Fair Value Accounting FAIR VALUE Ralph Blanchard NAIC

Fair Value Accounting FAIR VALUE Ralph Blanchard NAIC CATF - December 3, 2000

Fair Value Accounting Overview • Definition of Fair Value • Who is proposing it? • Insurance application - significant issues • Actuarial response • CAS white paper Format Previews Findings • Next steps - actuarial orgs • Next steps - accounting standard setters NAIC CATF - December 3, 2000

Fair Value Accounting What is “Fair Value? ” “DICTIONARY” DEFINITIONS “an estimate of the price an entity would have realized if it had sold an asset or paid if it had been relieved of a liability on the reporting date in an arm’s-length exchange motivated by normal business considerations. ” (FASB) “the amount for which an asset could be exchanged, or a liability settled, between knowledgeable, willing parties in an arm’s length transaction. ” (IASC) NAIC CATF - December 3, 2000 Slide 2 of 16

Fair Value Accounting What is “Fair Value” - Part 2 SHORT WORKING DEFINITION • The market value, if a sufficiently active market exist, OR • An estimated market value, otherwise ESTIMATED MARKET VALUE present value of future expected cash flows, adjusted for: • risk • market imperfections • “similar factors if market-based information is available to estimate those adjustments” (FASB) NAIC CATF - December 3, 2000 Slide 3 of 16

Fair Value Accounting Who is Proposing It? FASB: • • • Preliminary Views - Financial Instruments at Fair Value Focus is financial instruments Insurance defined as financial instrument, usually Comment deadline was May 31, 2000 IASC: Insurance Issues Paper • Focus is insurance • Discount all insurance liabilities • Fair value insurance liabilities IF all other financial instruments at fair value • Comment deadline was May 31, 2000 NAIC CATF - December 3, 2000 Slide 4 of 16

Fair Value Accounting Insurance Application - Significant issues? All Insurance? • Only indemnity contracts at fair value? • What about services? (e. g. , HMO) • What about option of cash/service? (e. g. , Property) • What about composite contracts? (e. g. , WC) Discounting Risk Provision • Reliably measurable? • “Market price” • Independent of holder? • Diversifiable vs. non-diversifiable risk? NAIC CATF - December 3, 2000 Slide 5 of 16

Fair Value Accounting Insurance Application - Significant Issues? Part 2 UPR replaced with unexpired contract reserve • No premium deficiency reserve • No Deferred Acquisition asset (DAC) • Include renewals in the fair value? • Return premium as a floor? Credit standing • Liability lower for shaky company? NAIC CATF - December 3, 2000 Slide 6 of 16

Fair Value Accounting Actuarial Response CAS special task force on fair value liabilities • Research • White paper www. casact. org/research/tffvl/index. htm AAA Fair Value Task Force • Responsed to FASB, IASC International Actuarial Association (IAA) • Responsed to IASC CAS liaison to IAA NAIC CATF - December 3, 2000 Slide 7 of 16

Fair Value Accounting CAS White Paper - Format A. Background, including a definition and history of fair value in general B. Fair Value in the insurance context C. Alternatives to Fair Value Accounting for p/c insurance liabilities D. Methods for Estimating Fair Value E. Implementation Issues surrounding the fair valuing of p/c ins. liabilities F. Accounting Presentation Issues, including alternative income statement or balance sheet formats in a “fair value” world. G. Accounting Concepts, or how well fair value accounting and the issues discussed in the earlier sections would be viewed in the context of general accounting concepts (such as reliability, relevance and representational faithfulness). H. Credit Standing and Fair Value Liabilities, a discussion of issues related to the reflection of credit standing in determining the fair value of liabilities. I. Professional Readiness J. Summary and Observations K. Technical Appendices NAIC CATF - December 3, 2000 Slide 8 of 16

Fair Value Accounting CAS White Paper - Preview - Fair Value Pros and Cons Potential advantages - Fair Value • Consistency with assets. • Eliminate accounting arbitrage. • Consistency with other financial instruments. • Relevance. Potential disadvantages - Fair Value • Difficulty in measuring. • Greater estimation reliance. • Volatility in earnings. • Cost. • Unintended or unexpected consequences. NAIC CATF - December 3, 2000 Slide 9 of 16

Fair Value Accounting CAS White Paper - Preview - Methods 1 - CAPM 2 - IRR 3 - Single-period RAD (Risk-Adjusted Discount) 4 - Methods Based on Underwriting Data 5 - Actuarial Distribution-Based Risk Loads 6 - Reinsurance market prices 7 - Direct estimation of market values 8 - Distribution Transform Method 9 - “Rule of thumb” Methods Others? NAIC CATF - December 3, 2000 Slide 10 of 16

Fair Value Accounting CAS White Paper - findings 1) 2) 3) 4) 5) 6) New requirement Alternatives for fair value Expected value versus best estimate Multiple methods Continuum from pricing methods “Typical” line/”typical” company limitation of most current methods 7) A fair value accounting standard would lead to new research 8) When market prices and “fair value” estimates are in conflict • Market disequilibrium • Market disruption • Information asymmetry • Significant intangibles NAIC CATF - December 3, 2000 Slide 11 of 16

Fair Value Accounting CAS White Paper - findings Part 2 9) Implications of risk margin approaches without value additivity 10) Susceptibility to actuarial estimate 11) Increased reliance on judgmental estimates in financials 12) Historical comparisons 13) Gross vs. net. 14) Tax issues 15) Credit standing reflection in valuing liabilities 16) Actuarial workload requirements 17) Professional Readiness 18) Standards vs. Principles NAIC CATF - December 3, 2000 Slide 12 of 16

Fair Value Accounting Next Steps - Actuarial orgs. CAS • Decide on next steps after White Paper • Participate in future IAA discussion/workproducts relative to IASC AAA • Continued dialog with FASB on “fair value” • Document actuarial issues with fair value • Future comments to IASC? AND/OR • Contribute to IAA • Continued dialog with IASC on “fair value” • Contribute to IASC Discounting discussion. NAIC CATF - December 3, 2000 Slide 13 of 16

Fair Value Accounting Next Steps - Accounting Standard Setters IASC • • • Field test and case studies (2000 -2001) Draft Statement of Principles (2001) Exposure Draft of Proposed IAS (2002) Final Standard (2003) Transition Period (2004) Effective (2005) SEC • Determine if statements filed under IASC standards will be accepted in U. S. • Comment deadline was May 15, 2000 NAIC CATF - December 3, 2000 Slide 14 of 16

Fair Value Accounting Next Steps - Accounting Standard Setters FASB • Review comments to-date. • Issue JWG fair value document (non-insurance). • Follow / influence IASC work on Insurance and fair value. • Would like to have fair value of financial liabilities Joint Working Group (JWG) • Partnership of accounting standard setters (e. g, FASB, IASC, U. K. , Germany, Japan, et al. • December(? ) 2000 discussion drafts • Includes ins. enterprises, excludes ins. contracts • Exposure drafts would follow, then Standards NAIC CATF - December 3, 2000 Slide 15 of 16

Fair Value Accounting Speed of Accounting Pronouncements “The Board’s Experience with Fair Value of Financial Instruments. . . The accounting profession, the SEC, bank regulators, and some providers of financial statement had urged the Board to deal with the subject comprehensively because the existing authoritative guidance was incomplete and inadequate. …resulted in ad hoc and inconsistent reporting practices. In 1986, the board agreed to undertake a major project on financial instruments. ” (from FASB “Financial Accounting Series, No. 206 -D/February 29, 2000, page 7) bolded font not in the original text NAIC CATF - December 3, 2000 Slide 16 of 16