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Miranjit Mukherjee - Actuarial Society of India

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TATA AIG GENERAL INSURANCE<br />

COMPANY LTD<br />

IFRS 4 / IND AS 104 – As applicable to<br />

General Insurance Companies<br />

MIRANJIT MUKHERJEE<br />

1 1- 1 -


AGENDA<br />

1. Background <strong>of</strong> IFRS 4<br />

2. Background <strong>of</strong> IND AS 104<br />

3. What is IFRS 4 / IND AS 104<br />

4. Recognition and measurement under IND-AS 104<br />

5. Insurance Contracts<br />

6. Examples <strong>of</strong> Insurance Contracts<br />

7. Liability Adequacy test and examples<br />

8. Disclosures principles and summary<br />

9. Comparison <strong>of</strong> IND AS 104 vs current requirements<br />

10. Balance Sheet – IND AS 104<br />

11. Additional disclosures under IND AS 104<br />

12. Key issues for implementation<br />

13. Impact <strong>of</strong> IND AS 104 / IFRS on general insurers<br />

14. Terms Used<br />

2


IFRS 4 – Phase I – BACKGROUND<br />

April 2001<br />

Comprehensive insurance contracts project carried over<br />

from IASC to new IASB<br />

May 2002<br />

Short-term insurance contracts project split <strong>of</strong>f from<br />

comprehensive project<br />

July 2003<br />

Exposure Draft ED 5 Insurance Contracts<br />

31 st Mar 2004<br />

IFRS 4 Insurance Contracts<br />

1 st Jan 2005<br />

Effective date <strong>of</strong> IFRS 4<br />

3


IND AS 104 – BACKGROUND<br />

2009<br />

IRDA issues exposure draft on IFRS Compliance<br />

2010<br />

Exposure Draft AS 39 on Insurance Contracts<br />

25 Feb 2010<br />

MCA notifies 35 IFRS (IND AS) incl IND AS 104<br />

1 April 2012<br />

Insurance cos prepare opening bal sheet as per IND AS<br />

Date - ?<br />

Preparation <strong>of</strong> opening bal sheet as per IND AS<br />

4


WHAT IS IFRS 4 – PHASE I – IND AS 104<br />

Interim standard - focused primarily on disclosures and classification <strong>of</strong><br />

insurance contracts.<br />

Introduces a definition for an insurance contract based on the contract<br />

containing significant insurance risk.<br />

Required only limited changes to existing accounting practices for insurance<br />

contracts and extensive disclosures.<br />

IFRS 4 does not affect the business fundamentals since there is<br />

‣ No change in the underlying transactions<br />

‣ No change in real cash flow<br />

5


RECOGNITION AND MEASUREMENT UNDER IND AS 104<br />

In most respects, IND AS 104 allows an entity to continue to account for insurance contracts<br />

under its previous accounting policies.<br />

However, the standard makes some limited improvements to accounting for insurance<br />

contracts<br />

Liabilities only on existing contracts : Catastrophe provisions and equalization provisions are<br />

not permitted. They are not liabilities.<br />

Liability Adequacy Test : The adequacy <strong>of</strong> insurance liabilities must be tested at the end <strong>of</strong><br />

each reporting period. The liability adequacy test is based on current estimates <strong>of</strong> future cash<br />

flows. Any deficiency is recognized in pr<strong>of</strong>it or loss.<br />

Impairment testing : Furthermore, reinsurance assets are tested for impairment.<br />

No <strong>of</strong>fsetting : Insurance liabilities are presented without <strong>of</strong>fsetting them against related<br />

reinsurance assets.<br />

No <strong>of</strong>fsetting : Insurance expense or income against related reinsurance income or expense.<br />

6


INSURANCE CONTRACTS<br />

IND AS 104 covers insurance contracts<br />

It applies to insurance contracts where policy holders pass insurance risk to insurance companies<br />

OR where insurers pass insurance risk to re-insurers<br />

What is an insurance contract<br />

In the contract one party accepts significant insurance risk from another party<br />

The party accepting insurance risk agrees to compensate the policy holder<br />

If a specified uncertain future event affects the policyholder<br />

What is an insurance risk<br />

The risk in the contract must be insurance risk, which is any risk except for financial risk<br />

This specified uncertain future event is known as the “insured event” while the uncertain future event<br />

that is covered by an insurance contract creates “insurance risk”.<br />

Uncertainty<br />

Uncertainty is the essence <strong>of</strong> an insurance contract . At least one <strong>of</strong> the following is uncertain at the<br />

inception <strong>of</strong> the contract :<br />

Whether an insured event will happen<br />

When will it occur<br />

How much the insurer needs to pay<br />

7


INSURANCE CONTRACTS<br />

Insurance Contract<br />

Insurer accepts Insurance Risk<br />

Significant Risk<br />

Insurer accepts Significant Risk<br />

No numerical range fixed for what is significant risk<br />

Meaning <strong>of</strong> significant : Payment <strong>of</strong> significant additional benefit<br />

Another Party<br />

Insurer must accept risk from another party .<br />

Insurer must be separate from the policy holder .<br />

Accordingly self insurance is not an insurance contract as per IND AS 104<br />

8


SIGNIFICANT INSURANCE RISKS<br />

INSURANCE RISK<br />

The underlying tenet behind insurance transactions.<br />

The purpose <strong>of</strong> this action is to take a specific risk, which is detailed in the insurance<br />

contract, and pass it from one party who does not wish to have this risk (the insured) to a party<br />

who is willing to take on the risk for a premium (the insurer).<br />

RISK TRANSFER<br />

Underwriting risk<br />

Risk transfer<br />

Conditions<br />

Timing Risk<br />

Amount Risk<br />

9


INSURANCE CONTRACTS<br />

Significant insurance risk<br />

Insurance Contract<br />

Contract<br />

Insignificant insurance risk<br />

Investment Contract<br />

NB : IFRS 4 applies to insurance contracts not to insurance companies<br />

10


EXAMPLES OF INSURANCE CONTRACTS - IND AS 104<br />

Insurance contracts covered<br />

Contracts to be excluded<br />

Theft / Damage to property<br />

Product / Pr<strong>of</strong>essional Liability<br />

Accident and Health<br />

Marine<br />

Engineering<br />

Product Warranty ( excl issued<br />

by manufacturer / dealer / retailer )<br />

Title Insurance<br />

Travel Insurance<br />

Reinsurance Contracts<br />

Self Insurance<br />

Credit related guarantee<br />

Weather derivative<br />

Catastrophic Bonds<br />

11


LIABILITY ADEQUACY TEST<br />

Must assess at each reporting date whether recognised insurance liabilities are adequate<br />

based on current estimates <strong>of</strong> future cash flows under insurance contracts.<br />

The assessment must use current assumptions and consider all contractual cash flows.<br />

If existing accounting policies include an assessment that meets<br />

the specified minimum requirements, no further action required.<br />

If not ?<br />

If no sufficient assessment, the carrying amount <strong>of</strong> the liability must<br />

be tested and, if necessary increased<br />

12


HOW DO YOU CARRY OUT LIABILITY ADEQUACY TEST<br />

If the present value <strong>of</strong> the expected cash flows arising out <strong>of</strong> future claims exceeds the<br />

unearned premium liability then the unearned premium liability is deficient . The recognized<br />

deficiency has to be recorded in the income statement .<br />

This should not be an issue in <strong>India</strong> as insurers are already required to create a<br />

premium deficiency in their accounts in the current accounting principles .<br />

13


EXAMPLES OF LIABILITY ADEQUACY TESTS<br />

Royal Sun Alliance<br />

At each balance sheet date an assessment is made <strong>of</strong> whether the provisions for unearned premiums are adequate.<br />

A separate provision is made, based on information available at the balance sheet date, for any estimated future<br />

underwriting losses relating to unexpired risks. The provision is calculated after taking into account future investment<br />

income that is expected to be earned from the assets backing the provisions for unearned premiums (net <strong>of</strong> deferred<br />

acquisition costs). The unexpired risk provision is assessed in aggregate for business classes which, in the opinion<br />

<strong>of</strong> the directors, are managed together.<br />

Zurich<br />

A provision should be made for unexpired risks where the expected value <strong>of</strong> claims and expenses attributable to the<br />

unexpired periods <strong>of</strong> policies in force at the balance sheet date exceeds the unearned premiums provision in relation<br />

to such policies after the deduction <strong>of</strong> any deferred acquisition costs. The need for an unexpired risk provision has<br />

been considered separately by reference to classes <strong>of</strong> business that are managed together, after taking into account<br />

the relevant investment returns. An unexpired risk provision was not found necessary for any business classes and<br />

therefore a provision is not raised in the accounts.<br />

SCOR RE<br />

For the Non Life segment the test is performed in the event the ultimate underwriting combined ratio is in excess <strong>of</strong><br />

100% to the unearned premium reserve net <strong>of</strong> deferred acquisition costs . The liability adequacy test is performed on<br />

the level <strong>of</strong> the actuarial segment and then aggregated at the entity level .<br />

14


PRINCIPLES OF DISCLOSURES UNDER IFRS 4<br />

Disclosure is particularly important for information relating to insurance<br />

contracts, as entities can continue to use local GAAP accounting policies for<br />

measurement.<br />

IFRS 4 has two main principles for disclosure.<br />

‣ Entities should disclose information that identifies and explains the<br />

amounts in its financial statements arising from insurance contracts.<br />

‣ Information that enables users <strong>of</strong> its financial statements to evaluate the<br />

nature and extent <strong>of</strong> risks arising from insurance contracts.<br />

15


SUMMARY OF DISCLOSURES REQUIRED UNDER IFRS 4<br />

Information that helps<br />

users understand the<br />

amounts in the financial<br />

statements arising from<br />

Insurance contracts<br />

Accounting policies for insurance contracts<br />

Recognized Assets , Liabilities , Income, Expenses and<br />

Cash Flows arising from these contracts<br />

Assumptions that impact value <strong>of</strong> Assets , Liabilities , Income<br />

and Expenses<br />

Historic claims development ( loss development triangle )<br />

Nature and extent <strong>of</strong> risks<br />

arising from Insurance<br />

contracts<br />

Risk management policies and objectives<br />

Information about insurance risk sensitivity and<br />

concentration<br />

Information about credit risk, liquidity risk and market risk<br />

16


EXISTING ACCOUNTING REQUIREMENT VS IND AS 104<br />

ISSUE EXISTING AS PER IND AS / IFRS Ref<br />

1 Financials Revenue A/cs , P/L , B/S , Cash Flow , Notes Income Stat , B/S , SOCE , Cash Flow, Disclosures , Notes<br />

2 Format As laid down by Insurance Act / Regulations No specified format<br />

3 Segments Fire , Marine and Miscellaneous Criteria specified + those reviewed by decision makers 108<br />

4 DAC Not permitted by Regulations IND AS 104 takes reference to DAC 104<br />

5 Investments Debt instruments (HTM ) / Equity (MTM) FVTPL ( MTM ) / HTM / AFS ( MTM )<br />

6 UEPR Minimum as per Sec 64V <strong>of</strong> Insurance Act As per Liability Adequacy Testing ( LAT ) 104<br />

7 UEPR Fire , Marine and Miscellaneous As per Liability Adequacy Testing ( LAT ) 104<br />

8 LAT Premium Deficiency specified by IRDA circular As per IND AS 104 104<br />

9 Solvency Workings as per Insurance Act / Regulations Not clear .<br />

10 Disclosures Disclosures as laid down by Regulations . Detailed disclosures laid down for Insurance transactions / Risks 104<br />

No disclosures on risks<br />

17


BALANCE SHEET UNDER IND AS 104 / IAS 39<br />

Investments<br />

Deferred Tax Asset<br />

Fixed Assets<br />

Cash and Bank Balances<br />

Advances and Other Assets<br />

Reinsurance share <strong>of</strong> insurance liab<br />

ASSETS<br />

Reinsurers<br />

recovery have<br />

to be shown<br />

separately<br />

Share Capital<br />

Reserves and Surplus<br />

Fair Value Change Account<br />

Borrowings<br />

Deferred Tax Liability<br />

Insurance Liabilities - gross<br />

Other Liabilities & provisions<br />

LIABILITIES<br />

Insurance<br />

Liabilities have<br />

to be Grossed<br />

up<br />

INVESTMENTS - EXISTING VALUATION INVESTMENTS - IND AS VALUATION<br />

Debt Instruments Amortised cost Fair value through P&L MTM<br />

Equity Shares MTM Held to Maturity Amortised cost<br />

Available for Sale<br />

MTM<br />

18


ADDITIONAL DISCLOSURES UNDER IND AS 104<br />

<br />

<br />

<br />

<br />

Section on Risk Management<br />

Insurance Risk ( underwriting risk / concentration risk )<br />

Financial Risk<br />

Market Risk ( Interest rate / Currency / Equity )<br />

Credit Risk<br />

Liquidity Risk<br />

Operational Risk<br />

Capital Management<br />

Liability Adequacy Test<br />

Impairment <strong>of</strong> Reinsurance Assets<br />

Loss development triangle<br />

19


KEY ISSUES THAT NEEDS TO BE ADDRESSED<br />

Start date<br />

Date for the opening balance sheet needs to be fixed<br />

Amendment<br />

Amendment required to the Insurance Act / Regulations<br />

F. Statements As per IND AS or existing basis or both<br />

Solvency<br />

Based on existing regulations or IND AS<br />

20


IMPACT OF IND AS 104 / IFRS ON INDIAN GEN INSURERS<br />

Ins Contracts<br />

Not very significant<br />

Disclosures<br />

Significant effort during the earlier years <strong>of</strong> implementation<br />

Investments<br />

Accounting and measurement would have a big impact<br />

LAT<br />

Segment wise LAT would impact solvency<br />

Op Segments<br />

Companies monitor performance on their chosen segments<br />

Solvency<br />

Would be impacted by Investments measurement / LAT<br />

21


TERMS USED<br />

<br />

<br />

<br />

<br />

<br />

<br />

<br />

<br />

<br />

MCA : Ministry <strong>of</strong> Corporate Affairs<br />

DAC : Deferring <strong>of</strong> acquisition costs<br />

LAT : Liability Adequacy Test<br />

URR : Unexpired Risk Reserve<br />

HTM : Held to Maturity<br />

MTM : Mark to Market<br />

AFS : Available for Sale<br />

SOCE : Statement <strong>of</strong> Change in Equity<br />

B/S : Balance Sheet<br />

22

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