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CEIOPS' Advice for Level 2 Implementing ... - EIOPA - Europa

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3.36 Hence where an (re)insurance undertaking assess the nature, scale and<br />

complexity of the risks – and subsequently considers whether a specific<br />

valuation method is proportionate to these risks - it should only have<br />

regard to the risk characteristics of the cash-flows related to settling the<br />

insurance contracts but not to other risks to which the undertaking may<br />

be exposed. Following such an approach is expected to improve the<br />

comparability and consistency of such assessments across different<br />

undertakings.<br />

Nature and complexity<br />

3.37 Nature and complexity of risks are closely related, and <strong>for</strong> the purposes<br />

of an assessment of proportionality could best be characterised together.<br />

Indeed, complexity could be seen as an integral part of the nature of<br />

risks, which is a broader concept. 26<br />

3.38 In mathematical terms, the nature of the risks underlying the insurance<br />

contracts could be described by the probability distribution of the future<br />

cash flows arising from the contracts. This encompasses the following<br />

characteristics:<br />

• the degree of homogeneity of the risks;<br />

• the variety of different sub-risks or risk components of which the risk<br />

is comprised;<br />

• the way in which these sub-risks are interrelated with one another;<br />

• the level of certainty i.e. the extent to which future cash flows can be<br />

predicted; 27<br />

• the nature of the occurrence or crystallisation of the risk in terms of<br />

frequency and severity;<br />

• the type of the development of claims payments over time;<br />

• the extent of potential policyholder loss, especially in the tail of the<br />

claims distribution.<br />

3.39 The first three bullet points in the previous paragraph are in particular<br />

related to the complexity of risks generated by the contracts, which in<br />

general terms can be described as the quality of being intricate (i.e. of<br />

being “entwined” in such a way that it is difficult to separate them) and<br />

compounded (i.e. comprising a number of different sub-risks or<br />

characteristics).<br />

3.40 For example, in non-life insurance travel insurance business typically has<br />

relatively stable and narrow ranges <strong>for</strong> expected future claims, so would<br />

tend to be rather predictable. In contrast, credit insurance business<br />

would often be “fat tailed”, i.e. there would be the risk of occasional<br />

large (outlier) losses occurring, leading to a higher degree of complexity<br />

and uncertainty of the risks. Another example in non-life insurance is<br />

catastrophe (re)insurance covering losses from hurricanes where there is<br />

26 I.e. whether or not a risk is complex can be seen as a property of the risk which is part of its nature.<br />

27 Note that this only refers to the randomness (volatility) of the future cash flows. Uncertainty which is<br />

related to the measurement of the risk (model error and parameter error) is not an intrinsic property of<br />

the risk, but dependent on the valuation methodology applied, and will be considered in step 2 of the<br />

proportionality assessment process.<br />

15/112<br />

© CEIOPS 2010

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