Added · Updated
The Office of the Superintendent of Financial Institutions established this guideline to implement a risk-based capital framework for federally regulated Canadian mortgage insurers, mandating minimum and supervisory target capital ratios of 100% and 150%. The framework defines qualifying capital across three categories, calculates requirements based on insurance, credit, market, and operational risks, and excludes reinsurance capital. Insurers must ensure continuous compliance through quarterly returns endorsed by authorized officers and submit mandatory annual audit reports within 90 days of their fiscal year-end.
Get OSFI alerts — same-day email on every new publication.
255 Albert Street
Ottawa, Canada
K1A 0H2 www.osfi-bsif.gc.ca
Guideline
Subject: Mortgage Insurer Capital Adequacy Test No: A Effective Date: January 1, 2025 Subsection 515(1) of the Insurance Companies Act (ICA) requires Federally Regulated Property and Casualty Insurance Companies (property and casualty companies) to maintain adequate capital. Under the provisions of the ICA, mortgage insurance companies (insurers) are considered to be property and casualty companies. The Mortgage Insurer Capital Adequacy Test (MICAT) Guideline is not made pursuant to subsections 515(2) of the ICA. However, the minimum and supervisory target capital standards set out in this guideline provide the framework within which the Superintendent assesses whether an insurer maintains adequate capital pursuant to subsection 515(1). Notwithstanding that an insurer may meet these standards, the Superintendent may direct the insurer to increase its capital under subsection 515(3). This guideline outlines the capital framework, using a risk-based formula, for target and minimum capital required, and defines the capital that is available to meet the minimum standard. The MICAT determines the minimum capital required and not the level of capital required at which insurers must operate.
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 2
Table of Contents
Page
Chapter 1. Overview and General Requirements.......................................................3
1.1. Overview ................................................................................................................3
1.2. General Requirements............................................................................................5
Chapter 2. Definition of Capital Available..................................................................7
2.1. Summary of Capital Components ..........................................................................7
2.2. Capital Composition Limits .................................................................................16
2.3. Regulatory Adjustments to Capital Available......................................................16
2.4. Capital Treatment of Interests in and Loans to Subsidiaries, Associates and Joint
Ventures................................................................................................................19
Appendix 2-A: Information Requirements for Capital Confirmations........................21
Chapter 3. Insurance Risk ..........................................................................................23
3.1. Residential exposures...........................................................................................23
3.2 Multi-unit Residential exposures..........................................................................31
3.3 Additional policy provisions ................................................................................38
Appendix 3-A. Determining supplementary capital requirement indicators...............39
Chapter 4. Credit Risk ................................................................................................46
4.1. Capital Requirements for Balance Sheet Assets ..................................................46
4.2. Capital Requirements for Off-Balance Sheet Exposures .....................................53
4.3. Capital Treatment of Collateral and Guarantees..................................................58
Chapter 5. Market Risk...............................................................................................62
5.1. Interest Rate Risk .................................................................................................62
5.2. Foreign Exchange Risk.........................................................................................67
5.3. Equity Risk ...........................................................................................................71
5.4. Real Estate Risk....................................................................................................74
5.5. Other Market Risk Exposures...............................................................................75
Chapter 6. Operational Risk.......................................................................................76
Chapter 1. Overview and General Requirements
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 3
Chapter 1. Overview and General Requirements
The Mortgage Insurer Capital Adequacy Test (MICAT) Guideline applies to Canadian mortgage insurance companies (insurers). This chapter provides an overview of the MICAT Guideline and sets out general requirements. More detailed information on specific components of the capital test is contained under subsequent chapters. Further guidance concerning some of the requirements of the MICAT Guideline may be found in other guidelines and advisories available on OSFI’s website.
Chapter 1. Overview and General Requirements
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 4 ii.) Credit risk1
(reference chapter 4):
a. Counterparty default risk for balance sheet assets; b. Counterparty default risk for off-balance sheet exposures; iii.) Market risk (reference chapter 5):
a. Interest rate risk; b. Foreign exchange risk;
c. Equity risk;
d. Real estate risk; e. Other market risk exposures. iv.) Operational risk (reference chapter 6). The MICAT does not include capital requirements or credit for reinsurance. Any mortgage insurer that is considering entering into a reinsurance agreement should contact OSFI for capital guidance.
1.1.3. Scope of consolidation
The capital adequacy requirements apply on a consolidated basis. The consolidated entity includes the insurer and all of its directly or indirectly held subsidiaries, which carry on business that the parent could carry on directly in accordance with the Insurance Companies Act (ICA), including holding companies. It therefore excludes:
Chapter 1. Overview and General Requirements
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 5
1.2. General Requirements
1.2.1. MICAT supervisory capital ratio for federally regulated mortgage insurers
The MICAT ratio is expressed as a percentage and is calculated by dividing the insurer's capital available by minimum capital required, which is derived from capital required calculated at the target level for specific risks. Federally regulated insurers are required, at a minimum, to maintain a MICAT ratio of 100%. OSFI has established an industry-wide supervisory target capital ratio (supervisory target) of 150% that provides a cushion above the minimum requirement and facilitates OSFI’s early intervention process. The supervisory target provides additional capacity to absorb unexpected losses and addresses capital needs through on-going market access. OSFI expects each insurer to establish an internal target capital ratio (internal target) per Guideline A-4 Regulatory Capital and Internal Capital Targets, and maintain on-going capital, above this target. However, the Superintendent may, on a case-by-case basis, establish an alternative supervisory target (in consultation with an insurer) based upon the insurer’s individual risk profile. Insurers are required to inform OSFI immediately if they anticipate falling below their internal target and to lay out their plans, for OSFI’s supervisory approval, to return to their internal target. OSFI will consider any unusual conditions in the market environment when evaluating insurers’ performance against their internal targets. Insurers are expected to maintain their MICAT ratios at or above their established internal targets on a continuous basis. Questions about an individual insurer’s target ratio should be addressed to the Lead Supervisor at OSFI.
1.2.2. Authorized official attestation
Each mortgage insurer is required to have an authorized Officer endorse the following statement on the MICAT Quarterly Return:
"I confirm that I have read the Mortgage Insurer Capital Adequacy Test guideline and related instructions issued by the Office of the Superintendent of Financial Institutions and that this form is completed in accordance with them." The Officer attesting to the validity of this statement on the MICAT Quarterly Return at year-end must be different from the insurer's Appointed Actuary.
1.2.3. Audit requirement
Insurers are required to engage their auditor appointed pursuant to section 337 of the ICA to report annually on the MICAT prepared as at fiscal year-end, in accordance with the relevant
Chapter 1. Overview and General Requirements
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 6 standards for such assurance engagements, as promulgated by the Canadian Auditing and Assurance Standards Board (AASB). The annual audit report of the MICAT must be prepared separately from the audit report for the financial statements, and is to be filed no later than 90 days after the insurers’ fiscal year-end. The annual audit opinion provided must be with respect to the current fiscal year-end, for page
10.10 of the insurers’ quarterly return.
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 7
Chapter 2. Definition of Capital Available
This chapter establishes requirements for the adequacy and appropriateness of capital resources used to meet capital requirements, having regard to their ability to meet insurers’ obligations to policyholders and creditors and to absorb losses in periods of stress. This includes the determination of the criteria for assessing the quality of capital components for inclusion in capital available and the composition of capital available for regulatory purposes, focusing on the predominance of highest quality capital.
2.1. Summary of Capital Components
The four primary considerations for defining the capital available of a company for the purpose of measuring capital adequacy are:
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 8
2.1.1.1. Qualifying criteria for inclusion of capital instruments in category A for regulatory
capital purposes3
For an instrument to be included in capital available under category A, it must meet all of the following criteria:
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 9
10. It is directly issued and paid-in4
and the insurer cannot directly or indirectly have funded the purchase of the instrument. Where the consideration for the shares is other than cash, the issuance of the common shares is subject to the prior approval of the Superintendent.
11. The paid-in amount is neither secured nor covered by a guarantee of the issuer or related
entity5 or subject to any other arrangement that legally or economically enhances the seniority of the claim.
12. It is only issued with the approval of the owners of the issuing insurer, either given
directly by the owners or, if permitted by applicable law, given by the Board of Directors or by other persons duly authorized by the owners.
13. It is clearly and separately disclosed on the insurer’s balance sheet, prepared in
accordance with the relevant accounting standards.
2.1.2. Category B capital
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 10
4. Is perpetual, i.e. there is no maturity date and there are no step-ups7
or other incentives to redeem8
5. May be callable at the initiative of the issuer only after a minimum of five years:
a. To exercise a call option, an insurer must receive prior approval of the Superintendent; and b. An insurer’s actions and the terms of the instrument must not create an expectation that the call will be exercised; and
c. An insurer must not exercise a call unless:
i. It replaces the called instrument with capital of the same or better quality,
including through an increase in retained earnings, and the replacement of this capital is done at conditions that are sustainable for the income capacity of the insurer9 ; or
ii. The insurer demonstrates that its capital position is well above the
supervisory target capital requirements after the call option is exercised.
6. Any repayment of principal (e.g. through repurchase or redemption) must require
approval of the Superintendent and insurers should not assume or create market expectations that such approval will be given.
7. Dividend/coupon discretion:
a. the insurer must have full discretion at all times to cancel distributions/payments;10 b. cancellation of discretionary payments must not be an event of default or credit event;
c. insurers must have full access to cancelled payments to meet obligations as they
fall due; d. cancellation of distributions/payments must not impose restrictions on the insurer except in relation to distributions to common shareholders.
8. Dividends/coupons must be paid out of distributable items.
7 A step-up is defined as a call option combined with a pre-set increase in the initial credit spread of the instrument at a future date over the initial dividend (or distribution) rate after taking into account any swap spread between the original reference index and the new reference index. Conversion from a fixed rate to a floating rate (or vice versa) in combination with a call option without any increase in credit spread would not constitute a step-up. 8 Other incentives to redeem include a call option combined with a requirement or an investor option to convert the instrument into common shares if the call is not exercised. 9 Replacement issuances can be concurrent with, but not after, the instrument is called. 10 A consequence of full discretion at all times to cancel distributions/payments is that “dividend pushers” are prohibited. An instrument with a dividend pusher obliges the issuing insurer to make a dividend/coupon payment on the instrument if it has made a payment on another (typically more junior) capital instrument or share. This obligation is inconsistent with the requirement for full discretion at all times. Furthermore, the term “cancel distributions/payments” means to forever extinguish these payments. It does not permit features that require the insurer to make distributions/payments in kind at any time.
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 11
9. The instrument cannot have a credit sensitive dividend feature, i.e., a dividend/coupon
that is reset periodically based in whole or in part on the insurance organization’s credit standing.11
10. The instrument cannot contribute to liabilities exceeding assets if such a balance sheet
test forms part of national insolvency law.
11. Other than preferred shares, category B instruments included in capital available must be
classified as equity per relevant accounting standards.
12. Neither the insurer nor a related party over which the insurer exercises control or
significant influence can have purchased the instrument, nor can the insurer directly or indirectly have funded the purchase of the instrument.
13. The instruments cannot have any features that hinder recapitalization, such as provisions
that require the issuer to compensate investors if a new instrument is issued at a lower price during a specified timeframe.
14. If the instrument is not issued directly by the insurer (e.g. it is issued out of a special
purpose vehicle or SPV), proceeds must be available immediately without limitation to an insurer in a form that meets or exceeds all of the other criteria for inclusion in capital available as specified under category B. For greater certainty, the only assets the SPV may hold are intercompany instruments issued by the insurer or a related entity with terms and conditions that meet or exceed criteria specified under category B. Put differently, instruments issued to the SPV have to fully meet or exceed all of the eligibility criteria under category B as if the SPV itself was an end investor – i.e. the insurer cannot issue a lower quality capital or senior debt instrument to an SPV and have the SPV issue higher quality capital instruments to third-party investors so as to receive recognition as qualifying capital under category B. Purchase for cancellation of Category B capital instruments is permitted at any time with the prior approval of the Superintendent. For further clarity, a purchase for cancellation does not constitute a call option as described in the above Category B qualifying criteria. Tax and regulatory event calls are permitted during an instrument’s life subject to the prior approval of the Superintendent and provided the insurer was not in a position to anticipate such an event at the time of issuance. Dividend stopper arrangements that stop payments on common shares or Category B instruments are permissible provided the stopper does not impede the full discretion the insurer must have at all times to cancel distributions or dividends on the Category B instrument, nor must it act in a way that could hinder the recapitalization of the institution pursuant to criterion number 13 above. For example, it would not be permitted for a stopper on a Category B instrument to:
11 Institutions may use a broad index as a reference rate in which the issuing institution is a reference entity; however, the reference rate should not exhibit significant correlation with the institution’s credit standing. If an institution plans to issue capital instruments where the margin is linked to a broad index in which the institution is a reference entity, the institution should ensure that the dividend/coupon is not credit-sensitive.
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 12
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 13
4. Maturity:
a. minimum original maturity of at least five years; b. recognition in regulatory capital in the remaining five years before maturity will be amortized on a straight line basis;
c. there are no step-ups13 or other incentives to redeem.
5. May be callable at the initiative of the issuer only after a minimum of five years:
a. To exercise a call option, an insurer must receive the prior approval of the Superintendent; and b. An insurer must not do anything that creates an expectation that the call will be exercised;14 and
c. An insurer must not exercise a call unless:
i. It replaces the called instrument with capital of the same or better quality,
including through an increase in retained earnings, and the replacement of this capital is done at conditions that are sustainable for the income capacity of the insurer;15 or
ii. The insurer demonstrates that its capital position is well above the
supervisory target capital requirements after the call option is exercised.
6. The investor must have no rights to accelerate the repayment of future scheduled
payments (interest or principal), except in bankruptcy, insolvency, wind-up, or liquidation.
7. The instrument cannot have a credit sensitive dividend feature, i.e. a dividend/coupon
that is reset periodically based in whole or in part on the insurer’s credit standing16 .
8. Neither the insurer nor a related party over which the insurer exercises control or
significant influence can have purchased the instrument, nor can the insurer directly or indirectly have funded the purchase of the instrument.
9. If the instrument is not issued directly by the insurer (e.g. it is issued out of an SPV),
proceeds must be available immediately without limitation to the insurer in a form that meets or exceeds all of the criteria for inclusion specified under category C. For greater certainty, the only assets the SPV may hold are intercompany instruments issued by the institution or a related entity with terms and conditions that meet or exceed the above 13 A step-up is defined as a call option combined with a pre-set increase in the initial credit spread of the instrument at a future date over the initial dividend (or distribution) rate after taking into account any swap spread between the original reference index and the new reference index. Conversion from a fixed rate to a floating rate (or vice versa) in combination with a call option without any increase in credit spread would not constitute a step-up. 14 An option to call the instrument after five years but prior to the start of the amortisation period will not be viewed as an incentive to redeem as long as the insurer does not do anything that creates an expectation that the call will be exercised at this point. 15 Replacement issuances can be concurrent with but not after the instrument is called. 16 Insurers may use a broad index as a reference rate in which the issuing insurer is a reference entity; however, the reference rate should not exhibit significant correlation with the insurer’s credit standing. If an insurer plans to issue capital instruments where the margin is linked to a broad index in which the insurer is a reference entity, the insurer should ensure that the dividend/coupon is not credit-sensitive.
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 14 category C criteria. Put differently, instruments issued to the SPV have to fully meet or exceed all of the eligibility criteria under category C as if the SPV itself was an end investor – i.e. the institution cannot issue a lower capital or a senior debt instrument to an SPV and have the SPV issue higher quality capital instruments to third-party investors so as to receive recognition as qualifying capital under category C. Category C capital instruments must not contain restrictive covenants or default clauses that would allow the holder to trigger acceleration of repayment in circumstances other than the insolvency, bankruptcy or winding-up of the issuer. Purchase for cancellation of category C instruments is permitted at any time with the prior approval of the Superintendent. For further clarity, a purchase for cancellation does not constitute a call option as described in the above Category C criteria. Tax and regulatory event calls are permitted during an instrument’s life subject to the prior approval of the Superintendent and provided the insurer was not in a position to anticipate such an event at the time of issuance. Where an amendment or variance of a Category C instrument’s terms and conditions affects its recognition as regulatory capital, such amendment or variance will only be permitted with the prior approval of the Superintendent17 . Institutions are permitted to “re-open” offerings of capital instruments to increase the principal amount of the original issuance provided that call options will only be exercised, with the prior approval of the Superintendent, on or after the fifth anniversary of the closing date of the latest re-opened tranche of securities. Defeasance options may only be exercised on or after the fifth anniversary of the closing date with the prior approval of the Superintendent.
2.1.3.2. Amortization
Category C capital instruments are subject to straight-line amortization in the final five years prior to maturity. Hence, as these instruments approach maturity, redemption or retraction, such outstanding balances are to be amortized based on the following schedule:
Amortization Schedule
17 Any modification of, addition to, or renewal or extension of an instrument issued to a related party is subject to the legislative requirement that transactions with a related party be at terms and conditions that are at least as favourable to the institution as market terms and conditions.
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 15
Years to Maturity Included in Capital
5 years or more 100%
4 years and less than 5 years 80%
3 years and less than 4 years 60%
2 years and less than 3 years 40%
1 year and less than 2 years 20%
Less than 1 year 0%
For instruments issued prior to January 1, 2015, where the terms of the instrument include a redemption option that is not subject to prior approval of the Superintendent and/or holders’ retraction rights, amortization should begin five years prior to the effective dates governing such options. For example, a 20-year debenture that can be redeemed at the insurer’s option at any time on or after the first 10 years would be subject to amortization commencing in year 5. Further, where a subordinated debt was redeemable at the insurer’s option at any time without the prior approval of the Superintendent, the instrument would be subject to amortization from the date of issuance. For greater certainty, this would not apply when redemption requires the Superintendent's approval as is required for all instruments issued pursuant to the above criteria in section 2.1.3.1. Amortization should be computed at the end of each fiscal quarter based on the "years to maturity" schedule above. Thus, amortization would begin during the first quarter that ends within five calendar years to maturity. For example, if an instrument matures on October 15, 2020, 20% amortization of the issue would occur on October 16, 2015 and be reflected in the December 31, 2015 regulatory return. An additional 20% amortization would be reflected in each subsequent December 31 return.
2.1.4. Non-controlling interests
Insurers are permitted to include, in capital available, non-controlling interests in operating consolidated subsidiaries, provided:
i. the capital instruments meet the qualifying criteria under category A, B and C;
ii. the capital in the subsidiary is not excessive in relation to the amount necessary to carry
on the subsidiary’s business; and
iii. the level of capitalization of the subsidiary is comparable to that of the insurance
company as a whole.
If a subsidiary issues capital instruments for the funding of the insurer, or that are substantially in excess of its own requirements, the terms and conditions of the issue, as well as the intercompany transfer, must ensure that investors are placed in the same position as if the instrument were issued by the insurer directly in order for it to qualify as capital available upon consolidation. This can only be achieved by the subsidiary using the proceeds of the issue to purchase a similar instrument from the parent. Since subsidiaries cannot buy shares of the parent insurance company, it is likely that this treatment will only be applicable to the subordinated
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 16 debt. In addition, to qualify as capital for the consolidated entity, the debt held by third parties cannot effectively be secured by other assets, such as cash, held by the subsidiary.
2.2. Capital Composition Limits
The inclusion of capital instruments qualifying under category B and category C criteria is subject to the following limits:
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 17
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 18 taxes levied by the same taxation authority and offsetting is permitted by the relevant taxation authority19. The DTLs permitted to be netted against DTAs must exclude amounts that have been netted against the deduction of goodwill, intangibles and defined benefit pension plan assets, and must be allocated on a pro rata basis between DTAs that are to be deducted in full and DTAs that are subject to the 10% risk factor (reference section 4.1).
5. Cumulative gains and losses due to changes in own credit risk on fair valued financial
liabilities:
All accumulated after-tax unrealized gains and losses that have resulted from changes in the fair value of insurer’s financial liabilities that are due to changes in the institution’s own credit risk must be deducted from capital available. In addition, with regard to derivative liabilities, all accounting valuation adjustments arising from the institution’s own credit risk should also be deducted on an after-tax basis. The offsetting between valuation adjustments arising from the institution's own credit risk and those arising from its counterparties' credit risk is not permitted.
6. Defined benefit pension fund assets and liabilities:
For each defined benefit pension fund that is in a surplus position and reported as an asset on the institution’s balance sheet, the amounts reported as a surplus asset on the balance sheet must be deducted from capital available, net of any associated deferred tax liability that would be extinguished if the asset becomes impaired or derecognized under the relevant accounting standards, and net of any amount of available refunds of defined benefit pension fund surplus assets to which the insurer has unrestricted and unfettered access. Insurers may only reduce this deduction by an amount of available refunds of defined benefit pension plan surplus assets if they obtain a prior written supervisory approval from OSFI20 .
7. Investments in own instruments (treasury stock):
All of institution’s investments in its own instruments, whether held directly or indirectly, must be deducted from capital available (unless already derecognized under IFRS). In addition, any own stock that the institution could be contractually obliged to purchase should be deducted from capital available.
8. Reciprocal cross holdings in the common shares of insurance, banking and financial entities:
Reciprocal cross holdings in common shares (e.g. Insurer A holds shares of Insurer B and Insurer B in return holds shares of Insurer A), also known as back-to-back placements, that are designed to artificially inflate the capital position of institutions must be fully deducted from capital available. 19 This does not permit offsetting of DTAs across provinces. 20 To obtain OSFI supervisory approval, an insurer must demonstrate, to OSFI’s satisfaction that it has clear entitlement to the surplus and that it has unrestricted and unfettered access to the surplus pension assets. Evidence required by OSFI may include, among other things, an acceptable independent legal opinion and the prior authorization from the pension plan members and the pension regulator.
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 19
9. Insurance acquisition cash flows:
Any asset for insurance acquisition cash flows must be deducted from capital available. Items that are deducted from capital available will be subject to a 0% risk factor for capitalrequired purposes.
2.3.2. Adjustments:
Adjustments to owner-occupied property valuations21:
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 20 insurer. Loans or other forms of lending provided to a non-qualifying subsidiary that are not reported as equity are subject to a risk factor of 45%. Receivables from non-qualifying subsidiaries will attract a risk factor of 5% or 10% depending on how long the balances are outstanding (reference section 4.1).
2.4.3. Associates
An enterprise is an associate of another enterprise if:
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 21 deduct from capital available their ownership interest. A “look-through” approach should be used for intra-group investments, similar to that for mutual funds (reference section 4.1).
2.4.7 Summary of exposures
Types of exposures an insurer might have with non-qualifying subsidiaries, associates, and joint ventures:
Examples of exposures and capital treatment
Exposure Capital treatment
Common or preferred shares (non-qualifying subsidiaries and associates) including share of accumulated earnings/losses less dividends received based on equity accounting Excluded from capital available Ownership interests > 10% joint venture Excluded from capital available Ownership interests ≤ 10% joint venture Included in capital available with a risk factor of 30% applied to the ownership interest Loans or other forms of lending (bonds, debentures, mortgages, etc.) reported as equity Excluded from capital available Loans or other forms of lending (bonds, debentures, mortgages, etc.) not reported as equity Included in capital available with a risk factor of 45% Receivables Included in capital available with a risk factor of 5% or 10% depending on how long the balances are outstanding
Appendix 2-A: Information Requirements for Capital Confirmations
Given the potential impact of the disqualification of a capital instrument, insurers are encouraged to seek confirmations of capital quality from OSFI prior to issuing instruments23. In conjunction with such requests, the insurer is expected to provide the following information to the Capital Division:
Chapter 2. Definition of Capital
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 22 b) the terms of any guarantee relating to the instrument.
5. Where the terms of the instrument include a redemption option or similar feature upon a tax
event, an external tax opinion confirming the availability of such deduction in respect of interest or distributions payable on the instrument for income tax purposes24 .
6. An accounting opinion describing the proposed treatment and disclosure of the capital instrument
(other than common shares) on the institution’s financial statements25 .
7. Where the initial interest or coupon rate payable on the instrument resets periodically or the basis
of the interest rate changes from fixed to floating (or vice versa) at a pre-determined future date, calculations demonstrating that no incentive to redeem, or step-up, will arise upon the change in the initial rate. Where applicable, a step-up calculation should be provided according to the swapspread methodology, which confirms there is no step-up upon the change in interest rate, and supported by screenshots of the applicable reference index rate(s).
8. Capital projections demonstrating that the insurer will be in compliance with its supervisory
target capital ratios as well as the capital composition requirements specified in section 2.2 at the end of the quarter in which the instrument is expected to be issued.
9. An assessment of the features of the proposed capital instrument against the qualifying criteria
for category B capital instruments or category C capital instruments, as applicable, as specified in the MICAT Guideline. For greater certainty, this assessment would only be required for an initial issuance or precedent and is not required for subsequent issuances provided the terms of the instrument are not materially altered.
10. A written attestation from a senior officer of the institution confirming that the insurer has
not provided financing to any person for the express purpose of investing in the proposed capital instrument. 24 OSFI reserves the right to require a Canada Revenue Agency advance tax ruling to confirm such tax opinion if the tax consequences are subject to material uncertainty. 25 OSFI reserves the right to require such accounting opinion to be an external opinion of a firm acceptable to OSFI if the accounting consequences are subject to material uncertainty.
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 23
Chapter 3. Insurance Risk
Insurance risk is the risk that the provisions that an insurer holds to cover its obligations under the insurance contracts it has written are insufficient under a severe but plausible scenario. The capital requirement for insurance risk consists of:
i. a capital requirement for future losses, i.e., losses associated with defaults that occur after
the reporting date, referred to as the capital required for liabilities for remaining coverage;
ii. a capital requirement for losses that have already occurred and for which settlement is not
yet complete, referred to as the capital required for liabilities for incurred claims; and,
iii. a capital requirement for the loss components of liabilities for remaining coverage.
For the purposes of this Guideline, a residential mortgage is a mortgage on a property that is designed for occupancy by not more than four family units or is a single-family unit of a condominium. A mortgage that is not considered to be a residential mortgage according to this definition will be referred to as a multi-unit residential mortgage.
Section 3.1 describes the calculation of the capital requirement for residential exposures while
section 3.2 describes the calculation for multi-unit residential exposures. Section 3.3 describes
the calculation of the additional policy provision. For residential exposures, the additional policy provision is an allocation of the requirement determined in section 3.1. For multi-unit residential exposures, the additional policy provision is an allocation of the requirement determined in
section 3.2.
3.1. Residential exposures
3.1.1. Capital required for liabilities for remaining coverage
Liabilities for remaining coverage are the liabilities that an insurer holds to cover future losses, i.e., losses associated with defaults that occur after the reporting date. The capital required for liabilities for remaining coverage associated with residential exposures is defined as max (𝑇 − 𝐿, 𝐹) where:
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 24
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 25 where 𝐿𝑇𝑉 represents the loan-to-value ratio for the mortgage loan as defined in subsection
3.1.1.5 and 𝜇1, 𝜇2, 𝜎1, 𝜎2, 𝐶1, 𝐶2 are defined as follows:
If the remaining term of insurance for the mortgage loan as of the reporting date is five years or less then 𝜇1 = 90% 𝑓𝑜𝑟 𝑇 ∗ ≤ 40 𝜇2 = 125% 𝑓𝑜𝑟 𝑇 ∗ ≤ 40 𝜎1 = {− 17% 𝑓𝑜𝑟 𝑇 ∗ ≤ 10 0.2% × 𝑇 ∗ + 19% 𝑓𝑜𝑟 10 < 𝑇 ∗ ≤ 25 14% 𝑓𝑜𝑟 25 < 𝑇 ∗ ≤ 40 𝜎2 = { 16% 𝑓𝑜𝑟 𝑇 ∗ ≤ 15.5 0.59% × 𝑇 ∗ + 7% 𝑓𝑜𝑟 15.5 < 𝑇 ∗ ≤ 40 𝐶1 = { 123 × 𝑇 ∗ + 520 𝑓𝑜𝑟 𝑇 ∗ ≤ 11 −25 × 𝑇 ∗ + 2,250 𝑓𝑜𝑟 11 < 𝑇 ∗ ≤ 40 𝐶2 = { 115 × 𝑇 ∗ − 85 𝑓𝑜𝑟 𝑇 ∗ ≤ 17 1,900 𝑓𝑜𝑟 17 < 𝑇 ∗ ≤ 40 Otherwise, 𝜇1 = 90% 𝑓𝑜𝑟 𝑇 ∗ ≤ 40 𝜇2 = 125% 𝑓𝑜𝑟 𝑇 ∗ ≤ 40 𝜎1 = 17% 𝑓𝑜𝑟 𝑇 ∗ ≤ 40 𝜎2 = { 16% 𝑓𝑜𝑟 𝑇 ∗ ≤ 15.5 1.09% × 𝑇 ∗ − 0.94% 𝑓𝑜𝑟 15.5 < 𝑇 ∗ ≤ 40 𝐶1 = { 123 × 𝑇 ∗ + 520 𝑓𝑜𝑟 𝑇 ∗ ≤ 16 −65 × 𝑇 ∗ + 3,515 𝑓𝑜𝑟 16 < 𝑇 ∗ ≤ 25 −39 × 𝑇 ∗ + 2,885 𝑓𝑜𝑟 25 < 𝑇 ∗ ≤ 40 𝐶2 = { 115 × 𝑇 ∗ − 85 𝑓𝑜𝑟 𝑇 ∗ ≤ 25 68 × 𝑇 ∗ + 1,110 𝑓𝑜𝑟 25 < 𝑇 ∗ ≤ 40 where 𝑇 ∗ represents the remaining amortization for the mortgage loan as of the reporting date and is measured in years28 . If the remaining amortization exceeds 40 years, 40 years should be used as 𝑇 ∗ . ii) Formula for 𝐵 𝐵 = {𝐶1 × exp ( − ( 1 𝐿𝑇𝑉 − 𝜇1) 2 2 ∙ 𝜎1 2 ) + 𝐶2 × exp ( − ( 1 𝐿𝑇𝑉 − 𝜇2) 2 2 ∙ 𝜎2 2 )} where 𝐿𝑇𝑉 represents the loan-to-value ratio for the mortgage loan as defined in subsection
3.1.1.5 and in this case, 𝜇1, 𝜇2, 𝜎1, 𝜎2, 𝐶1, 𝐶2 are defined as follows:
If the remaining term of insurance for the mortgage loan as of the reporting date is five years or less then 28 If a mortgage is split into tranches, then the remaining amortization used in this and subsequent formulas is the maximum of the remaining amortizations of all tranches.
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 26
𝜇1
= 94% 𝑓𝑜𝑟 𝑇
∗ ≤ 40 𝜇2
= {
0.62% × 𝑇
∗ + 121% 𝑓𝑜𝑟 𝑇
∗ ≤ 15
130% 𝑓𝑜𝑟 15 < 𝑇
∗ ≤ 40
𝜎1 = {
23% 𝑓𝑜𝑟 𝑇
∗ ≤ 14
−0.64% × 𝑇
∗ + 32% 𝑓𝑜𝑟 14 < 𝑇
∗ ≤ 25
16% 𝑓𝑜𝑟 25 < 𝑇
∗ ≤ 40
𝜎2 = {
14% 𝑓𝑜𝑟 𝑇
∗ ≤ 15
0.4% × 𝑇
∗ + 8% 𝑓𝑜𝑟 15 < 𝑇
∗ ≤ 40
𝐶1 = {
233 × 𝑇
∗ + 1,975 𝑓𝑜𝑟 𝑇
∗ ≤ 11
4,450 𝑓𝑜𝑟 11 < 𝑇
∗ ≤ 40 𝐶2 = {
1,550 𝑓𝑜𝑟 𝑇
∗ ≤ 15
400 × 𝑇
∗ − 4,450 𝑓𝑜𝑟 15 < 𝑇
∗ ≤ 18
130 × 𝑇
∗ + 420 𝑓𝑜𝑟 18 < 𝑇
∗ ≤ 25
30 × 𝑇
∗ + 3,020 𝑓𝑜𝑟 25 < 𝑇
∗ ≤ 40
Otherwise,
𝜇1
= {
94% 𝑇
∗ ≤ 19.75
−2.33% × 𝑇
∗ + 140% 19.75 < 𝑇
∗ ≤ 26
80% 𝑓𝑜𝑟 26 < 𝑇
∗ ≤ 40
𝜇2
= {
0.62% × 𝑇
∗ + 121% 𝑓𝑜𝑟 𝑇
∗ ≤ 33.25
142% 𝑓𝑜𝑟 33.25 < 𝑇
∗ ≤ 40
𝜎1 = {
23% 𝑓𝑜𝑟 𝑇
∗ ≤ 14.75
1.63% × 𝑇
∗ − 0.82% 𝑓𝑜𝑟 14.75 < 𝑇
∗ ≤ 40
𝜎2 = {
14% 𝑓𝑜𝑟 𝑇
∗ ≤ 19
1.03% × 𝑇
∗ − 5.84% 𝑓𝑜𝑟 19 < 𝑇
∗ ≤ 27
21.5% 𝑓𝑜𝑟 27 < 𝑇
∗ ≤ 40
𝐶1 = {
233 × 𝑇
∗ + 1,975 𝑓𝑜𝑟 𝑇
∗ ≤ 25
282 × 𝑇
∗ + 740 𝑓𝑜𝑟 25 < 𝑇
∗ ≤ 40 𝐶2 = {
1,550 𝑓𝑜𝑟 𝑇
∗ ≤ 19.25
133 × 𝑇
∗ − 1,030 𝑓𝑜𝑟 19.25 < 𝑇
∗ ≤ 26
−117 × 𝑇
∗ + 5,490 𝑓𝑜𝑟 26 < 𝑇
∗ ≤ 40 where 𝑇
∗ represents remaining amortization for the mortgage loan as of the reporting date and is measured in years. If the remaining amortization exceeds 40 years, 40 years should be used as 𝑇 ∗ . If a mortgage has payments that are contractually required to be reset within a period not exceeding one month, and the amortization of a mortgage loan at the end of a reporting period does not reflect the contractually required payment reset, a mortgage insurer may calculate T* as if that reset has occurred.
3.1.1.3. Supplementary capital requirement for an individual mortgage loan
If a mortgage loan originated after December 31, 2016 corresponds to a property that is located in one of the 11 metropolitan areas listed in Appendix 3-A and if the value of the supplementary capital requirement indicator (SCRI) for this metropolitan area is greater than the threshold value for this metropolitan area then a supplementary capital requirement must be determined for this mortgage loan and added to the base total requirement for this mortgage loan to determine the total amount for this loan.
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 27
The calculation of the SCRI is described in Appendix 3-A.
If a supplementary capital requirement must be determined for a particular mortgage loan, it is calculated using the following formula:
𝑆 = 𝑟 × 𝑇𝐵 where 𝑇𝐵 is as defined in subsection 3.1.1.2 and where the quantity 𝑟 is defined as follows. 𝑟 = 𝑎 + 𝑏 × exp (−0.1 ∙ 𝑇 ∗ ) where 𝑎 and 𝑏 are defined as follows:
If the remaining term of insurance for the mortgage loan as of the reporting date is five years or less then 𝑎 = 𝑚𝑖𝑛 {c + 0.1 × ( 1 𝐿𝑇𝑉 − 1) , 1.15}, 𝑏 = {
0.3 𝑓𝑜𝑟 𝑇
∗ ≤ 10
0 𝑓𝑜𝑟 10 < 𝑇
∗ ≤ 40
𝑐 = {
0.08 𝑓𝑜𝑟 𝑇
∗ ≤ 10
−0.013 × 𝑇
∗ + 0.32 𝑓𝑜𝑟 10 < 𝑇
∗ ≤ 13
0.19 𝑓𝑜𝑟 13 < 𝑇
∗ ≤ 40 where:
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 28
The credit score used to determine the value of 𝑚 for a particular mortgage loan should come from a reputable credit bureau and should also be used as part of the insurer’s business and risk management processes. It should not be acquired for the sole purpose of determining regulatory capital requirements. In cases where an insurer obtains credit scores from more than one credit bureau, the insurer should select the bureau whose scores the insurer primarily uses in the management of its business, and use the scores of this credit bureau consistently for all mortgage loans and from one reporting period to the next. The only exception is if there is no credit score available for a particular mortgage loan from the credit bureau whose scores the insurer primarily uses to manage its business; in this situation, the insurer may use the credit score from another reputable credit bureau until such time that a credit score becomes available from the bureau whose scores the insurer primarily uses. For mortgage loans with more than one borrower, the credit score used to determine the value of 𝑚 is the maximum of the credit scores of the individual borrowers. In cases where the credit scores of the individual borrowers are from different credit bureaus, the maximum is calculated using only the credit scores from the bureau whose scores the insurer primarily uses to manage its business. In cases where none of the credit scores of the individual borrowers is from the credit bureau whose scores the insurer primarily uses to manage its business, the maximum is calculated using the available scores. Credit Quality Adjustment Factors by Credit Score, 𝑚 Credit Score 𝒎 < 600 3.00 [600,620) 2.05 [620,640) 1.80 [640,660) 1.60 [660,680) 1.35 [680,700) 1.10 [700,720) 0.90 [720,740) 0.65 [740,760) 0.55 [760,780) 0.45 ≥ 780 0.40 The value assigned to the adjustment factor for credit quality, 𝑚, of a mortgage loan with no credit score is 1.3 unless more than 5% of an insurer’s mortgage loans considered residential exposures have no credit score, in which case the value assigned to the adjustment factor for credit quality, 𝑚, of a mortgage loan with no credit score is 3.0.
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 29
3.1.1.5. Loan-to-value ratio for an individual mortgage loan
This subsection describes the calculation of the 𝐿𝑇𝑉 input for the formulas given in subsections
3.1.1.2 and 3.1.1.3. Note that if the value of 𝐿𝑇𝑉 determined in this subsection is greater than
105% then an 𝐿𝑇𝑉 input of 105% should be used in the formulas in subsections 3.1.1.2 and 3.1.1.3. The value of the 𝐿𝑇𝑉 input for the formulas in subsections 3.1.1.2 and 3.1.1.3 depends on the origination date of the mortgage, and whether it is a First-Time Home Buyer Incentive (FTHBI) mortgage or not. i) Mortgages originated after December 31, 2015 that are not FTHBI mortgages For mortgages originated after December 31, 2015, the 𝐿𝑇𝑉 input is calculated by dividing the outstanding loan balance on the reporting date by the property value on the origination date or the date of the most recent appraisal, provided that the appraisal was commissioned by an independent third party entity other than an insurer. ii) FTHBI Mortgages For FTHBI mortgages, the reciprocal of the 𝐿𝑇𝑉 input is determined by taking a weighted average of the following two quantities:
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 30
𝐿𝑇𝑉𝑆𝐸 =
𝑜𝑢𝑡𝑠𝑡𝑎𝑛𝑑𝑖𝑛𝑔 𝑙𝑜𝑎𝑛 𝑏𝑎𝑙𝑎𝑛𝑐𝑒 + 𝑠ℎ𝑎𝑟𝑒𝑑 𝑒𝑞𝑢𝑖𝑡𝑦 𝑎𝑚𝑜𝑢𝑛𝑡 𝑝𝑟𝑜𝑝𝑒𝑟𝑡𝑦 𝑣𝑎𝑙𝑢𝑒 and 𝐿𝑇𝑉𝑀 = 𝑜𝑢𝑡𝑠𝑡𝑎𝑛𝑑𝑖𝑛𝑔 𝑙𝑜𝑎𝑛 𝑏𝑎𝑙𝑎𝑛𝑐𝑒 𝑝𝑟𝑜𝑝𝑒𝑟𝑡𝑦 𝑣𝑎𝑙𝑢𝑒 and 𝑤 = max [35%, min(95%, 200% × 1 𝐿𝑇𝑉𝑀 − 205%)] iii) Mortgages originated after December 31, 2004 but on or before December 31, 2015 For mortgages originated after December 31, 2004 but on or before December 31, 2015, the 𝐿𝑇𝑉 input is calculated by dividing the outstanding loan balance on the reporting date by the property value that is determined as follows.
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 31
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 32
3.2.1.1. Capital required for liabilities for remaining coverage (Expiration December 31,
2029)
The capital required for liabilities for remaining coverage associated with multi-unit residential exposures is the sum of the capital requirements for individual multi-unit residential exposures, where the sum is calculated over all multi-unit mortgage loans that were expected to be in-force on the reporting date based on the mortgage’s amortization schedule at the time of mortgage origination. Unlike the situation for residential exposures, an amount must be calculated and held for all multi-unit residential mortgages that were expected to be in-force on the reporting date based on the mortgage’s original amortization schedule, regardless of whether the mortgage is still in-force on the reporting date. The capital required for an individual mortgage loan is determined by the formula 𝐹1 × 𝐹2 × 𝐹3 × 𝐴 where:
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 33
Mortgage loan age
(years)
Value of 𝑭𝟏
7 0.4125
8 0.1250
≥ 9 0
The values for fractional ages can be determined by interpolation.
Calculation of 𝑭𝟐
The value of 𝐹2 for an individual mortgage loan depends on whether the mortgage’s loan-tovalue ratio at origination is greater or less than 80% and whether the underlying mortgage is a first or second mortgage, and is defined by the following table. Value of F2 by Priority and Loan-to-Value Priority Loan-to-Value Ratio at Origination First Mortgage Second Mortgage ≤ 80% 1.00 1.50
80% 1.50 1.50
Calculation of 𝑭𝟑
The value of 𝐹3 for an individual mortgage loan depends on the settlement option stated in the master policy and the mortgage’s loan-to-value ratio at origination. If the maximum amount payable on an individual mortgage loan after all recoveries is 100% or more of the mortgage balance at origination, then the value of 𝐹3 is as defined in the following
table.
Value of F3 by Loan-to-Value
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 34
Loan-to-Value Ratio at
Origination
Value of 𝑭𝟑
≤ 50% 100%
50% < LTV ≤ 65% 100%
65% < LTV ≤ 75% 100%
75% < LTV ≤ 80% 105%
80% < LTV ≤ 85% 110%
85% < LTV ≤ 90% 115%
90% < LTV ≤ 95% 140%
LTV > 95% 150%
If the maximum amount payable on an individual mortgage loan after all recoveries is less than 100% of the mortgage balance at origination, then the value of 𝐹3 is as defined in the following
table.
Value of F3 by Maximum Amount Payable
Maximum Amount Payable
(% of Balance at Origination)
Value of 𝑭𝟑
10% 73%
15% 80%
20% 84%
25% 100%
If the amount payable on an individual mortgage loan is a fixed percentage of the lender’s loss net of recoveries, then the value of 𝐹3 is determined by multiplying this fixed percentage by the value of 𝐹3 in the case where the maximum amount payable is 100% of the mortgage balance at origination. For example, if the master policy provides coverage for 50% of the lender’s loss net of recoveries, and the loan-to-value ratio at origination is 85%, then the value of 𝐹3 would be 55% (= 50% × 110%).
3.2.1.2. Capital required for liabilities for remaining coverage (Effective January 1, 2026)
The capital required for liabilities for remaining coverage associated with multi-unit residential exposures is defined as:
max (𝑇 − 𝐿, 𝐹) where:
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 35
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 36
(iv) the property is not a social welfare housing exposure (i.e., retirement housing, supportive housing, or student housing). LTV 𝐑𝐢𝐬𝐤 𝐖𝐞𝐢𝐠𝐡𝐭 (0%, 50%] 30% (50%, 60%] 35% (60%, 70%] 45% (70%, 80%] 50% (80%, 90%] 60% (90%, 100%] 75%
100% 105%
Furthermore, the risk weight for completed property exposures with social welfare housing exposure (i.e., retirement housing, supportive housing, or student housing) is defined by the following table. If, (i) the mortgage lender holds the senior lien over the property, i.e., the mortgage is in first position, (ii) the property securing the exposure is completed, i.e., it is not a new construction exposure, (iii) prudential underwriting standards are in place, and (iv) the property is a social welfare housing exposure (i.e., retirement housing, supportive housing, or student housing), then:
LTV 𝐑𝐢𝐬𝐤 𝐖𝐞𝐢𝐠𝐡𝐭
(0%, 60%] 70%
(60%, 80%] 90%
80% 110%
Otherwise, for completed property securing the exposures (i.e., it is not a new construction exposure) and regardless of whether or not the property is a social welfare housing exposure (i.e., retirement homes, nursing homes, or student housing), the risk weight is defined below. If:
(i) the mortgage lender holds the junior lien over the property, (i.e., the mortgage is without first position), or (ii) prudential underwriting standards are not in place The completed property securing the exposure has a risk weight = 150% for all LTV > 0. Risk weight – new construction property exposures Underwriting policies must also be appropriate when the repayment of the mortgage loan depends materially on the cash flows generated by the property, including relevant metrics (such as an occupancy rate of the property).
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 37
The new construction property securing the exposure has a risk weight = 150%. However, if (i) the mortgage lender holds the senior lien over the property, (ii) the property securing the exposure is a new construction exposure, (iii) pre-sale34 contracts amount to over 50% of total contracts or equity at risk equivalent to at least 25% of the real estate's appraised as-completed value has been contributed by the borrower (i.e., LTV at origination <= 75%), (iv) prudential underwriting standards are in place, and then the risk weight = 100%. When a property is no longer considered under development and construction, the property is considered an existing property for capital purposes.
3.2.1.3. Transition provisions
A.) The capital required for liabilities for remaining coverage for multi-unit residential mortgage in-force insurance policies effective on or after January 1, 2026, are subject to the MICAT rules under Section 3.2.1.2. B.) The capital required for liabilities for remaining coverage for multi-unit residential mortgage in-force insurance policies (“policy liabilities”) effective on or before December 31, 2025, are subject to the following transition:
i. Beginning January 1, 2026, all policy liabilities with an effective date of December
31, 2019, or earlier are subject to the MICAT rules under Section 3.2.1.2. All remaining policy liabilities effective between January 1, 2020, to December 31, 2025, may be subject to MICAT rules under Section 3.2.1.1.
ii. Beginning January 1, 2027, all policy liabilities with an effective date of December
31, 2021, or earlier are subject to the MICAT rules under Section 3.2.1.2. All remaining policy liabilities effective between January 1, 2022, to December 31, 2025, may be subject to MICAT rules under Section 3.2.1.1.
iii. Beginning January 1, 2028, all policy liabilities with an effective date of December
31, 2023, or earlier are subject to the MICAT rules under Section 3.2.1.2. All remaining policy liabilities effective between January 1, 2024, to December 31, 2025, may be subject to MICAT rules under Section 3.2.1.1.
iv. Beginning January 1, 2029, all policy liabilities with an effective date of December
31, 2024, or earlier are subject to the MICAT rules under Section 3.2.1.2. All remaining policy liabilities effective between January 1, 2025, to December 31, 2025, may be subject to MICAT rules under Section 3.2.1.1.
v. Beginning January 1, 2030, all capital required for liabilities for remaining coverage
for multi-unit residential mortgage in-force insurance policies are subject to the 34 Pre-sale contracts must be legally binding written contracts and the purchaser/renter must have made a substantial cash deposit which is subject to forfeiture if the contract is terminated.
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 38
MICAT rules under Section 3.2.1.2. The transition period closes, and the MICAT rules under Section 3.2.1.1 are no longer applicable for any policy liabilities. C.) Earlier adoption of the MICAT rules under Section 3.2.1.2. are permitted starting January 1, 2026.
3.2.2. Capital required for liabilities for incurred claims
The capital required for liabilities for incurred claims associated with multi-unit residential exposures is calculated by multiplying the liabilities for incurred claims associated with multiunit residential exposures by 20%.
3.2.3. Capital required for the loss components of liabilities for remaining coverage
The capital required for the loss components of liabilities for remaining coverage associated with multi-unit residential exposures is calculated by multiplying the loss component amounts associated with multi-unit residential exposures by 40%.
3.3 Additional policy provisions
This section describes the calculation of the additional policy provision for residential and multiunit residential exposures. An additional policy provision must be determined for every mortgage that was expected to be in-force on the reporting date based on the mortgage’s original amortization schedule, regardless of whether the mortgage is still in-force on the reporting date. When calculating the capital required at the supervisory target, the total of the additional policy provisions for residential and multi-unit residential mortgages is to be deducted from the capital required for liabilities for remaining coverage that is determined in sections 3.1.1, and 3.2.1.2 and then added to the capital required for additional policy provisions. The total of the additional policy provisions for multi-unit exposures that are subject to the MICAT rules under Section 3.2.1.1. is to be multiplied by 1.25 and added to the capital required for additional policy provisions. The additional policy provision for a mortgage loan is given by the following table:
Additional Policy Reserve as Per Cent of Single Premium Original Term of the Policy Completed Policy Duration in Years Up to 5 years Over 5 to 10 years Over 10 to 15 years Over 15 years 1 2.0 3.0 4.0 4.0 2 1.0 2.0 4.0 4.0 3 0.5 1.0 3.5 4.0 4 1.0 3.0 5.5 5 0.5 3.0 6.0
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 39
Additional Policy Reserve as Per Cent of Single Premium Original Term of the Policy Completed Policy Duration in Years Up to 5 years Over 5 to 10 years Over 10 to 15 years Over 15 years 6 0.5 2.0 5.0 7 0.0 1.0 3.5 8 1.0 2.0 9 1.0 1.5 10 1.0 1.5 11 0.0 1.0 12 1.0 13 0.5 14 0.5 15 0.5 16 0.5 17 0.5 18 0.5 19 0.5 ≥ 20 0.0
Appendix 3-A. Determining supplementary capital requirement indicators
This appendix describes how insurers are to calculate the supplementary capital requirement indicators (SCRIs) for the purpose of determining whether a supplementary capital requirement is applied to a given residential mortgage loan. The data sources necessary to calculate the SCRIs are outlined in Section 1 of this appendix. The Teranet – National Bank National Composite House Price Index (“Teranet index”) is used to measure house prices and Statistics Canada household disposable income and population data are used to measure per capita income. An SCRI is to be determined for 11 metropolitan areas in the Teranet index. For each metropolitan area, an SCRI is calculated on a quarterly basis and is determined as follows:
H
× s
I where:
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 40
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 41
3. Calculation of per capita income
The per capita income for use in the SCRI is determined as:
Per capita income =
1,000 × Household disposable income
Population where:
i. The “Household disposable income” is a quarterly data series from the table 36-10-0112-
01. The data characteristics for this table necessary to calculate the per capita income are:
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 42
Metropolitan area Scaling factor
Calgary 2,500
Edmonton 2,100
Halifax 1,900
Hamilton 2,000
Montréal 2,500
Ottawa-Gatineau 2,400
Québec 1,700
Toronto 3,300
Vancouver 4,200
Victoria 3,300
Winnipeg 1,400
5. Threshold values
Each metropolitan area has its own threshold value that has been determined by OSFI using an algorithm that ensured consistency across metropolitan areas. Threshold values will remain stable over time, but are subject to periodic review. The following table shows the threshold values for each metropolitan area used to determine whether a newly originated mortgage in a given area is subject to a supplementary capital requirement. For each metropolitan area, if the calculated SCRI has breached its threshold value, then effective the beginning of the next quarterly fiscal reporting period, any mortgage loan originated in that area is subject to the supplementary capital requirement for the life of the loan. Threshold Values by Metropolitan Area Metropolitan area Threshold values Calgary 10.0 Edmonton 9.0 Halifax 8.5 Hamilton 9.5 Montréal 11.0 Ottawa-Gatineau 11.0 Québec 9.0 Toronto 14.0 Vancouver 18.5 Victoria 12.5 Winnipeg 7.5 Exposures in those areas remain subject to the supplementary capital requirements until the SCRI for a metropolitan area falls below the threshold value. In this case, the supplementary capital requirement would no longer be required for mortgage loans originated in the next quarterly fiscal reporting period.
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 43
6. Timing of the calculation
The following table provides a summary of the timing for performing the SCRI calculation and determining when the supplementary capital requirement applies. Timing for performing and applying SCRI calculation As at date for data SCRI calculations performed36 Application of supplementary capital requirements December 31 March 1 April 1 March 31 June 1 July 1 June 30 September 1 October 1 September 30 December 1 January 1
7. Example
This example illustrates how to calculate the SCRIs for Q4 2015 for the 11 metropolitan areas in the Teranet index. Step 1: Calculation of metropolitan area smoothed Teranet indices The following table provides the monthly Teranet values for the 11 metropolitan areas for 2015 as well as the December 2015 smoothed values (determined as the 12-month average of the January through December 2015 values). Teranet Values of the 11 Metropolitan Areas for 2015 2015 Calgary Edmonton Halifax Hamilton Montréal OttawaGatineau January 184.68 182.74 137.60 157.15 146.81 140.58 February 184.10 181.24 136.72 157.60 146.42 137.65 March 184.45 181.93 138.36 157.07 147.49 137.20 April 184.85 183.11 139.39 156.99 148.92 136.30 May 178.84 184.28 142.62 157.97 151.34 138.30 June 183.23 184.27 142.05 161.85 152.61 140.58 July 179.75 182.93 140.56 166.27 153.10 143.75 August 186.70 182.02 140.05 170.33 152.35 144.64 September 187.98 182.04 142.71 172.53 151.72 143.88 36 The dates presented are approximate; they may vary according to the table 36-10-0112-01 release date.
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 44
October 186.51 182.33 140.30 172.08 151.32 143.00 November 184.20 180.77 138.32 172.52 151.65 141.22 December 181.10 180.21 140.45 171.51 149.74 139.19 December smoothed
183.87 182.32 139.93 164.49 150.29 140.52
Teranet Values for 11 Metropolitan Areas for 2015, continued 2015 Québec Toronto Vancouver Victoria Winnipeg January 173.71 166.18 185.94 139.41 194.74 February 173.46 165.99 188.66 140.04 192.88 March 176.09 166.42 189.14 139.70 193.33 April 179.12 166.44 189.20 139.47 197.00 May 180.71 169.10 191.58 140.19 197.39 June 179.74 171.86 193.90 143.87 196.80 July 178.61 175.91 196.94 146.36 195.89 August 176.59 178.75 198.08 145.89 197.08 September 173.15 179.79 201.20 147.08 194.32 October 172.84 180.35 202.42 147.55 198.09 November 173.58 180.53 205.15 150.15 197.48 December 174.52 180.82 207.40 150.17 194.55 December smoothed
176.01 173.51 195.80 144.16 195.80
Step 2: Calculation of per capita income
Given the following values for the data series “Household disposable income” (table 36-10- 0112-01) and “Population” data series (table 14-10-0287-01), the per capita income for Q4 2015 is determined as follows. The average population has to be rounded to the first decimal. Household Disposable Income and Population Data for 2015 Data type 2015 Statistics Canada data estimates Household disposable income Q4 1,131,400 Population October 29,377.5 Population November 29,401.2 Population December 29,419.0 Population Q4 (Average of October – December) 29,399.2 Then the per capita income for Q4 2015 is:
1,000 × 1,131,400
= 38,484.0 29,399.2
Chapter 3. Insurance Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 45
The per capita income value has to be rounded to the first decimal.
Step 3: Calculation of metropolitan area SCRIs Using the December 2015 smoothed Teranet values for the 11 metropolitan areas and the per capita income for Q4 2015, the SCRIs before and after scaling as at Q4 2015 are included in the
table below. The SCRI before scaling has to be rounded to the fifth decimal, while the final
SCRI has to be rounded to the second decimal.
SCRI Calculation for Q4 2015
Metropolitan area
Dec. 2015
Teranet index smoothed
(H)
Q4 2015
SCRI before scaling
(
𝑯
𝑰
)
Scaling Factor
(s)
Q4 2015
SCRIs
(
𝑯
𝑰
× 𝒔)
Calgary 183.87 0.00478 2,500 11.95
Edmonton 182.32 0.00474 2,100 9.95
Halifax 139.93 0.00364 1,900 6.92
Hamilton 164.49 0.00427 2,000 8.54
Montréal 150.29 0.00391 2,500 9.78
Ottawa-Gatineau 140.52 0.00365 2,400 8.76
Québec 176.01 0.00457 1,700 7.77
Toronto 173.51 0.00451 3,300 14.88
Vancouver 195.80 0.00509 4,200 21.38
Victoria 144.16 0.00375 3,300 12.38
Winnipeg 195.80 0.00509 1,400 7.13
Where for example the Calgary Q4 2015 SCRI before scaling ( H I ) is determined as:
183.87
= 0.00478 38,484.0
And the SCRI would be calculated as:
0.00478 × 2,500 = 11.95
As the threshold value is set at 10.0 for Calgary, had this Guideline been in effect in Q2-2016, the supplementary capital requirements would therefore have applied for the life of a mortgage loan originated in the Calgary metropolitan area during that reporting quarter.
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 46
Chapter 4. Credit Risk
In the context of this guideline, credit risk refers to any default risk as defined in this chapter other than the borrower default risk associated with mortgage insurance which is covered in
chapter 3, Insurance Risk.
Credit risk is the risk of loss arising from a counterparty’s potential inability or unwillingness to fully meet its contractual obligations due to an insurer. Exposure to this risk occurs any time funds are extended, committed, or invested through actual or implied contractual agreements. Components of credit risk include loan loss/principal risk, pre-settlement/replacement risk and settlement risk. Counterparties include issuers, debtors, borrowers, brokers, policyholders, and guarantors. All on- and off-balance sheet exposures are subject to a specific risk factor that either: 1) corresponds to the external credit rating of the counterparty or issuer or 2) represents a prescribed factor determined by OSFI. To determine the capital requirements for balance sheet assets, factors are applied to the balance sheet values or other specified values of these assets. To determine the capital requirements for off-balance sheet exposures, factors are applied to the exposure amounts determined according to the section 4.2. Collateral and other forms of credit risk mitigators may be used to reduce the exposure. No risk factors are applied to assets deducted from capital available (reference section 2.3). The resulting amounts are summed to arrive at the credit risk capital requirements. In respect of invested assets, insurers must comply with OSFI’s Guideline B-2 Property and Casualty Large Insurance Exposures and Investment Concentration.
4.1. Capital Requirements for Balance Sheet Assets
For the purpose of calculating the capital requirements for credit risk, balance sheet assets should be valued at their balance sheet carrying amounts, with the following exceptions:
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 47
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 48 currency. Canadian currency ratings, if separate, should only be used to determine the capital requirements for assets or obligations denominated in Canadian currency. The following additional conditions apply to the use of ratings:
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 49
Factors for Long-Term Obligations
Rating 1 year or less remaining term to maturity Greater than 1 year up to and including 5 years remaining term to maturity Greater than 5 years remaining term to maturity AAA 0.25% 0.50% 1.25% AA+ to AA- 0.25% 1.00% 1.75% A+ to A- 0.75% 1.75% 3.00% BBB+ to BBB- 1.50% 3.75% 4.75% BB+ to BB- 3.75% 7.75% 8.00% B+ to B- 7.50% 10.50% 10.50% Unrated 6.00% 8.00% 10.00% Below B- 15.50% 18.00% 18.00%
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 50
Factors for short-term obligations
Rating Factor
A-1, F1, P-1, R-1 or equivalent 0.25%
A-2, F2, P-2, R-2 or equivalent 0.50%
A-3, F3, P-3, R-3 or equivalent 2.00%
Unrated 6.00%
All other ratings, including non-prime and B or C ratings 8.00%
4.1.2.3 Asset-backed securities
The category of asset-backed securities encompasses all securitizations, including collateralized mortgage obligations and mortgage-backed securities, as well as other exposures that result from stratifying or tranching an underlying credit exposure. For exposures that arise as a result of asset securitization transactions, insurers should refer to Guideline B-5: Asset Securitization to determine whether there are functions provided (e.g., credit enhancement and liquidity facilities) that require capital for credit risk. National Housing Act (NHA) mortgage-backed securities:
NHA mortgage-backed securities that are guaranteed by Canada Mortgage Housing Corporation (CMHC) receive a factor of 0% to recognize the fact that obligations incurred by CMHC are legal obligations of the Government of Canada. Other asset-backed securities:
The capital requirements for all other asset-backed securities are based on their external ratings. In order for an insurer to use external ratings to determine a capital requirement, the insurer must comply with all of the operational requirements for the use of ratings in Guideline B-5: Asset Securitization. For asset-backed securities (other than resecuritizations) rated BBB or higher, the capital requirement is the same as the requirement specified in subsection 4.1.2.1 for a long-term obligation having the same rating and maturity as the asset-backed security. If an asset-backed security is rated BB, an insurer may recognize the rating only if it is a third-party investor in the security. The credit risk factor for an asset-backed security (other than a resecuritization) rated BB in which a company is a third-party investor is 300% of the requirement for a long-term obligation rated BB having the same rating and maturity as the security. The credit risk factors for short-term asset-backed securities (other than resecuritizations) rated A-3 or higher are the same as those in subsection 4.1.2.2 for short-term obligations having the same rating. The credit risk factor for any resecuritization rated BBB or higher is 200% of the risk factor applicable to an asset-backed security having the same rating and maturity as the resecuritization. The credit risk factor for securitization exposures classified within the highest risk category of securitization exposures in Guideline B-5: Asset Securitization, is 60%.
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 51
The credit risk factor for any asset-backed security that is not mentioned above (including unrated securities and any asset-backed security that is rated lower than BB) is 60%.
4.1.2.4 Preferred shares
Risk factors for preferred shares
Rating Factor
AAA, AA+ to AA-, Pfd-1, P-1 or equivalent 3.00% A+ to A-, Pfd-2, P-2 or equivalent 5.00% BBB+ to BBB-, Pfd-3, P-3 or equivalent 10.00% BB+ to BB-, Pfd-4, P-4 or equivalent 20.00% B+ or lower, Pfd-5, P-5 or equivalent or unrated 30.00%
4.1.2.5 Other balance sheet assets
Other risk factors for balance sheet assets
Factor Asset
0.00% • Cash held on the company’s own premises,
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 52
0.25% • Demand deposits, certificates of deposit, drafts, checks, acceptances and similar obligations that have an original maturity of less than three months, and that are drawn on regulated deposit-taking institutions subject to the solvency requirements of the Basel Framework. (Note: where the maturity of the asset is longer than three months, the risk factor related to the credit rating of the regulated deposit-taking institution would apply instead.) 2.50% • Investment income due and accrued. 4% • First mortgages on one- to four-unit residential dwellings. 5% • Receivables, outstanding less than 60 days, from agents, brokers, non-qualifying subsidiaries, associates, joint ventures, and policyholders, including instalment premiums and other receivables. 10% • Receivables, outstanding 60 days or more, from agents, brokers, non-qualifying subsidiaries, associates, joint ventures and policyholders, including instalment premiums and other receivables,
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 53
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 54
4.2.1.1. Derivatives
The credit equivalent amount for derivatives is the positive replacement cost (obtained by “marking to market”) plus an amount for potential future credit exposure (an “add-on” factor). Derivatives include forwards, futures, swaps, purchased options, and other similar contracts. Insurers are not exposed to credit risk for the full face value of these contracts (notional principal amount); only to the potential cost of replacing the cash flow (on contracts showing a positive value) if the counterparty defaults. The credit equivalent amounts are assigned the risk factor appropriate to the counterparty in order to calculate the capital requirement. The credit equivalent amount depends on the maturity of the contract and the volatility of the underlying instrument. It is calculated by adding:
i.) the total replacement cost (obtained by "marking to market") of all contracts with positive value; and ii.) an amount for potential future credit exposure (or "add-on"). This is calculated by multiplying the notional principal amount by the following factors:
Derivative “Add-On” Factors
Residual Maturity
(01)
Interest Rate
(02)
Exchange
Rate and Gold
(03)
Equity
(04)
Precious Metals except Gold
(05)
Other
Instruments
(06)
One year or less 0.0% 1.0% 6.0% 7.0% 10.0%
One year to five years 0.5% 5.0% 8.0% 7.0% 12.0% Over five years 1.5% 7.5% 10.0% 8.0% 15.0% Notes:
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 55
6. The add-ons are based on effective rather than stated notional amounts. In the event that
the stated notional amount is leveraged or enhanced by the structure of the transaction, companies must use the actual or effective notional amount when determining potential future exposure. For example, a stated notional amount of $1 million with payments calculated at two times LIBOR would have an effective notional amount of $2 million.
7. Potential credit exposure is to be calculated for all over-the-counter (OTC) contracts
(with the exception of single currency floating/floating interest rate swaps), regardless of whether the replacement cost is positive or negative. No add-on for potential future exposure is required for credit derivatives. The credit equivalent amount for a credit derivative is equal to the greater of its replacement cost or zero.
4.2.1.2. Other exposures
Commitments
A commitment involves an obligation (with or without a material adverse change or similar clause) of the insurer to fund its customer in the normal course of business should the customer seek to draw down the commitment. This includes:
i.) extending credit in the form of loans or participations in loans, lease financing receivables, mortgages or loan substitutes; or ii.) purchasing loans, securities, or other assets. Normally, commitments involve a written contract or agreement and a commitment fee or some other form of consideration. The maturity of a commitment should be measured from the date when the commitment was accepted by the customer, regardless of whether the commitment is revocable or irrevocable, conditional or unconditional, until the earliest date on which:
i.) the commitment is scheduled to expire, or ii.) the insurer can, at its option, unconditionally cancel the commitment. Repurchase and reverse repurchase agreements A securities repurchase (repo) is an agreement whereby a transferor agrees to sell securities at a specified price and repurchase the securities on a specified date and at a specified price. Since the transaction is regarded as a financing transaction for accounting purposes, the securities remain on the balance sheet. Given that these securities are temporarily assigned to another party, the factor accorded to the asset should be the higher of the factor of the security and the factor of the counterparty to the transaction (net of any eligible collateral). A reverse repo agreement is the opposite of a repo agreement, and involves the purchase and subsequent sale of a security. Reverse repos are treated as collateralized loans, reflecting the economic reality of the transaction. The risk is therefore to be measured as an exposure to the counterparty. Where the asset temporarily acquired is a security that attracts a preferential factor, this would be recognized as collateral and the factor would be reduced accordingly.
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 56
Guarantees provided in securities lending
In securities lending, insurers can act as principal to the transaction by lending their own securities or as agent by lending securities on behalf of clients. When the insurer lends its own securities, the risk factor is the higher of:
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 57
Credit Conversion Factors
Factor Instrument
100% • Direct credit substitutes (general guarantees of indebtedness and guarantee-type instruments, including standby letters of credit and nonowned deposits serving as financial guarantees for, or supporting, loans and securities).
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 58
Risk factors for structured settlements, which are considered long-term exposures, are based on the credit rating of the counterparty from which the annuity is purchased. The risk factors are as follows:
Risk Factors for Structured Settlements
Rating Risk factor
Rated A- and higher 2%
Rated BBB+ to B- 8%
Unrated 10%
Below B- 18%
If the structured settlement is not rated by one of the four rating agencies listed in section 4.1.1, an insurer may use a credit rating from another reputable rating agency. The use of an alternative rating agency must comply with all the criteria around the use of ratings specified in section 4.1.1, including a consistent use of the same rating agency in order to assign a risk factor based on the credit rating of the annuity underwriter.
4.3. Capital Treatment of Collateral and Guarantees
4.3.1. Collateral
A collateralized transaction is one in which:
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 59
4.3.2. Guarantees
Investments (principal and interest) or exposures that have been explicitly, directly, irrevocably and unconditionally guaranteed by a guarantor whose long-term issuer credit rating is A- and higher, may attract the risk factor allocated to a direct claim on the guarantor where the desired effect is to reduce the risk exposure. Thus only guarantees40 issued by entities with a lower risk factor than the underlying counterparty will lead to reduced capital requirements. To be eligible, guarantees must be legally enforceable. Where the recovery of losses on a loan, financial lease agreement, security or exposure is partially guaranteed, only the part that is guaranteed is to be weighted according to the risk factor of the guarantor (see examples below). The uncovered portion retains the risk factor of the underlying counterparty. All criteria in section 4.1 around the use of ratings remain applicable to guarantees. Where a rating is not available for the investment, exposure, or guarantor where applicable, no reduction in capital required is permitted. An insurer may not recognize a guarantee provided by a related party (parent, subsidiary or associate) of the insurer. This treatment follows the principle that guarantees within a corporate group are not a substitute for capital. The effects of credit protection may not be double counted. Therefore, no capital recognition is given to credit protection on claims for which an issue-specific rating is used that already reflects that protection. To be eligible, a guarantee must cover the full term of the exposure, i.e. no recognition will be given to a guarantee if there is a maturity mismatch41 .
4.3.2.1. Additional requirements for guarantees
The following conditions must be satisfied in order for a guarantee to be recognized:
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 60
3. Except as noted in the following sentence, the guarantee covers all types of payments the
underlying obligor is expected to make under the documentation governing the transaction, for example notional amount, margin payments etc. Where a guarantee covers payment of principal only, interest and other uncovered payments should be treated as an unsecured amount in accordance with section 4.1.2. Example 4-1: Credit risk exposure. To record a $100,000 bond rated AAA due in 10 years that has a government guarantee of 90%, the insurer would report a balance sheet value of $90,000 ($100,000 x 90%) in the 0% risk weighted category and a balance value of $10,000 ($100,000 - $90,000) in the AAA category under bonds expiring or redeemable in more than five years. The capital required in the 0% risk weighted category is $0 ($90,000 x 0.0%). The capital required in the AAA category is $125 ($10,000 x 1.25%) for a total capital requirement of $125. An example of the calculation, assuming no other assets, is provided in the chart below. Example of the credit risk calculation, assuming no other assets. Rating / Risk Factor Factor (%) Balance Sheet Value Capital Required 0% risk factor 0.0% $90,000 $0 Rating: AAA 1.25% $10,000 $125 Total $100,000 $125 Example 4-2: Type 1 structured settlement. To record a $300,000 Type 1 structured settlement rated BBB+ to B-, backed by collateral or a guarantee of $200,000 from a counterparty rated A- or higher, the insurer would report a credit equivalent amount of $300,000 and collateral and guarantees of negative $200,000 in the BBB+ to B- category, and collateral and guarantees of $200,000 in the A- and higher category. The capital required in the BBB+ to B- category is $4,000 (($300,000 - $200,000) x 50% x 8%). The capital required in the A- and higher category is $500 ($200,000 x 50% x 0.5%) for a total capital requirement of $4,500. An example of the calculation, assuming no other exposures, is provided in the table below.
Chapter 4. Credit Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 61
Example of the structured settlement calculation, assuming no other exposures:
Rating / Risk Factor
Credit
Equivalent
Amount
(01)
Collateral and
Guarantees
(02)
Credit
Conversion
Factor
(03)
Risk Factor
(04)
Capital
Required
(05)
0% risk factor n/a
Rated A- and higher n/a $200,000 50% 0.5% $500 Rated BBB+ to B- $300,000 ($200,000) 50% 8.0% $4,000 Total n/a $4,500
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 62
Chapter 5. Market Risk
Market risk arises from potential changes in rates or prices in various markets such as for interest rates, foreign exchange rates, equities, real estate, and other market risk exposures. Exposure to this risk results from trading, investing, and other business activities, which create on- and offbalance sheet positions. Investments in mutual funds or other similar assets must be broken down by type of investment (bonds, preferred shares, common shares, etc.) and assigned the appropriate risk factor relating to the investment. If these investments are not reported on a prorated basis, then the factor of the riskiest asset held in the fund is assigned to the entire investment.
5.1. Interest Rate Risk
Interest rate risk represents the risk of economic loss resulting from market changes in interest rates and the impact on interest rate sensitive assets and liabilities. Interest rate risk arises due to the volatility and uncertainty of future interest rates. Assets and liabilities whose value depends on interest rates are affected. Interest rate sensitive assets include fixed income assets. Interest rate sensitive liabilities include those for which the values are determined using a discount rate. To compute the interest rate risk margin, a duration and an interest rate shock factor are applied to the fair value of interest rate sensitive assets and liabilities. The interest rate risk margin is the difference between the change in the value of interest rate sensitive assets and the change in the value of interest rate sensitive liabilities, taking into account the change in the value of recognized interest rate derivative contracts, as appropriate.
5.1.1. General requirements
The components used to calculate the interest rate risk margin are as follows.
5.1.1.1. Interest rate sensitive assets
The interest rate sensitive assets to be included in the calculation of the interest rate margin are those for which their fair value will change with movements in interest rates. Although certain assets, for example loans and bonds held to maturity, may be reported on the balance sheet on an amortized cost basis, their economic value, and changes in that value, are to be considered for interest rate risk margin purposes. Interest rate sensitive assets include:
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 63
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 64
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 65
The portfolio duration (modified or effective) can be obtained by calculating the weighted average of the duration of the assets or the liabilities in the portfolio. The dollar duration of an asset or liability is the change in dollar value of an asset or liability for a given change in interest rates.
5.1.1.5. Modified duration
Modified duration is defined as the approximate percentage change in the present value of cash flows for a 100 basis point change in the annually compounded yield rate, assuming that expected cash flows do not change when interest rates change. Modified duration can be written as:
Modified = 1 x Ʃ t x PVCFt duration 1+Yield Market Value where, Yield = the annually compounded yield to maturity of the cash flows, PVCFt = the present value of the cash flow at time t discounted at the yield rate, and the sum in the numerator is taken over all times t at which a cash flow occurs.
5.1.1.6. Effective duration
Effective duration is a duration measure in which recognition is given to the fact that interest rate changes may change the expected cash flows. Although modified duration will give the same estimate of the percentage fair value change for an option-free series of cash flows, the more appropriate measure for any series of cash flows with an embedded option is effective duration. Effective duration is determined as follows:
Effective = Fair value if yields decline – fair value if yields rise duration 2 x (initial price) x (change in yield in decimal) where, ∆y = change in yield in decimal V0 = initial fair value V- = fair value if yields decline by ∆y V+ = fair value if yields increase by ∆y, then effective duration is as follows:
V- - V+
2 x (V0) x (∆y)
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 66
5.1.1.7. Portfolio duration
The duration of a portfolio of interest rate sensitive assets or liabilities is to be determined by calculating the weighted average of the duration of the assets or liabilities in the portfolio. The weight is the proportion of the portfolio that a security comprises. Mathematically, a portfolio’s duration is calculated as follows:
w1D1 + w2D2 + w3D3 + … + wkDK where, wi = fair value of security i/fair value of the portfolio Di = duration of security i K = number of securities in the portfolio.
5.1.1.8. Dollar fair value change
Modified and effective duration are related to percentage fair value changes. The interest rate risk requirements depend on determining the adjustment to the fair value of interest rate sensitive assets and liabilities for dollar fair value changes. The dollar fair value change can be measured by multiplying duration by the dollar fair value and the number of basis points (in decimal form). In other words, Dollar fair value change = duration x dollar fair value x interest rate change (in decimal)
5.1.1.9. Duration of allowable interest rate derivatives
Effective duration is the appropriate measure that should be used when assets or liabilities have embedded options. For portfolios with eligible plain-vanilla interest rate derivatives, insurers should be using effective dollar duration because the insurer is hedging the dollar interest rate risk exposure. Example 5-1: Effective dollar duration of a swap Assuming an insurer has a longer duration for its interest rate sensitive assets and a shorter duration for its interest rate sensitive liabilities, the current dollar duration position of the insurer, prior to taking into consideration any interest rate derivatives, is effectively as follows:
Insurer’s dollar duration = dollar duration of assets – dollar duration of liabilities > 0 The insurer enters into a single-currency interest rate swap in which it pays fixed-rate and receives floating-rate. The dollar duration of a swap for a fixed-rate payer can be broken down as follows:
Effective dollar duration of a swap for a fixed-rate payer = effective dollar duration of a floating-rate bond – effective dollar duration of a fixed rate bond
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 67
Assuming the dollar duration of the floating-rate bond is near zero, then Effective dollar duration of a swap for a fixed-rate payer = 0 – effective dollar duration of a fixed-rate bond The dollar duration of the swap position is negative; therefore, adding the swap position reduces the company’s dollar duration of assets and moves the insurer’s overall dollar duration position closer to zero.
5.1.2. Interest rate risk margin
The interest rate risk margin is determined by measuring the economic impact on the insurer of a ∆y change in interest rates. The ∆y interest rate shock factor is 1.25% (∆y = 0.0125). A. The estimated change in the interest rate sensitive asset portfolio for an interest rate shock factor increase of ∆y is determined as follows:
Dollar fair value change of the interest rate sensitive asset portfolio = ( Duration of interest rate sensitive asset portfolio ) x ∆y x ( Fair value of interest rate sensitive asset portfolio ) B. The change in the interest rate sensitive liabilities for an interest rate shock factor increase of ∆y is determined as follows:
Dollar fair value change of the interest rate sensitive liabilities = ( Duration of interest rate sensitive liabilities ) x ∆y x ( Fair value of interest rate sensitive liabilities )
C. The change in the allowable interest rate derivatives for the interest rate shock factor
increase of ∆y is determined as follows:
Effective dollar duration of the allowable interest rate derivatives portfolio = sum of the effective dollar duration of the allowable interest rate derivatives for a ∆y increase in interest rates D. The capital requirement for an interest rate shock factor increase of ∆y is determined as the greater of zero and A – B + C. E. Steps A through C are repeated for an interest rate shock factor decrease of ∆y (i.e. -∆y) and the capital requirement for an interest rate decrease of ∆y is the greater of zero and A – B + C. F. The interest rate risk margin is then determined as the maximum of D or E.
5.2. Foreign Exchange Risk
The foreign exchange risk margin is intended to cover the risk of loss resulting from fluctuations in currency exchange rates and is applied to the entire business activity of the insurer.
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 68
5.2.1. General requirements
Two steps are necessary to calculate the foreign exchange risk margin. The first is to measure the exposure in each currency position. The second is to calculate the capital requirement for the portfolio of positions in different currencies. The foreign exchange risk margin is 10% of the greater of:
i.) the aggregate net long positions in each currency, adjusted by effective allowable foreign exchange rate hedges if any are used, and ii.) the aggregate net short positions in each currency, adjusted by effective allowable foreign exchange rate hedges if any are used, where effective allowable foreign exchange rate hedges are limited to plain-vanilla foreign currency derivatives such as futures and forward foreign currency contracts and currency swaps. Investments in mutual funds and other similar assets should be broken down by type of investment (bonds, preferred shares, common shares, etc.) for calculating foreign exchange risk margin. The assets in the fund that are denominated in a foreign currency are to be included in the calculation to determine the capital requirement for each currency position. In cases where a claim liability is recorded in Canadian dollars but the settlement of the claim will be made in a foreign currency, the liability must be included in the calculation of the foreign exchange risk margin.
5.2.2. Foreign exchange risk margin
Step 1: Measuring the exposure in a single currency The net open position for each currency is calculated by summing:
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 69
Adjustments:
For insurers with foreign operations, those items that are currently deducted from capital available in calculating the MICAT ratio and are denominated in the corresponding currency may be excluded from the calculation of net open currency positions, to a maximum of zero. For example:
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 70
5.2.2.1. Allowable foreign currency hedges
Foreign currency derivatives are those for which the cash flows are dependent on future foreign exchange rates. They may be used to hedge an insurer’s foreign exchange risk and as such, may be recognized in the determination of the capital requirement for foreign exchange risk, subject to the following requirements. Only effective hedges that offset the changes in fair value of the hedged item may be included in the foreign exchange risk calculation. The company must be able to demonstrate to OSFI the effectiveness of its foreign exchange hedges. Companies with foreign currency derivatives on their balance sheet must be able to demonstrate that the addition of such derivatives does not result in increased risk. If the insurer cannot demonstrate that the derivatives do not result in increased risk, then OSFI may require additional capital. Only plain-vanilla foreign currency derivatives may be recognized in the calculation of the foreign exchange capital requirement. Plain-vanilla foreign currency derivative instruments are limited to the following:
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 71 selection of positions that are only beneficial to reducing the overall position will not be permitted for capital purposes.
5.3. Equity Risk
Equity risk is the risk of economic loss due to fluctuations in the value of common shares and other equity securities.
5.3.1. Common shares and joint ventures
A 30% risk factor applies to investments in common shares and joint ventures in which a company holds less than or equal to 10% ownership interest.
5.3.2. Futures, forwards, and swaps
Equity futures, forwards, and swaps attract a 30% risk factor, which is applied to the market value of the underlying equity security or index. Where a swap exchanges a return on an equity security or index for a return on a different equity security or index, a 30% risk factor applies to the market value of both equity securities or indices for which the returns are being exchanged. Example:
An insurer has entered into a one-year swap during which it will pay the 3-month Canadian Dollar Offered Rate (CDOR) plus fees, and receive the total return on a notional index of equities that was worth 100 at the time of inception. The index of equities is currently worth 110. A 30% equity risk charge will apply to 110 for the long position in the index, but no capital charge will be required on the short position in the bond because such a position is not subject to an equity risk charge. In addition to the capital requirements set out in this section, futures, forwards, and swaps are subject to credit risk requirements. Refer to section 4.2 for further details.
5.3.3. Short positions
The capital requirements for short positions in common shares, equity futures, forwards, and swaps that do not wholly or partially offset a long equity position are determined by assuming the instrument is held long and then applying the corresponding risk factor. Common shares, futures, forwards, and swaps eligible for offset recognition and the corresponding capital treatment are described in section 5.3.4.
5.3.4. Recognition of equity hedges
Equity futures, forwards, and swaps, as well as common shares can be used to wholly or partially hedge an equity exposure. Insurers may recognize qualifying equity hedges in the calculation of the capital requirements in accordance with section 5.3.4.1 and 5.3.4.2.
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 72
Insurers must document the equity hedging strategies employed and demonstrate that the hedging strategies decrease the overall risk. The documentation must be available for review, upon request. If the insurer cannot demonstrate, to the satisfaction of the Superintendent, that the hedging strategies result in decreased overall risk, then additional capital above that calculated as per sections 5.3.4.1 and 5.3.4.2 may be required, at the discretion of the Superintendent.45
For hedges to qualify, they must be issued by an entity that:
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 73 where:
A represents the historical correlation between the returns on the portfolio of instruments being hedged and the returns on the portfolio of hedging instruments B represents the minimum of [standard deviation of returns on the portfolio of instruments being hedged, standard deviation of returns on the portfolio of hedging instruments] C represents the maximum of [standard deviation of returns on the portfolio of instruments being hedged, standard deviation of returns on the portfolio of hedging instruments] The historical correlations and standard deviations must be calculated on a weekly basis, covering the previous 52-week period. The returns on each portfolio of hedging instruments used to calculate the components of the CF must be determined by assuming that the portfolio is held long. The returns on each portfolio must be measured net of additional capital injections, and must include the returns on each component of the portfolio. For example, the returns on both the long and short legs of a total return swap included in a portfolio must be reflected in the calculation of the CF. The CF for the previous 52 weeks is required to be calculated for each of the past four quarters. The Correlation Factor is the lowest of the four CFs calculated and is used to calculate capital requirements. In order for the portfolios to obtain the capital treatment set out in this section, the following conditions must be met:
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 74
Suppose a portfolio of instruments is valued at $200 and is paired with another portfolio of instruments as part of a qualifying equity hedge. Assuming that the second portfolio is worth $190 and that the Correlation Factor between the two portfolios is 0.95, the total capital charge for both portfolios will be 190 × 5% × 1.5 + $10 × 30% = $17.25. Portfolios that were established less than two years prior to the reporting date attract the following capital treatment:
Chapter 5. Market Risk
MI A Mortgage Insurer Capital Adequacy Test
November 2024 Page 75
5.5. Other Market Risk Exposures
Other market risk exposures include assets that fall in the category “other assets,” for example, equipment, that are exposed to asset value fluctuations that may result in the value realized upon disposal being less than the balance sheet carrying value. A 10% risk factor applies to other assets as part of the total capital requirements for market risk.
Chapter 6. Operational Risk
MI A
Mortgage Insurer Capital Adequacy Test
November 2024 Page 76
Chapter 6. Operational Risk
Operational risk is the risk of loss due to inadequate or failed internal processes, people and systems, or external events. It includes legal risk but does not include strategic or reputational risk. The capital required for an insurer’s operational risk is calculated using the following formula:
Operational risk capital required = 20% × [TC – SC] where:
TC is the insurer’s total capital required, before the calculation of the requirement for operational risk. SC is, if applicable, the supplementary capital required for insurance risk (reference subsection 3.1.1.3). -END-
Note from RegAlert. AI assistants can read this document in full, and search 70,000+ more, through the RegAlert MCP connector (https://mcp.regalert.today/mcp). Free with an account. How to connect ChatGPT, Claude or Cursor.
Source: Office of the Superintendent of Financial Institutions — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works