IFRS 17 And Embedded Value Reporting - Deloitte

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Insurance Accounting InsightsIFRS 17 and Embedded Value ReportingWhile the immediate challenge for many insurers around the globe is to determine accountinginterpretations and methodologies for insurance contracts, and transition from existing frameworksbefore the effective date of 1/1/2021,1 there are other areas indirectly impacted. One of those isEmbedded Value (EV) reporting.OverviewThe long-awaited IFRS standard for insurance contracts, IFRS 17,was finally released in May 2017, replacing IFRS 4. Many companiesroutinely calculate and publish EV results. Despite having acollection of rules and practices, EV is not technically an accountingframework. Rather, it reports risk-adjusted performance,recognizing both economic principles and constraints posed bylocal statutory laws in distributing earnings. This article aims todiscuss how the adoption of IFRS 17 will impact the future of EVreporting.Comparison – IFRS 17 vs. EVIFRS 17 is a current value framework which is intended to moreconsistently reflect economic reality than existing accountingframeworks under IFRS 4. Its adoption will align insuranceaccounting across the globe, and increase consistency,comparability and transparency.1.As illustrated in Figure 1, under IFRS 17, insurance contractliabilities consist of three components under the generalmeasurement model which is often referenced as the BuildingBlocks Approach (BBA) – probability-weighted mean present valueof future cash flows (expected PV of cash flows), Risk Adjustment(RA) and Contractual Service Margin (CSM). There are variationsto the general model such as the Premium Allocation Approachwhich is an option for certain short-term contracts, and theVariable Fee Approach which is applied to contracts withparticipating features that meet certain eligibility criteria. In thisarticle, unless otherwise noted, we will focus on the generalmeasurement model considering its broad applicability, andsimilarity to the EV framework.The IASB Board voted on November 14, 2018 to propose one-year deferral of the effective date of the IFRS 17 to 2022.IFRS 17 and Embedded Value Reporting

Figure 1. Comparison of IFRS 17 and EV balance sheets –for illustration purpose onlyEquityContract LiabilitiesRequired CapitalContratual servicemarginValue of InforceRiskAdjustmentCost of CapitalTVOGExpected PVof Cash FlowsEconomicLiability(Tax Effect NotConsidered)IFRS Insurance ContractEmbedded ValuePresent Value of Future Profits (PVFP)Free SurplusUnder the general measurement model, the expected PV of cashflows is akin to an economic liability. Discount rates are set basedon a top-down or bottom-up approach, reflecting the risks andcharacteristics of the contracts’ fulfilment cash flows. The riskadjustment is a component that recognizes the risks born bythe insurer in light of the variability of cash flows. One potentialapproach to quantify the RA is the cost of capital (CoC) approach,although IFRS 17 does not prescribe any technique other thanrequiring a confidence level disclosure. Last of all, the CSM is similarto a deferred profit liability concept that is expected to release timezero profit into revenue over time.As illustrated, IFRS 17 has components that are very similarto those under the EV reporting. EV reporting does not set ruleson how to calculate liabilities. By calculating the present value offuture profits (PVFP), implicitly EV reporting recognizes the valueembedded in the local statutory liability once the economic liabilityis removed (considering tax effect would add complication as PVFPis a post-tax calculation). Depending on whether Market ConsistentEV or European EV principles are followed, the discount rates usedfor the PVFP calculation could be real world risk discount ratesor market consistent rates with liquidity premiums. EV includesa CoC component that could be leveraged to modify into theIFRS 17 RA calculation. TVOG cannot be explicitly found fromIFRS 17 requirements, but it is conceivable for insurers to quantifya TVOG as part of the expected PV of cash flows in order to capturethe asymmetry of cash flows when optionalities exist in products.In order to assess the equity position under IFRS reporting,there are other IFRS standards in play such as IFRS 9 for financialinstruments. IFRS 17 is focused on the liability measurementand related presentation, while IFRS 9 provides guidance onasset valuation. The implementation of IFRS 9 can be deferred to1/1/20212 for insurers to sync with the timing of IFRS 17. In contrast,EV reporting defines the Adjusted Net Worth (ANW) which is thesum of required capital and free surplus, and akin to an “equity”concept.With the mandatory implementation of IFRS 17 for most globalinsurers, how will EV reporting be affected? Will IFRS 17 eliminatethe need to report EV? If insurers expect to continue reportingEV on a supplemental basis, what changes will we foresee afterthe implementation of IFRS 17?In comparison, EV, as a supplemental reporting framework, hasbeen widely used in Europe, Asia and other places of the worldas an important measuring stick when comparing financialperformance over time and against peers. It is based on economicprinciples, but also recognizes constraints posed by local statutorylaws in insurers’ ability to distribute earnings.2.2The IASB Board voted on November 14, 2018 to propose one-year deferral on the expiry date of the IFRS 9 deferral period to 2022.

IFRS 17 and Embedded Value Reporting Current State of EV ReportingThe European CFO Forum issued European EV Principles inMay 2004, and Market Consistent EV Principles in June 2008.The intent of these principles was to improve the allowance for riskin reported results, and to increase the transparency, consistencyand disclosures of EV reporting in Europe. They have beenfollowed by global insurers elsewhere in the world too. While moreEuropean companies report EV under the Market Consistent EVprinciples in light of the solvency framework which is also marketconsistent, elsewhere in the world such as Asia, it is more prevalentfor insurers to report European EV results which use real worldscenarios.As described earlier, EV is not an accounting framework. By design,EV reporting minimizes accounting biases in its calculation ofdistributable earnings. Its focus on value has gained popularityin the insurance industry, and EV-based measures have beenutilized in both external investor analysis and internal businessplanning and management compensation. In particular, EV-basedmeasures such as Value of New Business (VNB), new businessmargin (VNB over PV of new business premiums), EV operatingearnings (part of EV analysis of change, or “income statement”with economic impact excluded), and return on EV (EV operatingearnings as a % of EV) have been widely used.Insurance Accounting InsightsIn May 2016, the CFO Forum issued revised European EV andMarket Consistent EV Principles and Guidance, updated for theSolvency II regime which came to effect on 1/1/2016. The revisionrecognized the similarities between Solvency II and EV in theirmethodologies and assumptions, and that componentsof Solvency II reporting could be leveraged for EV reporting.Since then, some insurers, which previously reported MarketConsistent EV, have discontinued EV reporting, because SolvencyII is also a market consistent framework. Others have started usingSolvency II-based measures with adjustments for EV reportingpurposes. For example, Aviva reported VNB on both MarketConsistent EV and adjusted Solvency II Own Funds basis as of 2016year-end, stating that from 2017 onwards, the adjusted Solvency IIVNB will replace EV VNB as a key performance indicator.3

IFRS 17 and Embedded Value Reporting Insurance Accounting InsightsFuture State – Impact of IFRS 17Due to its wide applicability across the globe, it is expected thatIFRS 17 will have a profound impact on the insurance industry,ranging from financial reporting and investor relations, toperformance measurement and management compensation.Like any other accounting framework, IFRS 17, once implemented,will give rise to new accounting-based measures that will concerninternal and external stakeholders. Will those measures eliminatethe need to report under a value-based framework like Europeanor Market Consistent EV? Is IFRS 17 going to be the last straw sincethe adoption of Solvency II to finally push insurers to move awayfrom supplemental reporting like EV, and focus their resources onand completely leverage the primary reporting requirements?For example, the CSM is set up at time zero as a liability to capturethe profit of the insurance contract, and is released into P&L asservices are provided. It further functions as a shock absorber tothe extent it is not depleted, meaning there is still profit to defer tothe future, to offset any unfavorable changes in the expected PVof cash flows and the risk adjustments due to updates in noneconomic assumptions related to future services, resulting ina zero impact to the income statement.Only time will tell how the future of EV reporting will exactly unfold,but here are a few angles that may help practitioners think throughthe potential impact of IFRS 17 on EV reporting:Furthermore, IFRS reporting considers potential asset and liabilitymismatch, and has been designed in a way to mitigate suchmismatch in order to provide relevant and consistent financialperformance and cash flows to readers of financial statements.One example is the variable fee approach, which is a variationto the general measurement model when accounting for directparticipation contracts that meet certain eligibility criteria. Incomparison, EV as a value-reporting framework does not havesuch concern with asset and liability mismatch. In the analysis ofchange, the focus of the “income statement” components is merelyon the value created or destroyed in an economic fashion duringthe reporting year.1. Measurement ObjectivesWhile being a principle-based current value approach, IFRS17 has its own measurement objectives – designed for publicreporting under a going concern, IFRS 17 allows for certain degreeof matching of expenses and revenues, instead of immediaterecognition. Similarly, an anticipation of changes in future cashflows may or may not impact current period income from anaccounting perspective.4In comparison, should any future non-economic best estimateassumptions worsen, the impact would be reflected immediatelyon reported EV results, by flowing through the operating variancein the analysis of change (EV’s “income statement”).

IFRS 17 and Embedded Value Reporting 2. Technical ComponentsAs described earlier, certain technical components are similarunder IFRS 17 and EV reporting. In particular: Pre-tax PVFP in the EV calculation, if removing the statutoryreserve changes and investment incomes, would be comparableto the expected PV of cash flows in the IFRS 17 generalmeasurement model; The TVOG component of EV, with some slight adjustments, couldbe viewed as an additional provision in the IFRS 17 expectedPV of cash flows to account for the optionalities included ininsurance contracts; The CoC component of EV would be comparable to the RA in theIFRS 17 general measurement model, though there are otherways to calculate the RA under IFRS 17; Value of Inforce (i.e., PVFP less TVOG less CoC) represents thevalue generated from the inforce business. It can be analogizedto the CSM, which represents the profit generated frominsurance contracts. Although changes in future non-economicassumptions do not impact income due to the CSM’s shockabsorber nature, the CSM itself is adjusted for future favorableor unfavorable changes, thus it depicts a refined current pictureof future profitability in each accounting period just like the EVValue of Inforce.Of course there are various adjustments that need to be accountedfor, such as choices of discount rates, definition of contract cashflows, inclusion of risks in the RA, tax effect, contract boundary,Insurance Accounting Insightsand unit of account etc. However, both frameworks are basedon current best estimate assumptions, and virtually all technicalcomponents can be analogized or compared closely to eachanother from a balance sheet perspective. It is not inconceivablethat as insurers implement IFRS 17, they may leverage the samesystems and processes used for EV. With some adjustments takeninto consideration, stakeholders may gain additional insights bycomparing the results from the two frameworks.It is not inconceivable that as insurersimplement IFRS 17, they may leverage thesame systems and processes used for EV.3. Investor AppetiteIn some economies, investors have become accustomed toreview EV results to understand insurers’ performance from aneconomic perspective. With the convergence of global accountingsto be more principle-based, it is conceivable that investors thatunderstand these shifts well, such as Solvency II and IFRS 17,will be more empowered with the new financial information drivenby current assumptions. It is expected that certain insuranceproducts, if currently accounted for under a “book value” type ofreserving model that accretes the reserves over time, would bemore inclined to become “onerous” once reported under IFRS17 (i.e. loss-making in the terms of IFRS 17). This is one of theoutcomes of adopting a current value framework. However, it isalso likely that some investors still would like to hold on to thesimple concept of value creation.5

IFRS 17 and Embedded Value Reporting The impact of Solvency II is an example – useful EV data in Europehas been rapidly reduced since the adoption of Solvency II dueto some insurers seeking alignment between EV and Solvency IIand even discontinuing the reporting of EV. On the other hand,investors have not been thrilled by the amount of disclosuresprovided under the Solvency II framework, and how Solvency IIcomponents are assembled to measure profit performance andcash generation. IFRS 17, while having technical provisions that canbe analogized to EV, may create similar issues for external users.For example, IFRS 17 requires a confidence level disclosure for therisk adjustment, but does not specify a calculation technique. Theconfidence level disclosure is meant to provide transparency andcomparability amongst insurers, but from investors’ perspective,it may have limited value because the RA needs to be reflective ofentity’s own view in quantifying the risks per IFRS 17 requirements.Investor appetite will affect the continued existence of EVreporting, and how much value it still adds as a supplementalreporting framework. It is essential to have an “investor story”with a more coherent link between IFRS, EV and Solvency II.4. Business ManagementInsurers have historically used both accounting-based measuresand EV metrics in business planning and managementcompensation. With the adoption of IFRS 17, the accounting-basedmeasures, such as return on equity, operating income and profitmargin etc. will all be affected and volatility is expected whencomparing to historical values of these measures. Depending onbusiness model and profit structures, insurers may experiencevarying degree of volatility in those measures, which may lead toredefining long-term targets or reconsidering key performanceindicators that matter to insurers. In comparison, EV-basedmeasures will not be impacted, and may continue to be seen asvalid and effective in measuring insurers’ performance.6Insurance Accounting InsightsIt remains to be seen as to whether EV-based measures oraccounting-based measures will be regarded by insurers asmore relevant and effective in informing business decisions andperformance measurement.The Future will unfoldUndoubtedly, insurers will need to invest considerable amountof resources in order to comply with the detailed and complexIFRS reporting and disclosure requirements. We have observedinsurers taking this compliance exercise as an opportunity tomaximize the value of their investment by attempting to alsomodernize the operating model and reporting processes. It willbe beneficial for insurers to also keep the EV reporting in mindas they progress further in that journey, as to whether there arepotential synergies between IFRS 17 and EV from a production andreporting perspective, and whether a more coherent linkage canbe presented between accounting figures and EV metrics. After all,EV is not limited by the measurement objectives inherent in theaccounting models, and provides a more accurate view of insurer’scash generating capability. EV-based measures complement theaccounting-based measures, and provide another angle to bothinternal and external stakeholders to inform their decision-making.Investor appetite will affect the continuedexistence of EV reporting, and how muchvalue it still adds as a supplementalreporting framework.

Insurance Accounting InsightsIFRS 17 and Embedded Value Reporting Your contactsDarryl WagnerPartnerActuarial, Rewards & AnalyticsUnited States 1 860 725 3165dawagner@deloitte.comHui ShanSenior ManagerActuarial, Rewards & AnalyticsUnited States 1 860 725 3606hshan@deloitte.comGlobal IFRS Insurance networkFrancesco NagariGlobal IFRS Insurance LeaderChina 852 2852 1977fnagari@deloitte.co.ukEMEAAsia PacificThe AmericasThomas RingstedDenmark 45 27 14 20 44tringsted@deloitte.dkStuart AlexanderAustralia 61 2 9322 7155stalexander@deloitte.com.auLionel MoureArgentina 54 11 4320 2700lmoure@deloitte.comJerome LemierreFrance 33 1 55 31 40 78jlemierre@deloitte.frEric LuChina 86 10 8512 5809erilu@deloitte.com.cnJohn JohnstonBermuda 441 292 1301John.johnston@deloitte.bmColin SchenkeGermany 49 2118 7722404Cschenke@deloitte.deEtsuya WatanabeJapan 81 80 4341 5720Etsuyya.watanabe@tohmatsu.co.jpNeil HarrisonCanada1 416 601 6307nharrison@deloitte.caPeter TripeSouth Africa 27 21 427 5364ptripe@deloitte.co.zaArata OtakeJapan 81 90 6035 8857Arata.otake@tohmatsu.co.jpJavier VazquezMexico 52 555 080 6091javazquez@deloittemx.comJordi MontalboSpain 34 93 280 4040jmontalbo@deloitte.esShigeyuki GotoJapan 81 80 4601 0444shigeyuki.goto@tohmatsu.co.jpRajiv BasuUnited States 1 212 436 4808rbasu@deloitte.comEmel CanSwitzerland 41 58 279 7557emcan@deloitte.chRaj JutaSingapore 65 6800 2010rjuta@deloitte.comDarryl WagnerUnited States 1 860 725 3165dawagner@deloitte.comSung Ki JunSouth Korea 82 2 6676 1127sjun@deloitte.comRick SojkowskiUnited States 1 860 725 3094rsojkowski@deloitte.com7

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IFRS 17 requirements, but it is conceivable for insurers to quantify a TVOG as part of the expected PV of cash flows in order to capture the asymmetry of cash flows when optionalities exist in products. In order to assess the equity position under IFRS reporting, there are other IFRS standards in play such as IFRS 9 for financial instruments.

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