Treatment of Expense Overruns and Lapse Profits in Asset Share Calculations

Should Expense Overruns be adjusted against
Lapse Profits while calculating the asset shares
in participating business?
By Himanshu Bhatia, Yogita Rawat,
Ranjan Gupta & Swati Gupta
Guide : Mr. Suresh Sindhi
22
nd
 Indian Fellowship Seminar
Indian Actuarial Profession
Serving the Cause of Public Interest
Introduction
Treatment of Expense Overruns & Lapse profits
Current scenario
Should Expense Overruns be adjusted against Lapse Profits?-
Factors
Distribution of Surplus
Professional Framework
Regulatory Framework
UK Scenario
Summary & Conclusions
Questions?
Agenda
2
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+
Asset Shares
According to GN 6, an asset share for a policy grouping at a given
point in time is the accumulation of the premiums received plus
investment income earned from the inception of the policies,
less deductions due to benefit payments, commission, expenses,
tax, a reasonable cost of capital and of guarantees, contribution
from miscellaneous surplus (if considered appropriate) and
transfers to shareholders.
Accumulation of
Introduction: Asset share
3
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Premiums +
Investment income
-
Benefit payments + Commission +
Expenses + Tax + COC + COG + Misc.
Profit + Transfer to Share Holders
Asset Shares – Uses
Bonus rates
Surrender Values
Maturity Benefits
Introduction: Uses of Asset Share
4
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Treatment of Expense in
Asset Shares
Full expenses charged to
Asset share
Pricing Expense
Expense used in benefit
illustrations
Long term Best estimate
Treatment of Expense & Lapse profits in Asset Share
5
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High Initial Expenses
Many insurance companies still relying on agency and third party
distributors which involves high acquisition costs
High/significant costs involved in setting up Banc assurance/
Direct Marketing/Online sales
Low Volumes of business
High Maintenance Costs
Expense inflation & salary inflation
Enhanced regulatory constraints & reporting
      Eg. Significant system development required to cater Shadow
Accounting and Non-Residual Additions (NRA)
Scale of operations
Expense Overruns
6
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Treatment of Expense Overruns
Alternatives
Full expense charged to AS
Difference charged to Estate
Difference charged to Share holders
Expense Overruns
7
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Asset Shares calculation – current Indian Context
$
Treatment of expense overrun – 39% charged the difference to
the Estate, 31% charged the difference to the Share holder &
31% charged the full expense to the AS
Treatment of lapse profits – 31% credited to AS while 69%
credited to the estate
 
$ 
Based on “India Asset Share Survey” by Milliman dated 04.02.2014
 
(Based on responses from 14 companies out of 24 life insurance companies-
representing 58% of total market)
Current Scenario
8
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Current Scenario
9
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Why is the treatment of
expense overruns not
uniform across industry???
The Big Question : Should Expense Overruns be adjusted against
Lapse Profits
Answer would ideally depend on the following:
Age of the Insurer & Par-Fund
Par-Fund Estate
Company ‘s Par-Fund Management policy
Comparison of Actual Lapse profits v/s Assumed Lapse Profits
Policyholder Reasonable Expectations(PRE) set by Benefit
Illustrations & Other Disclosures
Shareholders’ Attitude & belief: Provisions for expense overruns
Practice followed by others in industry
Expense Overruns & Lapse Profits
10
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Charging Overruns to Asset Shares
Will impact the current generation of policyholders
Factors affecting distribution of surplus
Professional Framework
Regulatory Framework
Expense Overruns & Lapse Profits
11
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Distribution of Surplus: factors to consider
Equity among different class/generation of policyholders
Market practice and competitors' actions
Communications to the policyholders in form of sales
illustrations, With profit manual & other correspondence
Policyholders reasonable expectations and sales practices used
Shareholders role to support the business initially
Merge of expense overruns in best estimates expenses
Professional obligations and Regulatory framework
Par Fund Management
12
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Asset Shares Vs Par Fund Estate
Reversionary Bonus v/s Terminal Bonus rates
Surrender Values
Maturity Benefits
Par Fund Management
13
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GN 6
AA must consider the consistency of expenses being charged to
asset shares with what has and is being illustrated to customers.
Actual allocation to Asset Share w.r.t. renewal expense can vary
on discretion as long as Policy holders’ reasonable expectations
(PRE) encompass
Professional Framework
14
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GN 6
Professional Framework
15
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The amount of expenses charged to the historical asset share of policies
a) The Appointed Actuary must consider the 
consistency of expenses 
being
charged to asset shares with 
what has and is being illustrated to customers
. In
particular, the expenses intended to be allocated to the asset shares should be
consistent with the bonuses projected in benefit illustrations.
b) In respect of renewal expenses, so long as policyholders‟ 
reasonable
expectations 
encompass expense risk, the Appointed Actuary, when making
the actual allocation to asset shares, may use a degree of discretion in
departing from the expenses implicit in any benefit illustration issued at point
of sale. However, in respect of acquisition expenses, the level of expense
should be known with greater certainty.
Hence, the Appointed Actuary will have less scope to depart from the level of
expense implicit in any benefit illustration when allocating acquisition
expenses to asset shares. The Appointed Actuary 
should document any such
departur
e.
GN 6
Professional Framework
16
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c) Where the expenses allocated to the fund exceed those allocated to the
asset shares, the Appointed Actuary should consider the reasons for this, and
be satisfied 
that the approach:
i. 
is sustainable
;
ii. is not, by its effect on the estate, expected to 
affect policyholders‟
reasonable expectations 
adversely and materially; and
iii. is appropriately reflected in the 
expenses assumed in the statutory
valuation of liabilities
.
IRDA(Non-Linked Products) 2013 Regulations
Special Surrender Value(SSV) shall represent the asset share in
case of the par policies, where the asset share shall be
determined in accordance with the guidance or practice
standards issued by the Institute of Actuaries of India
With Profits Committee (WPC)
Independent committee w. r. t. Decisions related to Par business
Regulatory Framework
17
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Role of PPFM: A mandatory with profit guide
Role of Estate
Investment Flexibility
Requirements of Regulatory capital
Payment of Tax incurred by fund on distribution to shareholders
Covering overruns on existing  & new business expense
Smoothing flexibility
 Regulatory Approval for difference in pattern of distribution as
compared to previous practice
UK Framework
18
www.actuariesindia.org
The bigger picture!
Answer  depends on various factors
Role of Professional body & Regulatory Body
Freedom given to industry by the virtue of various provisions of
applicable Professional & Regulatory framework keeping in view
Sustainability of Fund, PREs, Equity Considerations, Shareholder
Approach & Overall Objectives of Business
Charging the overruns to asset share might be the only option for
sustainability of the company and policyholders ultimately
Charging the overruns to estate would serve as a balancing act
Charging the overruns to share holders would ultimately lead to fair
policyholder treatment & curtailing expenses
Summary & Conclusion:
19
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Time for Two way discussion
20
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Exploring the adjustment of expense overruns against lapse profits in determining asset shares for participating businesses. The discussion covers factors, distribution of surplus, professional and regulatory frameworks, and scenarios from the UK. Questions and conclusions round off the analysis.

  • Asset Share Calculations
  • Expense Overruns
  • Lapse Profits
  • Surplus Distribution
  • Regulatory Framework

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  1. Should Expense Overruns be adjusted against Lapse Profits while calculating the asset shares in participating business? By Himanshu Bhatia, Yogita Rawat, Ranjan Gupta & Swati Gupta Guide : Mr. Suresh Sindhi 22nd Indian Fellowship Seminar Indian Actuarial Profession Serving the Cause of Public Interest

  2. Agenda Introduction Treatment of Expense Overruns & Lapse profits Current scenario Should Expense Overruns be adjusted against Lapse Profits?- Factors Distribution of Surplus Professional Framework Regulatory Framework UK Scenario Summary & Conclusions Questions? www.actuariesindia.org 2

  3. Introduction: Asset share Asset Shares According to GN 6, an asset share for a policy grouping at a given point in time is the accumulation of the premiums received plus investment income earned from the inception of the policies, less deductions due to benefit payments, commission, expenses, tax, a reasonable cost of capital and of guarantees, contribution from miscellaneous surplus (if considered appropriate) and transfers to shareholders. Accumulation of Benefit payments + Commission + Expenses + Tax + COC + COG + Misc. Profit + Transfer to Share Holders Premiums + Investment income - + www.actuariesindia.org 3

  4. Introduction: Uses of Asset Share Asset Shares Uses Bonus rates Surrender Values Maturity Benefits www.actuariesindia.org 4

  5. Treatment of Expense & Lapse profits in Asset Share Treatment of Expense in Asset Shares Treatment of Lapse Profits in Asset Shares Full expenses charged to Asset share Credited to Asset Share Credited to Estate Pricing Expense Expense used in benefit illustrations Long term Best estimate www.actuariesindia.org 5

  6. Expense Overruns High Initial Expenses Many insurance companies still relying on agency and third party distributors which involves high acquisition costs High/significant costs involved in setting up Banc assurance/ Direct Marketing/Online sales Low Volumes of business High Maintenance Costs Expense inflation & salary inflation Enhanced regulatory constraints & reporting Eg. Significant system development required to cater Shadow Accounting and Non-Residual Additions (NRA) Scale of operations www.actuariesindia.org 6

  7. Expense Overruns Treatment of Expense Overruns Alternatives Full expense charged to AS Difference charged to Estate Difference charged to Share holders www.actuariesindia.org 7

  8. Current Scenario Asset Shares calculation current Indian Context$ Treatment of expense overrun 39% charged the difference to the Estate, 31% charged the difference to the Share holder & 31% charged the full expense to the AS Treatment of lapse profits 31% credited to AS while 69% credited to the estate $ Based on India Asset Share Survey by Milliman dated 04.02.2014 (Based on responses from 14 companies out of 24 life insurance companies- representing 58% of total market) www.actuariesindia.org 8

  9. Current Scenario Why is the treatment of expense overruns not uniform across industry??? www.actuariesindia.org 9

  10. Expense Overruns & Lapse Profits The Big Question : Should Expense Overruns be adjusted against Lapse Profits Answer would ideally depend on the following: Age of the Insurer & Par-Fund Par-Fund Estate Company s Par-Fund Management policy Comparison of Actual Lapse profits v/s Assumed Lapse Profits Policyholder Reasonable Expectations(PRE) set by Benefit Illustrations & Other Disclosures Shareholders Attitude & belief: Provisions for expense overruns Practice followed by others in industry www.actuariesindia.org 10

  11. Expense Overruns & Lapse Profits Charging Overruns to Asset Shares Will impact the current generation of policyholders Factors affecting distribution of surplus Professional Framework Regulatory Framework www.actuariesindia.org 11

  12. Par Fund Management Distribution of Surplus: factors to consider Equity among different class/generation of policyholders Market practice and competitors' actions Communications to the policyholders in form of sales illustrations, With profit manual & other correspondence Policyholders reasonable expectations and sales practices used Shareholders role to support the business initially Merge of expense overruns in best estimates expenses Professional obligations and Regulatory framework www.actuariesindia.org 12

  13. Par Fund Management Asset Shares Vs Par Fund Estate Reversionary Bonus v/s Terminal Bonus rates Surrender Values Maturity Benefits www.actuariesindia.org 13

  14. Professional Framework GN 6 AA must consider the consistency of expenses being charged to asset shares with what has and is being illustrated to customers. Actual allocation to Asset Share w.r.t. renewal expense can vary on discretion as long as Policy holders reasonable expectations (PRE) encompass www.actuariesindia.org 14

  15. Professional Framework GN 6 The amount of expenses charged to the historical asset share of policies a) The Appointed Actuary must consider the consistency of expenses being charged to asset shares with what has and is being illustrated to customers. In particular, the expenses intended to be allocated to the asset shares should be consistent with the bonuses projected in benefit illustrations. b) In respect of renewal expenses, so long as policyholders reasonable expectations encompass expense risk, the Appointed Actuary, when making the actual allocation to asset shares, may use a degree of discretion in departing from the expenses implicit in any benefit illustration issued at point of sale. However, in respect of acquisition expenses, the level of expense should be known with greater certainty. Hence, the Appointed Actuary will have less scope to depart from the level of expense implicit in any benefit illustration when allocating acquisition expenses to asset shares. The Appointed Actuary should document any such departure. www.actuariesindia.org 15

  16. Professional Framework GN 6 c) Where the expenses allocated to the fund exceed those allocated to the asset shares, the Appointed Actuary should consider the reasons for this, and be satisfied that the approach: i. is sustainable; ii. is not, by its effect on the estate, expected to affect policyholders reasonable expectations adversely and materially; and iii. is appropriately reflected in the expenses assumed in the statutory valuation of liabilities. www.actuariesindia.org 16

  17. Regulatory Framework IRDA(Non-Linked Products) 2013 Regulations Special Surrender Value(SSV) shall represent the asset share in case of the par policies, where the asset share shall be determined in accordance with the guidance or practice standards issued by the Institute of Actuaries of India With Profits Committee (WPC) Independent committee w. r. t. Decisions related to Par business www.actuariesindia.org 17

  18. UK Framework Role of PPFM: A mandatory with profit guide Role of Estate Investment Flexibility Requirements of Regulatory capital Payment of Tax incurred by fund on distribution to shareholders Covering overruns on existing & new business expense Smoothing flexibility Regulatory Approval for difference in pattern of distribution as compared to previous practice www.actuariesindia.org 18

  19. Summary & Conclusion: The bigger picture! Answer depends on various factors Role of Professional body & Regulatory Body Freedom given to industry by the virtue of various provisions of applicable Professional & Regulatory framework keeping in view Sustainability of Fund, PREs, Equity Considerations, Shareholder Approach & Overall Objectives of Business Charging the overruns to asset share might be the only option for sustainability of the company and policyholders ultimately Charging the overruns to estate would serve as a balancing act Charging the overruns to share holders would ultimately lead to fair policyholder treatment & curtailing expenses www.actuariesindia.org 19

  20. Time for Two way discussion www.actuariesindia.org 20

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