Analysis Of Responses To The Iasb Exposure Draft
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Analysis Of Responses To The Iasb Exposure Draft

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  • 1. Analysis of responses to the IASB Exposure Draft: Insurance Contracts Coordinated by ACLI and GNAIE
  • 2. Distribution of Responses by Type of Organization
  • 3. Distribution of Response by Location
  • 4. Question 1 – Relevant information for users (paragraphs BC13–BC50) Do you think that the proposed measurement model will produce relevant information that will help users of an insurer’s financial statements to make economic decisions? Why or why not? If not, what changes do you recommend and why? 10 2 Models 38 Disagree 71 Agree Number Question #1
  • 5. Question 2 – Fulfilment cash flows (paragraphs 17(a), 22–25 (a) Do you agree that the measurement of an insurance contract should include the expected present value of the future cash outflows less future cash inflows that will arise as the insurer fulfils the insurance contract? Why or why not? If not, what do you recommend and why? 1 Disagree 107 Agree Number Question #2a(ii)-Fulfillment value 5 Disagree 69 Agree Number Question #2a(i) – Net liability
  • 6. Question 2 – Fulfilment cash flows (paragraphs 17(a), 22–25 (b) Is the draft application guidance in Appendix B on estimates of future cash flows at the right level of detail? Do you have any comments on the guidance? 27 Disagree 69 Agree Number Question #2b
  • 7. Question 3 – Discount rate (paragraphs 30–34 and BC88–BC104) (a) Do you agree that the discount rate used by the insurer for non-participating contracts should reflect the characteristics of the insurance contract liability and not those of the assets backing that liability? Why or why not? 80 Total 16 Range of options 2 No discount rate 18 ARR-Asset return rate 0 RFR+OCR-Risk Free Rate with own credit rating 13 RFR+IA-Risk Free rate with illiquidity adjustment 31 RFR-Risk Free rate Number Question #3 27 Disagree 77 Agree Number Question #3a
  • 8. Question 3 – Discount rate (paragraphs 30–34 and BC88–BC104) (b) Do you agree with the proposal to consider the effect of liquidity, and with the guidance on liquidity (see paragraphs 30(a), 31 and 34)? Why or why not? 19 Disagree 21 Agree Number Question #3b(ii)-liquidity guidance 38 Disagree 70 Agree Number Question #3b(i)-Liquidity adjustment
  • 9. Question 3 – Discount rate (paragraphs 30–34 and BC88–BC104) (c) Some have expressed concerns that the proposed discount rate may misrepresent the economic substance of some long-duration insurance contracts. Are those concerns valid? Why or why not? 43 Concerned 19 Unconcerned Number Question #3c
  • 10. Question 4 – Risk adjustment versus composite margin Do you support using a risk adjustment and a residual margin (as the IASB proposes), or do you prefer a single composite margin (as the FASB favours)? Please explain the reason(s) for your view. 43 Margins-Single (Composite) 72 Margins-Risk/residual Number Question #4-Margin
  • 11. Question 8 – Premium allocation approach (a) Should the Board (i) require, (ii) permit but not require, or (iii) not introduce a modified measurement approach for the pre-claims liabilities of some short-duration insurance contracts? Why or why not? (b) Do you agree with the proposed criteria for requiring that approach and with how to apply that approach? Why or why not? If not, what do you suggest and why? 10 Don't use 39 Require 85 Permit Number Question #8a-Modified Approach
  • 12. Question 13 – Presentation (a) Will the proposed summarised margin presentation be useful to users of financial statements? Why or why not? If not, what would you recommend and why? (b) Do agree that an insurer should present all income and expense arising from insurance contracts in profit or loss? Why or why not? If not, what do you recommend and why? 52 Disagree 44 Agree Number Question #13a-Summarized Margin
  • 13. Question 17 – Transition and effective date (c) Is it necessary for the effective date of the IFRS on insurance contracts to be aligned with that of IFRS 9? Why or why not? (d) Please provide an estimate of how long insurers would require to adopt the proposed requirements. 1 84 months 2 72 months 13 60 months 7 48 months 36 36 months 19 24 months Number Question #17d-How Long? 6 Disagree 86 Agree Number Question #17c-Align IFRS 4 and 9