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Future Pathways
Fresh perspectives from actuaries of the future
Risk Management:
An overview of the development of ERM
in the insurance industry and the
pathway of the actuary
Prepared by
James Xu, AMP
Klaas Stijnen, Deloitte
Presented to the New Zealand Society of Actuaries
Future Pathways Sessional Meeting
15 – 16 March 2011
Abstract
The Global Financial Crisis (GFC) has forced the insurance industry to put a stronger focus on risk
management. Strengthening regulatory requirements and ever more risk-oriented business-needs
almost continuously increase the demand for actuaries focussed on risk management. Through the
GFC, the need for and willingness of actuaries to further embrace risk management as a key focus
has excelled.
Currently, and with increasing momentum, Enterprise Risk Management (ERM) is being
implemented across the financial industry. The International Actuarial Association responded to the
need for risk management focussed actuaries by introducing the Chartered Enterprise Risk Analyst
(CERA) credential, which aims to equip actuaries with the right tools to implement and manage ERM.
Managing the after-effects of the Global Financial Crisis requires will require changes by many
insurance companies. As a driver of these changes, the role of the actuary is one that will require
more than just technical skills, such as professionalism and leadership.
1. Introduction
Risk management is an often heard word nowadays especially in the finance industry. In the 15 years
before the Global Financial Crisis (GFC), the development of risk management had been fairly
gradual, driven by strengthening regulatory requirements as well as through business needs.
Actuaries have been seen by many as professionals with the right skill set and attitude to lead these
devlopments in insurance companies to fully embed risk management. Various educational actuarial
bodies increased the weight of risk management techniques such as Value at Risk in the actuarial
training during the first half of the last decade. This enforced focus coincided with an increasing
number of insurance companies in most developed countries implementing risk management
systems to identify, monitor and develop a deep understanding of risks. During the second half of
the same decade, as the understanding of risks and the regulatory push for risk management
increased, Enterprise Risk Management (ERM) moved to the forefront. ERM represents the concept
in which “an organisation (...) assesses, exploits, finances and monitors risks from all sources for the
purpose of increasing the organisation’s short- and long-term value to its shareholders”1
.
The GFC hit the financial industry hard during the second half of 2008, uncovering risks which
appeared to have not been managed properly. Unsurprisingly, poor risk management was the target
of various critics. The GFC changed the pace of the development of ERM in the financial industry.
The various financial failures in the financial industry exposed ERM as a critical tool in order for the
business to survive and succeed, driving a more rapid implementation in an increasing number of
companies and geographical areas. In response, the International Actuarial Association introduced
the Chartered Enterprise Risk Analyst (CERA) credential to distinguish a core actuarial body of risk
management knowledge alongside appropriate standards for achieving the qualification.
In the next section of this paper, we investigate the various causes, implications and lessons learned
from the GFC with a focus on the role of risk management. In the following section, we pay
particular attention to ERM. We discuss some best practices currently adopted by the insurance
industry. We explore the benefits of having ERM and what challenges a risk manager might have to
deal with in the implementation of ERM. In the last section, we provide an overview of the CERA
credential. We discuss the objectives of the qualification and provide a high level outline of the
course. Finally, we discuss how this qualification prepares an actuary for implementing and
performing ERM. Other papers presented at the Future Pathways Sessional Meeting extensively
cover prudential regulation. Therefore, we have chosen not to focus on this matter in this paper.
1
Various definitions of ERM exist. This definition is applied by the Casualty Actuarial Society.
2. Risk Management and the GFC
Over the years, we have observed many incidents that could have been avoided or at least mitigated
were an appropriate risk management process in place. The famous Baring Bank case, where lack of
disciplined investments led to a loss of $1.5 billion and the collapse of the entity, is a good example
which emphasises that the implementation of Enterprise Risk Management has become a burning
issue for financial services organisations.
One of the key drivers of risk management development is increasing regulatory requirements. From
the 1933 Act2
right after the start of the Great Depression to Sarbanes-Oxley to Solvency II,
regulators around the world have been working towards a much stricter environment for the entire
financial services industry, which has led to the shaping up of risk management for the financial
sector today.
Unfortunately, many of these regulatory changes only took place after a major collapse of the
industry, which was why the US government strengthened control over the financial sector after the
GFC had taken hold.
The boom of the US housing market, where a consecutive 10-year rise in house prices led to a belief
that a nationwide house price drop would never happen, is seen as the primary cause of the GFC. In
addition, there were many secondary causes contributing to the magnitude of the crisis, such as the
complex and ultimately ineffective regulatory system in the US. This system gave rise to a conflict of
interest which led to problems in the securitisation process. Also, an over-reliance on credit ratings
by market participants and regulators has been observed.
It is believed that one of the main contributors to the GFC were Residential Mortgage Backed
Securities (RMBS). A RMBS is a securitisation that uses the householders’ repayment on mortgages
as collateral in order to obtain a higher credit rating for the security. A lack of regulatory supervision
on securitisations contributed directly to the expansion of these securities, which resulted in a rapid
deterioration in quality of the underlying mortgages.
The RMBS were initiated by Government Sponsored Enterprises, namely Fannie Mae (FNMA),
Freddie Mac (FHLM) and Ginnie Mae (GNMA). Growth in the issue of RMBS over the years can be
found in the diagram below.
All dollar amounts are in USD.
2
This is the US Securities Act of 1933, which was introduced after the stock market crash in 1929. It requires
the listing of any new securities to be registered. The Securities and Exchange Commission (SEC) took over the
registration authority a year later.
source: Citigroup
As can be seen from the above graph, the securitisations issued by the three major entities (Ginnie
Mae, Fannie Mae and Freddie Mac) increased dramatically towards the end of the last century.
source: LoanPerformance
In addition to the government agency issued securities, there were numerous non-agency securities
that usually offered a higher return, but with the originator not guaranteeing the quality or the
repayment of the securities. In the diagram above, Alt-A loans usually refer to loans with borrowers
having an unstable source of income. ARM (Adjusted-Rate Mortgage) refers to periodically adjusted
interest rates on mortgages according to a series of publicly available indices. Subprime loans are
usually to borrowers with low credit quality while Whole Loans are loans that exceed the maximum
allowed loan size accepted by the government agencies. Similarly to the government agency
securities, the issue of non-agency securities also boomed together with house prices. However,
they then almost vanished due to the credit crunch after 2007 as can be seen from the above graph.
Since borrowers have a variety of credit quality, when a sufficiently large pool of mortgages had
been accumulated, the issuers were able to divide these into different tranches with different
seniorities. Tranches with lower seniority were then expected to bear the initial loss if borrowers
defaulted. Following this restructuring, despite the poor credit quality of individual loans, rating
agencies would have “enough” evidence to show that some of the tranches in fact qualified as a
“AAA” rating.
A similar situation was observed with Collateralised Debt Obligations (CDOs)3
, especially in CDO-
squared, where poor quality CDOs were accumulated to construct a tranche-like structure in order
to qualify for a better credit rating.
It is clear that not only were there flaws in the regulatory frameworks, but it also created serious
incentive problems for the participants in the process of focussing on short term goals (e.g. volume
and bonus) rather than the long term viability (the quality of the loans).
The US regulatory framework will not be discussed further in this paper, since it is less relevant to
the New Zealand insurance market. We will therefore turn our focus to a less systemic but more
behaviour-driven analysis.
The fact that many of the participants in the securitisation process (such as appraisers, bankers,
mortgage brokers, and investment bankers) aimed for short-term results with little consideration for
longer-term outcomes led to high volume and low quality of the securities. Since many had little
financial stake in the process, it is no surprise that they pursued volume and speed at the cost of
quality. Market self-regulation in this process did nothing to help the maintenance of origination
standards. Cases of lax underwriting and even fraud, such as intentional appraisal inflation or loan
application alteration, were uncovered.
In addition, not all buyers of these securities did their homework appropriately. Many simply relied
on the credit rating from the rating agencies rather than conducting a thorough review of the true
risks they were taking on. Even though the rating agencies usually have more insight into a security
and hence would be able to properly assess the quality of a security, the tranche structure was new
to them and they appeared unable to accurately assess risks embedded in the security and assign an
appropriate credit rating. This is particularly true for institutional investors, such as insurance
companies and banks, who in fact had the required resources and knowledge to conduct in-depth
analysis of the risks. Unfortunately, most of these institutional investors also failed to understand
the potential negative impacts of the agreements they entered into.
This leads to the discussion of Credit Default Swaps (CDS). A CDS is a derivative where the payoffs
are dependent on the survival of a particular entity. Typically, the buyer will pay the seller a series of
payments in exchange for a lump sum payment should the reference entity default. In most cases
during the GFC, institutional investors inadequately assessed that the house price would not fall and
hence there should hardly be any defaults. Therefore, they entered into the CDS transactions
without knowing exactly what or whom they were covering. Due to the existence of these CDS
agreements, everyone thought they were in a perfectly safe position. However, when the market
3
A CDO is a security whose value depends on the cashflow of a portfolio of fixed interest assets. Usually many
CDOs are grouped together in order to divide into different tranches, namely senior, mezzanine and equity
tranches. Equity tranches will bear the first loss while senior tranches have better security in terms of interest
and principal payments.
started to shake, these securities suddenly deteriorated as insurance companies would often find
their counterparties’ names listed in the “Defaulted” category.
What happened to Swiss Re back in 2008 was a very good example of why institutional investors
should conduct a careful investigation for their investments.
From 2003, the Swiss Re asset management business had been growing strongly. In terms of total
assets under management (AUM), it grew from 3% to more than 10% of the total AUM of the group
in just 3 years. This growth helped Swiss Re become one of the biggest reinsurers in the world.
However, their success reversed once the credit quality of their CDS deteriorated. In 2008, Swiss Re
announced a CHF$1 billion (equivalent to NZD $1.629 billion as at 31/12/2008) loss and had its credit
rating downgraded by all major rating agencies4
.
Thus, some of the lessons learned from the GFC are:
 There is no free lunch - the old principle “high risk, high return” still applies. Investors should
carefully investigate risks they are taking on.
 Investors should develop a robust system that enforces understanding the systemic risks of
aggregate exposures, including those which may not be obviously seen.
 Always challenge the accurateness and reliability of the analytical model, such as the one
that underpinned the tranche structure. Investors should familiarise themselves with any
underlying model.
In the next section, we will discuss the importance of ERM and how best practices could help
mitigate the potential risks one can confront in the financial industry.
4
Swiss Re Annual Reports
3. Enterprise Risk Management nowadays
As discussed in the introduction, Enterprise Risk Management is about ´an organisation (...)
assessing, exploiting, financing and monitoring risks from all sources for the purpose of increasing
the organisation’s short- and long-term value to its shareholders´. Traditionally, most insurance
companies have been predominantly managed on profit and loss (earnings) and book value (of
equity) and less so on risk-based measures.
Crises, on several occasions, have revealed that these measures, which are relatively short term
focussed and not always market value equivalent, do not provide significant insight into the various
risks insurance companies are exposed to. In the case of the UK-based insurance company Equitable
Life, policyholders were guaranteed investment returns of 8% or more. The economic value of these
guarantees was not reflected on the balance sheet, however it became significant when over the
course of several years, investment returns dropped well below 8%. The option was not properly
hedged and therefore, amongst other reasons, the company wasn´t able to meet policyholders´
benefits and closed its doors to new business in 2000.
One of the goals of accounting is to provide ´relevant´ information. Relevance in this context means
that information presented in financial statements should be appropriate and assist a person
evaluating the statements to make educated assumptions regarding the future financial state of a
company. Because of events such as the collapse of Equitable Life, accounting standards have
progressively been moving toward fair valuation in order to provide more relevance to accounting
standards.
To protect policyholders and society from systemic damage, such as described in the previous
section, insurance regulators world-wide have progressively introduced new requirements for
insurance companies to develop risk management techniques and to disclose more advanced risk-
based information for the regulator to better assess the capability of insurance companies to keep
their promises to policyholders during times of financial distress.
There are also compelling business reasons to further develop ERM, not only from a risk perspective,
but also from a return perspective, where superior knowledge and understanding of risk can help to
not only mitigate but also exploit risks. However, it should be noted that the weight of these reasons
can also depend on the compensation of directors, which is decided upon by shareholders, who
often have a shorter term investment horizon compared to life insurance, for example. With
accounting standards moving towards fair valuation (i.e. aiming to also capture the market price of
risk), possible materialisation of longer-term risks are also being reflected in the current profit and
loss and balance sheet. This (arguably) more relevant information available to the public effectively
increases the transparency for investors investing in the insurance business.
For all these reasons there is a clear trend in the insurance industry to increase the relevance of risk
management in day-to-day management and to implement ERM. ERM is effectively implemented in
various stages:
 Risk identification
 Risk monitoring
 Risk management (reactive risk management)
 Implementation of risk based strategy (proactive risk management)
In order to successfully implement ERM in strategy, ERM needs to be fully embedded in the
operating model, which requires capabilities in risk analytics. After having established the right
capabilities, the execution of ERM needs to mature. Integration of risk in performance management
incentivises ERM, guaranteeing the execution of ERM for the goal of growing and protecting long-
term shareholder value through a more thorough and deeper understanding of the business, which
is acquired in the process of implementing risk management.
A currently widely used framework to adopt ERM consists of the following elements:
 Risk appetites
Risk appetites represent how much a company is willing to put at risk with a certain
probability over a defined time horizon. The measure defining loss should be directly aligned
with the company’s objectives (e.g. earnings, embedded value and solvency capital). As risk
and return are naturally related, risk appetite statements are directly related to the targeted
return.
 Risk tolerances
A maximum potential reduction is allocated for each risk appetite to the various risk factors
(discussed below) through risk tolerances.
 Key risk indicators (KRIs)
KRIs are measures used for management reporting indicating the status of a risk such as the
total exposure per investment class.
 Risk limits
These are fixed business operation limits, (e.g. a maximum investment in stocks of 30%).
Risk management is about balancing risk and shareholders objectives and identifying the comfort
zone on the risk return curve, which is what this framework aims to do.
Establishing ERM requires a change of thinking about the business and its risks and therefore
enforces a change to a certain extent. Both employees and the board will need to further evolve
their way of thinking about the business. Implementing ERM is about following the right process,
acquiring the right capabilities and about enriching the understanding of the business, but even then
ERM is not likely to succeed without thought leadership. Actuaries are well placed to develop the
required skills to take up this role. Actuaries, more than most others in the insurance industry, are
used to viewing the business from a risk perspective. In addition, actuaries can relatively easily take
up the modelling skills required for ERM.
One of the cornerstones of successful implementation of ERM is reliable, accepted and understood
measurement of value and risks. Some risks can be modelled more reliably than other risks. The
availability of data is often key. For this reason in practice, operational and business risk is often
managed based on risk indicators and less so on modelled quantification. Where reliably possible,
the eventuation of relevant risks and their effect on various value measures are modelled. As
illustrated above, most commonly used value measures are:
 Embedded value
 Earnings
 Capital (Economic and solvency amount available and solvency capital ratios)
These models aim to derive these value measures under a current (base) scenario and stressed
scenarios. In practices, modelled risks factors are:
 Insurance Risk
Most commonly: mortality and longevity, general insurance, expense, lapse and inflation risk
 Market Risk
Most commonly: interest / swap rates, stock price, credit (deteriorating credit quality and
widening of credit spreads – market appreciation of credit risk), currency and liquidity risk.
Operational and business risks are not often modelled currently. Stress scenarios are usually
determined using a one year horizon and confidence interval, often between 90% and 99.99%
,depending on the type of value measurement, geography, regulation and other factors.
4. Professionalism, ethics and CERA
Financial crises are in many cases directly linked with unethical practice, which has contributed to
various corporate failures in the past. For example, when investigators were examining the causes of
HIH’s collapse, they uncovered the fact that senior management, including key actuarial
stakeholders had “intentionally misled and lied to the company’s auditors from time to time”5
As actuaries are taking up responsible roles within the organisation, they may confront
circumstances where professional ethics may be challenged in practice. An actuary should act with
integrity and make professional decisions upon all situations in order to achieve a successful
actuarial practice. A professionalism course is therefore an integral part of any actuarial education
scheme. Candidates must successfully complete a professionalism course in order to become a
qualified actuary.
The CERA designation was developed in the wake of awareness of the importance of risk
management. A Chartered Enterprise Risk Analyst (CERA) has “demonstrated knowledge in the
identification, measurement and management of risk within risk–bearing enterprises”, according to
the Society of Actuaries. Combined with the professionalism course, which covers the professional
code of conduct and the importance of adherence to recognised standards of practice, the CERA
designation is deemed to be an appropriate qualification of a risk manager.
One of the advantages of CERA is its global recognition. That is, there are no national boundaries as
with actuarial credentials currently. This effectively means a CERA designation gives one the ability
to work in many different countries – from Canada to Australia – as a professional who has
appropriate credentials within risk management.
A CERA holder must go through a series of technical and professional trainings in order to earn the
designation, which includes:
 Understanding of the ERM concept / framework
 Familiarity of the ERM process
 Ability to identify and categorise different risks
 Modelling various risks individually as well as on an aggregate level
 Applying appropriate risk metrics to quantify risks where possible
 Communicating the results of the analysis in plain English and in an effective manner
 Having a strong understanding of Economic Capital and its applications in the real world
A CERA designation could be earned through one of the actuarial education associations, including:
 Society of Actuaries (SOA) – the United States
 Institute / Faculty of Actuaries – the United Kingdom
5
Corporate governance, managerial malfeasance and incentive compensation schemes: The case of HIH
Insurance in Australia. Dr Scott Bourke and Dr Neil E. Bžchervaise.
 Institute of Actuaries of Australia – Australia
 Actuarieel Genootschap – the Netherlands
 Actuarial Society of South Africa – South Africa
For example, the CERA from SOA comprises 8 exams and according to the SOA website it usually
takes the student three to four years to complete the entire education on a part time basis6
. The
Dutch Actuarial Society offers an intense CERA training schedule over four months.
Most actuaries becoming technical experts in the insurance industry focus on risk management of
insurance risks and financial market risks. It is less common for actuaries to become experts in the
field of operational and business risks. Generally, insurance and financial market risks are modelled
risks (hence the preferred choice of actuaries) and operational and business risks less so.
Most life insurance companies in New Zealand currently perform some form of embedded value
calculation, which is often used solely for management reporting rather than performance
management. Some form of earnings projection exists as part of actuarial reporting. Most insurance
companies in New Zealand have not (yet) established an economic capital (or Value at Risk) model.
Asset and liability modelling techniques, used to model the combined impact of asset and liabilities,
are applied in economic capital and embedded value models. Investment mandates, designed within
ERM frameworks are often driven by risk ERM return ratios. To conclude, most models required for
ERM in the framework as described in section 3 are present in some form, but need to be further
developed and integrated to grow from reporting / monitoring purposes to more mature stages of
ERM.
Embedded Value, Economic Capital and earnings projection models need to be internally consistent,
complete and theoretically sound to be understood and accepted. For most New Zealand insurance
companies to further develop ERM, an integrated suite of models will be required to grow risk
management to being integrated in strategy and enhance performance.
Building on existing knowledge and actuarial training, the CERA qualification will help actuaries to
further develop a good understanding of the technicalities behind financial market and insurance
risks modelling for ERM. Furthermore, it also trains actuaries to obtain a general understanding of
risk management, including non-modelled risks and the processes required in order to establish and
maintain an ERM framework.
Risk management in the insurance industry is a technical area. To clearly communicate ERM model
results, it is essential to obtain buy-in from management and the board. Actuaries can take a leading
role as they understand ERM model results and can support the board and management to
effectively apply the results and understand the relevant underlying assumptions and shortcomings
of these models.
Leading and supporting ERM transitions in insurance companies can be a challenging and rewarding
experience, enriching both technical and interpersonal skills. Actuaries are driving ERM within the
6
http://www.ceranalyst.org/overview.asp
insurance industry, the banking industry and (although on a lesser scale currently) in the energy
industry. Most of the technical and non-technical challenges present within the insurance industry
are equally present in these other industries.
References
 American Academy of Actuaries, 2002, Fair Valuation of Insurance Liabilities: Principles and
Methods, Public Policy Monograph.
 Hayre, Lakhbir S., Robert Young, 2004, Guide to Mortgage-Backed Securities, Citigroup.
 Wheeler, Darrell, et al, 2007, A Simple Guide to Subprime Mortgages, CDO, and
Securitization, Citigroup.
 Society of Actuaries. www.soa.org

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FP - Risk_Management

  • 1. Future Pathways Fresh perspectives from actuaries of the future Risk Management: An overview of the development of ERM in the insurance industry and the pathway of the actuary Prepared by James Xu, AMP Klaas Stijnen, Deloitte Presented to the New Zealand Society of Actuaries Future Pathways Sessional Meeting 15 – 16 March 2011
  • 2. Abstract The Global Financial Crisis (GFC) has forced the insurance industry to put a stronger focus on risk management. Strengthening regulatory requirements and ever more risk-oriented business-needs almost continuously increase the demand for actuaries focussed on risk management. Through the GFC, the need for and willingness of actuaries to further embrace risk management as a key focus has excelled. Currently, and with increasing momentum, Enterprise Risk Management (ERM) is being implemented across the financial industry. The International Actuarial Association responded to the need for risk management focussed actuaries by introducing the Chartered Enterprise Risk Analyst (CERA) credential, which aims to equip actuaries with the right tools to implement and manage ERM. Managing the after-effects of the Global Financial Crisis requires will require changes by many insurance companies. As a driver of these changes, the role of the actuary is one that will require more than just technical skills, such as professionalism and leadership.
  • 3. 1. Introduction Risk management is an often heard word nowadays especially in the finance industry. In the 15 years before the Global Financial Crisis (GFC), the development of risk management had been fairly gradual, driven by strengthening regulatory requirements as well as through business needs. Actuaries have been seen by many as professionals with the right skill set and attitude to lead these devlopments in insurance companies to fully embed risk management. Various educational actuarial bodies increased the weight of risk management techniques such as Value at Risk in the actuarial training during the first half of the last decade. This enforced focus coincided with an increasing number of insurance companies in most developed countries implementing risk management systems to identify, monitor and develop a deep understanding of risks. During the second half of the same decade, as the understanding of risks and the regulatory push for risk management increased, Enterprise Risk Management (ERM) moved to the forefront. ERM represents the concept in which “an organisation (...) assesses, exploits, finances and monitors risks from all sources for the purpose of increasing the organisation’s short- and long-term value to its shareholders”1 . The GFC hit the financial industry hard during the second half of 2008, uncovering risks which appeared to have not been managed properly. Unsurprisingly, poor risk management was the target of various critics. The GFC changed the pace of the development of ERM in the financial industry. The various financial failures in the financial industry exposed ERM as a critical tool in order for the business to survive and succeed, driving a more rapid implementation in an increasing number of companies and geographical areas. In response, the International Actuarial Association introduced the Chartered Enterprise Risk Analyst (CERA) credential to distinguish a core actuarial body of risk management knowledge alongside appropriate standards for achieving the qualification. In the next section of this paper, we investigate the various causes, implications and lessons learned from the GFC with a focus on the role of risk management. In the following section, we pay particular attention to ERM. We discuss some best practices currently adopted by the insurance industry. We explore the benefits of having ERM and what challenges a risk manager might have to deal with in the implementation of ERM. In the last section, we provide an overview of the CERA credential. We discuss the objectives of the qualification and provide a high level outline of the course. Finally, we discuss how this qualification prepares an actuary for implementing and performing ERM. Other papers presented at the Future Pathways Sessional Meeting extensively cover prudential regulation. Therefore, we have chosen not to focus on this matter in this paper. 1 Various definitions of ERM exist. This definition is applied by the Casualty Actuarial Society.
  • 4. 2. Risk Management and the GFC Over the years, we have observed many incidents that could have been avoided or at least mitigated were an appropriate risk management process in place. The famous Baring Bank case, where lack of disciplined investments led to a loss of $1.5 billion and the collapse of the entity, is a good example which emphasises that the implementation of Enterprise Risk Management has become a burning issue for financial services organisations. One of the key drivers of risk management development is increasing regulatory requirements. From the 1933 Act2 right after the start of the Great Depression to Sarbanes-Oxley to Solvency II, regulators around the world have been working towards a much stricter environment for the entire financial services industry, which has led to the shaping up of risk management for the financial sector today. Unfortunately, many of these regulatory changes only took place after a major collapse of the industry, which was why the US government strengthened control over the financial sector after the GFC had taken hold. The boom of the US housing market, where a consecutive 10-year rise in house prices led to a belief that a nationwide house price drop would never happen, is seen as the primary cause of the GFC. In addition, there were many secondary causes contributing to the magnitude of the crisis, such as the complex and ultimately ineffective regulatory system in the US. This system gave rise to a conflict of interest which led to problems in the securitisation process. Also, an over-reliance on credit ratings by market participants and regulators has been observed. It is believed that one of the main contributors to the GFC were Residential Mortgage Backed Securities (RMBS). A RMBS is a securitisation that uses the householders’ repayment on mortgages as collateral in order to obtain a higher credit rating for the security. A lack of regulatory supervision on securitisations contributed directly to the expansion of these securities, which resulted in a rapid deterioration in quality of the underlying mortgages. The RMBS were initiated by Government Sponsored Enterprises, namely Fannie Mae (FNMA), Freddie Mac (FHLM) and Ginnie Mae (GNMA). Growth in the issue of RMBS over the years can be found in the diagram below. All dollar amounts are in USD. 2 This is the US Securities Act of 1933, which was introduced after the stock market crash in 1929. It requires the listing of any new securities to be registered. The Securities and Exchange Commission (SEC) took over the registration authority a year later.
  • 5. source: Citigroup As can be seen from the above graph, the securitisations issued by the three major entities (Ginnie Mae, Fannie Mae and Freddie Mac) increased dramatically towards the end of the last century. source: LoanPerformance In addition to the government agency issued securities, there were numerous non-agency securities that usually offered a higher return, but with the originator not guaranteeing the quality or the repayment of the securities. In the diagram above, Alt-A loans usually refer to loans with borrowers having an unstable source of income. ARM (Adjusted-Rate Mortgage) refers to periodically adjusted interest rates on mortgages according to a series of publicly available indices. Subprime loans are usually to borrowers with low credit quality while Whole Loans are loans that exceed the maximum allowed loan size accepted by the government agencies. Similarly to the government agency securities, the issue of non-agency securities also boomed together with house prices. However, they then almost vanished due to the credit crunch after 2007 as can be seen from the above graph.
  • 6. Since borrowers have a variety of credit quality, when a sufficiently large pool of mortgages had been accumulated, the issuers were able to divide these into different tranches with different seniorities. Tranches with lower seniority were then expected to bear the initial loss if borrowers defaulted. Following this restructuring, despite the poor credit quality of individual loans, rating agencies would have “enough” evidence to show that some of the tranches in fact qualified as a “AAA” rating. A similar situation was observed with Collateralised Debt Obligations (CDOs)3 , especially in CDO- squared, where poor quality CDOs were accumulated to construct a tranche-like structure in order to qualify for a better credit rating. It is clear that not only were there flaws in the regulatory frameworks, but it also created serious incentive problems for the participants in the process of focussing on short term goals (e.g. volume and bonus) rather than the long term viability (the quality of the loans). The US regulatory framework will not be discussed further in this paper, since it is less relevant to the New Zealand insurance market. We will therefore turn our focus to a less systemic but more behaviour-driven analysis. The fact that many of the participants in the securitisation process (such as appraisers, bankers, mortgage brokers, and investment bankers) aimed for short-term results with little consideration for longer-term outcomes led to high volume and low quality of the securities. Since many had little financial stake in the process, it is no surprise that they pursued volume and speed at the cost of quality. Market self-regulation in this process did nothing to help the maintenance of origination standards. Cases of lax underwriting and even fraud, such as intentional appraisal inflation or loan application alteration, were uncovered. In addition, not all buyers of these securities did their homework appropriately. Many simply relied on the credit rating from the rating agencies rather than conducting a thorough review of the true risks they were taking on. Even though the rating agencies usually have more insight into a security and hence would be able to properly assess the quality of a security, the tranche structure was new to them and they appeared unable to accurately assess risks embedded in the security and assign an appropriate credit rating. This is particularly true for institutional investors, such as insurance companies and banks, who in fact had the required resources and knowledge to conduct in-depth analysis of the risks. Unfortunately, most of these institutional investors also failed to understand the potential negative impacts of the agreements they entered into. This leads to the discussion of Credit Default Swaps (CDS). A CDS is a derivative where the payoffs are dependent on the survival of a particular entity. Typically, the buyer will pay the seller a series of payments in exchange for a lump sum payment should the reference entity default. In most cases during the GFC, institutional investors inadequately assessed that the house price would not fall and hence there should hardly be any defaults. Therefore, they entered into the CDS transactions without knowing exactly what or whom they were covering. Due to the existence of these CDS agreements, everyone thought they were in a perfectly safe position. However, when the market 3 A CDO is a security whose value depends on the cashflow of a portfolio of fixed interest assets. Usually many CDOs are grouped together in order to divide into different tranches, namely senior, mezzanine and equity tranches. Equity tranches will bear the first loss while senior tranches have better security in terms of interest and principal payments.
  • 7. started to shake, these securities suddenly deteriorated as insurance companies would often find their counterparties’ names listed in the “Defaulted” category. What happened to Swiss Re back in 2008 was a very good example of why institutional investors should conduct a careful investigation for their investments. From 2003, the Swiss Re asset management business had been growing strongly. In terms of total assets under management (AUM), it grew from 3% to more than 10% of the total AUM of the group in just 3 years. This growth helped Swiss Re become one of the biggest reinsurers in the world. However, their success reversed once the credit quality of their CDS deteriorated. In 2008, Swiss Re announced a CHF$1 billion (equivalent to NZD $1.629 billion as at 31/12/2008) loss and had its credit rating downgraded by all major rating agencies4 . Thus, some of the lessons learned from the GFC are:  There is no free lunch - the old principle “high risk, high return” still applies. Investors should carefully investigate risks they are taking on.  Investors should develop a robust system that enforces understanding the systemic risks of aggregate exposures, including those which may not be obviously seen.  Always challenge the accurateness and reliability of the analytical model, such as the one that underpinned the tranche structure. Investors should familiarise themselves with any underlying model. In the next section, we will discuss the importance of ERM and how best practices could help mitigate the potential risks one can confront in the financial industry. 4 Swiss Re Annual Reports
  • 8. 3. Enterprise Risk Management nowadays As discussed in the introduction, Enterprise Risk Management is about ´an organisation (...) assessing, exploiting, financing and monitoring risks from all sources for the purpose of increasing the organisation’s short- and long-term value to its shareholders´. Traditionally, most insurance companies have been predominantly managed on profit and loss (earnings) and book value (of equity) and less so on risk-based measures. Crises, on several occasions, have revealed that these measures, which are relatively short term focussed and not always market value equivalent, do not provide significant insight into the various risks insurance companies are exposed to. In the case of the UK-based insurance company Equitable Life, policyholders were guaranteed investment returns of 8% or more. The economic value of these guarantees was not reflected on the balance sheet, however it became significant when over the course of several years, investment returns dropped well below 8%. The option was not properly hedged and therefore, amongst other reasons, the company wasn´t able to meet policyholders´ benefits and closed its doors to new business in 2000. One of the goals of accounting is to provide ´relevant´ information. Relevance in this context means that information presented in financial statements should be appropriate and assist a person evaluating the statements to make educated assumptions regarding the future financial state of a company. Because of events such as the collapse of Equitable Life, accounting standards have progressively been moving toward fair valuation in order to provide more relevance to accounting standards. To protect policyholders and society from systemic damage, such as described in the previous section, insurance regulators world-wide have progressively introduced new requirements for insurance companies to develop risk management techniques and to disclose more advanced risk- based information for the regulator to better assess the capability of insurance companies to keep their promises to policyholders during times of financial distress. There are also compelling business reasons to further develop ERM, not only from a risk perspective, but also from a return perspective, where superior knowledge and understanding of risk can help to not only mitigate but also exploit risks. However, it should be noted that the weight of these reasons can also depend on the compensation of directors, which is decided upon by shareholders, who often have a shorter term investment horizon compared to life insurance, for example. With accounting standards moving towards fair valuation (i.e. aiming to also capture the market price of risk), possible materialisation of longer-term risks are also being reflected in the current profit and loss and balance sheet. This (arguably) more relevant information available to the public effectively increases the transparency for investors investing in the insurance business. For all these reasons there is a clear trend in the insurance industry to increase the relevance of risk management in day-to-day management and to implement ERM. ERM is effectively implemented in various stages:
  • 9.  Risk identification  Risk monitoring  Risk management (reactive risk management)  Implementation of risk based strategy (proactive risk management) In order to successfully implement ERM in strategy, ERM needs to be fully embedded in the operating model, which requires capabilities in risk analytics. After having established the right capabilities, the execution of ERM needs to mature. Integration of risk in performance management incentivises ERM, guaranteeing the execution of ERM for the goal of growing and protecting long- term shareholder value through a more thorough and deeper understanding of the business, which is acquired in the process of implementing risk management. A currently widely used framework to adopt ERM consists of the following elements:  Risk appetites Risk appetites represent how much a company is willing to put at risk with a certain probability over a defined time horizon. The measure defining loss should be directly aligned with the company’s objectives (e.g. earnings, embedded value and solvency capital). As risk and return are naturally related, risk appetite statements are directly related to the targeted return.  Risk tolerances A maximum potential reduction is allocated for each risk appetite to the various risk factors (discussed below) through risk tolerances.  Key risk indicators (KRIs) KRIs are measures used for management reporting indicating the status of a risk such as the total exposure per investment class.  Risk limits These are fixed business operation limits, (e.g. a maximum investment in stocks of 30%). Risk management is about balancing risk and shareholders objectives and identifying the comfort zone on the risk return curve, which is what this framework aims to do. Establishing ERM requires a change of thinking about the business and its risks and therefore enforces a change to a certain extent. Both employees and the board will need to further evolve their way of thinking about the business. Implementing ERM is about following the right process, acquiring the right capabilities and about enriching the understanding of the business, but even then ERM is not likely to succeed without thought leadership. Actuaries are well placed to develop the required skills to take up this role. Actuaries, more than most others in the insurance industry, are used to viewing the business from a risk perspective. In addition, actuaries can relatively easily take up the modelling skills required for ERM. One of the cornerstones of successful implementation of ERM is reliable, accepted and understood measurement of value and risks. Some risks can be modelled more reliably than other risks. The availability of data is often key. For this reason in practice, operational and business risk is often managed based on risk indicators and less so on modelled quantification. Where reliably possible,
  • 10. the eventuation of relevant risks and their effect on various value measures are modelled. As illustrated above, most commonly used value measures are:  Embedded value  Earnings  Capital (Economic and solvency amount available and solvency capital ratios) These models aim to derive these value measures under a current (base) scenario and stressed scenarios. In practices, modelled risks factors are:  Insurance Risk Most commonly: mortality and longevity, general insurance, expense, lapse and inflation risk  Market Risk Most commonly: interest / swap rates, stock price, credit (deteriorating credit quality and widening of credit spreads – market appreciation of credit risk), currency and liquidity risk. Operational and business risks are not often modelled currently. Stress scenarios are usually determined using a one year horizon and confidence interval, often between 90% and 99.99% ,depending on the type of value measurement, geography, regulation and other factors.
  • 11. 4. Professionalism, ethics and CERA Financial crises are in many cases directly linked with unethical practice, which has contributed to various corporate failures in the past. For example, when investigators were examining the causes of HIH’s collapse, they uncovered the fact that senior management, including key actuarial stakeholders had “intentionally misled and lied to the company’s auditors from time to time”5 As actuaries are taking up responsible roles within the organisation, they may confront circumstances where professional ethics may be challenged in practice. An actuary should act with integrity and make professional decisions upon all situations in order to achieve a successful actuarial practice. A professionalism course is therefore an integral part of any actuarial education scheme. Candidates must successfully complete a professionalism course in order to become a qualified actuary. The CERA designation was developed in the wake of awareness of the importance of risk management. A Chartered Enterprise Risk Analyst (CERA) has “demonstrated knowledge in the identification, measurement and management of risk within risk–bearing enterprises”, according to the Society of Actuaries. Combined with the professionalism course, which covers the professional code of conduct and the importance of adherence to recognised standards of practice, the CERA designation is deemed to be an appropriate qualification of a risk manager. One of the advantages of CERA is its global recognition. That is, there are no national boundaries as with actuarial credentials currently. This effectively means a CERA designation gives one the ability to work in many different countries – from Canada to Australia – as a professional who has appropriate credentials within risk management. A CERA holder must go through a series of technical and professional trainings in order to earn the designation, which includes:  Understanding of the ERM concept / framework  Familiarity of the ERM process  Ability to identify and categorise different risks  Modelling various risks individually as well as on an aggregate level  Applying appropriate risk metrics to quantify risks where possible  Communicating the results of the analysis in plain English and in an effective manner  Having a strong understanding of Economic Capital and its applications in the real world A CERA designation could be earned through one of the actuarial education associations, including:  Society of Actuaries (SOA) – the United States  Institute / Faculty of Actuaries – the United Kingdom 5 Corporate governance, managerial malfeasance and incentive compensation schemes: The case of HIH Insurance in Australia. Dr Scott Bourke and Dr Neil E. Bžchervaise.
  • 12.  Institute of Actuaries of Australia – Australia  Actuarieel Genootschap – the Netherlands  Actuarial Society of South Africa – South Africa For example, the CERA from SOA comprises 8 exams and according to the SOA website it usually takes the student three to four years to complete the entire education on a part time basis6 . The Dutch Actuarial Society offers an intense CERA training schedule over four months. Most actuaries becoming technical experts in the insurance industry focus on risk management of insurance risks and financial market risks. It is less common for actuaries to become experts in the field of operational and business risks. Generally, insurance and financial market risks are modelled risks (hence the preferred choice of actuaries) and operational and business risks less so. Most life insurance companies in New Zealand currently perform some form of embedded value calculation, which is often used solely for management reporting rather than performance management. Some form of earnings projection exists as part of actuarial reporting. Most insurance companies in New Zealand have not (yet) established an economic capital (or Value at Risk) model. Asset and liability modelling techniques, used to model the combined impact of asset and liabilities, are applied in economic capital and embedded value models. Investment mandates, designed within ERM frameworks are often driven by risk ERM return ratios. To conclude, most models required for ERM in the framework as described in section 3 are present in some form, but need to be further developed and integrated to grow from reporting / monitoring purposes to more mature stages of ERM. Embedded Value, Economic Capital and earnings projection models need to be internally consistent, complete and theoretically sound to be understood and accepted. For most New Zealand insurance companies to further develop ERM, an integrated suite of models will be required to grow risk management to being integrated in strategy and enhance performance. Building on existing knowledge and actuarial training, the CERA qualification will help actuaries to further develop a good understanding of the technicalities behind financial market and insurance risks modelling for ERM. Furthermore, it also trains actuaries to obtain a general understanding of risk management, including non-modelled risks and the processes required in order to establish and maintain an ERM framework. Risk management in the insurance industry is a technical area. To clearly communicate ERM model results, it is essential to obtain buy-in from management and the board. Actuaries can take a leading role as they understand ERM model results and can support the board and management to effectively apply the results and understand the relevant underlying assumptions and shortcomings of these models. Leading and supporting ERM transitions in insurance companies can be a challenging and rewarding experience, enriching both technical and interpersonal skills. Actuaries are driving ERM within the 6 http://www.ceranalyst.org/overview.asp
  • 13. insurance industry, the banking industry and (although on a lesser scale currently) in the energy industry. Most of the technical and non-technical challenges present within the insurance industry are equally present in these other industries. References  American Academy of Actuaries, 2002, Fair Valuation of Insurance Liabilities: Principles and Methods, Public Policy Monograph.  Hayre, Lakhbir S., Robert Young, 2004, Guide to Mortgage-Backed Securities, Citigroup.  Wheeler, Darrell, et al, 2007, A Simple Guide to Subprime Mortgages, CDO, and Securitization, Citigroup.  Society of Actuaries. www.soa.org