Coming Together


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Coming Together

  1. 1. Coming Together Capital and Risk Management
  2. 2. Coming Together Capital and Risk Management Capital management is critical for financial With the increased use of economic capital services firms. Successful capital management measures, the roles of the capital management brings together a good understanding of a firm’s and risk management functions will become capital requirements and funding possibilities, ever more closely linked. In an integrated risk and provides an effective process for managing and capital management approach, the two capital allocation to individual business units. functions will collaborate in a joint effort to enhance their firm’s risk/return balance in line In this issue of our Embedding ERM series, with its strategic management goals and risk we analyze the roles and responsibilities of the preferences. capital management function in these key areas: • Determining capital requirements • Monitoring and managing the capital position • Managing the fungibility of capital • Funding the capital position • Optimizing capital efficiency
  3. 3. An economic approach should provide a more Determining Capital accurate view of: Requirements • The risks facing the business Assessing the level of capital required to support the • How diversified these risks are business is a key task of the capital management • The capital required to meet them function. Capital requirements are typically determined Current rating agency capital requirements are on a number of different bases — both for the firm typically a mixture of economic and more simplistic as a whole and for individual business units. These formula-driven approaches. However, some rating might include: agencies have indicated their willingness to take into • Regulatory capital account, to some extent, the results of companies’ “ In an integrated capital • Economic capital internal capital models in assessing capital require- • Rating agency capital ments. Such treatment is conditional on the model management approach, passing the rating agencies’ own criteria, which the capital management At the same time, the level of available capital will normally require, among other factors, the model to also need to be determined separately for each and risk management be used and embedded in the business decision- basis, as different approaches are adopted for functions will collabo- making process. This approach is very similar to the valuation of assets and liabilities. In addition, that set out under the forthcoming Solvency II rate in a joint effort to regulatory and rating agency bases often restrict the regulation in Europe. enhance a firm’s risk/ admissibility of certain assets in this assessment. This results in three distinct assessments of the The capital management function must understand return balance in line with company’s capital position, each with a different which capital requirements are of the greatest its strategic management level of sensitivity to risk (see sidebar, page 4). importance in the decision-making process. Priorities goals and risk preferences.” might vary over time between different business units In some jurisdictions, the regulatory capital regime and between the business unit and group levels. may already be based on an economic approach. But, in most regions (including the European Union As already mentioned, the comparison of capital until the formal implementation of Solvency II in positions under these different bases is complicated 2012), regulatory regimes are based on more by variation in the available capital, as well as simplistic formula-based approaches rather than variation in the capital requirement between the fully risk-oriented approaches. bases. One way to simplify the issue is to focus on the amount of excess or free capital under each For example, the U.K. regulatory system currently approach. However, even this strategy is not as requires both a relatively simplistic formula-based simple as it appears, since expectations of capital approach, albeit with some risk-sensitive elements buffers in excess of requirements vary between for with-profits (participating) business, and, in bases. For example, it would be normal to maintain parallel, an economic risk-based measure designed a buffer in excess of regulatory capital requirements to capture the specific risk characteristics of each to ensure the requirement can still be met after an individual firm (the individual capital assessment). adverse event. The same would not be the case for In the U.S., regulators have for some time adopted a economic capital requirements for the company’s risk-based approach (risk-based capital), using risk- target risk appetite. In this situation, the expectation based factors to determine capital requirements. would often be to manage available capital to be This method is somewhere between simplistic close to the economic requirement but without formula-based approaches (e.g., a fixed percentage incorporating an explicit buffer. of reserves) and economic approaches currently being introduced in a number of countries. The U.S. regulatory regime is also moving in a more economic direction with the gradual introduction of principle- based approaches for an increasing number of product lines. Coming Together: Capital and Risk Management 3
  4. 4. Conflicting Regulatory Messages In many European countries, insurance regula- Under Solvency I regulation in most Continental tors have already started to embrace economic European countries, the assets are marked to capital measures, partly in anticipation of market, while the liabilities are based on book Solvency II and partly to promote best practice reserves and generally remain unchanged under risk management approaches. Yet earlier, more varying interest rates. In this instance, rising “ Monitoring the capital simplistic regulation, often based on Solvency interest rates is the key risk to meeting solvency I approaches, still remains in force. These two requirements, since falling asset values are not position and ensuring a very different regulatory approaches can send compensated by any liability movement. sufficient quantity and conflicting messages to capital managers and This complicates the task of managing interest- quality of capital is one make risk and capital management very difficult. rate risk, as both rising and falling interest rates of the key tasks of the Countries with these dual regimes include increase capital requirements on one of the bases Finland, Switzerland and the U.K. capital management to be determined. In practice, one of the capital function.” This challenge is illustrated by considering the bases will be dominant at any given time. But interest-rate risk for life businesses. Typically, significant interest-rate movement may result in asset duration is lower than liability duration the alternative basis becoming more onerous, for life insurers and, from an economic point of potentially requiring a shift in risk management view, falling interest rates would be the key risk. policy. Moving to a matched asset-liability position (or at least closing the duration gap) would reduce the capital requirements. For some insurers, particularly in the U.S. where regulatory and rating agency capital requirements Monitoring and Managing still differ from an economic viewpoint, it may seem the Capital Position unnecessary to add a third type of capital manage- ment. However, the U.S. regulatory basis does not Monitoring the capital position and ensuring a provide a consistent picture of performance across sufficient quantity and quality of capital is one heterogeneous businesses (such as long-term of the capital management function’s key tasks. versus short-term business), nor is it aligned with This work has close links to business planning, as the individual risk situation of the company. That is it has to account for the capital needs of future why developing an economic capital capability offers business expected to be underwritten. Such capital distinct business advantages. It allows management projections should be based on the “best estimate” to understand how much of shareholders’ capital is view of the world, as well as other more positive truly at risk and whether this fits with the firm’s and adverse scenarios. In today’s economic climate, strategic goals and risk management policies. And prolonged recession and/or high-inflation scenarios since economic capital relies on granular data, it might be seen as particularly relevant. This will help provides helpful management information across management understand what actions to take if heterogeneous businesses that can be used to set these scenarios actually develop (e.g., varying new financial targets for business units and assess their business levels or raising capita), as well as what performance over time. actions to take now to change the impact of certain scenarios (e.g., hedging extreme tail events). It can also generate useful information to communicate to shareholders. In the European Solvency II context, such capital planning would form a key component of the Own Risk and Solvency Assessment (ORSA). 4
  5. 5. An organization’s future capital needs are determined More details on this topic can be found in the third by the use, consumption and release of capital by article of this ERM series, “Consistent Performance the various lines of business it writes. Different Measurement — Aligning Risk, Value and Capital insurance products have very different patterns of Management.” capital requirement over their lifetimes. For example, in most short-tail property & casualty lines, the Managing the Fungibility greatest need for capital funding is on inception of a policy, with capital being released later as claims of Capital from the underwriting year run off. In contrast, When capital cannot be moved freely between long-term life business might start with a relatively entities, the issue is referred to as a lack of low capital requirement (aside from funding require- fungibility. If capital is not fungible, insurers will ments for initial expenses and regulatory reserving not be able to take full credit for the diversification strain), but capital needs gradually build as reserves effects between risks, which leads to higher increase. Also, liquidity management is important, economic capital requirements. That’s why it is particularly for companies exposed to substantial important to allow for a degree of capital fungibility, natural catastrophe risks, where significant claim both in determining economic capital requirements payments could fall due in a short time frame. It is and business planning. Scenario testing can help also important for companies subject to contractual pinpoint where potential fungibility constraints might funding or margin call requirements, and especially exist within a group of companies, but the impact so during the recent financial crisis. A clear under- on economic capital can often only be quantified standing of how capital and liquidity might be freed through stochastic simulation. up in certain areas and redeployed elsewhere is essential for active capital management. Fungibility is particularly important for insurers, “ A clear understanding since many have evolved complex legal structures of how capital and Another activity in which capital management partici- both across and within the various geographies pates — linked to general business management liquidity might be freed where they operate. The fact that available capital and strategic goal setting — is actively allocating resources are distributed across a substantial up in certain areas and (available) capital to areas where return expecta- number of entities (as opposed to residing within a redeployed elsewhere is tions are particularly value enhancing for the firm. limited number of balance sheets) often limits the This requires a clear understanding of how value essential for active ability to move capital from one entity to another, (after allowing for risk) is generated and should capital management.” due to legal, tax or regulatory constraints. be used to set financial targets for both the orga- nization and individuals within the organization. Own Risk and Solvency Assessment The requirement to conduct an Own Risk and The importance of ORSA’s forward-looking Solvency Assessment (ORSA) in Europe under nature is recognized by the Solvency II Solvency II will formalize what might currently framework and supplements the one-year risk be regarded as best practice capital manage- horizon view of the capital requirement. An ment and planning processes into a regulatory insurer’s ORSA should include an analysis of requirement. The ORSA encompasses the entire likely future changes in the risk profile, capital risk management system, whereby insurers requirements and sources of capital to meet have to assess and manage their own short- these requirements. and long-term risks and the amount of funds The capital management process will therefore necessary to cover them, given their particular move from being an important component of a risk strategy and appetite. This is independent well-run company to a regulatory requirement. of whether the company is using the standard approach for the Solvency Capital Requirement or an approved internal model. Coming Together: Capital and Risk Management 5
  6. 6. Fungibility of capital can be increased by concentrat- business, the more absorptive the capital structure ing the business within a smaller number of entities. should be, which will inform the choice of capital Reinsurers have been among the first to see the (equity, preferred equity, senior debt, unsecured advantages of operating from a single balance debt, hybrid debt) to be raised. sheet. But with the freedom-of-services regulation In addition, the capital management function can now in place in Europe, primary insurers are also play a role in designing and implementing innovative taking advantage of this opportunity (see sidebar forms of capital — ideally both low cost and risk below). absorptive — linked to the specific needs of the business (see sidebar, page 7). Funding the Capital Position The stresses in financial markets since mid-2007 The capital management function will be heavily have forced a number of insurers to pay closer involved in raising new capital, even if another attention to both their capital needs and explaining department, such as the finance function, actually these needs to the market. While many insurers goes to market to physically raise funds. have raised capital, this has usually come in the The capital management function should forecast form of debt issuance or the divestiture of businesses the likely timing for raising future capital and rather than by going directly to shareholders for support more specific decisions about when capital more equity capital. Insurers have also introduced is required and what sort of capital should be raised. scrip dividends (when the dividend is paid in new The type of capital raised, in particular its absorptive shares) or cut their cash dividend to preserve capacity and treatment by regulators, affects many capital, since raising capital from shareholders is aspects of the business, including its corporate often viewed as something of a last resort. risk profile and profitability. In theory, the riskier a “ The stresses in financial Enhancing Fungibility markets since mid-2007 have forced a number Capital management considerations often based pan-European carriers for its life and of insurers to pay substantially influence the legal structure of non-life business in early 2008. According to closer attention to both an insurance group (with tax typically being Swiss Re, “The restructuring enables Swiss their capital needs and the other major driver). For example, writing Re to free up hundreds of millions of francs explaining these needs business out of one legal entity and setting up in capital — and thus to enhance both its branches in other countries, instead of operating capacity and to offer competitive solutions to to the market.” out of a range of local subsidiaries, can have its clients.”* The existing business written in many advantages. In addition to reducing the other Swiss Re entities is being transferred to complexity of the group structure, it allows a these new entities. company to concentrate its capital resources • Primary insurers are also starting similar in one entity rather than spread its funds over reorganizations. ZFS has now concentrated its a number of entities, and thereby increase the pan-European general insurance and corporate fungibility of capital and the crystallization of client businesses in a Dublin-based carrier. diversification benefits: ZFS cited, “flexibility in capital efficiency and • Reinsurers have traditionally operated from solvency” and “reduced complexity and a single balance sheet and have often used costs due to fewer legal entities and one EU branch structures instead of subsidiary regulator”** as reasons for this move. companies, particularly in Europe. Swiss Re, for example, opened two Luxembourg- *, Swiss Re press release: swiss-re-inaugurates-its-european-headquarters-in-luxembourg//21/ **, page 46 6
  7. 7. Innovative Forms of Capital Management A good example of innovative capital raising Another example: Aviva’s 2009 longevity swap,** is Blue Coast Ltd, which in 2008* issued covering £475 million of annuity reserves. an insurance-linked security covering U.S. While this action did not raise capital from hurricane risks. The innovation in this security the markets, the effect of the swap was to is that losses are allocated down to the level release Pillar I regulatory capital as well as of individual counties in the U.S., reducing the being accretive to Aviva on both IFRS and MCEV basis risk to the issuer. In addition to this risk bases. transfer, the issue raised $120 million. * See Towers Watson 2008 Q3 edition of Emphasis, “All-Weather Insurance Securitization.” ** See the Towers Watson Update, “Aviva Transfers Longevity Risk to the Capital Markets,” September 2009. The capital management function’s work is simi- Optimizing Capital Efficiency larly based on a capital management policy, which The final aspect of capital management addressed typically includes references to desired economic in this article is the optimization of capital efficiency. capital and rating levels. These may be expressed This can be achieved by reducing the cost of raising in absolute terms, such as a free capital amount or and holding capital through risk mitigation and rating target or, in relative terms, such as in relation transfer instruments, such as reinsurance, hedging to competitors’ rating and financial strength levels. or capital market securitizations, or through other It is likely that within Europe, as an economic view capital actions such as legal restructurings or of both risk and capital becomes more prevalent, reorganizations. Solvency II will be a significant catalyst for the In seeking a capital-efficient structure, the capital convergence of both risk and capital management management function will have to balance the desire functions. to minimize the amount of capital held per dollar of While risk and capital functions must work together, expected profit with the requirement to ensure they focus on different aspects. The risk function, sufficient capital is held to attract customers and which deals with the nature, level and concentration investors. Of course, improvements to capital of risks taken, leads in risk modeling and determining efficiency involve the amount of expected profit, as diversification benefits, and derives, sets and moni- well as the amount of capital. Improving the profitability tors risk limits. In contrast, the capital management of the business can be achieved through better function determines and monitors capital require- capital allocation and performance management ments, cost-effectively funds and manages capital, (see the third article in this ERM series, “Consistent deploys capital into business opportunities with “ The capital of a business Performance Measurement — Aligning Risk, Value attractive risk/return combinations, and enhances the cannot be viewed in and Capital Management”). capital structure by one-off restructurings or capital isolation; it must be measures (for an overview, see sidebar, page 8). Bringing Risk looked at in the context Ultimately, an economic perspective of risk and Capital Together and capital provides worthwhile insights into of the risks that the the business even when the regulatory capital business is running.” Business capital cannot be viewed in isolation; it must be looked at in the context of the risks the regime diverges from an economic view. For business is running. example, this approach allows management to understand business risks and whether they fit For the risk management function, the risk strategy with the risk appetite. It can also provide highly and risk appetite statements provide crucial input granular information on business unit and product and guidance on the boundaries for risk taking line performance that can be used to drive (for more detail, see the second article in this ERM improvements. series, “Risk Appetite — The Foundation of Risk Management”). Coming Together: Capital and Risk Management 7
  8. 8. Roles of Capital and Risk Management Capital and Risk Management Tasks Activities led by… Activities supported by… Capital Management Risk Management Capital Management Risk Management Determining and Setting risk tolerances Capital management Risk appetite monitoring capital and limits policy and strategy adequacy Business planning and Economic capital Mergers and Sounding board for scenario testing requirements acquisitions business units Determining risk Monitoring/setting Center of excellence Cost-effective fund concentrations/ business unit for business unit raising/capital actions diversification performance targets risk management Monitoring Reporting capital Investor/rating agency Managing business unit risks positions communication operational risk against tolerance The capital and risk functions are deeply involved with Capital allocation to Reporting setting capital management policy and risk strategy, business units risk positions respectively. In principle, however, these roles are carried out by the board, supported by the capital and risk functions. The capital and risk functions will remain distinct due to the different roles they play. The capital function is more heavily involved in capital raising and business planning, while the risk function is more concerned with monitoring group risks. However, as regulatory and rating capital measures converge toward an economic basis over time, it is likely that the capital and risk functions will collaborate even more. In particular, the role of determining and monitoring capital requirements will become very similar to determining economic capital requirements. For more information, contact: Wolfgang Hoffmann Linda Chase-Jenkins 49 221 9212 3421 212 309 3897 View our complete thought leadership series Ian Farr on embedding ERM into your business at 44 20 7170 2395 About Towers Watson Towers Watson is a leading global professional services company that helps organizations improve performance through effective people, risk and financial management. With 14,000 associates around the world, we offer solutions in the areas of employee benefits, talent management, rewards, and risk and capital management. Copyright © 2010 Towers Watson. All rights reserved.