some comments from you too, Sati.
MacLean: Yeah, Houston, it’s quite interesting. As we are racing towards January 1, 2023, in terms of IFRS 17 implementation, I think a lot of organizations have been concentrating, as we said last time in the previous podcast, on getting over that finish line.
And the question that does come to my mind is whether there are sufficient resources, so that IFRS 17 FCT is ready. A lot of companies have worked through their transition figures.
We know that there will be some impacts on the Minimum Capital Test that will be different under IFRS 4 and IFRS 17, and really, the FCT testing will need to be calibrated to be able to pick up from that different starting point.
Actuaries, I think – the ones who are doing the FCT testing in the second half the year – are really going to have a view as to what that impact is in terms of internal targets going into 2023, when IFRS 17 will be live.
It’s quite interesting. Houston, you talked about the level of detail that’s required, and its being a lot more detail than the IFRS 17 in terms of FCT modelling versus IFRS 4.
IFRS 17 – personally, I’ve found that the devil really is in the detail. Many companies are building out the FCT models, they’re having to think about how to adapt their current view of the balance sheet to be able to incorporate IFRS 17 policy decisions and the impact on the presentation of the financials.
OSFI pro formas need to be incorporated into FCT models as well. And some of the impacts, even if on transition, the MCT for a company doesn’t change very much, maybe when running some of these stress scenarios that are run in the FCT, they do see that there’s a different view of the stress under an IFRS 17 view of the financials versus IFRS 4.
So, in principle, the stress scenarios themselves may not be very different, but the presentation in the financials could look different.
I think a lot of actuaries are going to have to work through understanding where the most significant differences are. We’re not going to be able to solve everything in a day, and especially to get that early view of IFRS 17 when the FCT models are still work in progress, having a view of where some of those key differences are will be important.
And the other things for me that jumped out with FCT: Will any additional tests be required? Discount rates jumping to mind for me at the moment, in particular given the current environment, but that would be the case under IFRS 4 as well as IFRS 17.
But for instance, for IFRS 17, is there a divergence in terms of the impact of the discount rate, given that the liabilities and the assets and the return on assets and the discounting for liabilities are decoupled in some way? They are decoupled in terms of how you’re meant to do the assessment of the discount rate for assessing your liabilities.
So, are there any additional stress scenarios that would need to be run to test that impact on the MCT? And risk adjustments – that’s something where the current risk adjustments could be quite different to PfADs, and are there any additional tests that will be needed to sort of kick the tires and terms of a company’s financial robustness using an IFRS 17 metric around risk adjustment?
And then lastly, my mind goes to the board, and what do they need to know? And I think every company’s board is going to be at a different point in terms of their journey with IFRS 17 financials, and FCT, when you lay that on top of boards trying to get familiar with the new geography of IFRS 17 financials, means that there may be some additional education that’s needed, and especially if any stress scenarios result in a different impact on the MCT, the Minimum Capital Test, than is currently the case, then that’s going to need some communication and explanation.
And lastly, I’ll just say, IFRS 17, as we go into 2023, we know it will evolve and hopefully it’s an evolution as opposed to a pivot. I know we like to use the word pivot a lot these days, but hopefully we’re not going to pivot in IFRS 17.
But whatever happens, whether it’s an evolution or a pivot, FCT, and the actuaries running FCT and communicating FCT results, they’ll need to be prepared to evolve with that.
Cheng: I agree with you, Sati. I think I do see it as an evolution on the modelling.
We are taking this opportunity to enhance some of the existing pieces within our model. And you brought up a lot of great points, in terms of the actual modelling and the analysis within the testing and communication between the Appointed Actuary and the board and management and understanding the difference between 4 and 17.
So good points in terms of needing to come up with potentially different scenarios, because some of the scenarios may interact differently just because of the breakage of the discount versus the investment yield. So, I think there are a lot of areas where you definitely touched on and made some good points there.
Fievoli: Let’s turn to key performance indicators. We’re likely to see some changes under IFRS 17. What are these going to look like?
MacLean: When I think of KPIs for insurance, there are some obvious ones that come to mind.
Firstly, how much money or how much business are we writing – what is our revenue? And then secondly, how much money are we making, i.e., is it profitable?
And then there often tends to be a focus as well around our expenses: how much does it cost for us to generate that business and run our business? And often the KPIs are used to assess internally looking at different products.
Are certain products more successful and more profitable than others? And then also being able to compare against other industries and other players within the industry and the market. So, under IFRS 17, what’s changing? Premiums.
Instead of having written premium and earned premium as a metric that we’ll be able to look at in the financials, we’re going to have insurance revenue, which is comparable to earned premium.
And for a lot of insurers, I don’t think that will necessarily look very different to what they have today. So are we going to be able to get a measure of revenue? I think so, yes.
Reinsurers could see a difference due to the way ceded commissions will be treated, i.e., that they won’t be shown in premium. Rather, the premiums will be net of any ceding commissions that are paid directly to a cedent. So it will be quite interesting to see what the reinsurance industry looks like.
But overall, we should be able to get a view of premium and revenue. If we look at where that premium goes, we obviously have to pay losses.
And under IFRS 17, the discount impacts and the risk adjustment and the way they flow through the financials could mean that we see a different level of losses, incurred losses going through the income statements.
So companies’ policy decisions – I’ve mentioned IFRS 17 policy decisions before, but the policy decisions will really dictate how some of those losses get recognized through the financial statements, how the discounting is being done and as well as if an insurer has decided to use the other comprehensive income to present the change in discount rates.
Comparing two insurers that have a different policy there – even though you’ve got the same business, you could see a different level of losses coming through.
And also, if an insurer has something like a loss component that they have to recognize, the way that flows through the financials into the insurance expenses, and thereby flows into the income, could look quite different to what we see under IFRS 4.
But one of the big measures for P&C that we look at when it comes to profitability is COR – the combined operating ratio. Effectively, it’s a ratio of how much you have earned in terms of premiums less your losses and expenses.
And a COR that’s less than 100 indicates profitability. A COR that’s more than 100 would need a bit of digging, because there could be some reasons why a COR more than 100 is OK. But typically, the gold standard is a COR less than 100, and in some cases quite a lot less than 100, to indicate you’re making enough profits.
So what’s going to happen with the combined operating ratio? And I think this is going to be a really interesting question for us in Canada as well as globally.
How is discounting going to be brought into that? Currently, a lot of companies look at undiscounted combined operating ratio measures and IFRS 17 discounting is going to be embedded in there.
How will a component such as the loss component be considered? You could have a combined operating ratio in an IFRS 17 world that looks very profitable, but a company that’s posting a lot of liability under loss components, what does that mean?
So, I think there are there will be KPIs that will be impacted, and we’re going to be on a journey to understand and decipher what a IFRS 17 world means, I think, before we can then come up with what some longer-term metrics or normalized metrics would look like.
And Houston, what do you think?
Cheng: I’m seeing a theme here, Sati. So we talked about evolution and FCT, and I think this is a bit of an evolution as well. And maybe a step jump and then continuing evolvement.
Your point on the integration of discounting and KPIs – I’ve definitely been hearing a lot of companies ask that question.
So, in terms of internal management, broker compensation, oftentimes discounting and, to some extent, maybe even PfADs have not been included internally. But some companies, and this might differ depending on the type of company, be it mutual or publicly held or whatnot, so different insurers do have different needs.
So some companies are thinking, well, if my financials are under IFRS 17, maybe we ought to manage them internally as well on that basis. So, questions around granularity: How detailed do we model? And obviously, when we talk about discounting and then risk adjustment, how do we integrate some of these into our KPIs?
And then on the granularity, some of the questions around – the same as the FCT – do we do we care to split this over finance expense? Is that something that can be measured and tracked?
And I think building on top of what you talked about, Sati, with the COR, is that going to now loop back more so into the onerous contract consideration, if it wasn’t specifically tracked for reserving purposes or valuation purposes? So these are things that I think will continue to evolve. Other areas – I wouldn’t say this is typically a KPI, though it does measure capital, so internal targets will likely need to be revisited, right?
So, some companies already did revisit their internal capital and internal target this year, based on the various OSFI quizzes and internal measurements.
I think the message here is that the measurement sticks changed. MCT calculation, as much as – on an industry-wide basis, after various adjustments that OSFI has made – it’s largely neutral for different companies, I think there are some impacts either way, plus or minuses.
So the fact that the measurement stick has changed, it certainly merits a look at the internal target. That’s something that, Sati, you and I talked about earlier this week as to, you know, what companies need to be prepared for, and what’s the timing of that preparation? Do we need to prepare this for Q1, or is it something that we do in conjunction with FCT next year?
So we’re certainly in a bit of a transition here. It will be interesting to see how much effort and resources actuaries and companies can put into this type of work.
I think the last point I’ll make on the KPIs, and it’s again the underlying theme here, is just trying to bridge the gap between the IFRS 4 and 17. What does it mean changing from 4 to 17?
And Sati, you certainly went into a lot of detail as to the premiums and claims and things along those lines on what’s changed.
I think, overall, that’s really the name of the game. There are things that companies, regulators, management – they’re used to looking at under IFRS 4, and now they either have been eliminated or changed or modified under 17.
So, it’s really taking that that lens and either looking across the industry to see what others are doing, or maybe doing some digging internally and just seeing what matters most for you as a company.
MacLean: It was quite interesting – as you were going through the KPIs, and also when I did this, I very much looked at it from a perspective of IFRS 17 versus IFRS 4.
The other interesting aspects will be whether other industries – there are KPIs that are used by other industries that the insurance industry currently doesn’t use that actually become part of the way we describe the financials.
Certainly it should be possible to compare life and P&C companies, insurance companies, a lot more, but are there going to be better comparables with banks?
Are insurance companies going to be compared with the Amazons and the Apples and the Nikes of the world? It would be quite interesting to see if there are additional metrics that get added to how we describe the financials of an insurance company.
Fievoli: Well, certainly this is a new world for everyone, and I’m just wondering, for people who aren’t as close to the action – so, for example, actuaries who are doing valuation roles – what are the major things they should look out for? How will this impact them even if they’re not directly involved in valuation and financial reporting?
Cheng: I think if, as an actuary, you are a user of financial statements in whatever role you’re in, it’s highlighting the differences again and the major theme of needing to know some of the differences between IFRS 4 and 17.
So I think one of those key things is that discounting is no longer linked with assets, right? So, in terms of your investment policies and strategy and how you invest, that may be different.
And just the fact that there have been some changes in the MCT calculation, and along with the actual delinking of the yields between assets and liabilities on the income statement, I think that that’s one area where it could impact the different areas within the company.
For example, in pricing, how do you consider discount rate now? In the past, companies may have used a similar discount rate as the valuation, but now does that make sense?
Is it time to go back to the drawing board and see what discount rate makes sense for pricing?
In Canada, I think a lot of companies and actuaries were used to – and again, these are actuaries not in the context of valuation – but actuaries are familiar with the concept of PfAD, in terms of the PfAD methodology and how you come up with it. The three main components of the PfAD.
So now we’re moving into an area where it’s no longer familiar. There’s no comparability that we have across the industry. Where in the past if you take any line of business, auto or liability, you would get to a pretty close margin across the industry, just because of the longevity that we’ve had with this approach.
We do know that, short tail versus long tail and data availability and whatnot, actuaries have been more or less in the driver’s seat of determining that and with comparability.
Now, post transition, we don’t have that anymore, and I think at least for the first few years, where companies have been in their little boardrooms or huddle rooms or virtually talking about this, now we’re going to start seeing some public statements, in terms of the file statements with the regulators, and we can start to compare across the industry on how companies are approaching the risk adjustment. You might start to get some alignment.
And that depends on, I think, the approach that the companies have decided on, and you might have differences between domestically held versus foreign-held companies, where foreign companies will have some sort of element from global and from headquarters in terms of how they set the risk adjustment, whereas for Canadian-held companies, it will be different.
So, I think this is one area where, if you’re new IFRS 17 or you’re not in the valuation process, it will take some learning and understanding that there will be differences between companies.
Another area where, if you’re not a valuation actuary, it’s really just understanding, again, and reconciling the differences between 4 and 17.
So one example might be if you’re used to looking at loss ratios within an income statement, this is technically not there anymore. What do you do? And it will take some time to reorient yourself on those things.
MacLean: Yeah, Houston, it’s quite interesting – in terms of reorientation, I think fundamentally, when I look at it, IFRS 17 is an accounting standard. It’s an assessment of liability at two points in time.
Where the income statement explaining or showing what happens in between the fundamentals are the same, but the geography of the income statement and the balance sheet are quite different in some places.
And if there’s any advice I’d have for anyone who’s not familiar with IFRS 17 and thinking about getting themselves familiar, it’s to get familiar with the new terminology. And I think that that will go a long way.
I certainly find myself translating back from IFRS 17 into IFRS 4, which feels a lot more familiar and understandable, and then going back to IFRS 17 to then go, OK, this is this is what the new world looks like.
And actuaries, we sometimes get accused of going into the detail a bit too much and potential paralysis by analysis, and I think that there’s a risk as IFRS 17 results start to become available that we’re going to have in some ways a lot more information and in some ways a lot less information, and we’re going to have to make sense of it.
And IFRS 17, I think, is going to feel weird, and there’s going to be a lot of new information to digest and make sense of. It will take some time before we get to a steady state and understand what the IFRS 17 results at an industry level look like, as well as where individual players lie.
But you know, regardless of whether you’re a valuation actuary or a capital actuary or a pricing actuary, having a fundamental understanding of where the industry sits, if there’s a product you’re designing, what does it look like when you when you run it through the financials?
Does it still look quite so profitable, or not, or is it as profitable as you need it to be to be able to compete in the market?
Understanding what’s happening at the industry level, what the financials look like and how your company or your product could compare is, I think, just a fundamental of one of the roles actuaries play. We look at the financials, we look at the numbers and we help companies understand what the impacts and the implications are.
So in terms of why this is important for all actuaries, not just valuation actuaries, the IFRS 17, as I said, it describes the financials of an insurance company, and where insurers are competing for capital against other industries and insurers, the financials provide a view of how one company measures up against another.
Obviously, the financial view isn’t everything. There are other metrics that organizations are measured on and they track, ESG being something that’s very hotly debated and tracked and discussed these days. But the financials are key to describing how profitable or not an insurance company is.
And I think as actuaries, we’re familiar with numbers, and we’re well placed to help senior management and others in the organization understand how to read the numbers. Whether you’re working in a corporate actuarial role or capital or pricing, our familiarity and our understanding of how insurance company financials are pulled together and what they mean I consider to be a fundamental actuarial skill, and we need to be able to do it in an IFRS 17 world.
And lastly, just to add to something that Houston said in terms of different jurisdictions and different countries adopting IFRS 17, I think we must remember it is an almost global standard that’s intended to bring comparability within the insurance industry, but it’s not universal. Famously, the US isn’t going to be adopting IFRS 17.
And we talked about how the devil is in the detail, but when you get into the detail of it, it may not be as easy to compare one company to the next, depending on the accounting policy decisions that they’ve made.
So understanding what some of the key metrics are, or the key decisions are, that companies could make and how they could affect the view of the financials, even if you are not the one doing the valuation, I think is going to be really important.
Fievoli: I know you had some thoughts to share about newer actuaries and why it would be important for them to get involved with IFRS 17. So, if we could talk about that, that’d be great.
MacLean: I think, as I mentioned, understanding the financials and being able to explain the financials is a really important, fundamental actuarial skill that enables us to assess how well an insurance company is doing, make peer comparisons and get a glimpse into potential headwinds that a company or a product could be facing.
I think for a newer actuary coming into the profession and thinking about where they would want to go or get exposure and experience, currently IFRS 17 is the biggest accounting change to hit the industry in a very long time.
IFRS 17 is new to a lot of people, and newer actuaries aren’t limited in their ability to learn and apply IFRS 17 and engage in the dialogue early on, and that isn’t necessarily always the case in more well-established areas. I think at the moment, there’s a steep learning curve for everyone, and newer actuaries shouldn’t be put off by the fact that maybe they don’t know as much.
I think this is the case for a lot of people. I think it’s a real opportunity for actuaries to come in and also help others in the organization understand IFRS 17.
Cheng: That’s an interesting question, Chris. We talked about getting close to the finish line.
In various prior settings, either at the AA seminar or even, I think, at act22 this year, we talked about how this is the year – we’re six months, three months, now two months away from the 11/20/23 time frame.
But I think there are going to be a lot of companies and a lot of processes that will still need to be finalized. I saw companies where they’re really just getting over the line – I don’t know if it’s a jog or a hump or a bit of, we’ve just got to do it and get it over with.
But there are going to be a lot of areas where there’s room for improvement – in terms of how you do things, a documentation or even in terms of improving and making processes flow better within the actuarial side of things, as well as overall within the company.
So I think there was a lot of, well, I wouldn’t say excitement, but there was a lot of interesting work that came out of IFRS 17, where if you’re not scared of the unknown, there were a lot of areas where you could explore – different models that you can build, different processes that that you can work on.
I think the opportunity’s still sort of there, even though we’re getting close to the implementation time frame. There will be areas where, as a new actuary entering the profession, you have skills that the more experienced actuaries may not have – tools that you know how to use – and you might just see a better way of doing things.
So, I think that that’s certainly an area where I do see some of the newer actuaries in the profession can help on IFRS 17 still.
Fievoli: Well, we’re coming close to the end of 2022, and coming close to the end of this episode. So, let’s wrap up with the question.
Do either of you have any New Year’s resolutions pertaining to IFRS?
Cheng: I think, for me, it dovetails on what I just talked about. So, I think it would be nice to have a push button operation for some of these things.
One resolution could be to develop a push button operation to get, for example, the OSFI’s requirements from the AA. So there are quite a few requirements from OSFI on reporting various aspects of IFRS 17 details, and there are various tables and data that OSFI is gathering from AAs, and I think it would be nice to have a push button operation where I can just push a button and then that data gets extracted or aggregated automatically, and that’s where I am speaking to some of the new actuaries entering the profession.
MacLean: New Year’s resolutions – I’m not very good at New Year’s resolutions, but firstly, I think maybe getting some sleep. It’s been very busy, and some R&R is needed just to make sure that I’ve got the energy for the final push and to be ready for the storm.
I don’t think we’re quite in the eye of the storm yet. I think there’s a lot that needs to happen and it will continue to unfold in 2023.
A big takeaway for me is that it doesn’t have to be perfect. We don’t have to get everything right. We need to get the important parts right, and we’re not necessarily going to have everything right on January 1, 2023. And we’re going to need to be able to figure out how to course correct if necessary.
But I have to say, I am excited about 2023. I see some huge opportunities in terms of taking IFRS 17 forward, helping peers within the organization understand and decipher what this means.
I think we’re getting towards the top of the mountain and I’m really looking forward to admiring the views and not thinking about having to try and come down at the other at the other end of it.
Cheng: That’s a great analogy, Sati.
And I’m going to sneak in one more resolution. IFRS 17 may be coming to a close, but I tend to agree that we’re not close to the eye of the storm, and at some point we’ll reach the top of the mountain.
But, and I talked to you about this earlier in the week, and you mentioned this in one of your discussions on ESG, and I think that’s one of the things that’s beyond IFRS 17, and I’m starting to get the view that IFRS 17 is a dress rehearsal.
So it was a large mountain to climb for the insurance industry, but I think the next wave that’s already here across all industries is ESG. I think IFRS 17 gave us a lot of tools and processes and challenged actuaries and insurance companies to report under a different standard, and I think we’re going to have a brand-new challenge coming ahead in the next few years.
Fievoli: OK, that sounds good. Thanks once again for speaking to us to us today, and thanks for doing this mini-series with us.
MacLean: Thank you, Chris.
Cheng: Thank you, Chris.
Fievoli: We now have over 150 episodes in our podcast series going back over the past three years, so we encourage everybody to subscribe. You can do so through whatever platform you use to get your podcasts.
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Until next time, I’m Chris Fievoli, and thank you for tuning in to Seeing Beyond Risk.
This transcript has been edited for clarity.
The following comments were shared by readers:
Eric Keen: Thanks to both Houston and Sati for good discussions. It is nice to hear some positivity from both actuaries as I am overwhelmingly negative on the whole IFRS 17 process. I have read most of the Ed Notes, attended AA seminars and listened to podcasts and I fail to see the utility of the change in standards. Everyone will be trying to understand IFRS 17 by comparing it with IFRS 4 and 17 does not make for a level playing field or consistent comparisons among insurers. I also fear that as a peer reviewer for some significant reinsurers that I will not be able to do as good a job as a consulting actuary for an accounting firm who is immersed in the changes, models and procedures. Also, OSFI is not helping by adding whole new levels of reporting and changes heaped on top of everything. Two thumbs down for IFRS 17 – the USA has it right!
Thanks to both Houston and Sati for good discussions. It is nice to hear some positivity from both actuaries as I am overwhelmingly negative on the whole IFRS 17 process. I have read most of the Ed Notes, attended AA seminars and listened to podcasts and I fail to see the utility of the change in standards. Everyone will be trying to understand IFRS 17 by comparing it with IFRS 4 and 17 does not make for a level playing field or consistent comparisons among insurers. I also fear that as a peer reviewer for some significant reinsurers that I will not be able to do as good a job as a consulting actuary for an accounting firm who is immersed in the changes, models and procedures. Also, OSFI is not helping by adding whole new levels of reporting and changes heaped on top of everything. Two thumbs down for IFRS 17 – the USA has it right!