2025-02-18
Added · Updated
The Financial Services Commission of Jamaica issued this guideline to establish mandatory requirements for the valuation of actuarial reserves and other policy liabilities by life insurers. It mandates that Appointed Actuaries submit a comprehensive Appointed Actuary’s Report within ninety days of the financial year-end, detailing methodologies, assumptions, and data quality assessments. The document further outlines specific filing formats, review processes, and the regulator's authority to reject inappropriate assumptions or require re-filings.
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AR-GUID-2025/01-0002
GUIDELINE FOR APPOINTED ACTUARIES
Requirements for the Valuation of Actuarial Reserves and Other Policy Liabilities for Life Insurers FINANCIAL SERVICES COMMISSION October 2024
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Table of Contents
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2.4.2. Product Type Reporting............................................................................................................22
2.4.3. Product Descriptions in respect of actuarial reserves and other policy liabilities not valued
using IFRS 17.............................................................................................................................................27
2.5. Additional Liability Disclosures.........................................................................................................27
2.5.1. Scenario Testing of Discount Rates..........................................................................................27
2.5.2. Bulk Provision ...........................................................................................................................28
2.5.3. Reinsurance Program ...............................................................................................................29
2.5.4. Liability Roll Forward ................................................................................................................30
2.5.5. Currency Exchange Rates .........................................................................................................31
2.6. Asset Liability Management (ALM) ..................................................................................................31
2.7. Other Disclosure Requirements.......................................................................................................32
2.7.1. New Appointment....................................................................................................................32
2.7.2. Annual Required Reporting to the Board or Audit Committee................................................33
2.7.3. Continuing Professional Development Requirements.............................................................33
2.7.4. Conflict of Interest Statement..................................................................................................33
2.7.5. Reporting Relationships of the Appointed Actuary..................................................................33
2.7.6. Peer Review of the Work of the Appointed Actuary................................................................34
2.7.7. Cash Value Deficiencies and Negative Policy Liabilities...........................................................34
2.8. Capital Adequacy and Annual Stress Testing ...................................................................................34
Appendix 1: Opinion of the Appointed Actuary ...........................................................................................35
Appendix 2: Two examples of circumstance requiring a qualified opinion .................................................36
REFERENCES .....................................................................................................................................................38
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The AAR should also include text, calculations and information used to support and complete the insurer’s Life Insurance Capital Adequacy Test. In forming his/her opinion, the AA shall assess:
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Where an AA uses another person’s work regarding the accuracy of the data used in the valuation, the AA, in addition to fulfilling the requirements of generally accepted actuarial practice, shall obtain a signed statement from the other party(ies) in the following format and include the signed statement(s) below in
Section 2.4.2.10 of the AAR.
STATEMENT OF ACCURACY OF POLICY RECORDS
I, Name, Title of Company Name, Address of Company hereby affirm that the listings and summaries of policies and contracts as of 31 December 2024, prepared for and submitted to Actuary Name are to the best of my knowledge and belief substantially accurate and complete. ________________________________________________________________ Signature of Name ________________________________________________________________ Address of Company Name The words in bold should be adapted to the situation.
1.5. Filing Requirements for the AAR
The filing deadline for the AAR, which includes the supplementary tables to the AAR, is ninety (90) days after the end of the calendar year. For the AAR, the insurer is required to submit:
AR-GUID-2025/01-0002 the FSC the authority to reject assumptions and methods. Since the review of an AAR may take place over an extended period after filing, the FSC may request the AA to provide supplemental detail to sufficiently assess the assumptions and methods. The AA shall respond promptly to all supplemental requests. Working papers and documentation required to support the computation of the actuarial reserves and other policy liabilities reported in the annual financial return and the AAR shall be available at all times at the company’s head office and should be made available to the FSC upon request. Where the FSC assesses that the assumptions or methods do not sufficiently demonstrate the appropriateness of the actuarial reserves or other policy liabilities, the FSC shall require the AA to choose other acceptable assumptions or methods, and to re-compute the actuarial reserves and other policy liabilities. In such a situation, the AA must re-file the AAR. The FSC may also require the insurer to amend the annual financial return. Alternatively, the FSC may ask the insurer to reflect the changes in the annual financial return for the following year. The FSC may, in accordance with Section 44(5) of the Act request a report from an independent actuary.
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2. GENERAL LAYOUT
The format and order of presentation specified in this Guideline must be followed. The report is ordered so that summary total insurer information is presented first. This should give the reader an overview of the insurer’s actuarial reserves and other policy liabilities. The data should be ordered to be consistent with, first, the way that the insurer is reported externally and, second, the way that the insurer is managed, analysed and reported internally. A uniform manner of presentation allows the FSC to compare methodologies and assumptions more easily between insurers. Even if a section is not applicable to an insurer, it must still be included in the report. To facilitate the FSC’s review, the AAR should include a table of contents and have clearly identified sections and numbered pages. Reference to such pages should be part of the table of contents.
2.1. Overview
2.1.1. Overview of Insurer
The overview section of the AAR must include:
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2.1.2. Expression of Opinion
In forming his/her opinion, the AA shall assess:
AR-GUID-2025/01-0002 included in the annual financial statements presented to the shareholders and policyholders. Caveats or any form of disclaimer should be excluded from the opinion but could be included in supplementary information supporting the opinion. Appendix 2 provides two examples of situations where a reservation in reporting is required. The list is not exhaustive, and the examples are meant to be illustrative. The AA is required to amend the opinion to fit the circumstance which gave rise to the qualification.
2.1.1 Materiality Standards
The AA should describe the materiality standard applied in their work and how they determined that amount. The AA should compare their materiality to the external audit materiality.
2.2. Total Insurer Data
2.2.1 Summary Reporting of Data
The AA must complete the following summary tables of the accompanying supplementary table spreadsheet:
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The AA must complete Table 2.2a and/or 2.2b of the accompanying supplementary table spreadsheet for the risk adjustment information.
Table 2.2a should report the risk adjustment by risk for the current year and prior year where the margin
approach is used or if an insurer uses the margin approach to replicate the aggregate risk adjustment derived from other approaches (other than the margin approach). The AA should describe how diversification benefits are included in the reported risk adjustment. If diversification benefits by product type cannot be quantified as required in Table 2.2a, entities may disclose the diversification benefits at a higher level than the product type level. The AA should explain why the diversification benefits cannot be quantified at the product type level specified in the table. The AA is only required to complete Table 2.2b if the risk adjustment for the current and prior years is determined using an approach other than the margin approach.
2.2.3 Summary Reporting of Changes in Methods and Assumptions
Table 2.3a and 2.3b show the assumption and methodology changes in liabilities/assets for (re-)insurance
contracts issued and reinsurance contracts held related to non-financial and financial risks, respectively. Multiple changes must not be netted in a manner where material changes are offset by one another, and the net impact does not reflect the magnitude of the individual changes. The changes should be described at the level of granularity required in tables 2.3a, 2.3b, and 2.3c, at a minimum. The AA should confirm that the total changes at an insurer level are reconciled to the values reported in the annual financial return. The description of the changes shown in the tables should be succinct. Detailed descriptions of the changes must be included in the product section of the AAR. Allocations are permitted when the assumption changes are determined at a higher level. Each of the changes in assumptions or methodology must be disclosed separately. If more than one change is made to any of the product types, the AAR must show separately the effects of each change, i.e. netting should not be used. Assumption and methodology changes could have an impact on CSM and loss component. The AA should report the full assumption and methodology change impact on CSM without reflecting the amount that goes to loss component. For example, if the CSM balance is $50 and an assumption change impact is $60, with $10 going to the loss component, then the AA should report the full $60 impact in Table 2.3a rather than the $50 impact on the CSM. The AA should disclose the changes in (re-)insurance contract assets/liabilities by portfolio and by quarter due to market impacts such as, but not limited to, change in risk free rates, credit risk premiums, currency exchange rates, etc. in Table 2.3c.
2.2.4 Portfolio Mapping (Unconsolidated)
The AA must complete Table 2.4 of the accompanying supplementary table spreadsheet for information related to each portfolio.
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2.2.5 Liabilities for Investment and Service Contracts
The AA must complete Table 2.5 of the accompanying supplementary table spreadsheet for the liabilities for investment and service components and the liabilities for distinct investment or service components where the components are separable from the host insurance contracts.
2.3. General Valuation Information
According to paragraph 3 of the IFRS 17 standard, an insurer shall apply IFRS 17 to:
a) insurance contracts, including reinsurance contracts, it issues, b) reinsurance contracts it holds; and c) investment contracts, with discretionary participation features, it issues, provided the insurer also issues insurance contracts.
Section 2.3 and 2.4 apply to these contracts only.
2.3.1. Level of Aggregation
The AA should disclose the different levels at which (re-)insurance contracts issued and reinsurance contracts held are aggregated. The AA should provide a high-level description of each of the portfolios in Table 1 under column (04) of the accompanying supplementary table spreadsheet. The AA should explain how a portfolio of (re-)insurance contracts issued, or reinsurance contracts held is classified into groups according to the degree of profitability at initial recognition using the following criteria:
For insurance and reinsurance contracts issued,
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The AA should report the discount rate curves used to discount cash flows that do not vary based on the returns on the underlying items in Table 3.2a of the accompanying supplementary table spreadsheet. The AA should disclose the discount curves by currency, by liquidity category and by spot/forward basis. Under special circumstances (such as small, run-off blocks of business) where these blocks are immaterial in size and low risk, the FSC will consider different details of reporting where appropriate. Please contact Actuarial@fscjamaica.org for further discussion of these specific circumstances.
2.3.2.1. Bottom-Up Approach
If the bottom-up approach is used, provide the following information in detail:
Risk-free rates by currency
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The AA should provide any additional explanations and information pertinent to choices made in implementing the Bottom-Up approach.
2.3.2.2. Top- Down Approach
If the top-down approach is used, the following information should be disclosed in detail:
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Excluding the cash flows that vary with the returns on the underlying items, the AA should provide the following:
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The AA should disclose the results of two recoverability tests (required per IFRS 17.28E and B35D) on insurance acquisition cash flows if facts and circumstances indicate that the asset may be impaired.
2.3.5. Reinsurance Contracts Held
2.3.5.1. Non-Performance Risk
The AA must explain how the allowance for the effect of any risk of non-performance by the issuer of the reinsurance contracts held is measured. The AA should indicate whether the adjustment is applied to the cash flows directly, to the discount rates, or a combination of the two. The AA should detail all factors considered in the risk of non-performance by issuers of the reinsurance contracts held, including but not limited to, items such as the effect of collateral and losses from disputes.
2.3.5.2. Assumptions Used to Measure the Estimates of the Present Value of Future Cash Flows
The AA should disclose any reinsurance contracts held where the IFRS 17 measurement method or assumptions are different from the measurement of the underlying insurance contracts and explain the drivers of the different methods or assumptions are between the (re-)insurance contracts issued and reinsurance contracts held. The AA should disclose where the contract boundary of the reinsurance contracts held is materially different than the underlying direct contracts and the reasons for such differences.
2.3.6. Comparison with Other Reporting
The AA should compare the expected non-financial assumptions used in the valuation of the (re-)insurance contracts issued and reinsurance contracts held with the comparable expected non-financial assumptions used in other reporting or actuarial analysis. Comparisons include:
(i) the assumptions underlying the base scenario for the annual stress testing projections required pursuant to Regulation 72H of the insurance Amendment Regulations, 2022, (ii) the current pricing assumptions compared to the valuation assumptions for the same blocks of new business in the current year, (iii) any comparable assumptions underlying the current business plan for the insurer, if applicable. It is accepted that there could be valid reasons for any differences in expected non-financial assumptions, but if there are such differences, the AA must comment on the reasons.
2.3.7. Valuation System and Model Governance
The AA should disclose the model and version numbers for the valuation system(s) used. The AA should also include whether the valuation system is an in-house system or a commercially purchased system. Any changes in valuation systems (e.g. moving from an in-house system to a commercially purchased system, new valuation system, changes in providers, etc.) should be disclosed and the effects quantified. As well, the AAR should describe the results of any audit or review related to changes in valuation systems and who performed the audit or review. It should also be noted if changes in valuation systems have not been subject to audits or reviews. Additionally, the AA should include a summary or commentary on the governance framework as it relates to selecting the valuation model and the process for setting and changing assumptions.
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2.4. Details by Portfolios and Product Lines – Actuarial reserves and other policy
liabilities valued using IFRS 17
The section of the AAR should document the portfolios and product type details of the valuation of the (re- )insurance contracts issued reinsurance contracts held, investment contracts with DPFs as per paragraphs 3 and 29 of IFRS 17. This section of the AAR must follow the same order as is shown in Summary Table 2.1b. Thus, this section must follow the same cascade of insurer/branch/par or non-par/portfolio/ (re-)insurance contracts issued, reinsurance contracts held, investment contracts with DPFs/ product type. The FSC recognizes that not all the elements that are requested to be disclosed are calculated at the same level of detail. For example, the actual to expected experience studies may be carried out at a more summarized product level. Similarly, some of the descriptions of methodology or some assumptions may be the same for more than one product type (e.g. the same mortality table is used for several product types), portfolio, or group. If this is the case, the information need only be disclosed once in the AAR at the appropriate summary level (i.e. aggregating information across portfolios or product types), but the detailed product sections must make direct reference to it. If reinsurance contracts held have the same assumptions as direct contracts, the AA should provide references to the assumptions of the direct contracts. Each product section must be self-contained. It must have either the data within the section or an explicit reference to a specific section or page at a different summarized level. The reader of the AAR should not have to search through non-cross-referenced sections of the AAR. If allocation method(s) is/are used for any items (e.g. CSM by product type), the AA should describe the allocation approach. The FSC expects the allocation approach should be consistent year after year. However changes (if any) should be specifically disclosed and explanation for the change should be provided.
2.4.1. Portfolio Reporting
The reporting of each portfolio should include the following:
2.4.1.1. Measurement Approach
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2.4.1.2.1. Other Items to Include in the Estimates of Future Cash Flows
For items that were separately reported as liabilities under IFRS 4 but are now included, as part of the estimates of future cash flows, such as policy loans, amounts on deposit, dividends on deposit, prepaid premium accounts, experience rating refunds, claim fluctuation reserves, premium stabilization reserves, market conduct provisions, etc., the AA should describe how these items are included in the estimates of future cash flows (such as methodology, models and assumptions, and if the amounts are treated as time zero cash flows) and provide the rationale to support the selected approach(es) underlying the results in
Table 4.1.2.1 of the accompanying supplementary table spreadsheet.
The liabilities in Table 4.1.2.1 are not required to be reported in detail by product line. However, more details are expected to be provided in the Product Line Reporting (Section 2.4.2) for liabilities that are material. In particular, the AA should describe in detail how the incurred but not reported claims, reported but not admitted claims, experience rating refunds, claims fluctuation reserves, premium stabilization reserves, market conduct provisions are treated in the future cash flows. If the “other” item is significant, the AA should describe the specifics in detail (e.g. how the IBNR provision is determined including the processes, systems, assumptions and methodologies).
2.4.1.3. Risk Adjustment for Non-Financial Risk
The AA should disclose the methodology chosen including the equivalent confidence level of the calculated risk adjustment. The AA should provide rationale to support why the chosen methodology reflects the compensation the insurer requires for uncertainty. The AA should describe how the confidence level is determined for the chosen methodology. The confidence level of the risk adjustment (either on a gross or net basis) for non-financial risk at the insurer level should be disclosed in Table 2.1a. The AA should describe the considerations taken in quantifying the amount of non-financial risk transferred to the reinsurer. If the insurer has chosen different risk adjustment confidence levels by portfolio or other more granular level, the AA should disclose the approach(es) and rationale. If the risk adjustment is determined at a higher level than the group of contracts, the AA should describe the approach to allocate the risk adjustment to the different levels. If the insurer chooses to reflect the benefits of diversification in its risk adjustment, then the AA should disclose the techniques used to determine the diversification benefit, such as a correlation matrix. The AA should describe how the discount rate curve, if applicable, used to discount the risk adjustment is constructed and if the discount rate curve is different from the one used for the associated future cash flows. The AA should also provide the rationale for the approach chosen. The AA should disclose the following information for various methodologies used to determine the risk adjustment. Margin Approach The AA should disclose how the margins for each of the non-financial risks are determined and explain the differences between current and prior year. If crossover points are used to determine the lapse margin, the AA should disclose the steps used to determine the crossover points.
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Cost of Capital Approach
The AA should disclose the projected average capital amounts, cost of capital rate and discount rates used to determine the risk adjustment at the insurer level in Table 4.1.3i of the accompanying supplementary
table spreadsheet. In addition, the AA should disclose:
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For products with minimum interest rate guarantees, the AA should disclose the key information pertaining to the minimum interest rate guarantees for material blocks (e.g. (re-) insurance contracts liabilities, account value by product, issue year and guarantee rate). For example, Universal Life with Level Cost of Insurance:
Minimum Guaranteed
Interest Rate
Issue Year Current Year Insurance
Contract Liabilities
Account Values
5%
6%
…
If the (re-)insurance contracts liabilities by minimum guaranteed interest rate are not available, allocation methods can be used. Please provide details of the allocation method(s) used.
2.4.2.3. New Products
The AAR should disclose details on the features of the new products, guarantees, benefits, contract boundary, etc. This description should be sufficient to support the assumptions and methodology used. Where the product is novel or experimental, and relevant experience data is not available, the AA should describe the work performed to measure the risk associated with these new contingencies. For new participating products, the AAR should also disclose if the new product(s) are in the same dividend class or participating sub-account as the in force participating products. The AA should provide the rationale and considerations for the associated practice, and a description of how the insurer ensures that intergenerational equity is maintained.
2.4.2.4. Modelling for the valuation of contracts with financial guarantees
The AA should disclose how the provision for the financial guarantees is determined, including details such as the valuation approaches, modelling, market variables and parameters, and assumptions used to determine the market consistent valuation for insurance contracts that contain financial guarantees. Th AA should provide the rationale for the choices made.
2.4.2.4.1. Stochastic Models
For products with financial guarantees using a stochastic approach to measure the market consistent value of the guarantees, the AA should explain the appropriateness of the model being used and that the range of stochastic scenarios adequately reflects the liability cash flows. Discussion should include, but not be limited to, the description of the interest rate model, equity return model, calibration process, and types of tests performed to ensure that the number of scenarios used were appropriate. Discussion is expected to include, but not be limited to, the following by currency and by type of product, as appropriate:
AR-GUID-2025/01-0002 o Description of the interest rate, bond indices and equity return model, calibration process and parameters (e.g. mean, volatility, mean-reversion level and speed, etc.) o Modelling of discount rates o Assessment on the appropriateness of the number of scenarios used to ensure the convergence of the valuation of the actuarial liabilities o The sources of data used o Rationale for the choice of the use of a specific model; o Adjustments made to the model to reflect differences between the embedded options/guarantees and the financial instruments used to derive the market observable inputs; o Basis risk modelling; and o Any approximations and simplifications made to stochastic modelling. The AA is expected to discuss the above by various product types as follows:
i. Equity-linked contracts;
ii. universal life insurance contracts; and
iii. other types of contracts with financial guarantees such as Participating products with guaranteed
minimum dividends, adjustable products, annuity contracts with minimum interest guarantees, and accumulation contracts with indexation guarantees.
2.4.2.4.2. Non-Stochastic Models
For products with financial guarantees using a non-stochastic approach to measure the market consistent value of the guarantees, the AA should explain how this approach meets the objective of consistency with observable market variables based on the specific facts and circumstances. If a replicating portfolio is used, the following information should be disclosed:
AR-GUID-2025/01-0002 well as the current assumptions should be disclosed in the AAR. These include mortality, morbidity, mortality improvement, morbidity improvement, lapses, directly attributable expenses, inflation, renewal/conversion, disability/recovery, transaction-based taxes, investment income tax, policyholder behaviour (such as dynamic lapse (if applicable) function and sample rates, base lapse rates, full lapse rates, partial withdrawal rates, fund transfers, future deposits, and for living benefit products - utilization rates and payout levels) and any other contingencies that are applicable. If an assumption is common to several products, the AA can then specify where the relevant assumption is discussed in the AAR. For lapses, the AA must report on the extent to which the assumption reflects variables such as product type, term to maturity, surrender charge period and degree to which the contract is in-the-money. The formula should produce relatively low or zero lapses in situations where the contract is deep in-the-money and close to maturity. While the FSC expects all assumptions to be documented, the AA must use judgement in deciding on the amount of detail included in the AAR with respect to assumptions. A description of the processes and approaches used to conduct experience studies, such as number of years of data used, frequency of conducting the study, how data are analysed, use of predictive analytics, etc., should be included. The AAR must disclose how the expected experience assumptions were determined with specific reference to insurer experience studies and industry data as applicable. The credibility of the insurer data is to be disclosed, as is any blending of insurer and industry data. If industry tables are available, but not used, the AA should provide the rationale for the choice made and show broadly how the selected assumptions compare with a relevant industry table. For assumptions where limited experience exists, the AA should disclose the basis and rationale for determining the assumptions selected. Any use of implicit assumptions or approximations requires disclosure, discussion and justification in the context of the assessment of appropriateness of the valuation The AA should disclose when the expected experience assumptions were last updated or reviewed, and briefly describe the policy (ies) and guidelines that govern how frequently each expected experience assumption is to be updated or reviewed. For material assumptions, the FSC expects the period for review should be at least annual. The AA must disclose when the expected experience assumptions were last updated or reviewed. The AAR should also note if the frequency of updating or review of expected experience assumptions is not governed by any policy or guideline. A comparison of actual experience versus expected experience assumptions should be shown separately for each material assumption within each product and for the last three years if the data
is available. The AAR should document where such studies are done at a more aggregate level than the product level. This comparison should be shown separately for the key risk assumptions. The results for lapse should be shown separately for lapse-supported products and non-lapse supported products. Where a full formal experience study is not conducted, the comparison can be based on an analysis of expected experience per the valuation system versus actual experience taken from the accounting data should be disclosed with consistent differences in one direction and large swings explained. If such actual to expected comparisons are done for only a portion of the product lines, the AAR should show the proportion that is measured. The AAR should also disclose if such studies are not available.
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2.4.2.7. Construction of Discount Rate for Cash Flows that Vary with Returns on Underlying Items
The AA should discuss how the financial risk is reflected in the valuation per IFRS 17 paragraph B74 (b)(i.e. whether discount rates reflect the effects of financial risk or adjust cash flows for the effect of financial risk or some combination). Under IFRS 17, it is possible to separate the insurance contract cash flows between those that vary with returns on underlying items and those that do not vary, and to use different discount rates to discount different sets of the cash flows. If a separation of cash flows is used, the AA is required to explain in detail the methodology or methodologies used to determine the corresponding discount rate curves used for cash flows that vary with returns of underlying items, including the underlying assets, and the relationship between the actual yield rates and discount rates. If the cash flows being valued are not separated, the AA should explain what valuation approach is used and how the discount rate curve is developed for discounting the cash flows. The AA should disclose the discount rate used in Table 4.2.7 of the accompanying supplementary table spreadsheet.
2.4.2.8. Method and Assumption Changes:
The changes must be described by quarter (if applicable). If the assumptions/methods are changed, the AAR should explicitly document the previous assumptions/methods. This will allow for easier comparisons.
2.4.2.9. CSM Amortization
The AA should disclose the coverage unit chosen for each product type, and the setting of the discount rate if the insurer opted to use discounting to determine the coverage units. If there are multiple coverages within a group of contracts, the AA should also describe the approach to combine the coverages in development of coverage units. The AA should comment on the non-financial assumption unlocking where there is material impact on the CSM and coverage units. Other events, such as de-recognition of contracts, could materially have an impact on the CSM and coverage units.
2.4.2.10. Internal Control Analysis of Actuarial Reserves and Other Liabilities
The AA typically makes use of some method(s) of internal analysis to verify or validate the actuarial reserves and other policy liabilities. This can take a variety of forms. Examples are (i) ratios of face amount to (re- )insurance contracts issued liabilities/assets, (ii) trend analysis, (iii) ratios to fund values, etc. The AA should discuss the internal analysis used to validate the actuarial reserves and other policy liabilities and disclose the numbers from this process in the AAR. In particular, the AA should describe the type of data provided and the review and verification procedures applied and the procedures and steps undertaken to ensure that the valuation data is sufficient, reliable and accurate. For example, data for liabilities should be reconciled between the source administration systems and the valuation system. Where any information is found to be inconsistent, the AA should explain what actions have been taken to adjust/correct for any errors found. It is the FSC’s expectation that the AA has established suitable procedures to verify that the data utilized is reliable and sufficient for the valuation of actuarial reserves and other policy liabilities.
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The AA should describe 1) any use of the work of another actuary or other professionals; 2) the scope of such use; 3) a rationale for such use and 4) the extent of the review of the other person‘s work.
2.4.3. Product Descriptions in respect of actuarial reserves and other policy liabilities not valued using
IFRS 17
For those contracts that are not in the scope of IFRS17, only high-level descriptions of the products are required.
2.5. Additional Liability Disclosures
2.5.1. Scenario Testing of Discount Rates
The AA is also asked to disclose the effect of using the following discount rates as valuation rates:
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3) “Other” – this category includes all other (re-)insurance contracts issued liabilities/assets and
reinsurance contracts held assets/liabilities not included in category 1 and 2. If the (re-)insurance contracts issued and reinsurance contracts held have both cash flows that vary and do not vary with returns on underlying items such as universal life insurance contracts, and the insurer cannot segregate the cash flows that do not vary with cash flows that vary with returns on the underlying items, then the insurance contracts will be included in this category. Insurers should include all ripple effects (this includes but is not limited to impacts on risk adjustment, cash flows of products that have cash flows that vary with underlying items, etc.) resulting from the shocked scenarios. The tests should be based on data at the financial year-end. The above shocks are defined on a spot rate basis; insurers should increase/decrease the discount rate curve by the magnitude of these shocks on spot rate basis. Each shock should be performed independently. In addition, insurers should further break down the (re-)insurance contracts issued liabilities/assets and reinsurance contracts held assets/liabilities by present value of future cash flows, risk adjustment, and contractual service margin. If the margin approach is not selected to calculate the risk adjustment, the AA should report the constant risk adjustment in the table. The sensitivity tests are the same for all jurisdictions and could result in negative interest rates in certain scenarios and countries/regions. In these instances the rates should not be floored at zero. For assumed inflation rates, Investment Income tax, participating policyholder dividends, adjustable features and minimum credited interest rates, the AA should reflect the interest rate scenarios as mentioned above. For example, for a universal life contract that has minimum interest guarantees and a stochastic valuation is used, the market consistent value of the guarantees should be projected as a cash flow at time zero, and should be revalued under the scenarios mentioned above so that the change in the market consistent value of the guarantees in response to movements in interest rates is appropriately captured. Under each scenario, the AA should discuss the impact on participating policyholder dividends and/or participating surplus resulting from the use of the discount rates.
2.5.2. Bulk Provision
The AAR must disclose the amounts of any bulk provisions, with each disclosed separately for the last two years in Table 5.3 of the accompanying supplementary table spreadsheet. Bulk provisions are expected to be temporary in nature and calculated outside the core valuation platform. Examples of such provisions that fall into this category include:
(i) manual adjustment reserves that are the result of the absence, or the inadequacies, of a valuation system, (ii) a bulk reserve to cover potential data problems, (iii) liabilities held to cover cyclical fluctuations, (iv) a manual adjustment that does not have a natural run-off pattern based on the underlying policies, and (v) manual adjustments used to offset current experience fluctuations, etc. The above are examples only and should not be considered an exhaustive list.
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The disclosure should include the reasons for holding these provisions, the methods and assumptions used to determine the provisions, and policies for releasing these provisions in the future, and the allocation methodology of the bulk provisions to portfolio level. Any changes in these provisions must be disclosed as a methodology/assumption change and reported by quarter in Table 2.3a or 2.3b. and annually in Table 2.3a. The FSC expects entities to have approved policies describing the purpose and criteria for building and releasing such provisions. The AA should disclose the purpose, the criteria for determining and releasing the provisions.
2.5.3. Reinsurance Program
The AA must document the insurer’s reinsurance program. The AA should describe significant changes in its reinsurance arrangements (e,g. changes in retention limits), and the rationale for change, if any. The scope of the descriptions should include contracts accounted for under IFRS17 as well as other international financial reporting standards5 . . The disclosure should also include any insurer policies with respect to the maximum exposure allowed to a single reinsurer. The AA should give a list of all reinsurance agreements and indicate whether the arrangements are with related parties as defined by the insurance legislation. The AA should detail the type of reinsurance, a description of the products covered, portfolio(s) the products belong to, key risks transferred, amount of risk ceded, retention limits, the effective and expected termination dates, experience or profit share arrangements, any cancellation or adjustability clauses, and recapture clause. The AA should also clearly describe stop loss and catastrophe arrangements. The AAR should also detail the treatment of expense sharing between the reinsurer and the direct writer. The FSC is concerned about the use of back-to-back reinsurance contracts. Any reinsurance arrangements where an insurer cedes a block of business to a reinsurer and then accepts the same, or a similar, block of business back on a different basis requires full disclosure in the AAR. The FSC does not permit entities to take capital credit for these arrangements. The AA must disclose information about any financial reinsurance agreements where there is no significant transfer of insurance risk between the ceding insurer and the reinsurer, or where there are other reinsurance agreements or side letters that could offset the financial effect of the first reinsurance agreement. If no such agreements exist, the AA must state that there are no financial reinsurance agreements. The AA should also describe the process or assessment to evaluate the risk transfer used to reach the above conclusion. Entities should not use insurance contract accounting for transactions that are substantially a form of financing, or principally involve the transfer of financial risks. The AAR must list all of the assumption reinsurance agreements entered into or exited from during the last three years. This information, which is expected from both the ceding and the assuming entities, should include the:
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For (re-)insurance contracts issued:
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Similarly, some of the descriptions of methodology or some assumptions may be the same for more than one asset segment. This only needs to be disclosed once in the AAR at an appropriate summary level, with a direct reference, where applicable. An example of this would be where the ALM is the same. The AA should disclose the policy for determining the type of assets used to back the liabilities in this asset segment. The statement asset values (excluding the surplus segments if they are separated from the liability segments) should be the same as are used in the annual financial return. Any inter-segment notes should be shown as positive and negative amounts in Table 6.1. If there are any “other assets”, “other liabilities”, or “other investments” which are material to that asset segment, the AA is expected to provide more detail. If the asset mix, such as bond quality, has changed materially between years, the reason should be discussed. If the investment policy, strategy, or ALM approach, practice and process has changed during the year, including any changes related to IFRS 17 requirements and/or implementation, this should be discussed. The use of assets other than bonds, mortgages, equities, real estate, policy loans and cash to back (re-)insurance contract issued liabilities/assets must be disclosed. Such assets include, but are not limited to, inter-segment notes, derivatives, goodwill, loans to subsidiaries or parents, etc. Briefly describe where the use of intersegment notes as a part of the insurer’s investment policy framework and the controls associated with their use. The AA should disclose the current year yield rates for fixed income assets and the actual/expected returns for non-fixed income assets (where applicable) by asset segment in Table 6.2 of the accompanying supplementary table spreadsheet. The non-fixed income actual/expected returns should include dividend/income return and capital gain separately (if possible), used for ALM purposes. If it is not possible to separate them, the total actual/expected returns should be provided. The actual/expected returns are the returns earned over the past 12 months. For rows where actual/expected returns are noted, please provide the actual return if available. If this is not readily available, list the expected annual return rate. If a surplus segment is separate from the liability segment, it is not required to provide the asset information for the stand-alone surplus segment in Table 6.2.
2.7. Other Disclosure Requirements
2.7.1. New Appointment
The FSC expects Appointed Actuaries to comply with the qualification requirements outlined in Regulation 76 of the Insurance Regulation, 2001. If the AA was appointed to the role during the last year, the AAR must include the following disclosures:
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2.7.6. Peer Review of the Work of the Appointed Actuary
If the work of the AA was peer reviewed in the last three years, the AA should summarize the key findings or recommendations, and the status of each finding/recommendation by year. For the recommendations from peer reviews before the effective date of IFRS17, the AA should indicate whether the recommendations are still applicable under IFRS17.
2.7.7. Cash Value Deficiencies and Negative Policy Liabilities
The AA should include a report on:
(a) cash value deficiencies calculated net of reinsurance on an aggregate basis within sets of policies by product type. Deficiencies must be calculated relative to fulfilment cash flows (i.e. including risk adjustment for non-financial risk) and should be floored at zero. (b) Total negative policy liabilities calculated policy-by-policy on best estimate assumptions (i.e. excluding risk adjustment) and net of reinsurance. The net amount is subject to a minimum of zero. Prior and current year comparatives must be presented as follows:
Current Year ($’000) Prior Year ($’000)
Cash Value Deficiencies calculated on an aggregate basis Negative Policy Liabilities calculated on a policy-by-policy basis
2.8. Capital Adequacy and Annual Stress Testing
The AAR shall include:
a) A summary of the key findings of these tests and recommendations, b) A discussion and summary of the exposure of the company to significant risks, c) Discussion of asset default provisions and any asset concentration and quality issues, d) A comment on the quality and composition of assets allocated to surplus, e) A description of the process used to measure and manage risk (e.g. liquidity, capital), f) Completed Confirmation of Life Insurance Capital Adequacy Test requirements:
I, Actuary Name, Appointed Actuary, of Company Name, Address of Company hereby affirm that the requirements of the capital adequacy test have been followed. ____________________ _________________________ ________________________ Name of Appointed Actuary Signature of Appointed Actuary Date The words in bold should be adapted to the situation.
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Appendix 1: Opinion of the Appointed Actuary
I certify that:
(a) I am a member in good standing with my governing actuarial body, [Name of Organization] and comply with its [Code/Rules of Professional Conduct]; (b) I meet the qualification standards of Financial Services Commission to value the actuarial reserves and other policy liabilities of [Name of insurance company]; and (c) The valuation of actuarial reserves and other policy liabilities was conducted in accordance with the Insurance Act, 2001 and its regulations, International Financial Reporting Standards, generally accepted actuarial practice in Jamaica and guidelines issued by the Financial Services Commission. In my opinion, the amount of the actuarial reserves and other policy liabilities of [Name of Insurance Company] reported in its annual financial statements prepared in accordance with International Financial Reporting Standards for the year ended [Date] is appropriate for this purpose and the annual financial statements presents fairly the results of the valuation. _________________________ Name of Appointed Actuary Signature of Appointed Actuary Date [Name, Title, Qualification]
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Appendix 2: Two examples of circumstance requiring a qualified opinion
"Liabilities different than those calculated by the actuary .25 If the [annual] financial statements of an insurer report [actuarial reserves and other] policy liabilities that are materially different from those calculated and reported by the actuary then the actuary would need to disclose the difference in the amounts and identify where to find an explanation for the difference. If possible, such explanation would include the important reasons for the difference. “ The opinion could be as follows:
I certify that:
(a) I am a member in good standing with my governing actuarial body, [Name of Organization] and comply with its [Code/Rules of Professional Conduct]; (b) I meet the qualification standards of the Financial Services Commission to value the actuarial reserves and other policy liabilities of [Name of insurance company]; and (c) The valuation of actuarial reserves and other policy liabilities was conducted in accordance with the Insurance Act, 2001 and its regulations, International Financial Reporting Standards, generally accepted actuarial practice in Jamaica and guidelines issued by the Financial Services Commission. In my valuation, the amount of the actuarial reserves and other policy liabilities is $[X]. The corresponding amount in the annual financial statements is $[Y]. The sources of this difference are described in [reference]. In my opinion, the amount of actuarial reserves and policy liabilities in the annual financial statements is not appropriate and as explained in [reference] the annual financial statements do not present fairly the results of my valuation. Source: Canadian Institute of Actuaries June 2023 Consolidated Standards of Practice 2230
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“Change in assumption or methodology affecting disclosure items in the annual financial statements .27 If an item valued by the actuary is materially affected by a change in assumption or methodology that is not disclosed in the [annual] financial statements, the actuary would modify the opinion paragraph in the standard reporting language to disclose this situation.” 8 The opinion could be as follows:
I certify that:
(d) I am a member in good standing with my governing actuarial body, [Name of Organization] and comply with its [Code/Rules of Professional Conduct]; (e) I meet the qualification standards of the Financial Services Commission to value the actuarial reserves and other policy liabilities of [Name of insurance company]; and (f) The valuation of actuarial reserves and other policy liabilities was conducted in accordance with the Insurance Act, 2001 and its regulations, International Financial Reporting Standards, generally accepted actuarial practice in Jamaica and guidelines issued by the Financial Services Commission. In my opinion, the amount of the actuarial reserves and other policy liabilities of [Name of Insurance Company] reported in its annual financial statements for the year ended [Date] is appropriate for the stated purpose. As explained in [reference], [the assumption/methodology for XX] was changed from that used for the previous year. Except for the absence of the disclosure of this change and its impact, the annual financial statements, in my opinion, presents fairly the results of the valuation. Source: Canadian Institute of Actuaries June 2023 Consolidated Standards of Practice 2230
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REFERENCES
OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS, IFRS 17 LIFE MEMORANDUM TO THE APPOINTED ACTUARY (2023) Memorandum to the Appointed Actuary (2023) - Office of the Superintendent of Financial Institutions (osfibsif.gc.ca) http://www.osfi-bsif.gc.ca/Eng/fi-if/rtn-rlv/fr-rf/ic-sa/lic-sav/Pages/AA_Memo_2023.aspx#b.5.4 OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS, MEMORANDUM TO THE APPOINTED ACTUARY (2024) Memorandum to the Appointed Actuary (2024) - Office of the Superintendent of Financial Institutions (osfibsif.gc.ca) CANADIAN INSTITUTE OF ACTUARIES, EDUCATIONAL NOTE, ROLE OF THE APPOINTED ACTURY UNDER IFRS17, December 2022 https://www.cia-ica.ca/docs/default-source/2022/222174e.pdf CARIBBEAN ACTUARIAL ASSOCIATION, STANDARDS OF PRACTICE, APS0: GENERAL ACTUARIAL PRACTICE, December 2019 https://drive.google.com/file/d/1ccploy0sw34SnoxSV3TYLMC4BmowLkk4/view CARIBBEAN ACTUARIAL ASSOCIATION, STANDARDS OF PRACTICE, APS6: ACTUARIAL SERVICES IN CONNECTION WITH INTERNATIONAL FINANCIAL REPORTING STANDARD 17, June 2023 CANADIAN INSTITUTE OF ACTUARIES, ACTUARIAL STANDARDS BOARD, STANDARDS OF PRACTICE, June 2023 https://www.cia-ica.ca/docs/default-source/standards/sc063023e.pdf INTERNATIONAL ACTUARIAL ASSOCIATION, INTERNATIONAL ACTUARIAL NOTE 100, APPLICATION OF IFRS 17 INSURANCE CONTRACTS, August 2021 https://www.actuaries.org/IAA/Documents/Publications/IANs/IAA_IAN100_31August2021.pdf
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Source: Financial Services Commission Jamaica — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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