IFRS 17: Regulatory Impact: Ali Qureshi
IFRS 17: Regulatory Impact: Ali Qureshi
IFRS 17: Regulatory Impact: Ali Qureshi
17: Regulatory Impact
ALI QURESHI
Introduction
Adoption of IFRS 4 was never really fully achieved (a standard that allowed for continuation of
existing measurement practices)
◦ Adopted in 2009/2010
◦ Some clauses were deferred
The challenge will be much larger for IFRS 17 – partial‐adoption not possible
Today’s learnings would be theoretical without a review and alignment of regulations
An opportunity to improve any weaknesses in the accounting framework
SECP’s Current Regulatory Framework
1. Licensing, Registration, Capital & Solvency
Insurance Ordinance 2000 2. Statutory funds for life insurers
(Draft bill 2016) 3. Accounts and Audit
1. Insurance Rules, 2017 (Accounting Regs)
Rules 2. Takaful Rules, 2012
Regulations/Notifications/ 1. IFRS 4 Adoption Notification, 2009
Directives/Guidelines/Circulars
IFRS 17 Working Group
ICAP’s thrust to see Pakistan become an IFRS compliant region
ICAPs IFRS17 working group has representation from industry professionals (accountants and
actuaries) and SECP
Working group will propose regulatory amendments are going to be proposed to SECP
(consensus has been reached on some important items in the working group)
Agenda
1) Why revision in regulations is necessary
2) Specific areas that need to be addressed : Draft Insurance Bill
3) Specific areas that need to be addressed : Insurance Rules 2017
4) Updates from Working Group
Agenda
1) Why revision in regulations is necessary
2) Specific areas that need to be addressed : Draft Insurance Bill
3) Specific areas that need to be addressed : Insurance Rules 2017
4) Updates from Working Group
IFRS 17: At its Core
IFRS 17 Objective: IFRS 17 Insurance Contracts establishes principles for the measurement,
recognition, presentation and disclosure of insurance contracts.
“First accounting standard issued by the IASB”: first time our regulations will have to change to
accommodate an accounting standard
Our current insurance regulations address all 4 areas (in current accounting context):
Measurement (valuation of liability)
Recognition (through earnings)
Presentation and disclosure
IFRS 17: New practices
Aggregation, Identification of “portfolio”
Measurement (model types; initial vs. subsequent)
PV of net cashflows (fulfillment cashflows)
Risk margin, contractual service margin (calculation and tracking)
Discount rate – marked to market
Classification of contracts as onerous
Transition approaches
Revisions Necessary for 3 Reasons
Reason No. 1: Basic framework affected
◦ Statutory Funds, surplus distribution
◦ Impact on general insurance companies relatively less but will impact certain classes of business
Reason No. 2: Deviation on accounting methodology
◦ Adoption of IFRS 17 without changes in the ordinance and rules would prove burdensome for
industry players (especially life industry)
◦ Practically 2 sets of financial statements would be required: public and regulator
Reason No. 3: Significant discretion left to preparer of financial statements
◦ Discretionary practices that are associated with IFRS 17
◦ Difference in approach/judgement could lead to materially different results for the same
contracts/business/risks
Thrust of Regulation Review
Amendment to existing sections
New sections altogether
The timing of the circular stating “Adoption of IFRS 17” hinges on regulatory changes
Placement: ordinance v. rules v. professional guidance v. left in the hands of entity
Accounting regulations should not be part of the Act; should be kept in the easier to amend Rules.
Agenda
1) Why revision in regulations is necessary
2) Specific areas that need to be addressed : Draft Insurance Bill
3) Specific areas that need to be addressed : Insurance Rules 2017
4) Updates from Working Group
Insurance Bill: Areas Affected
Draft Bill Clause Summary
17. Assets, liabilities, revenues About the receiving and crediting of amounts pertaining to the business of the various statutory
and expenses of funds funds
18. Disposition of assets of
Assets of the fund are only available for expenditures related to the business of that particular fund
statutory funds
21. Distribution of capital in a life How capital is to be distributed through transfers to shareholders fund, another statutory fund or as
insurance statutory fund bonuses to participation policyholders
22. Allocation of surplus on life Maintaining details of retained earnings, definition of surplus and its components, and how it is to
insurance business be allocated as per the ordinance
23. Restriction on dividends and Talks about the restrictions on dividends and bonuses, the role of the appointed actuary in this
bonuses regard, and cases where such restrictions would apply
64. Valuation of assets and How assets and liabilities are to be valued as per the Commission. Includes directions for valuation
liabilities of liabilities regarding outstanding claims and unexpired risk
Details about the statements and accounts required to be compiled and audited by an approved
99. Accounting and reporting
auditor.
Details of the Actuarial Report and the Financial Condition Report to be compiled by the appointed
103. Actuarial report
actuary, including a valuation of the policyholder liabilities
Statutory Fund Requirement
Currently
Separate statutory funds exclusive to each type of business (investment linked, capital redemption,
pension, accident and health, outside PK)
Considerations for alignment:
• Business has to be divided into multiple portfolios – statutory funds will further complicate it to the
point it is totally unworkable
• Unit linked policies need to be unbundled
• Therefore serious need to re‐define “fund” requirements
Assets, Liabilities, Revenues and
Expenses
Currently
“All assets, liabilities, revenues and expenses of a life insurer shall be referable to one or more
(shareholder or statutory) funds of the insurer.”
Considerations for alignment:
◦ Definition of revenue, expenses, liability, assets
◦ Apportionment between two or more statutory funds to be done on fair and equitable basis
Statutory Accounts
Currently:
Statutory accounts need to be submitted to SECP
Considerations for alignment:
◦ Section will need to be completely revised to align with IFRS17 presentation
◦ Additional forms to cover new items particular to IFRS 17
Allocation of Surplus
Currently:
Surplus earned on participating business to be distributed in form of bonus
Considerations for alignment:
◦ IFRS17 profitability measure is different
◦ How should that impact surplus allocation mechanism
◦ Need to ensure adoption of IFRS 17 doesn’t reduce the distributable surplus to policyholders (change in
accounting regulations shouldn’t effect this distribution)
Responsibilities of Appointed Actuary
Currently
List of duties such as performing annual investigation, equitable apportionment of revenues and
expenses, certifying terms and conditions are workable
Considerations for alignment:
◦ SECP has room to prescribe other duties
◦ How will the role of Appointed Actuary change, if at all
Requirement to Audit
Currently
Every insurer shall appoint an auditor who expresses an opinion on a number of items (e.g.
statements reflect books and records, in accordance with act)
Considerations for alignment:
◦ Given the actuarial nature of insurance revenue and expenses – opinion of an actuarial“audit expert”
will be necessary
◦ Systems are reliably tracking contracts’ csm, risk margin
Agenda
1) Why revision in regulations is necessary
2) Specific areas that need to be addressed : Draft Insurance Bill
3) Specific areas that need to be addressed : Insurance Rules 2017
4) Updates from Working Group
Rules: Areas Affected
Section Summary
14. Net admissible assets of life Annexure III (Detailed descriptions of methodology to be used to calculated the solvency margin,
insurer including percentages, ratios and factors to be used)
19. Accounting and reporting Annexure II (Financial statements of life insurance companies)
Annexure IV (Details of the Forms required to be submitted in the FCR, including statements and
22. Financial condition report
declarations by the Appointed Actuary)
Annexure V (Minimum Valuation methodologies to be adopted to calculate the liabilities for
23. Minimum valuation basis
different type of life insurance products)
Solvency Regime
Currently
Solvency margin = X% of PHL + Y% of sum at risk
where X and Y varies by product
Considerations for alignment:
◦ PHL definition will change with IFRS 17
• Would not want company’s solvency to be adversely affected
◦ Re‐calibration of factors if going to continue with factor based approach so that solvency requirement is
not substantially affected
◦ Regulations leave room for regulator to introduce risk‐based capital – evaluate possibility of introducing
both together?
Statutory Accounts Format
Currently
Effective January 1, 2018 – Format will change for life insurers (B/S, cashflows, comprehensive
income, change in equity on face)
Considerations
◦ IFRS 17 totally different from existing presentation: Revenue is an actuarial‐driven result (not premium),
investment component disaggregated, change in insurance liabilities no longer required
◦ OCI Accounting policy to be provided
Valuation Basis
Currently:
Details assumptions and valuation methodology by product type
Considerations:
◦ Section will change significantly
◦ Section will need to be re‐structured along the various measurement models and their technicalities
◦ Given marked to market nature – there may need to be a mechanism whereby the PSoA can provide a
reasonable range of assumptions. Cashflow assumptions: lapse, expense, discount rate
Actuarial Report
Currently:
Report to be prepared on financial condition by appointed actuary
Considerations for alignment:
◦ Valuation of liabilities, assumptions, methodologies, surplus distribution, solvency
◦ How would the nature of this report change in light of IFRS 17
Agenda
1) Why revision in regulations is necessary
2) Specific areas that need to be addressed : Draft Insurance Bill
3) Specific areas that need to be addressed : Insurance Rules 2017
4) Working Group: Consensus Reached So Far
Consensus on Key Items
1. Assist SECP to draft a circular requiring insurance companies to submit an initial high level plan for
implementation of standard
2. Role of actuaries in life insurance regime
3. Statutory Funds
4. To ensure consistency on discretionary practices a central body must provide ongoing professional
guidance
5. Tax authorities to be brought into working group once clarity is achieved within Working Group
Implementation Roadmap (dates are
illustrative)
1. Setting up of an internal dedicated group (possibly with full time actuarial personnel)
[September 2018]
2. Awareness and training of required personnel [last quarter 2018]
3. Building a framework – modifying accounting systems, etc [needs to be implemented by 31
December 2019]
4. Development / (possible acquisition) of actuarial modeling tools and related training of
personnel in their use [by 31 December 2018]
5. Actual building and testing of models [throughout 2019]
6. Using models to generate comparative numbers for periods beginning 1 January 2020) [mid
2020 onwards]
Role of Actuaries: Life Insurance
Internal actuarial function should be given the core responsibility of such implementation
Head of actuarial function should at least be a Fellow from recognized actuarial body;
Appointed Actuary may be consulted by the insurer whenever deemed appropriate;
Appointed Actuary will have no responsibility regarding such implementation; and
CFO and financial controller must support actuarial function whenever needed
Statutory Funds: Life Insurance
Have essentially two divisions of life business
◦ One each for Takaful and Conventional
◦ Could have one but this may not be acceptable under Shariah
Have fund maintenance requirements for all groups of assets which require segregated maintenance.
This would include
◦ All linked funds (including Family Takaful PIFs and conventional unit linked funds)
◦ Takaful Funds
◦ Participating Funds
Solvency to be maintained within Shareholders’ Fund(s)
Admissibility limits will need to be adjusted
Statutory Funds: Likely Model
Conventional Life Fund Family Takaful Fund
Shareholders’ Sub‐Fund
Shareholders’ Sub‐Fund
Unit Linked Without Profits
+ All Charges + All Premiums + non‐risk chgs
‐ SAR part of claims ‐ Claims ‐ Expenses
‐ Expenses ‐ Expenses
With Profits ‐ + wakala fees
+ Share of Surplus ‐ + inv income