Public

Application Paperon
Liquidity Risk Management

29 June 2020

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About the IAISThe International Association of Insurance Supervisors (IAIS) is a voluntary membershiporganisation of insurance supervisors and regulators from more than 200 jurisdictions. The
mission of the IAIS is to promote effective and globally consistent supervision of the insurance
industry in order to develop and maintain fair, safe and stable insurance markets for the benefit
and protection of policyholders and to contribute to global financial stability.
Established in 1994, the IAIS is the international standard setting body responsible fordeveloping principles, standards and other supporting material for the supervision of theinsurance sector and assisting in their implementation. The IAIS also provides a forum forMembers to share their experiences and understanding of insurance supervision andinsurance markets.
The IAIS coordinates its work with other international financial policymakers and associationsof supervisors or regulators, and assists in shaping financial systems globally. In particular,
the IAIS is a member of the Financial Stability Board (FSB), member of the Standards Advisory
Council of the International Accounting Standards Board (IASB), and partner in the Access to
Insurance Initiative (A2ii). In recognition of its collective expertise, the IAIS also is routinely
called upon by the G20 leaders and other international standard setting bodies for input on
insurance issues as well as on issues related to the regulation and supervision of the global
financial sector.
Application Papers provide additional material related to one or more ICPs and/or
ComFrame, including actual examples or case studies that help practical application ofsupervisory material. Application Papers could be provided in circumstances where thepractical application of principles and standards may vary or where their interpretation andimplementation may pose challenges. Application Papers can provide further advice,illustrations, recommendations or examples of good practice to supervisors on how
supervisory material may be implemented.
International Association of Insurance Supervisors
c/o Bank for International Settlements
CH-4002 Basel
Switzerland
Tel: +41 61 280 8090 Fax: +41 61 280 9151
www.iaisweb.org
This document is available on the IAIS website (www.iaisweb.org).
© International Association of Insurance Supervisors (IAIS), 2020.
All rights reserved. Brief excerpts may be reproduced or translated provided the source isstated.

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Contents
Acronyms .............................................................................................................................. 4
1

Introduction .................................................................................................................... 5
1.1

Rationale ................................................................................................................ 5

1.2

Terms ..................................................................................................................... 6

1.3

Scope ..................................................................................................................... 6

1.4

Proportionality ......................................................................................................... 7

1.5

Structure ................................................................................................................. 7

2

Governance ................................................................................................................... 7

3

Liquidity risk identification .............................................................................................. 8
3.1

Exposure to insurable events .................................................................................. 8

3.2

Policyholder behaviour ............................................................................................ 9

3.3

Contingent or off-balance sheet exposures ............................................................. 9

3.4

The impact of a deterioration in the insurer’s financial condition or credit rating ...... 9

3.5

The ability to transfer liquidity across entities, countries and portfolios .................... 9

3.6

Foreign exchange convertibility and access to foreign exchange markets ............ 10

3.7

The reduction in secured and unsecured wholesale funding ................................. 10

3.8

The correlation and concentration of funding sources ........................................... 10

4

Liquidity stress testing .................................................................................................. 10

5

Meeting liquidity shortfalls in stress .............................................................................. 12

6

5.1

Characteristics of highly liquid assets.................................................................... 12

5.2

Other considerations ............................................................................................. 16

Contingency funding plan............................................................................................. 17
6.1

7

8

Key elements of a contingency funding plan ......................................................... 17

Liquidity risk management report ................................................................................. 18
7.1

Risk appetite and risk limits................................................................................... 19

7.2

Strategies, policies and processes for liquidity risk management .......................... 20

7.3

Analysis of the insurer’s liquidity profile ................................................................. 21

Supervisory review and reporting ................................................................................. 22
8.1

Supervisory review................................................................................................ 22

8.2

Reporting to the supervisor ................................................................................... 24

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Acronyms
ALM

Asset-Liability Management

BOLI

Bank-Owned Life Insurance

COLI

Corporate-Owned Life Insurance

ComFrame

Common Framework for the Supervision of IAIGs

ERM

Enterprise Risk Management

FSB

Financial Stability Board

GICs

Guaranteed Investment Contracts

IAIGs

Internationally Active Insurance Groups

IAIS

International Association of Insurance Supervisors

ICP

Insurance Core Principle

ORSA

Own Risk and Solvency Assessment

SFT

Securities Financing Transactions

SPV

Special Purpose Vehicle

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1

Introduction

1.
This Application Paper on Liquidity Risk Management provides guidance on the
supervisory material related to liquidity risk management in the Insurance Core Principles(ICPs) and the Common Framework for the Supervision of Internationally Active InsuranceGroups (ComFrame). In particular, it is related to the material in ICP Standards 16.8 and 16.9
(ICP 16 Enterprise Risk Management (ERM) for Solvency Purposes) and ComFrame 16.9.a– 16.9.d. As part of the holistic framework for systemic risk in the insurance sector, the IAIS
enhanced the ERM requirements in ICP 16 to more explicitly address liquidity risk. 1
2.
The Paper does not establish standards or expectations for the implementation of aliquidity risk management framework, but instead provides additional detail on particular
aspects of the Supervisory Material relating to liquidity risk to assist implementation, and also
provides examples of good practice. It should, however, not be considered an exhaustive
guide to liquidity risk management.
3.

This Paper provides guidance and examples on:

considerations on applying liquidity risk management measures in a proportionate way
and the ways that supervisors may tailor requirements.
• detailed components of the four elements for “more detailed risk management
processes” contained in ICP Standard 16.9:
o liquidity stress testing;o maintenance of a portfolio of unencumbered highly liquid assets in appropriate
locations;o a contingency funding plan; ando the submission of a liquidity risk management report to the supervisor.
• integration of liquidity risk into insurers’ ERM frameworks as described in ICP Standard
16.8, including recommendations for governance.
1.1 Rationale•

4.
In the normal course of business, insurers typically rely on premiums, income frominvestment and other sources for liquidity. Nevertheless, they need to maintain adequate
liquidity to fulfil expected and unexpected payment obligations and funding needs. Liquidity
risk management is essential to the proper operation of the insurer, the protection ofpolicyholders and financial stability.
5.
Past experience demonstrates that even solvent insurers may experience material
financial distress, including failure, if they do not manage their liquidity prudently. Althoughmany of an insurer’s liabilities are long-term in nature or contingent on the occurrence of anevent, certain activities may create significant and unanticipated demands for liquidity. Whenconfronted with stress events, insurers with insufficient liquidity may be forced to take remedialactions that can amplify or accelerate stresses through the financial system.
6.
Liquidity fundamentally differs from capital: while both are essential to remaining agoing concern, liquidity has a “real time” dimension that capital does not. Insufficient liquidity
can cause sudden distress and/or default in insurers that are otherwise well-capitalised. As a

1 Next to liquidity risk, enhanced requirements targeted at macroeconomic exposure and counterparty

exposure were also introduced. These are not within the scope of this Application Paper.
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result, the insurer’s capital management framework may be inappropriate or inapplicable toliquidity risk management.
7.
Liquidity risk is very much company and scenario specific. Supervisory measures forliquidity risk management are intended to help the insurer with its overall risk management. In
addition to helping to protect the insurer’s solvency and soundness, integrated liquidity risk
management can inform strategic initiatives, product design and pricing, investment allocationand operational resilience. Additionally, the supervisory measures may provide the supervisor
with a view on vulnerabilities that may cause funding shortfalls in stress situations. Havingsuch a view may assist the supervisor in identifying common exposures and vulnerabilities
across the insurance sector and in coordination with other financial sector supervisors.
1.2

Terms

8.
In this Application Paper, all terms have the same meaning as set out in the IAIS
Glossary and the Introduction to the ICPs.
1.3

Scope

9.
As stated in ICP Standard 16.8 “the supervisor requires the insurer’s ERM frameworkto address liquidity risk and to contain strategies, policies and processes to maintain adequate
liquidity to meet its liabilities as they fall due in normal and stressed conditions”. This Paper
describes a particular set of approaches for managing liquidity risk, but the concepts may be
relevant to the supervisors of all insurers and reinsurers.
10.
This Paper is intended to be particularly useful for supervisors that require moredetailed liquidity risk management processes. The processes identified in ICP Standard 16.9
are expected to be applied to Internationally Active Insurance Groups (IAIGs) through theapplication of ComFrame Standards 16.9.a – 16.9.d, and other insurers as necessary, basedon the nature, scale and complexity of the activities that lead to increased liquidity risk
exposures and risk amplification effects related to their size.
11.
Liquidity risk can manifest when there is an imbalance between the insurer’s liquidity
sources and liquidity needs. Certain activities can increase insurers’ exposure to liquidity risk
by generating unexpected liquidity needs and, thus, may warrant more robust risk
management, including the application of the policy measures described in ICP Standard 16.9.
Examples of such activities may include, but are not limited to:•••

Derivatives: Many derivatives contracts require collateral or a margin to be posted formark-to-market declines in the value of the contract. These derivatives, used to hedge
market risk arising from investments and liabilities, transform capital risk into liquidity
risk. A significant macroeconomic shock against hedges, while potentially improving
an insurer’s capital position, could trigger calls for additional margins or collateral,
forcing insurers to raise liquidity;
Securities lending transactions: If funds received are reinvested in illiquid assets,
sudden recalls of these funds could force the insurer to sell assets. In a stressedmarket, these sales could impact the insurer’s creditworthiness, triggering morecollateral demands and leading to a price spiral as the lender sells assets to meetcollateral needs; andBacking liquid liabilities with illiquid assets: Some products offered by insurers containprovisions whereby a policyholder can withdraw cash from the policy with little noticeor penalty. When insurers do not adequately match such liabilities with sufficiently

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liquid assets, this may lead to a liquidity shortage in certain circumstances andultimately trigger fire sales.
Liquidity risk drivers are discussed in more detail in Section 3.
12.
When not properly managed, these activities can cause the insurer’s failure and, incertain circumstances, contribute to systemic risk.
13.
While the tools discussed in this Paper are primarily related to an insurer’s own ERM,
there is also an interlinkage with the role of a supervisor in assessing trends and identifying
vulnerabilities in the insurance sector (see ICP 24 Macroprudential Supervision). While
aspects such as interconnectedness within the financial sector and counterparty concentration
may be briefly touched upon in this Paper, these will be discussed in the forthcoming
Application Paper on Macroprudential Supervision.
1.4

Proportionality

14.
This Application Paper should be read in the context of the proportionality principle,
which acknowledges supervisors’ flexibility to tailor their application of supervisory
requirements and supervision to achieve the outcomes stipulated in the Principle Statements
and Standards, as described in the Introduction to ICPs and ComFrame. The advice,illustrations, recommendations or examples of good practice in this Paper do not supersede
this overarching proportionality principle.
15.
More specifically, the supervisor may, as per ICP 16.9.5 and ComFrame 16.9.b.2,
increase or decrease the intensity of the requirements set out in ICP 16.9, for example byvarying the frequency, scope and granularity of liquidity stress testing, the proportion andquantity of various types of assets that the insurer may consider as highly liquid or the form
and level of detail in the contingency funding plan and liquidity risk management report. The
supervisor may also decide on varying the form and level of detail in updates to thecontingency funding plan and liquidity risk management report by taking into consideration
subsequent material changes since the initial assessment.
1.5

Structure

16.
Some common principles of risk management are risk identification, quantification ormeasurement of those risks, management and mitigation of those risks and contingency
planning. This is supplemented by reporting to the supervisor. The remainder of thisApplication Paper is structured along these lines:
•
•
•
•
•
•
•

2

Section 2: Governance
Section 3: Liquidity risk identification
Section 4: Liquidity stress testing
Section 5: Meeting liquidity shortfalls in stress
Section 6: Contingency funding plan
Section 7: Liquidity risk management report
Section 8: Supervisory review and reporting

Governance17.
In the ongoing management of its business, an insurer relies on the availability ofcapital and liquidity. This demonstrates a need for the insurer to have an appropriate systemof governance for liquidity risk in place. A proper liquidity risk management governancePublicApplication Paper on Liquidity Risk Management
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framework supports the identification, assessment, management, reporting and planning ofrisk-mitigating decision making.
18.
The insurer’s risk appetite statement should be approved by the insurer’s Board, whichshould be responsible for its effectiveness on an on-going basis. The insurer should also
periodically review its liquidity risk practices and performance to determine if it is operating
within its stated risk appetite.
19.
The insurer’s Senior Management is responsible for applying the insurer’s risk appetite
in pursuit of its strategic objectives. In doing so, Senior Management is responsible for several
key liquidity risk management functions. Most importantly, Senior Management is responsiblefor integrating the insurer’s risk appetite into day-to-day operations. Senior Management
should also review the insurer’s stress testing methodology and results. Senior Management
should periodically report the insurer’s current liquidity profile to the Board or the relevant
Board Committee, specifically highlighting any vulnerabilities identified and proposing
appropriate remedial action. Where the insurer has or is likely to breach its liquidity risk
appetite, consistent with ICP Guidance 8.1.12, Senior Management should immediately informthe Board.
20.
In the case of groups, the group Senior Management should receive clear and timely
information from material legal entities on the entities’ liquidity position and emerging liquidity
stress events. The group’s Senior Management should report periodically to the group’s Boardor the relevant Board Committee on the group’s current liquidity risk profile. Where
appropriate, reporting on all material legal entities can suffice.
21.
The insurer should establish and maintain an appropriate process for monitoring
liquidity. This should include a process for management reporting which provides clear,concise, timely and accurate liquidity risk reports to control functions within the insurer.
Reports on liquidity risk should be provided on a regular basis to the insurer’s Board or to therelevant Board Committee, Senior Management and other appropriate personnel. Reports tothe insurer’s Board or to the relevant Board Committee may be less detailed and less frequent
than reports to Senior Management with responsibility for managing liquidity risk.

3

Liquidity risk identification

22.
The insurer’s liquidity risks may be influenced by certain factors including: insurable
events, policyholder behaviour, funding structure, transferability of assets and liquidity
impairments on capital markets. In addition to the following elements, severe stress scenarios
should consider potential correlated impairments to capital markets that may further hinder aninsurer’s ability to manage a liquidity event. The following liquidity risk drivers may beconsidered when designing and assessing stresses:
3.1

Exposure to insurable events

23.
This may include considerations of the nature, frequency and severity of exposures toinsurable events, including catastrophic events or material legal decisions that may occur
within the relevant time horizon. The insurer should consider its dependence on reinsurance
and the possibility that a material portion could be uncollectible or not funded in a timely
manner, even if it is ultimately collectible.

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3.2

Policyholder behaviour

24.
This includes an assessment of the possible withdrawals from different product types,
taking into account features such as guarantees, surrender penalties, potential tax
implications, maturity dates, interest rate sensitivity, product purposes, customer type andborrowing costs (in case of policy loans). Stresses should also assess potential reductions inregular premium payments, non-renewals and declines in new business and their impact on
net cash flows.
3.3

Contingent or off-balance sheet exposures

25.
The insurer should include an assessment of derivative cash flows and collateralrequirements caused by market changes, maturity, exercise of options, margin or collateralcalls, changes in the value of posted collateral and additional costs to rebalancing portfolios.
The insurer should also consider additional collateral needs that could arise from inwards oraccepted reinsurance contracts in-force and any other potentially material liquidity needs
arising from off-balance sheet commitments, contracts or facilities.
3.4

The impact of a deterioration in the insurer’s financial condition or credit
rating

26.
The insurer should consider all types of outflows and collateral requirements resulting
from its own credit downgrades of varying magnitude. This should include considerations on
the types, quantity and timing of potential collateral and margin requirements. This analysis
should encompass retail and institutional policyholders as well as capital markets andreinsurance counterparties.
3.5

The ability to transfer liquidity across entities, countries and portfolios

27.
The insurer should assess the transferability of intragroup and intra-entity liquidity. 2
This should include considerations of existing legal, regulatory and operational limitations totransfers of liquidity and unencumbered assets between entities, business lines and countries.
The insurer should note that during periods of market stress, liquidity might not be freelytransferable between and within group entities, or across national borders and the potential
for affiliates to default on intragroup obligations. A prudent assumption may be that, understress, a part or the entire liquidity may become non-transferrable, so it is expected that theinsurer will demonstrate that its approach to transferability is realistic.
28.
As part of its stress testing, where material, the insurer should appropriately address
legally or operationally ring-fenced assets. Such assets could include legally insulated
separate accounts, closed blocks 3, with-profits funds or matching adjustment portfolios. These
blocks of assets, therefore, should only be included as cash flow sources to back cash flowneeds arising from these same accounts. The insurer should also detail how assets in theseblocks may affect the insurer’s balance sheet through guarantees, hedging programmes orother regulatory requirements to replace or maintain assets.
2 Assets may not be fungible within legal entities due to reasons such as those discussed in paragraph 46 andregulations regarding branch assets. See IAIS, Issues Paper on Supervision of Cross-Border Operations ThroughBranches (2013) at Section 2.2.
3 Within the context of this Application Paper, closed blocks refer to discrete pools of assets that are set aside tosupport the dividend expectations of participating policyholders from the periods prior to demutualisation, as wellas anticipated policy benefits. Typically, changes of their values would be largely offset by future changes in thedividend rates on these participating policies.
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3.6

Foreign exchange convertibility and access to foreign exchange markets

29.
Where appropriate, the insurer should assess liquidity needs by individual currency tosupport an assessment of how shortfalls can be funded in a stressed market with impaired
access to foreign exchange markets and loss of convertibility.
3.7

The reduction in secured and unsecured wholesale funding

30.
The insurer should identify any sources of wholesale funding 4 and assess how theywould behave under stressed conditions. This should include the risk of shortening tenors, forexample if the funding provider has call options, or refusal to roll over or extend the maturityof funding. A prudent assumption is that, for the length of the stress horizon, funding providers
will be unable or unwilling to provide new unsecured borrowings or roll over or extend thematurity of existing funding. Wholesale funding that provides the counterparty with optionality,of acceleration in particular, should be noted and elaborated on.
3.8

The correlation and concentration of funding sources

31.
The insurer should consider the instrument type, markets, currency and counterparty,
including groups of related counterparties. This assessment should analyse the effectivenessof diversification across the insurer’s chosen sources of funding.

4

Liquidity stress testing

32.
Insurers should have a sound understanding of the magnitude of the liquidity risk towhich it is exposed – so stress testing is an important part of liquidity risk management.
33.
Using the sources of liquidity risk described in Section 3, or any other sources that may
be relevant, an insurer’s stress test should include an appropriate range of severe, butplausible scenarios, covering short-term and protracted macroeconomic, sector-wide andidiosyncratic events that appropriately reflect the distinctive features of its business.
Depending on its business model and activities, which may contribute to larger or lesspredictable liquidity needs, an insurer may be vulnerable to different liquidity stresses thanother insurers. Stress scenarios should be chosen to reveal potential vulnerabilities in theinsurer’s liquidity profile. In this way, the chosen stresses should help management to identify
material risks to the insurer. The scenarios and model parameterisation should not be limited
to historical events, distributions and correlations, but should also be forward-looking.
34.
Through its stress testing, the insurer should assess the impact of its chosen scenarios
on cash inflows and outflows and liquidity resources, both at a group level and for all material
legal entities. Stressed cash flows should be produced at a level that allows comparison tobaseline results, both at a group level, where applicable, and for all material legal entities. For
material legal entities that are part of a group, this includes, where appropriate, locallydeveloped stresses that reflect local business vulnerabilities and market conditions. Where
appropriate, the supervisor may accommodate stress testing only on material legal entities
provided that the head of the insurance group is able to demonstrate reasonableconsiderations of intragroup funding transactions, including off-balance exposures andcommitments, and transferability of assets.
4 Wholesale funding generally includes any financing from institutions (e.g. banks, pension funds, money market

mutual funds, other financial intermediaries, non-financial corporates).

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35.
To ensure that stress tests capture a sufficiently diverse set of risks, the insurer should
use a variety of time horizons for its scenario planning. The insurer should consider several
relevant time horizons (such as one month, three months or longer term horizons, up to one
year as relevant to its liquidity profile). While insurers are generally exposed to, and expected
to plan for, medium- to longer-term risks, certain activities, such as collateral calls orwithdrawals from large or institutional policies, can result in sudden, large demands forliquidity. Where applicable, the supervisor may also suggest any other planning horizons
relevant to the insurer’s liquidity risk profile. For example, for insurers with significant activity
in capital markets that could generate short-term liquidity needs, the supervisor may findhorizons of one week or less appropriate.
36.
The insurer should make realistic and conservative assumptions, both qualitative andquantitative, in determining the stress scenarios and in calculating their impacts. Additionally,
insurers should not consider the impact of any macroprudential policy actions taken underadverse circumstances in their post stress liquidity position. Key assumptions should be
described and justified in relation to the level of severity of the scenario and relevant risk
factors taken into account.
37.
It may be the case that an insurer has facilities with liquidity providers or access toother off-balance sheet sources of liquidity that it could draw on. While an insurer may consider
such off-balance sheet sources in the assessment of its liquidity position, it is a prudent
practice to assume that they would not be available in either its stress testing or business as
usual risk management. While these off-balance sheet sources may provide funding undernormal conditions, they may not be available when needed, in times of stress, as a large
number of institutions may try to seek funding from the same sources. As such, these offbalance sheet sources may amplify shocks to the financial system by transmitting the insurer’s
liquidity demands to other financial counterparties or signal liquidity events to markets.
Therefore, insurers should consider stress scenarios both with and without the availability ofoff-balance sheet sources of funding, where relevant. Borrowings from off-balance sheet
sources may be more appropriately considered as emergency measures in the insurer’s
contingency funding plan (discussed in Section 6).
38.
Other potential cash inflows, such as future premiums and reinsurance claims, may
still be assumed to be available under stressed conditions, though the insurer should adjust
their assumed availability in line with stress scenarios. For example, a spike in interest rates
may make alternative savings products more appealing, reducing the inflow of new premiums.
In regards to reinsurance, the insurer should consider the credit quality of the reinsurer andmake reasonable assumptions on the availability and timeliness of reinsurance recoverables,
taking into account the value, after applying an appropriate haircut 5, and liquidity of any
collateral posted.
39.
The supervisor should assess an insurer’s responses to a liquidity stress: these should
not include actions that would significantly damage the insurer’s franchise or reputation. In linewith this, the supervisor may consider whether it could send an inappropriate signal topolicyholders and markets more broadly. Anticipated management actions should beconsistent with the insurer’s contingency funding plan.

5 A haircut is a reduction applied to the value of an asset. A haircut is intended to reflect the risk of an asset’s value

declining when the holder wishes to monetise it.

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40.
Events that have a significant impact on capital may not have a significant impact onliquidity. As such, stress testing work for capital purposes may not be relevant or adequate forliquidity risk management.
41.
Where the insurer is required to submit a liquidity risk management report to thesupervisor, the degree of conservatism of the scenarios and assumptions, alongside theresults, should be discussed in the report and assessed by the supervisor.

5

Meeting liquidity shortfalls in stress

42.
ICP Standard 16.9 requires, as necessary, the insurer to establish more detailed
liquidity risk management processes, as part of its ERM framework that include maintenanceof a portfolio of unencumbered highly liquid assets in appropriate locations. ComFrame 16.9.b
requires the insurer and the Head of the IAIG to establish and maintain an adequate level of
unencumbered highly liquid assets in appropriate locations. These highly liquid assets areintended to be monetised in order to fill any shortfalls of cash in-flows relative to cash outflows arising over a particular time horizon: they should therefore be available to respond toliquidity shortfalls as they arise.
43.
The insurer should establish an adequate level of highly liquid assets to hold using thestressed cash in-flows and out-flows from its liquidity stress testing scenario(s).
5.1Characteristics of highly liquid assets

44.
Highly liquid assets should be easily and immediately convertible into cash. Suchassets generally have low credit risk and low volatility; have easy, transparent and accuratevaluations; and have low correlation with risky assets. These assets typically also haveconsistently active markets with evidence of market breadth and depth with a diverse groupof active buyers and sellers. Finally, assets should have a proven record as a reliable sourceof liquidity during stressed market conditions. The insurer should be able to demonstrate theliquidity of any assets it considers highly liquid assets.
45.
To ensure their availability to meet the insurer’s liquidity needs, highly liquid assets
should be unencumbered, meaning they are (i) free of legal, regulatory, contractual and otherrestrictions on the insurer’s ability to promptly sell or transfer the asset and (ii) not pledged orused to secure or provide credit enhancement to another transaction.
46.
The insurer should impose an appropriate haircut to the fair market value of its highly
liquid assets in order to account for the increased credit risk and market volatility during a
stress event. The haircuts should appropriately reflect differences in credit quality and market
volatility across asset types and the amount of time that would be required to sell the asset.
The assumed haircuts should be documented and key assumptions underlying themdescribed.
47.
Highly liquid assets may include the following, though insurers should be able todemonstrate that the assets they consider as highly liquid meet the criteria in paragraph 44:••

Demand deposits; provided that these are sufficiently diversified across institutions
so as not to create a concentration risk;
Government money market mutual funds; provided the funds hold high levels of cash
or liquid assets and have a stated objective to provide liquidity on demand;

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•

•
•
•
•
•
•

Securities issued or unconditionally guaranteed by sovereign entities, supranationalorganisations, such as the Bank for International Settlements, the International
Monetary Fund, the European Central Bank, the European Union, or a MultilateralDevelopment Bank and other non-sovereign public sector entities that are backed by
the full faith and credit of the issuing entity; 6
Other securities issued by a sovereign entity in its own currency used to backliabilities in that sovereign’s jurisdiction;
Securities issued by a government sponsored enterprise that are senior to preferred
equity;Covered bonds; 7
Vanilla corporate debt securities, including commercial paper, not issued by afinancial institution or any of its affiliated entities; 8
Fixed income instruments issued by public sector entities; andCommon equity shares publicly traded on an exchange, included in a major stockindex, and not issued by a financial institution or any of its affiliated entities.

Other assets may be considered as highly liquid where the insurer can demonstrate to thesupervisor that they have low credit risk and low volatility, are liquid and readily marketable
and have a proven record as a reliable source of liquidity during stressed market conditions.
48.
Instruments issued by other financial institutions have the potential for wrong-way risk
(ie that their liquidity is correlated with developments in the financial markets and/or broader
economy) and may exacerbate stress at the insurer level. Moreover, such instruments could
contribute to systemic risk by increasing the insurer’s interconnections with the rest of thefinancial sector. As a result, it would not generally be expected that instruments issued byfinancial institutions or their affiliated entities would be appropriately considered as highly
liquid.
49.
There are natural differences in the liquidity of these assets that would limit theinsurer’s ability to monetise them during a stressed situation. As a result, the insurer should
group assets according to their usability in stress with sufficient granularity to adequately
manage risks in its liquidity profile. To ensure their usability in stress and to minimise financial
stability impacts from the monetisation of financial assets, insurers generally should not rely
on lower quality assets for shorter stress periods as they may be unable to monetise theseassets quickly enough to meet liquidity needs. Moreover, large sales of lower quality assets
in a short time period, particularly in stressed conditions, could impact market prices, thereby
affecting similar assets held by other institutions through, for instance, the recording of markto-market losses or loss of confidence that may in turn exacerbate the negative price impact
loop.
50.
To reflect differences in liquidity, highly liquid assets may be further considered asPrimary, Secondary or Tertiary. Primary assets are generally those of the highest quality and6 This will generally exclude special revenue bonds or other obligations which are backed by a specific stream ofrevenue.

7 Covered bonds are bonds issued by a bank or mortgage institution and are subject by law to special public

supervision designed to protect bond holders. Proceeds deriving from the issue of these bonds must be invested
in conformity with the law in assets which, during the whole period of the validity of the bonds, are capable ofcovering claims attached to the bonds and which, in the event of the failure of the issuer, would be used on apriority basis for the reimbursement of the principal and payment of the accrued interest.
8 These securities’ valuation is readily available based on standard methods and does not depend on private
knowledge, ie these do not include complex structured products or subordinated debt.
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liquidity and are more likely to have willing buyers in very short horizons, even during stressed
conditions. Because of this, primary assets should generally comprise a majority share of theinsurer’s stock of highly liquid assets. Secondary assets are still of high quality, but will
generally incur larger haircuts and/or take more time to find a buyer than Primary assets.
Tertiary assets will, in general, have less active markets, and therefore take even more time
to find a willing buyer, or will incur more substantial haircuts on sale during stressed market
conditions.
51.
Different proportions of Primary, Secondary and Tertiary assets may be appropriate
depending on the horizon of the liquidity stress. For short-term stresses, for example those of
one week or less, insurers should rely on Primary assets, though they may also consider
limited quantities of Secondary assets. For medium-term stresses, for example those between
one week and three months, the insurer should rely on both Primary and Secondary assets,
but may also, in certain circumstances, consider limited quantities of Tertiary assets to beappropriate. For longer-term stress periods, for example those longer than three months, theinsurer would likely be expected to sell assets more strategically to minimise losses. As such,Primary, Secondary and Tertiary assets could be used in any quantity.
By way of illustration, the table below provides one example of how groups of assets may
be considered for the purposes of assessing their availability to meet liquidity needs in
different stress horizons. The provided example may not, however, meet all the specificitiesof the business or the local market. As a result, an insurer should still be able to demonstrate
to the supervisor, and the supervisor should review the suitability of, the assets that theinsurer considers usable to meet liquidity needs in the chosen liquidity stress horizon.
Asset Class

Other Considerations

Liquidity
BucketTime horizons

Demand deposits

Sufficiently diversified

PrimaryAll

PrimaryAll

Government money
market funds

Hold high levels of cash
or liquid assets and havea stated objective toprovide liquidity on
demand 9
Used to back liabilities inthe sovereign’s
jurisdiction

PrimaryAll

Rated AA- / Aa3 or better

PrimaryAll

Rated A- / A3 or better,but less than AA- / Aa3

SecondaryMedium- and longterm

Securities issued or
guaranteed bysovereign,supranational orother non-sovereign
public sector
entities backed bytheir full faith andcreditShort-term inlimited quantities
and higher haircuts

9 Examples may include Government money market funds or public debt constant net asset value

money market funds (public debt CNAV MMF). The insurer should be able to demonstrate that a given
fund meets the criteria for the fund to be considered eligible as highly liquid.

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Securities issued bya Government
Sponsored
Enterprise senior topreferred equity

Rated AA- / Aa3 or better

PrimaryAll

Rated A- / A3 or better,but less than AA- / Aa3

SecondaryMedium- and longterm
Short-term inlimited quantities
and higher haircuts

Rated AA- / Aa3 or better

Secondary

Short-term inlimited quantities
and higher haircuts

Covered bonds

Vanilla corporate
debt securities,
includingcommercial paper

Medium- and longterm

Rated BBB- / Baa3 or
better, but less than AA- /Aa3

Tertiary- Rated AA- / Aa3 (A1 /P1 for commercial paper)or better; AND

SecondaryMedium-term inlimited quantities
and higher haircuts
Medium- and longterm
Short-term inlimited quantities
and higher haircuts- Not issued by a financial
institution or its affiliates.
- Rated BBB- / Baa3 (A2 /P2 for commercial paper)or better, but less thanAA- / Aa3 (A1 / P1 forcommercial paper); AND

Long-term

TertiaryLong-term
Medium-term inlimited quantities
and higher haircuts- Not issued by a financial
institution or its affiliates.*
Other fixed income
instruments issued
by public sector
entities- Rated BBB- / Baa3 or
betterTertiary

Common equity
shares- Publicly traded on amajor exchange; AND

Tertiary

Medium-term inlimited quantities
and higher haircuts

Demonstrated to have low
credit risk and low
volatility, is liquid andreadily marketable andhas a proven record as areliable source of liquidity

PublicApplication Paper on Liquidity Risk Management
June 2020

Long-term
Medium-term inlimited quantities
and higher haircuts- Not issued by a financial
institution or its affiliates
Other assets

Long-term

Secondary /Tertiary(dependent on thetier)Page 15 of 25

during stressed market
conditions.
*Vanilla debt securities (consistent with seventh bullet point in paragraph 47 issued byfinancial institutions may, at the supervisor’s discretion, be considered as Tertiary assets,
provided that the insurer can demonstrate to the satisfaction of the supervisor that they meetthe conditions in paragraph 44.
52.
To avoid double-counting, assets generating future cash inflows used in the insurer’s
stressed cash flow projections, for example through coupon, interest payments or maturities,
should not count toward the level of highly liquid assets for the selected stress scenario as theinsurer would be unable to realise these inflows if the assets were sold. This does not meanthat assets used to meet cash flow needs outside of the relevant time horizon could not becounted toward this level as the insurer would likely have time to re-balance its portfolio.
5.2

Other considerations

53.
An insurer’s highly liquid assets should be sufficiently diversified to reduce the risk ofa material portion of the insurer’s portfolio becoming illiquid just when it needs to monetise
them to meet cash flow shortfalls. In its liquidity risk management report, where relevant, theinsurer should assess the diversity of its highly liquid assets by counterparty, including groupsof related counterparties, counterparty jurisdiction and instrument. This should be done withregard to its own asset portfolio and also considering the broader market (ie the insurer does
not hold a substantial share of the market for a particular counterparty or asset class) to ensurethat the market will be able to bear the insurer’s sales without adversely impacting its ability tomonetise its highly liquid assets as planned. To assist in the fulfilment of these objectives, theinsurer may find it appropriate to establish, in its liquidity risk management framework,
quantitative limits on assets and exposures, as necessary.
54.
The insurer should assess its ability to convert its highly liquid assets into cash in ashort time frame. This may involve periodically testing internal operational procedures ofexecuting asset sales. This may help the insurer assess its access to the market, theeffectiveness of its processes for monetisation and the availability of the assets. Even where
policyholders fully bear the investment risk of these assets, large-scale asset sales orpurchases for these policies may still present operational challenges. As such, the insurer
should consider its ability to monetise assets without compromising on either speed of disposal
or price. As part of this assessment, the insurer should describe and justify all key assumptions
about the amount of time needed to sell significant blocks of assets or the availability of willingcounterparties.
55.
The insurer should consider transferability of assets in determining an adequate levelof highly liquid assets and the location where these assets are held. To protect policyholders,insurers are often restricted from transferring liquidity out of insurance legal entities in stressed
conditions. As such, insurers should not assume that assets held in insurance legal entities
are readily available to cover liquidity shortfalls elsewhere in the group. In the context of thegroup’s liquidity risk management, these assets should only be considered as available up to
the amount of the net stressed cash outflows as calculated under the relevant internal liquidity
stress tests plus any additional amounts that would be available for transfer to all other entities
within the group during times of stress not subject to statutory, regulatory, contractual orsupervisory restrictions on transfer. Funds held in regulated legal entities that have cash flow
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surpluses during the stress test and that would not be transferrable within the group should
not be considered available at the group level.
56.
Finally, in times of stress, access to foreign exchange markets may be impaired,especially those for less frequently traded currencies. When determining the appropriate
location and currency of its highly liquid assets, the insurer should be aware of the risk of nonconvertibility of foreign currencies, particularly over short time horizons.

6

Contingency funding plan57.
As indicated in ICP Guidance 16.9.3, contingency funding planning to respond toliquidity stress events may assist the insurer in addressing stress situations where its highly
liquid assets are insufficient or unexpectedly become illiquid. It should include the actions thatthe insurer could realistically take to ensure that liquidity sources are sufficient to maintainnormal operations and continue to meet its financial obligations, including collateral needs,
under stress. Such a plan should describe the insurer’s strategies for addressing liquidity
shortfalls in emergency situations in a timely manner and at a reasonable cost.
58.
The form and level of detail of the plan and the frequency of testing, reviewing andupdating should take into account the proportionality principle, as well as the results of its
liquidity stress testing, which may reveal funding sources most likely to be impacted during
stress and which the insurer is most reliant on.
59.
An insurer should regularly test its contingency plan to identify any dependencies andbarriers to execution and ensure that it remains operationally robust. Based on this, but also
as a way of good practice, the insurer should regularly review and update its contingency plan
to ensure that it remains fit for purpose, especially when there are material changes to thenature, scale and complexity of the insurer’s activities, highly liquid assets, funding profile ormarket environment. An insurer with a more volatile liquidity position may wish to test its
contingency funding plan more frequently than others.
6.1

Key elements of a contingency funding plan60.
An insurer’s contingency funding plan should include a diversified set of viable, readily
available and flexibly deployable methods that the insurer would use to access alternative
sources of funding. These may include off-balance sheet liquidity facilities to the extent thatsuch facilities cannot be unilaterally revoked, are already available and can be accessed
without further action by liquidity providers, such as new approval to access a liquidity facility.
The plan should also describe when and how each of the actions could be activated and thetime needed to access funds and quantity of funds that would be expected to be available
from each contingency source in the given stress. The plan should describe clear steps thatallow the insurer to make timely and informed decisions, execute contingency measuresefficiently, and communicate effectively. No one particular method, such as accessing a prefunded liquidity facility, is expected to be included as part of this plan. The plan serves as areference point to inform and guide the actions of the insurer in times of actual stress, though
the insurer’s ultimate action should be adapted to the conditions of the actual stress event.
61.
The insurer’s contingency funding plan should address a range of plausible stresses
and in different time horizons, including intraday horizons where relevant. An insurer that is
exposed to a broader array of risk drivers should plan for a wider set of applicable
circumstances.
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62.
The contingency funding plan should include quantitative metrics that the insurer would
use to identify a range of liquidity stress events, including the level and nature of the effect itwould have on the insurer’s liquidity position and on sources of available funding. Such metrics
should be informed by the insurer’s stress tests and could include sharp increases in interest
rates, a catastrophic event, steep equity market declines, multiple ratings downgrades or otherevents that could affect the policyholder’s or counterparties’ perception of the insurer’s liquidity
or solvency condition. On the basis of these metrics, the plan should define a variety ofcircumstances in which it would be executed to respond to liquidity shortfalls for identified
stress events. The insurer may wish to use different metrics to differentiate between systemic
and idiosyncratic liquidity stress. For instance, with an idiosyncratic liquidity stress the insurer
may have a broader range of possible actions that it could use to raise liquidity or make moretime to execute planned actions, compared to a systemic liquidity stress.
63.
The plan should clearly set out a process for which actions to take and their timing,
who can take them, and what needs to be escalated or prioritised. The plan should establish
a clear allocation of roles and clear lines of management responsibility and define proceduresfor identifying early warning indicators for potential liquidity stress events that are based on
the distinctive features of its business. The plan should also contain a governance process for
escalation. It should establish the lines of communication to ensure that the Board and Senior
Management receive the necessary management information in a timely manner. It is
important that the relevant employees are aware of the operational procedures to transfer
liquidity and collateral across legal entities and accounts as well as the restrictions that governsuch transfers.
64.
The insurer’s contingency funding plan should take into account the impact of stressedmarket conditions on its ability to monetise assets, including market-imposed haircuts oroperational limitations, the impact of a freeze in typically available market funding options, thefinancial, reputational or other consequences for the insurer of executing its contingency
funding plan and its ability to transfer liquidity between entities. The plan should also outline
how it will manage both internal communications and those with external stakeholders.
65.
Given the overlapping focus, the insurer may integrate its contingency funding plan
into its recovery planning.

7

Liquidity risk management report66.

A liquidity risk management report should include at least the following:

A liquidity risk appetite statement;
Established liquidity risk limits;
A discussion of the current liquidity position of the insurer in relation to its liquidity risk
appetite and limits;• A summary of strategies, policies and processes that the insurer has in place tomanage liquidity risk;• A discussion of potential vulnerabilities in the insurer’s liabilities as well as the meansof enhancing the liquidity position; and• The insurer’s approach to, and results of, liquidity stress testing.
67.
A key purpose of a liquidity risk management report is to document and demonstrateoverall liquidity adequacy, both under current and stressed market conditions. The report
should set out an insurer’s approach to liquidity and funding. It should be clear and self•••

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explanatory so that any outside person familiar with the subject matter can easily understandit. The liquidity risk management report should also be tailored to the risks to which an insurer
is exposed.
68.
The liquidity risk management report should be regularly updated, and for IAIGs it isrequired to be updated at least annually 10. More frequent updates are expected particularly
when there are material changes to the nature, scale and complexity of the insurer’s activities
that lead to increased liquidity risk exposure as well as the risk amplification effects related tothe size of the insurer.
7.1

Risk appetite and risk limits

69.
A central component of liquidity risk management is a clear articulation of theacceptable level of liquidity risk that the insurer may assume to achieve its strategic objectives.
This should be described in the liquidity risk appetite statement and should define the durationand type of stress or stresses that the insurer aims to survive. This statement should include
both quantitative targets, such as excess liquidity or liquidity coverage ratios, and qualitative
objectives. As per ICP Guidance 16.4.5, the insurer’s risk appetite statement should bearticulated in a way that all levels of management can clearly understand and apply it to all
aspects of liquidity risk management throughout the organisation. All elements of the liquidity
risk management report should be consistent with the risk appetite statement. The liquidity
risk appetite statement is an integral part of the insurer’s general risk appetite framework andshould be separately identified within the framework to ensure that it is given the appropriateemphasis.
70.
To the extent possible, the insurer’s liquidity risk management report should include a
description of the systems and metrics used to measure and monitor liquidity risk. A numberof techniques can be used for measuring liquidity risk, ranging from simple calculations tohighly sophisticated modelling. The degree of sophistication in risk metrics should be reflectiveof the scale, nature and complexity of the insurer’s activities.
71.
In order to implement the insurer’s stated liquidity risk appetite, based on these metrics,
management should consider where limits should be set, in accordance with the nature, scaleand complexity of the insurer’s activities. Activities that may warrant limits to be set are (i) noninsurance liabilities maturing or redeemable within various time horizons; (ii) off-balance sheet
or other exposures that could create liquidity needs during stressed market conditions; (iii)
concentrations of highly liquid assets and funding sources by currency, single counterparty orgroup of related counterparties, counterparty type, instrument type and instrument seniority;(iv) liquidity risk arising from insurance liabilities; (v) maturity gaps; and (vi) the value or
proportion of encumbered assets. These limits should be documented in the insurer’s liquidity
risk management report, including how they interact with the insurer’s stated liquidity risk
appetite as well as in relation to the insurer’s current liquidity position.
72.
The liquidity risk appetite statement should be approved by the Board or the relevant
Board Committee. The liquidity risk limits should be approved by the Senior Management.
10 CF 16.9.d states the following: “The group-wide supervisor requires the Head of the IAIG to report, at least

annually, on its management of liquidity risk. The report includes at least the following: a liquidity risk appetitestatement, established liquidity risk limits, a discussion of the current liquidity position of the IAIG in relation to its
liquidity risk appetite and limits, a summary of strategies, policies and processes that the IAIG has in place tomanage liquidity risk, a discussion of potential vulnerabilities in the IAIG’s liabilities as well as the means ofenhancing the liquidity position, and the IAIG’s approach to, and results of, liquidity stress testing.”

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Senior Management should disseminate the insurer’s liquidity risk appetite and limits to
involved employees and ensure that these employees work cooperatively to implement thestrategies, policies and processes that the insurer has in place to manage liquidity risk.
Throughout its liquidity risk management report, the insurer should demonstrate how theliquidity risk appetite is applied, in particular, how it and the insurer’s liquidity risk
management report are integrated into the risk management framework and how they informbusiness decisions (ie a use test).
73.
Regarding the use test, for example, liquidity risk should be integrated withinvestment risks and influence business decisions around purchases and sales and asset
allocation. Liquidity risk and liquidity risk appetite should generally also influence productdesign when considering large policy limits, guaranteed rates, surrender periods andbenefits.
7.2

Strategies, policies and processes for liquidity risk management74.
The insurer’s liquidity risk management report should discuss the strategies, policies
and procedures that the insurer has in place to manage liquidity risk and implement its statedliquidity risk appetite.
75.
Where applicable to its business, the report should detail the policies it has in place forthe monitoring of intraday liquidity risk exposure, including any obligations that must be settled
at a specific time within the day or where intraday events could materially and adversely affectthe insurer’s liquidity position. For instance, where intraday movements of asset prices could
force the insurer to rebalance its hedging portfolio, the report should describe the proceduresthat the insurer has in place to monitor and mitigate the risk to its liquidity position. Other
examples of intra-day risks could include securities trade settlements, where an insurer has
used intra-day credit to fund all or part of the transaction, or margin calls on derivatives
contracts.
76.
Insurers with significant collateral needs, for example through derivatives, securities
financing transactions 11 (SFTs) or certain reinsurance agreements, should have in placesystems and procedures to monitor assets that have been encumbered or are available to beloaned or pledged in such transactions. Where applicable, these systems and proceduresshould be detailed in the liquidity risk management report. In addition, the report should
describe how the insurer monitors the levels of unencumbered assets that could be loaned orpledged. The insurer should also take into account any operational restrictions that could
impair its ability to pledge certain assets, such as their geographical location or currency.
77.
Insurance legal entities that are part of a group face additional considerations in theirliquidity risk management. Groups should elaborate on all key considerations within theirliquidity risk management report at a group level and also for all material legal entities orfunctional sub-groups of entities. The liquidity risk management report should consider if, andto what extent, entities or sub-groups are self-sufficient or dependent on liquidity support fromother parts of the group and whether such arrangements are both prudent and expected to be

11 Securities Financing Transactions (SFTs) are transactions such as repurchase (repo) and reverse repurchase(reverse repo) agreements, buy-sell back and sell-buy back transactions, dollar and reverse dollar rolls, security
lending and borrowing, and margin lending transactions, where the value of the transactions depends on the market
valuations and the transactions are often subject to margin agreements.

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honoured in a stress scenario. As part of its ERM framework, groups should ensure theconsistent reporting of results at the level of group and the legal entities.
7.3

Analysis of the insurer’s liquidity profile78.
The insurer should consider potential vulnerabilities in its liability profile, both
insurance-related and non-insurance-related. The insurer’s liquidity risk management report
should discuss its outstanding products in sufficient detail so that a reader can understandtheir features. The insurer should pay particular attention to product features that may
encourage withdrawals or otherwise create significant liquidity demands under certain
circumstances, for example the following:
To the extent the insurer provides bank- or corporate- owned life insurance (BOLI or
COLI), it should describe the exposures and assess the potential liquidity needs that
could arise from these products;• The insurer should mention any deposit-type contracts or similar products. 12 Where atrust or special purpose vehicle (SPV) or other structure is used to transform thematurity of the issued instrument, for example in a funding agreement-backed
securities programme, these structures may exacerbate liquidity risk and the insurer
should describe such structures in the report;• The insurer should maintain adequate ability to regularly quantify, monitor and reportto the supervisor insurance contracts that could present material funding draws due topolicyholder decisions. This should be done at such a level to identify blocks ofbusiness that may behave similarly. Companies should be able to monitor theseamounts net of surrender penalties and market-value adjustments to assess maximum
cash flow needs and to identify changes in the aggregate profile of a block’s surrendercharges;• Material outstanding legal decisions that could create unexpected liquidity needs;• The insurer’s report should describe any non-insurance liabilities that could contributeto liquidity stress. A detail should be provided of yield enhancing activities, such as,
SFTs that the insurer engages in, including reinvestment practices and its internal
policies regarding such activities; and• The insurer should also describe how its hedging strategy and hedge efficiency affects
the ways through which it manages the associated liquidity risk, for instance, throughmargin calls or rebalancing.
79.
To complement an analysis of its liabilities, the supervisor should also require theinsurer to consider its means for raising or retaining cash. This may include an assessment ofreturns on investments, off-balance sheet instruments, such as credit lines, its ability to issue
debt or commercial paper and its ability to reduce dividends. As part of this analysis, the report
should detail any legal or operational restrictions, covenants, etc. that might limit its ability to
use these means to raise funds under stress. This analysis should also include an assessmentof the liquidity of the insurer’s investment portfolio. It should consider material assets that havebeen pledged, encumbered or are otherwise unavailable to raise cash. The supervisor may
expect the insurer to assess the extent that it has generally illiquid investments, such as•

12 Deposit-type insurance liabilities are those products that do not incorporate significant insurance risk. Examples

of products that should be reported include Guaranteed Investment Contracts (GICs), Funding Agreements, Capital
Redemption Policies, Annuities Certain, and Funding Agreement-backed or Fixed Annuity-backed securities

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privately placed securities, real estate or mortgages that it is using to support liabilities that
could be subject to material cash demands.
80.
In the normal course of business, the insurer should periodically produce cash flow
projections, commensurate with the relevant time horizon, that incorporate, where relevant
and material, (i) anticipated claim and annuity payments; (ii) policyholder options including
surrenders, withdrawals and policy loans; (iii) collateral requirements; (iv) expenses; (v)intercompany transactions; (vi) maturities and renewals of funding instruments, including
through the exercise of provisions that could accelerate their maturity; (vii) premiums fromnew and recurring business; (viii) investment income; and (ix) any other potential cash flowsthat are relevant to the unique nature of the insurer’s business and activities. Cash flows
should be reported with sufficient detail on the underlying activity and at sufficient granularity
with respect to the time interval for the insurer to assess areas for potential vulnerabilities.
Cash flows from asset disposals should be accounted for separately. In its liquidity plan, theinsurer is expected to document and justify all key assumptions used in generating the cash
flow projections. In the plan, the insurer should also identify and analyse any potential, discreteand cumulative cash flow mismatches over various time horizons, as applicable to its activities
and business.

8

Supervisory review and reporting

8.1

Supervisory review

81.
Guidance on elements of liquidity risk management presented in this Paper cansupport the supervisory review of the insurers’ framework. This section presents additional
considerations to assist the supervisor in its assessment.
82.
With respect to evaluating the integration of liquidity risk into an insurer’s ERM
framework discussed in ICP Standard 16.8, the supervisor may follow its usual approach forthe review of the ERM. For liquidity risk management specifically, the supervisor should
assess whether the insurer’s framework adequately considers the time horizons andtransferability of liquidity across entities, purposes and currencies. As timing is a criticaldimension to liquidity risk, the supervisor should assess whether the insurer maintains
sufficient operational capabilities, including information systems, to manage liquidity stressevents. This includes assessing whether the Board and Senior Management of the insurer
has access to timely information to identify and manage liquidity events.
83.
Where contingency funding plans of multiple insurers envision the use of liquidity
facilities to respond to a liquidity stress event, the supervisor should review theappropriateness of these in meeting potential stressed liquidity needs. As part of the review,
the supervisor should assess whether insurers’ facilities are concentrated with a particularcounterparty or market (see the forthcoming Application Paper on Macroprudential
Supervision).
84.
In line with ICP Guidance 16.9.6, where an insurer is required to establish detailed
liquidity risk management processes, the supervisor should assess the effectiveness of theirimplementation, including the interaction with existing control mechanisms.
85.
The following paragraphs address the supervisory review of specific elements in ICP
Standard 16.9.
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86.
Liquidity Stress Testing: While stress testing should be the insurer’s responsibility,
taking into account its own ERM framework, the supervisor should review an insurer’s stresstest design and results. The review should focus on whether:
the set of scenarios are appropriate and adequate for the insurer’s liquidity
exposures;• scenarios and associated assumptions and parameters are forward-looking, coherent
and conceptually sound;• anticipated management actions are realistic and consistent with stated contingency
plans;• there are appropriate controls around the stress testing process; and• stress testing results inform business and risk management practices.
In reviewing the appropriateness of the chosen stress scenarios, the supervisor should also
consider the time horizons, as well the segments they are divided into, used by the insurer in
its liquidity risk assessments, the key assumptions used in the models used for cash flow
projections and stress testing, such as economic variables, capital markets conditions,differences in lapse sensitivity, debt issuance and refinancing, new business and theoccurrence of insured events.
•

87.
Highly Liquid Assets: The supervisor may need to assess the suitability of the assetsthat the insurer considers to be highly liquid in the context of the timing of a particular insurer’s
liquidity needs. To account for the differences in the timing of payments and possible volumesof liquidity needs, the supervisor can use the insurer’s stress testing as an input to theassessment of the quality and quantity of the insurer’s highly liquid assets. The supervisor
may set expectations of the overall quality or liquidity of assets depending on the insurer’s
liquidity risk profile or may allow insurers to identify multiple portfolios of assets with differing
proportions of Primary, Secondary and Tertiary assets to cover liquidity needs in different
stressed horizons. As part of its review, the supervisor should assess whether these assets
are accessible by relevant entities to ensure that they are able to meet their liabilities as theyfall due.
88.
Contingency Funding Plan: The supervisory review of an insurer’s contingency funding
plan should cover the adequacy of the plan and the insurer’s preparedness to execute theplan. The supervisor should assess whether the plan covers an adequate range of scenarios,
relies on actions that are realistic for the particular scenario, including ability to execute in atimely manner and provides enough flexibility to react to unforeseen scenarios. Scenarios
considered in the contingency funding plan should be informed by, but not limited to, theresults of the insurer’s liquidity stress tests. The supervisor should assess whether processes
are current and documented and whether key employees have been trained. The supervisor
should assess whether the insurer regularly and adequately tests aspects of the plan to ensurethat plans can be executed if required. This includes testing access to funding sources,
production of necessary reporting and coordination among relevant stakeholders.
89.
Liquidity Risk Management Report: the supervisor should assess whether theframework in the report is sound, reflective of the insurer’s risk profile and is currently being
put into practice as presented. The supervisor should assess the reporting on the insurer’s
risks and risk positions and determine whether it provides the supervisor and Board withadequate insight into the insurer’s risks and risk management. The liquidity risk appetite andlevels of limits should have sound rationale and be appropriately monitored and enforced. The
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supervisor should assess whether liquidity policies are documented and are being applied as
required in business decision making.
90.
Where the supervisor deems that the insurer’s liquidity risk management is not
appropriate to the nature, scale and complexity of the insurer or its activities, it should require
the insurer to take effective and timely action. This could be in the form of further supervisory
reporting or additional qualitative and quantitative requirements arising from the supervisor's
assessment. As per ICP Guidance 16.16.14, additional quantitative requirements should only
be applied in appropriate circumstances and be subject to a transparent supervisory
framework.
8.2

Reporting to the supervisor

91.
As noted in section 7, the insurer should report regularly to the supervisor on its liquidity
management and planning. Moreover, an IAIG should be required to report this annually or
more frequently in the event of material changes to its liquidity plan or liquidity risk profile. The
report and other related information may be shared within the insurer’s supervisory college
where relevant.
92.
The insurer should ensure consistency between its liquidity risk management reportand all other supervisory required documents, such as recovery and resolution plans or Own
Risk and Solvency Assessments (ORSAs). However, to the extent that elements of the report
are incorporated in other material, the supervisor may allow the insurer to satisfy the reporting
requirement by reference to those other risk management materials and/or the ORSA.
93.
As part of its liquidity risk management, the insurer should report the ratio of the highly
liquid assets to net stressed cash outflows, under each time horizon, as produced by its stresstest(s).
94.
The supervisor should collect additional information on the set of risks that may be
relevant for a particular insurer as part of its monitoring of potential vulnerabilities arising fromliquidity risk in the insurance sector. 13
95.
By way of illustration, possible additional data elements that the supervisor could
collect, after taking into consideration expected costs and benefits of additional reporting
requirements, are included below:••

General funding make-up 14 (including, at a minimum, information on residual
maturities of assets and liabilities, pledged, secured, and unsecured funds, offbalance sheet transactions). This could be applied to all insurers, with larger, more
complex insurers submitting more granular information.
SFTs, in line with FSB’s recommendation 15, with the intent of capturing both thematurity structure of these transactions (and the extent that the entity uses them toconduct maturity transformation) and for assessing intra-financial connections.

13 See, for example, the Section, Data Elements and Granularity in FSB (2015): Transforming Shadow Banking

into Resilient Market-based Finance: Standards and processes for global securities financing data collection andhttp://www.fsb.org/wp-content/uploads/FSB-Standards-for-GlobalSecurities-Financing-Dataaggregation,
Collection.pdf.
14 See eg Figures 6 and 17 from http://www.fsb.org/wp-content/uploads/r_121029.pdf
15 See, eg the section, Data Elements and Granularity from http://www.fsb.org/wp-content/uploads/FSBStandardsfor-Global-Securities-Financing-Data-Collection.pdf
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•

•

•
•
•

This may be most efficiently applied to insurers conducting a material amount of
SFTs (eg 1% of total liabilities or gross SFT liabilities greater than 5 billion USD).
Surrender information to assess the likelihood of and the insurer’s resilience to amass lapse event. Information could be requested by any product type, distribution
channel, policyholder age (bucket), interest rate sensitivity, contract age, remaining
policy duration or premium payment type.
Funding instruments (including information on contractual maturities, both interim
and final, and embedded optionality) with information on the use of short-term
funding and the use of funding instruments that may unexpectedly become shortterm. This may be most efficiently applied to insurers with a material amount ofoutstanding debt or deposit-type contracts (eg 5% of total liabilities).
Available unencumbered assets to assess insurers’ ability to monetise assets. This
could be applied to all insurers, with larger, more complex insurers submitting moregranular information.
Funding concentrations (by counterparty and product/instrument type > 1% ofassets) to assess liquidity concentration risk. This could be applied to all insurers,
with larger, more complex insurers submitting more granular information.
Derivatives 16 with the intent of capturing counterparty information (intra-financial
considerations) and assessing the potential for future collateral calls from volatile
positions. This may be most efficiently applied to insurers conducting a material
amount of derivatives activity (eg notional greater than 100 billion USD).

16 See for instance http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R0104&from=EN, Table

1, items 2-7, 14, 17, 20-35, and Table 2 Sections 2a-2C, items 1-11, 17-24, 26-30.
PublicApplication Paper on Liquidity Risk Management
June 2020

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