Title: 2006 General Meeting
1Canadian Institute of Actuaries
LInstitut canadien des actuaires
- 2006 General Meeting
- Assemblée générale 2006
- Chicago, Illinois
2Improving Actuarial Processes Beyond AuG-43
Compliance
- Jacqueline Friedland, FCAS, FCIA, MAAA KPMG LLP
- Neville Henderson, FSA, FCIA, MAAA PwC LLP
3Presentation Outline
- Introduction
- Current environment
- Implications
- Controls
- Recomputation
- Conclusion
4Introduction New Audit Guideline AuG-43
- Replaces old guideline AuG-15
- New guideline includes insurance enterprises
- Applicable to life insurers, PC insurers,
reinsurers, and workers compensation boards - May also be used for enterprises whose products
have similar characteristics to insurance
products - Issued December 2005, effective 2006
5Introduction Why the change?
- Auditor audits the financial statement as a whole
- Audit opinions do not (and cannot) express
reliance on the AAs opinion - CIA/CICA Joint Policy Statement provides
framework - Greater consistency with US and UK GAAS
- Change in audit standards with respect to
internal controls
6Introduction Basic Principles
- AA is responsible for valuing policy liabilities
- Requirement for independent check on actuarial
liabilities - Requires use of audit support actuary
- Clarifies that AA cannot provide audit support
role - Requires corroborative evidence for use of AAs
work
7Introduction Audit Approach
- Understand and test internal controls over the
actuarial valuation (new) - Substantive tests
- Test data used in valuation
- Review of valuation for reasonableness
- Testing of calculations, including consideration
of complex models (new) - Extent of testing dependent on
- Complexity and subjectivity of estimation of
policy liabilities - Availability and reliability of data
- Nature and extent of assumptions
- Degree of uncertainty of future events
8Current Environment Life Insurers
- Prior to AuG-43 wide variance in practice
- Dependent on circumstances
- Little documentation or testing
- Reliance on post review
- Controls have not kept pace
- Poorly documented processes and controls
- Increasingly complex products
- AuG-43 forces Actuaries to re-examine processes
controls
9Current Environment Property Casualty Insurers
- Not significant communication between AA and
audit actuary - Review of assumptions, methodology, findings
- Varying degree of review of calculations
10Implications Life Insurers
- AuG-43 provides guidance on reviewing policy
liabilities - Address the risk of material misstatement
- Identify the risks and how they are mitigated
- Review the effectiveness of the controls
- Independent corroborative evidence
- Recomputation
- Recomputation is complex for insurers
- Improve controls to minimize recomputation
11Implications Property Casualty Insurers
- Requirement for documentation of internal
controls and data validation procedures - Requirement for more communication with AA
- Expect closer relationship with AA
- The audit actuary must test (not do over) the
AAs calculations - Extent of recalculation depends on
- Nature of policy liabilities
- Internal control processes
- Difference of opinion regarding within a
reasonable range - Timing of AA work and audit actuarial specialist
12Controls General
- Traditionally more reliance on back-end
- Increasingly difficult due to tighter timelines
- Simple trending not enough with complex products
- More controls on the front-end
- Quality control rather than correction
- Limited resources can focus more on analysis
- Three critical stages to valuation process
- Collection of data
- Complex valuation models and calculation systems
- Other adjustments
13Controls Data I
- Issues beyond usual IT controls
- Quality of data filters handling of rejected
data - Interfaces all data transfer points
- Data from third parties or specialty admin
systems - Legacy systems and multiple admin platforms
- Admin may improvise for shortcomings in systems
- Handling of new products
- Critical information in comment sections
14Controls Data II
- Actuaries need to capture all policy attributes
that materially affect valuation - Is the right information being extracted for
valuation? - Sufficient differentiation for complex products
- UL min vs max funding
- Lapse experience dependent on premium features
- Review use of averages and approximations
- AuG-43 forces actuaries to review these issues
and document controls
15Controls Valuation Models
- Complex models to value complex products
- Commercial software vs home-grown models
- Similar control issues
- Different approaches to testing
- Set-up of valuation assumptions
- Check consistency between assumptions and studies
- Consider uncertainty in future events
- Reasonableness in the range
16Controls Reasonability
- Complex models combined with complex products
- How do actuaries get comfort with result?
- Critical back-end checks and analysis
- Trending reserve / 1000 face amount
- Reserve roll-forward or reserve continuity
- Variance to plan / budget
- Strain at issue compared to pricing expectations
- Earnings by source
- Techniques for analyzing results have evolved but
documentation may not have
17Controls Adjustments Outside the Model
- Adjustments occur throughout the process
- Several types of adjustments (post model)
- Handling of financial statement presentation
- Inclusion of liabilities not modeled
- Known model deficiencies
- Significant challenge due to fewer controls
- Late adjustments
- Use of spreadsheets
18Controls Spreadsheets
- Steps to ensure appropriateness of adjustments
- Itemize and track changes in adjustments
- Regular review of need and reasonability
- Limit who has ability to approve
- Many adjustments rely on spreadsheets
- Need same discipline as model
- Limit authority
- Version control
- Establish naming conventions
- Perform independent checks
- Document in addition to comments
19Recomputation
- Significant effort in case of most life insurance
products - Commercial software vs home-grown models
- Companies to perform and document self- testing
- Better controls are demonstrated then need for
recomputation reduced - Always some requirement for testing
20Conclusion
- Audit is more robust with improved quality of
financial statements - Greater consistency with other jurisdictions
- Forcing actuaries to document is not the point
- Reduce need for recomputation
- Hopefully identify control gaps and fix
- Improve processes before a problem occurs
21Presenters Contact Details
- Jacqueline Friedland, FCAS, FCIA, MAAA
- KPMG LLP
- (416) 777- 8320
- jfriedland_at_kpmg.ca
- Neville S. Henderson, FSA, FCIA, MAAA
- PricewaterhouseCoopers LLP
- (416) 941-8437
- neville.s.henderson_at_ca.pwc.com