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Systemic Risk from Insurance Product Features(previously referred to as Non-traditional Noninsurance activities and products)
16 June 2016

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About the IAISThe International Association of Insurance Supervisors (IAIS) is a voluntary membershiporganization 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.
International Association of Insurance Supervisors c/o Bank for International Settlements
CH-4002 Basel
Switzerland
Tel: +41 61 225 300
Fax: +41 61 280 151
www.iaisweb.org© International Association of Insurance Supervisors (IAIS), 2016.
All rights reserved. Brief excerpts may be reproduced or translated provided the source isstated.

PUBLICPreface
In July 2013, the IAIS published a framework of policy measures for global, systemicallyimportant insurers (G-SIIs), which included a classification table of typical insurance products
and activities. 1 Interactions with stakeholders showed that the notion of Non-traditional Noninsurance (NTNI) activities and products required further clarification. As described in the IAIS
report, Insurance and Financial Stability 2, two important factors for assessing the systemic
importance of insurers are NTNI activities and Interconnectedness. However, the IAIS
recognises that there may be some conceptual overlap between these two categories. The
2015 consultation further revealed that a number of stakeholders consider the term Non
Traditional (NT) to be confusing. Based on these considerations, the IAIS has decided to
discontinue using the NTNI product label. The IAIS has decided to replace the NTNI labelwith a more granular and nuanced assessment of product features, which maintains theconsideration that subject to their characteristics or features, certain insurance products may
have a greater potential to pose systemic risk. This paper sets out the rationale for the IAIS’s
revisions to the NTNI definition and a detailed description of Potentially Systemic Insurance
Product Features.
In late 2015, the IAIS launched a consultation soliciting feedback from stakeholders on the
NTNI definition and the relevant conclusions described in the consultation document.
This document revises and clarifies the concepts of substantial liquidity risk andmacroeconomic exposure 3 (e.g. if a firm’s financial position is highly correlated with thebroader economy, the risk of systemic impact from insurance failures increases) described in
the consultation document, after reviewing the comments provided and further discussions
among IAIS Members.
As noted in the consultation paper, this work is intended to provide further clarification on thenotion of NTNI, in particular NT, and explain how product characteristics drive the systemic
relevance. In particular, the 2013 G-SII Assessment Methodology contained some indicatorsin the NTNI category (e.g. derivatives trading (CDS sold), minimum guarantees on variable
products, and financial guarantees) that serve as a proportionate approximation for thesensitivity of an insurer’s entire balance sheet to macroeconomic stress.
The IAIS recognises that these simplified indicators are proxies and notes that they do not
capture some of the different ways that an insurer could be correlated with the broader
economy. Therefore, the IAIS is committed to a continuing development of alternative metrics
and reviewing these indicators accordingly, in order to refine the measurement ofmacroeconomic exposure. This ongoing review will include the development of alternative
approaches to better measure an insurer’s macroeconomic exposure, including but not limited
to, the various methods and tools within the ICS framework to measure macroeconomic
exposure across an insurer’s whole balance sheet. 4 This ongoing review will also include a
review of the calibration of the liability liquidity indicator. If necessary, the IAIS will publicly
consult throughout the continuation of this ongoing work. The continued development of
metrics and indicators to measure macroeconomic exposure should lead to a consistent
application across jurisdictions.

1 See Global Systemically Important Insurers: Policy Measures, 18 July 2013

2

See Insurance and Financial Stability, November 2011

3 Referred to as (substantial) market risk in the G-SIIs Policy Measures document

4 The completed outcome of this ongoing review will be of relevance to the development of HLA. The

IAIS’s work on the ICS, however, does not depend on this framework
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As discussed in more detail throughout this document, products that have features that expose
the insurer to substantial macroeconomic risk (including credit guarantees) or substantial
liquidity risk through the exposure and asset liquidation transmission channels contribute tohigher systemic potential of insurers.
Regarding the list of products affected by the macroeconomic exposure assessment(‘substantial market risk’ in the consultation) , the IAIS has decided to remove any double
counting between the derivatives and minimum guarantees on variable products indicators in
the G-SIIs Assessment Methodology, particularly in light of the consultation feedback
received. It is worth noting though that the list of product features, and by extension products,
remains unchanged from the current methodology.

Scope of this document
This paper is not meant to be a comprehensive analysis of the different ways an insurer’s
financial distress could be transmitted to the broader economy.
It is only focused on insurance product features and related activities that may raise thepotential for an insurer to pose systemic risk upon failure. The following sources of risk arebeyond this scope and are not directly considered:••••

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sector-wide risks related to the aggregate exposure of the insurance industry which do
not stem from the failure of a single institution;risks that are related to size, global activity, or substitutability, and are not directly
related to the transmission channels of exposure and asset liquidation;risks related to the transmission channels of exposure or asset liquidation that do notstem directly from insurance product features – this includes but is not limited to intrafinancial assets and liabilities, level 3 assets and short-term lending;risks stemming from non-insurance activities.

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Glossary of abbreviations
BIS
CDS
FSB
G-SIBsG-SIIs
G20
HLA
IAIS
ICS
IMF
NTNI

PUBLICBank for International Settlements
Credit Default Swap
Financial Stability Board
Global Systemically Important Banks
Global Systemically Important Insurers
Group of Twenty Countries
Higher Loss Absorbency
International Association of Insurance Supervisors
Insurance Capital Standard
International Monetary Fund
Non-traditional Non-insurance

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Contents
Preface .................................................................................................................................................. 3
1

Introduction .................................................................................................................................... 7

2

The “Non-traditional” Product Label .............................................................................................. 8

3

Transmission Channels.................................................................................................................... 8

4

Macroeconomic Exposure and Substantial Liquidity risk ............................................................. 10
4.1

4.1.1

Contractual Features-Based Assessment of Macroeconomic Exposure ...................... 10

4.1.2

Potential mitigating and exacerbating factors on Macroeconomic Exposure.............. 15

4.1.3

Envisioned evolution in the IAIS’s assessment of Macroeconomic Risk....................... 16

4.2

5

Macroeconomic Exposure .................................................................................................... 10

Substantial Liquidity Risk ...................................................................................................... 16

4.2.1

Assessment of Substantial Liquidity Risk ...................................................................... 17

4.2.2

Delays in Access ............................................................................................................ 17

4.2.3

Economic Penalty Relative to Account Value ............................................................... 17

4.2.4

Potential Mitigating and Exacerbating Factors on Substantial Liquidity Risk ............... 17

Indicators in the G-SII Assessment Methodology ......................................................................... 19
5.1

Contractual Approach to the Minimum Guarantees on Variable Products Indicator .......... 20

5.2

Liability Liquidity indicator .................................................................................................... 20

5.3

Phase III considerations ........................................................................................................ 21

6

Implications for HLA and BCR ....................................................................................................... 25

7

Relationship with NTNI Principles in the 2013 Policy Measures Document................................. 25

8

References .................................................................................................................................... 26

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NTNI Transmission Analysis
1

Introduction
1.1. Since its introduction the Non-traditional (NT) concept and the label itself have been
seen as confusing. The 2013 G-SII Policy Measures document did not provide
stakeholders with a detailed explanation of the framework.
1.2. In 2015, the IAIS therefore decided to issue a consultation document on the NTNI
definition. This document builds on the discussions among IAIS Members and thefeedback received from stakeholders. The IAIS decided to discontinue the NTNI
product label and to focus on substantial liquidity risk and macroeconomic exposureand their related systemic risk transmission channels.
1.3. It should be noted that this paper does not cover the full spectrum of aspects withininsurance that can be of systemic relevance. It is not meant to be a comprehensive
analysis of the different ways an insurer’s financial distress could be transmitted to thebroader economy. At the core of the analysis are the transmission channels and thefeatures of products and activities that could contribute to systemic impact upon
failure.
1.4. Other sources of systemic risk including the case where a set of firms in one or several
jurisdictions (or the insurance sector as a whole) has exposures that are correlatedwith market movements 5 warrant supervisory attention but are not within the scope of
this paper. These sources of risk require tools that are applied more broadly to thesector. The IAIS will consider alternative approaches to better measure an insurer’s
macroeconomic exposure, including, but not limited to, the consideration of various
methods and tools within the ICS framework currently being developed.
Section 2 provides a more in-depth discussion on why the NTNI label was
discontinued.
Section 3 outlines the two main transmission channels of Asset Liquidation andExposure.
Section 4 provides a high-level overview on the two sets of risks used to identify
whether product features are likely to expose an insurer to a greater degree ofsystemic risk:
Macroeconomic exposure: in addition to the IAIS’s rationale for considering
this source of risk, this sub-section discusses 1) the current approach tomeasuring macroeconomic exposure based on insurance contract featuresand 2) how this approach could evolve in subsequent reviews to cover themacroeconomic risks stemming from the full balance sheet of an insurer.
Substantial liquidity risk: this sub-section sets out the IAIS’s rationale forconsidering this source of risk and the key aspects in measuring it for the
purposes of G-SII designation.
Section 5 gives a brief outline of how the framework has been translated into theindicators used for G-SII designation. Further details of this are set out in the GSII Assessment Methodology document.
Section 6 briefly outlines the process for how this paper and the G-SII
Assessment Methodology document should be considered as part of the reviewof the BCR/HLA in 2017.
Section 7 explains the relationship with the NTNI Principles in the 2013 G-SII
Policy Measures document.

5

Cf. International Monetary Fund Global Financial Stability Report (April 2016), pp. 90ff.

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2The “Non-traditional” Product Label
2.1 The IAIS’s 2013 initial G-SII Initial Assessment Methodology (the 2013 Methodology)
set out a framework whereby systemic risk in insurance could be measured byindicators grouped into five categories: (i) Non-traditional Non-insurance activities; (ii)interconnectedness; (iii) size; (iv) global activity; and (v) substitutability. The G-SII
Policy Measures set out three principles for identifying Non-traditional insurance
products and Non-Insurance activities.
2.2 These three principles set forth in the 2013 paper were intended to guide thedetermination of whether activities are classified as traditional or non-traditional noninsurance. 6 Because the IAIS has discontinued the term NTNI, the first two NTNI
principles in the 2013 IAIS G-SII Policy Measures document will no longer be used,having been superseded by the more detailed assessment set out in this document.
Section 7 nevertheless sets out a revised high-level description of the concept that
better focuses on the anchor points of this analysis – the potential transmission ofmacroeconomic exposure and substantial liquidity risk through the asset liquidationand exposure channels. Unlike the previous NTNI Principles, this description is notintended to provide criteria for a binary classification of insurance products. On thecontrary, it is merely intended to provide a concise summary of the revised framework.
2.3 Apart from these Non-traditional insurance products, insurers can also engage inactivities that may more appropriately be categorised as “shadow banking” thaninsurance and thus may be captured by the term Non-insurance. Investment andfunding or other capital market activities that result in maturity or liquidity
transformation, leverage or imperfect transfer of credit risk, such as repo and securities
lending, should be considered potentially systemic non-insurance activities.
2.4 The 2015 IAIS consultation sets out a description of certain insurance product featuresthat could be identified as likely to expose the insurer to “Substantial Market Risk” or“Substantial Liquidity Risk”. Feedback on the consultation revealed that the NTconcept and the framework were confusing. Furthermore, Substantial Market Risk waslargely interpreted as a micro-prudential concept that was inappropriate for the
analysis.
2.5 In reviewing the framework, the IAIS has therefore chosen to discontinue the NTNI
term and to replace the term “Substantial Market Risk” with the term “Macroeconomic
Exposure” as the latter captures more accurately the nature of the transmission
channel. Overall, the main focus is on the two most relevant underlying transmission
channels: exposure and asset liquidation.

3

Transmission Channels
3.1 According to the FSB, IMF and BIS in their 2009 Report to the G-20 Finance Ministers
and Central Bank Governors, systemic risk is the potential of “disruption to the flow offinancial services that is (i) caused by an impairment of all or parts of the financial
system; and (ii) has the potential to have serious negative consequences to the real
economy.” More specifically, when applied to insurers, systemic impact can materialise“through contagion (where policyholders or markets consider that similar problems
may exist in similar products from other insurers) and financial links (for example, in

6

IAIS G-SII Policy Measures Paper, 18 July 2013, at pp. 13-14.

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the derivatives markets) and may have an impact on the broader economy through a
failure to make good on promises to policyholders or to engage in new transactions
that would foster economic activity.” 7
3.2 This paper analyses how certain contractual insurance policy features and theinvestment and risk-management practices an insurer undertakes in managing them
may contribute to systemic impact upon the failure of an insurer. It also describes theassociated channels by which losses could be transmitted to third parties. As
discussed in more detail throughout this document, product features and related
activities that expose the insurer to substantial macroeconomic risk (including credit
guarantees) or substantial liquidity risk should be considered to have potentiallysystemic insurance product features.
3.3 A simplified illustration of the mechanics of the risk transmission is given in figure 1.
Each element depicted is explained in further detail in the subsequent sections.
Figure 1: Simplified Assessment Framework

3.4 It is in particular worth noting that a single insurance product could propagate systemicrisks through different channels. The specific details on how these features areincorporated in the G-SII Assessment Methodology are briefly outlined in Section 6 but
are covered in more detail in the G-SII Assessment Methodology document.
3.5 Three channels for systemic risk transmission are considered: (i) the exposure
channel; (ii) asset liquidation channel; and (iii) the critical function or service channel 8.
The IAIS has evaluated these channels and concluded that the two most relevant
systemic risk channels for the analysis of insurance product features in this context are
the exposure and asset liquidation channels, as defined below:•

Exposure Channel: A shock to the insurer may spread more easily to otherfinancial institutions or markets where there are direct and indirect exposures ofcreditors, counterparties, investors or other market participants.

7 See Financial Stability Board (2014).
8

The IAIS has not finally concluded on the concept of critical functions in insurance.

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•4

Asset Liquidation Channel: An insurer could be forced to liquidate assets quickly
and on a scale that, exacerbates market movements and contributes to asset
price volatility. Such asset sales could impact asset prices and thereby disrupt
trading or funding in key markets, potentially triggering losses for other firms withsimilar holdings.

Macroeconomic Exposure and Substantial Liquidity risk
4.1 In its 2011 paper, Insurance and Financial Stability, the IAIS noted that insurance relieson the premise of insurability, which is defined by several criteria. This framework
focuses on two of them: (1) whether there are a large number of uncorrelated andhomogeneous risks (i.e. losses are subject to the law of large numbers); and (2)whether the losses are accidental (i.e. not controlled by the insured). The following two
sections describe the analysis starting from these criteria.

4.1

Macroeconomic Exposure
4.2 As a result of the characteristic of insurance that the losses are subject to the law oflarge numbers, insurers are able to largely diversify away idiosyncratic losses andaccurately estimate expected losses across their portfolio. The limitation of suchidiosyncratic losses, affecting particular firms rather than the broader financial system,is largely the domain of micro-prudential regulation.
4.3 One way that systemic as opposed to idiosyncratic risk can arise is through common
exposures to macroeconomic risk factors across institutions. 9 In such cases, theunderlying exposures are highly correlated with each other and with the market, limiting
the potential to diversify through the pooling of idiosyncratic risks. If a firm’s financial
position is highly correlated with the broader economy, the risk of systemic impact frominsurance failures increase. Losses given default will be higher when the economy isalready under stress.
4.4 All three of the transmission channels identified could conceivably play a role in this.
Under the exposure channel, counterparties will have, on average, diminished capacity
to bear losses making a domino effect more likely. Additionally, externalities from asset
sales will be higher under stress as liquidity is typically reduced. Finally, although lessof a focus for this analysis, the relative scarcity of capital during macroeconomic stressmakes market entry more difficult and will lower substitutability, potentially increasing
the costs of market withdrawal for important functions and services.
4.1.1

Contractual Features-Based Assessment of Macroeconomic Exposure

4.5 The contractual benefit features considered are described with the accompanying
varieties to be analysed in the table below. The combinations of these featuresconsidered should cover the vast majority of insurance products sold acrossjurisdictions.

9Cf. IMF (2016)

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Contractual
FeatureVarieties to be analysed

Product type

Indemnity, covering a particular loss, e.g. theft or medical expenses
Fixed benefit, e.g. paying a regular distribution to the insured overtheir lifetime or a lump sum on death or survival to a particular age
Profit participation, where policyholders share in profits of the insurer
Unit linked or property linked, where benefit is related to theperformance of an underlying fund or set of assets

Contractual
Guarantees 10

No guarantees provided
Guarantees on:-vested benefits (e.g. declared bonuses for participating products
or 'ratchet up' features on linked benefits)
future benefit accruals (e.g. interest guarantees or fixed minimum
bonus levels)

Credit guarantees, e.g. credit default swaps, financial guarantee or
mortgage insurance
Extent to which an
insurer can invest
in order to match
cash-flows ofliabilities

Significant contractual limitations on the insurer’s ability to align asset
and liability exposures by matching liability cash-flows-

No significant contractual limitations on ability to match liability
cash-flows (the insurer has the discretion to invest to match theliability cash-flows)

4.6 The current assessment of the degree to which a benefit feature could expose theinsurer to macroeconomic risk has two steps. The first step is to identify whether amaterial benefit guarantee applies, thereby transferring a risk from the policyholder tothe insurer. The second step is to determine whether the insurer is able to invest theassets backing the guarantee in a manner that aligns the asset and liability exposuresor, put differently, that matches the benefit cash-flows of the applicable guarantee. Thisis depicted in Figure 2.
4.7 Beyond the contractual features, there may be additional influences that are relevantto the discussion of systemic risk but go beyond certain product features and/or requireconsideration of qualitative aspects. These effects could exacerbate or mitigate thesystemic effects.

10 Note that guarantee in this context focusses on explicit minimum benefit guarantees (i.e. those made in thecontract) and does not, for instance, include implicit assumptions made in product pricing.

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Figure 2: 2-step contractual assessment of exposure to macroeconomic risk

4.8 Under step 1 of the assessment framework, the IAIS is assessing whether the producthas a contractual feature providing a guarantee. The step 1 column in the table below
lists the various guarantees being considered by the IAIS.
4.9 For the purposes of step 2 of the assessment framework, cash-flow matching refers to
the extent to which insurers can invest to replicate the benefit guarantees. Limitations
to cash-flow matching are based on specific contract clauses that directly or indirectly
limit the insurer’s ability to replicate benefit guarantees in the way they invest thebacking assets. It is important to note that this assessment focusses entirely on thecontractual features or characteristics of a product, taking any such limitations on theability to align asset and liability exposures as a proxy for the degree of market or
macroeconomic risk actually assumed by the insurer. Therefore, any market risks
assumed by the insurer which are not directly related to such contractual limitations on
the product are not taken into account by this approach. The IAIS in particular
recognises that this assessment focusses on the liability side only, ignoring risks
stemming from the way assets are actually managed by the insurer in practice. Suchconsiderations would require an approach that spans both sides of the balance sheet,
and will be developed as part of the on-going work of the IAIS in this area (as set out
in the next section). Specifically, for the purpose of the contractual features approach
only, the following points are not considered in the assessment of the ability to cash
flow match:

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Issuer default: the possibility of issuers defaulting on the matching assets.

•

Surrender options: an inability to match policyholder options to surrender apolicy or lapse.

•

Richness of guarantees: the possibility that insurers offering very rich interest
rate guarantees may not be able to cash-flow match their liabilities because theguaranteed rate exceeds the return on the insurer’s invested assets.

•

Reinvestment risks: even where guarantees do not exceed the rates of returnavailable on assets, an insurer may be unable to match liabilities at long
maturities due to a lack of fixed-income assets of a sufficient duration. Since
the ability to match is limited to contractual considerations, this approach does
not consider any such reinvestment risks faced by insurers.

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4.10 Even under this contractual approach, however, these points are very important
aspects to be considered by supervisors in the broader designation process (cf.
section 5.3 on Phase III considerations below).
4.11 Two further points are worth noting on the application of this approach:•

The assessment of cash-flow matching in step 2 does not take into accountmatching through the use of derivatives. The IAIS recognises that the use ofderivatives may be an effective risk-mitigating tool for specific types of productfeatures and should not be discouraged. However, it is also recognised thatwhile derivatives may be effective in mitigating micro-prudential risk, from amacro-prudential perspective they may act merely to transfer market
exposures to other market participants without necessarily eliminating them.
This framework therefore does not consider derivative hedges as a mitigationof macro-prudential risk, but neither does it penalise firms for carrying out suchhedging. Indeed, the value of the derivatives used for hedging purposes isdeducted from the Minimum Guarantees on Variable Products indicator, inorder to avoid hedged writers of such guarantees drawing a higher designation
score than unhedged writers in the G-SII Assessment Methodology (cf. section
5.1).

•

Any contractual inability to match benefit guarantees, whether the backing
assets are managed in a separate fund or not, should be considered as part ofthis assessment.

4.12 Each of the benefit combinations are analysed individually in the table below.
Nature of thebenefitStep 1:
Guarantee

Step 2: Contractual
limitations on cash
flow matching

Is there substantial
macroeconomic risk?

Indemnity(covering aparticular loss,
e.g. theft or
medicalexpenses)

Not applicable

Asset restrictions are
rare.

Indemnity policies provide
cover for a specific loss, not aguaranteed value, and thus do
not expose the insurer tosubstantial
macroeconomicrisk.

Fixed benefit

Guarantees on
future accruals(such as interest
guarantees)

Asset restrictions are
rare. Insurers are notcontractually limited intheir ability to invest in
fixed income assets
which could provide
the cash flows
required to meet
contractual obligations.

For these products insurers areable to limit the guarantees
they offer on benefits to rates ofinvestment return they earn on
their backing assets, or thatthey are able to secure under
the current market conditions.

(e.g. paying a
regulardistribution to
the insured overtheir life time ora lump sum on
death or survival
to a particulargroup)

This contractual ability to aligntheliabilityand
asset
exposures means insurers areable to avoid taking on
substantial
macroeconomic
risk.
Where insurers do not inpractice align their asset andliability exposures, fixed benefit

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policies
withguaranteed
benefit accruals may expose
the insurer to movements ininterest rates, and therefore tomacroeconomic risk. Under thecontractual
approach,supervisors should consider
such mismatches in making theoveralldesignationassessment (as set out in the
Phase III considerations in
section 5 below).
Profitparticipation(wherepolicyholders
share in profits
of the insurer)

Guarantees onvested benefits
or future
accruals (suchas interest
guarantees)

Insurers generally arecontractually able toinvest to match theguarantees offered;however, liabilities
may go unmatched inpractice to allow for
greater bonus
accumulation.

In the same manner as fixed
benefit guarantees, insurers
are able to limit the guarantees
they offer on such products to
the rates that can be earned onbacking assets, or that they areable to secure under thecurrent market conditions.
Where they are left unmatched,
however, these guarantees
could expose the insurer tosubstantial
macroeconomicrisk (again this should beconsidered as part of Phase III,
as set out in section 5 below).

Unit linked /variable annuity(where benefits
are related tothe performanceof an underlying
fund or set ofassets)PUBLICNo guarantees
provided

Cash flows arematched byconstruction as theliability is determinedby the value of theassets.

Insurers, serving as a pass-thru
for investment returns (i.e. theinsurer does not guarantee
performance),
andaretherefore
generallynotexposedtomarketormacroeconomic risk throughthese products.

Guarantees onvested benefits
or future
accruals

The underlying assets
are typically held in a
combination of fixedand variable
investments. Assetliability matching istherefore not possible
without the use ofderivatives, which froma macro-prudential
perspective may
merely serve totransfer themacroeconomic
exposure to a third
party.

Losses accrue to the insurer’sbalance sheet through theguarantee. Furthermore, due tothe variability of liabilities, theinsurercannoteffectively
match asset and liability cashflows without the use ofderivatives. These products are
therefore likely to expose theinsurer to a high degree ofmacroeconomic risk and forthis reason are used as a proxy
for the correlation with themarket.

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Selling of credit
protection

4.1.2

Guarantees on
the value of thereference assets

Default events are
unpredictable, limiting
the insurer’s ability tocarry out asset-liability
matching.

These
product
featuresguarantee the value of someasset, which exposes theinsurer to movements in asset
or market prices. Trigger
eventsareoftenhighlycorrelated with market cycles
and, as a result, theseguarantees can expose theinsurertosubstantial
macroeconomic risk.

Potential mitigating and exacerbating factors on Macroeconomic Exposure

4.13 Outside of the insurance contract features listed above, there may be additional
factors that are relevant to the discussion of systemic risk. These factors, in practice,
do affect the systemic risk assessment of an insurer. As described in section 5.3,
while these factors are not currently used in calculating the indicators in themacroeconomic exposure sub-category, they are relevant for consideration as partof Phase III (the Discovery Phase) in the process for the Identification of G-SIIs.
These factors include, but are not limited to:

PUBLIC•The lack of suitable assets could exacerbate the risk embedded in certain
products and jurisdictions. For example, in the recent low interest rateenvironment, certain fixed benefit or annuity policies may have exhibited a
substantial duration gap, i.e. there are insufficient quantities of long-tenor assets
to match liabilities. As a result, insurers may be exposed to reinvestment risk
where they have had to resort to investing in shorter-tenor assets and rolling overthe positions when the assets mature. Also, data on the duration are based onassumptions for particular business models specific to national requirements thatneed to be taken into account during the assessment. This includes the treatmentof future profit participation, which would be dependent on the economic
environment. Therefore, data may overstate or understate the duration of theliability side - specifically in cases where a firm uses conservative or aggressive
reserving assumptions. As a result, ALM risk as measured by the duration gap
needs to be evaluated carefully and where possible amended appropriately
based on verifiable analysis. In many jurisdictions, insurers have to carry out
rigorous cash flow testing to test their ability to pay claims as they come due.
Many insurers use a range of stochastic and deterministic scenarios to test theseparameters in various stress situations – beyond the normally expected paymentof claims. This testing may better prepare for periods of stress.

•

Insurers may have tools at their disposal to potentially mitigate the impact ofmacroeconomic exposure on particular contract features. Some firms havecontractual ability to adjust premiums when guarantees are in the money. Such
instruments could limit the transmission of a market shock. They could also
possibly have unintended consequences when exercised by creating a fear
among policyholders that they will not have access to their funds and triggering
higher lapses and surrenders.

•

In addition, any contractual ability to align the liability and asset exposures needs
to be seen in conjunction with the contractually determined actuarial calculations
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for the undertakings’ specific business model under national law. This contractual
ability to align the liability and asset exposures could potentially mitigate theimpact of macroeconomic exposure on particular contract features.
4.1.3

Envisioned evolution in the IAIS’s assessment of Macroeconomic Risk

4.14 The IAIS recognises that these simplified indicators are proxies and notes that they
do not capture some of the different ways that an insurer could be correlated with thebroader economy. Therefore, the IAIS is committed to a continuing development ofalternative metrics and reviewing these indicators accordingly, in order to refine themeasurement of macroeconomic exposure. This ongoing review will include thedevelopment of alternative approaches to better measure an insurer’s
macroeconomic exposure, including but not limited to, the various methods and tools
within the ICS framework to measure macroeconomic exposure across an insurer’s
whole balance sheet. This ongoing review will also include a review of the calibrationof the liability liquidity indicator. If necessary, the IAIS will publicly consult throughout
the continuation of this ongoing work. The continued development of metrics andindicators to measure macroeconomic exposure should lead to a consistent
application across jurisdictions.
4.2

Substantial Liquidity Risk
4.15 The second key criterion of insurability is that losses should be accidental, i.e. notinfluenced by the insured. Product features allowing for payments that are nottriggered by the occurrence of an insurable event, such as surrenders or otherwithdrawals, depart from this definition of insurability and may have features thatmake them closer in nature to deposits. These product features are the focus of thissection setting out higher systemic potential stemming from substantial liquidity risk.
The IAIS also recognises that the analysis needs to consider any incentives ordisincentives for early repayment.
4.16 Bank runs are a commonly cited example of a systemic event. Runs can occur
because of a bank’s balance sheet profile: liquid liabilities are used to fund long-term,
illiquid assets. Because the assets cannot all generally be sold at face value, theposition of a depositor in the “queue” to redeem deposits will directly affect theamount they will receive on their claim. This mechanism provides an incentive to be
the first in line, creating a possible dynamic where rational depositors all run basedon their expectations of other depositors’ behaviour. A bank run can have spill-overeffects on the real economy as the run could cause the bank to withdraw funding to
productive investment or cause other “healthy” banks to be run on and fail(contagion).
4.17 Policyholder “runs” are rare in insurance, though they have occurred in the past.
Policyholders may have incentives to run, including, but not limited to: (1) market
movements (higher external returns, either spikes in interest rates or stock returns
could lead to higher lapse rates, while higher internal returns, such as surplus
participation, could lead to lower lapse rates); (2) personal financial distress or
liquidity concerns; and (3) a general collapse of confidence in a company, product orindustry. There have also been several instances where policyholders grew
concerned about the financial condition of a firm, either through regulatory action orother public knowledge about potential problems of the firm. These experiences did
not necessarily have systemic implications, which potentially could have been caused
by a variety of factors, such as regulatory intervention, the size of the insurer, or the

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normal economic environment. On the other hand, most of the runs occurred atsmaller insurance companies and during a normal economic environment and it isunclear what effect they might have had during a period of significant stress.
4.2.1

Assessment of Substantial Liquidity Risk

4.18 Generally speaking, mass surrenders, withdrawals or terminations could beconsidered as a tail event (albeit with a very large potential impact), which is unlikely
to have a single trigger. More likely, a complex interaction between contract features,the state of the insurer, the market environment, individual characteristics and otherdynamics will determine the extent to which counterparties have an incentive tosurrender. The revised framework therefore sets out a combination of quantifiablefactors and areas for supervisory judgement in determining the extent to which
product features could increase the risk of a run.
4.19 Two key quantifiable factors that the IAIS developed in the 2013 Methodology are (1)the delay in access and (2) the economic penalties applicable to counterparties
wishing to withdraw. These factors, unlike the other potential mitigating andexacerbating factors described below, can be divided into discrete quantitative
categories to capture the extent to which they may create a disincentive forpolicyholder withdrawal.
4.20 It is acknowledged that those simplifying “product characteristics” do not fully capture
the heterogeneity of markets and products and the potentially different behaviours ofpolicyholders. Therefore, it is acknowledged that supervisory judgement also plays arole in the analysis of substantial liquidity risk.
4.2.2

Delays in Access4.21 The more quickly policyholders are able to access their funds, the more likely it is that
insurers may have to engage in disruptive fire sales of assets to make the payments
promised. The longer the delay, the more opportunities insurers will have to spreadthe sale of assets over time or to access liquidity through other means. In addition, asubstantial delay in access may create a disincentive for counterparties to surrendertheir contracts.
4.2.3

Economic Penalty Relative to Account Value

4.22 The larger the tax, legal or contractual penalties that counterparties must bear on
surrender, the smaller the incentive to withdraw funds. Conversely, the smaller thetax, legal or contractual costs that counterparties must bear on surrender, the larger
the incentives to withdraw funds. A substantial penalty, by itself, will not remove all
surrender risk, as some counterparties may be immune to any monetary disincentive(e.g. in case of panic).
4.2.4

Potential Mitigating and Exacerbating Factors on Substantial Liquidity Risk

4.23 With regard to liquidity risk specifically, there is also a range of further factors thatcannot directly be translated into an ex ante monetary economic penalty, but thatnevertheless provide incentives or disincentives for surrendering policies.
Importantly, the incentive to surrender or maintain a contract could vary over time.
These specifically include:

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•

Purpose of the policy: Policies offering protection to holders serve a different
economic purpose than products used as a vehicle for saving, which makes themless likely to be seen as deposits. They therefore do not have the same incentives
for surrender. In particular, the two quantifiable factors mentioned above do nottake into account the purpose of the policy, meaning that the substantial liquidity
risk may be overestimated for products that are primarily for protection. Based on
this consideration, the NTNI consultation document states that thoseparticularities may override the findings based on a simple penalty/delay of
payment categorisation. Therefore, the purpose of the policy and any foregone
benefits needs to be carefully taken into account in a holistic assessment ofliquidity risk created through products.

•

Surrender value relative to market value: The value of surrendering the policy
may be different from the market value of the assets backing it at the time ofliquidation, creating an incentive to surrender and earn a premium (or disincentive
to surrender and realise a loss).

4.24 Other mitigating and/or exacerbating factors also include:

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Replacement of cover: the risk that the policyholder may not be able to obtaincoverage or the same amount of coverage for comparable costs.

•

Although the economic penalties mentioned above encompass all monetary
penalties including tax penalties, there may be other economic penalties tosurrendering policies, including loss of tax benefits, for instance through the tax
treatment of policies and surrenders.

•

Loss of guarantees: the policyholder may forfeit any guarantees associated withthe policy, such as guaranteed interest rates or guaranteed minimum living/death
benefits.

•

Flexibility to lower policy surrender values: A lower benefit on surrender may deter
policyholders from forgoing the future benefits of the policy. Under certain
circumstances, it may also have the opposite effect of triggering a behaviour thatthe intervention was intended to prevent in the first place (“self-fulfilling –prophecy”).

•

In addition, some supervisors have tools at their disposal, such as the authority
to impose stays or lower surrender values that can prevent runs or mitigate theimpact of runs on the financial system. However, some Members are concernedthat the use of supervisory stays could exacerbate systemic risk through thedisruption in market confidence caused by delayed payouts.

•

Policyholder protection schemes and mechanisms: Unlike the other points listed
above, this does not relate to the contractual features of a product. However, if
policyholders are confident that they will still be paid if an insurer fails, they may
have less incentive to run. This factor may therefore also be of relevance in somecases. Alternatively, the lack of a credible policyholder protection scheme or
mechanism could exacerbate problems on a relative basis.

•

It is important to note that contract features, including (but not limited to) premium
structure, remaining time in force and fee structure, may also exacerbate or
mitigate surrenders.

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•5

To the extent that an insurer has invested in liquid assets, this may mitigate someof the effects of a forced asset liquidation. If faced with sudden liquidity demands,
the insurer may be able to sell assets, even in a stressed market, without
significantly impacting prices. However, if the insurer has a significant shortageof liquid assets, then it may be forced to sell more liquid assets at a loss,
potentially exacerbating market movements in a stressed environment, or failingto meet claims.

Indicators in the G-SII Assessment Methodology
5.1 As explained earlier, the revised framework amends the former NTNI category suchthat the relevant indicators are organised along the transmission channels and arehence included in the Asset Liquidation category and the Macroeconomic Exposure
sub-category respectively. The relevant indicators are highlighted in bold. This
reclassification is intended to enhance the clarity of the framework through thealignment of the indicators with the transmission channels, maintaining the importanceof the indicators in the previous NTNI category. For the sake of completeness, theother three categories within the G-SII Assessment Methodology are also included in
the table below.
Category

Sub-category

Size

Indicators
Total Assets
Total Revenues

Global activity

Revenues derived outside of home country
Number of Countries
Intra-financial assets
Counterparty
ExposureInterconnectedness
Macroeconomic
Exposure

Asset liquidation

Intra-financial liabilities
Reinsurance
Derivatives
Derivatives trading (CDS or similar
derivatives instrument protection sold)
Financial guarantees
Minimum guarantees on variableinsurance products
Non-policy holder liabilities andnoninsurance revenues
Short term funding
Level 3 assets
Turnover
Liability liquidity

Substitutability

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Premiums for specific business lines

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5.1

Contractual Approach to the Minimum Guarantees on Variable Products
Indicator
5.2 Under the current framework for determining the products that will be included in the
Phase II indicator, the IAIS has determined to address the double counting in theassessment of risks of derivatives and minimum guarantees on variable products. The
revised Methodology removes the double counting of hedged exposures by deducting
the portion of the derivatives indicator score attributable to hedges of minimum
guarantees from the minimum guarantees indicator 11. While derivatives do noteliminate the systemic risk created by these exposures for minimum guarantees
products, the IAIS believes it is appropriate to avoid the double counting the exposure.
Consider, for instance, the cases of hedged and unhedged writers of guarantees onvariable products:•

Unhedged writers of significant amounts of rich guarantees on variable products
could be unlikely to avoid solvency concerns following a significant market
downturn. The impact of failure of a major insurer and the ensuing destruction ofvalue passed to debtholders and policyholders – as well as the ensuing fears about
the sector – would be far greater if this occurred at the bottom of the market whenliquidity is strained and cascades most likely. The revised framework therefore
recognises the increased impact of correlation with the broader economy.

•

Hedged writers: hedging using derivatives may not eliminate market risks from amacro-prudential perspective, but it is unlikely to increase it either. The view of the
IAIS is that it is appropriate for insurers to seek to hedge variable market exposuresand does not wish to discourage such practices.

5.3 The IAIS is aware that the same adjustment could theoretically be made with regard
to other indicators that capture macroeconomic exposure, i.e. Derivatives Trading and
Financial Guarantees. However, the IAIS has not introduced such an adjustment
taking into account the fact that in practice the double counting in relation to these
indicators is not significant and that they will be subject to absolute reference values.
Any relevant consideration will be made in any case in Phase III. The issue will bemonitored in the context of the review of the methodology.
5.2

Liability Liquidity indicator
5.4 In a standardised framework as used for the liability liquidity indicator, economic
penalties and time restraints are important contractual aspects that impact thepropensity of policyholders to surrender in stressed conditions. The lower the penalty
and the shorter the time restraint, the more likely it is that policyholders may surrender,
thus putting the insurer under a considerable liquidity strain under distress. To reflect
the difference in severity, a gradated approach is applied. The combination of time
restraints and economic penalties determines the weight that liabilities receive under
the Liability Liquidity indicator, according to the following table. The IAIS is committed
to an ongoing review of the calibration of the liability liquidity indicator.

11 Amended Minimum Guarantees on Variable Products indicator:

𝑀𝑀𝑀𝑀𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓

𝑀𝑀𝑀𝑀𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠−

𝐷𝐷𝑀𝑀𝑀𝑀,𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓
𝐷𝐷𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠(Where ‘D’ and ‘MG’ denote the exposuresused in the indicators for the firm, the sample or the portion covering hedged minimum guarantees)

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Economic
Penalties

None
Low (< 20%)High (> 20%)

Delay in accessNone(< 1 week)
100%
50%
2.5%

Low
(< 3 months)
50%
25%
0%

High
(> 3 months)
2.5%
0%
0%

Where:
Delays in access are based on the average time between the request by a policyholder
and the settlement under the normal course of business.
Economic penalties include all contractual monetary penalties that insurers can
impose on policyholders that surrender early.

••

5.5 To reflect the fact that reasons for early surrender are multifaceted and cannot always
be fully reflected in general Methodology, further mitigating and accelerating factors
are assessed in Phase III in order to get a more encompassing picture.
5.3

Phase III considerations 12
5.6 The 2016 G-SII Assessment Methodology is based on quantitative outputs that arecomplemented by an important additional assessment phase (Phase III) in which
additional information, including qualitative and quantitative considerations, are taken
into account. The qualitative and quantitative elements in Phase III enable the IAIS tounderstand and assess systemic risk within the global insurance industry. In particular,
Phase III allows for an assessment that reflects the heterogeneity of structures,
activities, products, exposures and geographies within the global insurance industry,and differences in data quality reported across insurers and across jurisdictions.
5.7 The following factors should be considered when applying supervisory judgment in theinterpretation of the score (Phase III). These additional factors serve the purpose of
having a more accurate measure of the indicators of Minimum Guarantees on Variable
Products and Liability Liquidity. They aim to provide additional insights for theassessment of the systemic relevance. Some of those factors are difficult to measure.

12

Phase III of the G-SIIs Assessment Methodology is discussed in detail in the Methodology document.

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Minimum guarantees on variable products
1. Degree to which liabilities of firms are cash-flow matched in practiceRationale

Example of
mitigating factor
Example ofexacerbating factor

The minimum guarantees indicator is based on a contractual
assessment of the ability of firms to match the cash flows arising fromguarantees. Firms may, in practice, be restricted (or choose torestrict) the degree to which cash flows can be matched. This should
be taken into account in Phase III. However, any data provided byfirms must be interpreted with caution as the calculation of theduration of liabilities is based on assumptions.
A small or no duration gap (perfect matching of liabilities in practice).
A substantial duration gap (assessment needs to be made that putboth, asset and liability duration into perspective. For undertakings
with material business with features such as future discretionary
benefits, particular ratios, which uses liability cash flows that betterreflect the duration of the liabilities might be calculated bysupervisors after additional requests for information from theundertaking).

2. Derivatives to hedge guaranteed returns for variable products
Rationale

The minimum guarantees indicator is net of risk mitigation. This isappropriate; hedging could reduce micro-prudential risk, but may not
reduce macro-prudential risk as it transfers the exposure to a third
party. Certain derivatives could pose higher risks than others.

Example of
mitigating factor

The use of centrally cleared derivatives.

Example ofexacerbating factor

The use of OTC derivatives.

Liability liquidity
1. Purpose of the policy
Rationale
The purpose of a policy may play a relevant role in the likelihood ofpolicyholder runs occurring. Specifically, policies that are principally
providing protection are less likely to result in runs as policyholders
would typically value the protection element.
Example of
Policies providing principally protection.
mitigating factor
Example of
Policies principally providing savings
exacerbating factor

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2. Surrender value relative to market value of underlying assets.
Rationale
Run dynamics tend to be aggravated where the surrender value
exceeds the market value of underlying assets; this provides
incentives for policyholders to surrender early to ensure there ismoney left (the typical “bank run”).
Example of
Where the surrender value cannot contractually exceed the market
mitigating factor
value of underlying assets
Example of
Where the surrender value can contractually exceed the market
exacerbating factor value of underlying assets.
3. Supervisory interventions: stays and lowering surrender value
Rationale
Some supervisors have tools at their disposal, such as the authority
to impose stays or lower surrender values that can prevent runs or
mitigate the impact of runs on the financial system.
Example ofSupervisory interventions (such as stays and the lowering of
mitigating factor
surrender values) are legally feasible and can reasonably be
assumed to be used by supervisors in case of crisis.
Example of
There are concerns that the use of supervisory stays could
exacerbating factor
exacerbate systemic risk through the disruption in market confidence
caused by delayed payments.
4. Maximum contractual stays
Rationale
Some contracts allow for very long stays (under stressed conditions)
Example ofLong contractual stays give insurers the flexibility to manage themitigating factor
outflows somewhat in case of higher liquidity needs.
Example ofThose (long) contractual stays could potentially not be exercised inexacerbating factor
stressed conditions, particularly if there is a discrepancy between
normal pay-out times and contractual maxima.
5. Replacement of cover
Rationale
Whether or not replacement of cover is possible will affect thelikelihood of policyholder runs occurring. Specifically, disincentives
for policyholder to surrender policies are larger in case cover is noteasily replaced by another firm or policy due to unavailability of thesame/similar cover and/or significant increase in premiums or othercosts for the same/similar cover.
Example of
Cover is not easily replaced.
mitigating factor
Example of
Cover is easily replaced.
exacerbating factor

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6. Tax penalties
Rationale

Example of
mitigating factor
Example ofexacerbating factor

Although economic penalties referred to above (see paragraph4.2.3) encompass all monetary penalties, including tax penalties, inpractice, there may be other tax considerations that could pose adisincentive to surrender a policy.
Additional 13 tax penalty or the loss of a tax benefit (e.g. exemptions
from inheritance tax) when early surrendering a policy.
N/A

7. The existence of policyholder protection schemes and mechanisms
Rationale
Policyholder protection schemes and mechanisms can be effective
in reducing incentives for policyholder to surrender their policies,
especially if policyholder runs were driven by concerns over thesolvency of firms and fear of not receiving their account values.
Example of
The existence of a credible and effective policyholder protection
mitigating factor
scheme or mechanism
Example of
The lack of a credible policyholder protection scheme or mechanism
exacerbating factor
8. Liquidity of assets
Rationale
Policyholder surrenders at a large enough scale may lead to theforced sale of assets to ensure policyholders can be paid. The forcedsale of illiquid assets is more disruptive than the sale of liquid assets.
Example ofAssets are very liquid relative to liabilities.
mitigating factor
Example ofAssets are very illiquid relative to liabilities
exacerbating factor
9. Derivatives Collateral Requirements
Rationale
A liquidity shortfall at an insurer can arise not only from a large
amount of policyholder surrenders, but also from collateral posting
requirements relating to derivative liabilities. This was observed
during the financial crisis.
Example of
Limited derivatives collateral needs under a variety of scenarios such
mitigating factor
as a downgrade or spike in interest rates
Example ofLarge derivatives collateral needs under a variety of scenarios such
exacerbating factor
as a downgrade or spike in interest rates

13

Additional to those already taken into account in Phase 2.

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6

Implications for HLA and BCR
6.1 As stated in the HLA document issued in October 2015, the IAIS work on the 2016 GSII Assessment Methodology and this paper will be closely monitored and evaluatedin the context of HLA. Changes to the G-SII Assessment Methodology and this paper
will lead to a change in HLA design and calibration. It is anticipated that the periodic
annual analyses of insurer field testing data in 2016-2018 and the BCR and HLA review
process will also lead to changes to the HLA design and calibration, prior to the
proposed implementation of HLA. The ICS is intended to replace the BCR as the basis
for HLA in the future.

7

Relationship with NTNI Principles in the 2013 Policy Measures Document
7.1 With this paper the IAIS discontinues the term NTNI and provides further clarificationon the notion of Non-traditional insurance products, by introducing a more granularand nuanced assessment of the product features that influence the systemic potentialof an insurer. The first two NTNI principles in the 2013 IAIS G-SII Policy Measures
document will no longer be used, having been superseded by the more detailed
assessment set out in this document.
7.2 The following statement provides a concise summary of the revised framework. Unlike
the former NTNI principles, it is not intended to be a criterion for binary classificationof products or activities conducted by insurers.

Policies or products that have features that expose the insurer to substantial
macroeconomic risk (including credit guarantees) or substantial liquidity risk through theexposure and asset liquidation transmission channels contribute to higher systemic
potential of insurers.
In this context:• Substantial macroeconomic risk relates to exposures where an insurer’s financial
position is highly correlated with the broader economy.
• Substantial liquidity risk relates to exposure to the risk of a policyholder run.

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8

References

Financial Stability Board (2011), Shadow banking: strengthening oversight and regulation,
Recommendations of the Financial Stability Board.
Financial Stability Board (2014), Key attributes of effective resolution regimes for financial
institutions, Recommendations of the Financial Stability Board.
IAIS (2011), Insurance and financial stability, Policy
http://iaisweb.org/index.cfm?event=openFile&nodeId=34041.

paper,

availableat

IAIS (2013), Global systemically important insurers: initial assessment methodology, Policy
paper, available at http://iaisweb.org/index.cfm?event=openFile&nodeId=34257.
IAIS (2013), Global systemically important insurers: policy measures, Policy paper, available
at http://iaisweb.org/index.cfm?event=openFile&nodeId=34256.
International Monetary Fund, Bank for International Settlements, Financial Stability Board(2009), Guidance to assess the systemic importance of financial institutions, markets andinstruments: initial considerations, Report to G20 Finance Ministers and Central Bank
Governors(availableat
http://www.financialstabilityboard.org/wpcontent/uploads/r_091107c.pdf?page_moved=1).
International Monetary Fund Global Financial Stability Report (April 2016), The Insurance
Sector – Trends and Systemic Risk Implications (available at:
http://www.imf.org/External/Pubs/FT/GFSR/2016/01/index.htm )PUBLIC

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