Draft Implementation Guidance
ED FRS INSURANCE CONTRACTS
Comments to be received by 30 September 2003
This draft Implementation Guidance accompanies the proposed Financial Reporting Standard (FRS) set out in ED FRS Insurance Contracts.
Comments on the draft FRS and its accompanying documents are most helpful if they indicate the specific paragraph or group of paragraphs to which they relate, clearly explain the problem and provide a suggestion for alternative wording with supporting reasoning.
Comments should be submitted in writing, so as to be received by 30September 2003, preferably by email to: or addressed to:
Council on Corporate Disclosure and Governance c/o Ministry of Finance
100 High Street #06-03
The Treasury
Singapore 179434
Fax: 6337 4134
Contents
ED FRS Insurance Contracts
[Draft] Implementation Guidance
paragraphs
INTRODUCTIONIG1
DEFINITION OF INSURANCE CONTRACT IG2
EMBEDDED DERIVATIVES IG3-4
UNBUNDLING A DEPOSIT COMPONENT IG5-6
DISCLOSUREIG7-61
Explanation of reported amounts IG7-30
Accounting policies IG7-8
Material assets, liabilities, income and expense IG9-18
Significant assumptions and other sources of measurement uncertaintyIG19-23
Changes in assumptions IG24-26
Changes in insurance liabilities and related items IG27-30
Amount, timing and uncertainty of future cash flows IG31-59
Risk management objectives and policies for mitigating insurance riskIG37
Terms and conditions of insurance contracts IG38-39
Insurance risk IG40
Sensitivity analysis IG41-43
Concentrations of insurance risk IG44-47
Claims development IG48-49
Interest risk and credit risk IG50-53
Material exposures to interest risk or market risk under embedded derivativesIG54-58
Key performance indicators IG59
Fair value of insurance liabilities and insurance assets IG60-61
LIST OF EXAMPLES
after paragraphs
1Application of the definition of an insurance contract IG2
2Embedded derivatives IG4
3Unbundling a deposit component of a reinsurance contract IG6
4Disclosure of claims development IG49
[Draft] Guidance on
implementing [draft] FRS X Insurance Contracts
This guidance accompanies, but is not part of, the [draft] FRS.
INTRODUCTION
IG1This implementation guidance:
(a)illustrates which contracts and embedded derivatives are subject to the [draft] FRS (see paragraphs IG2-IG4).
(b)includes an example of an insurance contract containing a deposit component that needs to be unbundled (paragraphs IG5 and IG6).
(c)discusses how an insurer might satisfy the disclosure requirements in the [draft] FRS (paragraphs IG7-IG61).
DEFINITION OF INSURANCE CONTRACT
IG2IG Example 1 illustrates the application of the definition of an insurance contract. The example does not illustrate all possible circumstances.
IG Example 1: Application of the definition of an insurance contractContract type / Treatment in phase I
1.1Insurance contract (see definition in Appendix A of the [draft] FRS and guidance in Appendix B). / Subject to the [draft] FRS, unless covered by scope exclusions in paragraph 4 of the [draft] FRS. Some embedded derivatives and deposit components must be separated (see below).
1.2Death benefit that could exceed amounts payable on surrender or maturity. / Insurance contract (unless contingent amount is insignificant in all plausible scenarios). Insurer could suffer a significant loss on an individual contract if the policyholder dies early.
1.3Life-contingent annuity. Insurance contract (unless contingent amount is insignificant in all plausible scenarios). / Insurer could suffer a significant loss on an individual contract if the annuitant survives longer than expected.
1.4Pure endowment. Policyholder receives a payment on survival to a specified date, but beneficiaries receive nothing if the policyholder dies before then. / Not an insurance contract unless there is a significant probability that the holder will not survive until the specified date. The contract provides a fixed payment with a small possibility of a significant gain for the issuer if the policyholder dies.
1.5Deferred annuity: policyholder will receive, or can elect to receive, a life-contingent annuity at rates guaranteed at inception. / Insurance contract. Insurer is exposed to significant mortality risk from inception, because it could suffer a significant loss on an individual contract if the annuitant elects to take the life-contingent annuity and survives longer than expected (unless the contingent amount is insignificant in all plausible scenarios).
1.6Deferred annuity: policyholder will receive, or can elect to receive, a life-contingent annuity at rates prevailing when the annuity begins. / Not an insurance contract at inception, if the insurer can reprice the mortality risk without constraints. Subject to FRS 39 Financial Instruments: Recognition and Measurement, unless the contract contains a discretionary participation feature.
Will become an insurance contract when the annuity rate is fixed (unless the contingent amount is insignificant in all plausible scenarios).
continued…
IG Example 1: Application of the definition of an insurance contract
Contract type / Treatment in phase I
1.7Investment contractthat does not contain a discretionary participation feature. / Subject to FRS 39.
1.8Investment contract containing a discretionary participation feature. / Paragraph 25 of the [draft] FRS sets out requirements for these contracts, which [would be] excluded from the scope of FRS 39.
1.9Investment contract in which payments are contractually linked (with no discretion) to returns on a specified pool of assets held by the issuer. / Subject to FRS 39. The link to the investment return creates an embedded derivative that typically requires separation.
1.10Contract that requires the issuer to make payments to a creditor if a specified debtor fails to make payment when due. The contract may have various legal forms (e.g. insurance contract, financial guarantee or letter of credit). / Insurance contract. Subject to the [draft] FRS, unless the contract arises from the derecognition of assets or liabilities.
If the issuer’s existing accounting policies do not require it to recognise a liability at inception, the loss recognition test in paragraphs 11-13 of the [draft] FRS applies.
The legal form of the contract does not affect its recognition and measurement.
1.11A financial guarantee that does not, as a precondition for payment, require that the holder is exposed to, and has incurred a loss on, the failure of the debtor to make payments on the guaranteed asset when due. / Not an insurance contract. Subject to FRS 39 (see FRS 39 Implementation Guidance IGC 1-2, IGC 1-5-a and IGC 1-5-b).
1.12A financial guarantee contract that provides for payments to be made in response to changes in a specified interest rate, security price, commodity price, credit rating or credit index, foreign exchange rate, index of prices or rates, or other variable, provided in the case of a non-financial variable that the variable is not specific to a party to the contract. / A derivative. Subject to FRS 39.
1.13Guarantee fund established by contract. The contract requires all participants to pay contributions to the fund so that it can meet obligations incurred by participants (and, perhaps, others). Participants would typically be from a single industry, e.g. insurance, banking or travel. / The contract that establishes the guarantee fund is an insurance contract (see 1.10 above).
1.14Guarantee fund established by law. The commitment of participants to contribute to the fund is not established by a contract, so there is no insurance contract. / Subject to FRS 37 Provisions, Contingent Liabilities and Contingent Assets.
1.15Residual value insurance or residual value guarantee. Guarantee by one party of the fair value at a future date of a non-financial asset held by a beneficiary of the insurance or guarantee. / Insurance contract subject to the [draft] FRS. The risk of changes in the fair value of the non-financial asset is not a financial risk because the fair value reflects not only changes in market prices for such assets (a financial variable) but also the condition of the specific asset held (a non-financial variable).
However, if the contract compensates the beneficiary only for changes in market prices and not for changes in the condition of the beneficiary’s asset, the contract is a derivative and subject to FRS 39.
Residual value guarantees given by a lessee under a finance lease are within the scope of FRS 17 Leases.
IG Example 1: Application of the definition of an insurance contract
Contract type / Treatment in phase I
1.16Product warranties issued directly by a manufacturer, dealer or retailer. / Insurance contracts, but excluded from scope (see FRS 18 Revenue and FRS 37 Provisions, Contingent Liabilities and Contingent Assets).
1.17Product warranties issued by a third party. / Insurance contracts, no scope exclusion. Same treatment as other insurance contracts.
1.18Group insurance contract that gives the insurer an enforceable and uncancellable contractual right to recover claims paid out of future premiums. / Insurance contract, if insurance risk is significant.
If insurance risk is insignificant, financial instrument subject to FRS 39. Servicing fees are subject to FRS 18 Revenue (recognise as services are provided, subject to various conditions, see paragraph 19 of FRS 18).
1.19Catastrophe bond: bond in which principal and/or interest payments are reduced if a specified triggering event occurs and the triggering event does not include a condition that the issuer of the bond suffered a loss. / Financial instrument with embedded derivative. [The current scope of FRS 39 excludes weather derivatives, but the [draft] FRS would remove this scope exclusion.] Both the holder and the issuer measure the embedded derivative at fair value.
1.20Catastrophe bond: bond in which principal and/or interest payments are reduced if a specified triggering event occurs and the triggering event includes a condition that the issuer of the bond suffered a loss. / The contract is an insurance contract, and contains an insurance contract component (with the issuer as policyholder and the holder as the insurer) and a deposit component.
(a)Paragraph 7 of the [draft] FRS requires the holder to unbundle the deposit component and apply FRS 39 to it.
(b)The issuer accounts for the insurance component as reinsurance if it uses the bond for that purpose. If the issuer does not use the insurance component as reinsurance, it is not within the scope of the [draft] FRS, which does not address accounting by policyholders for direct insurance contracts.
(c)Under paragraph 9 of the [draft] FRS, the holder could continue its existing accounting for the insurance component, unless that involves the practices prohibited by paragraph 10.
1.21A contract issued by an insurer to a defined benefit pension plan covering the employees of the insurer, or of another entity consolidated within the same financial statements as the insurer. / The contract will generally be eliminated from the financial statements, which will include:
(a)the full amount of the pension obligation under FRS 19 Employee Benefits, with no deduction for the plan’s rights under the contract.
(b)no liability to policyholders under the contract.
(c)the assets backing the contract.
EMBEDDED DERIVATIVES
IG3FRS 39 Financial Instruments: Recognition and Measurement requires an entity to separate embedded derivatives that meet specified conditions from the host instrument that contains them, measure the embedded derivatives at fair value and recognise changes in their fair value in profit or loss. However, an insurer need not separate an embedded derivative that itself meets the definition of an insurance contract (paragraph 5 of the [draft] FRS). Nevertheless, separation and fair value measurement of an embedded derivative are not prohibited if the insurer’s existing accounting policies require such separation, or if an insurer changes its accounting policies and that change meets the criteria in paragraph 14 of the [draft] FRS.
IG4IG Example 2 illustrates the treatment of embedded derivatives contained in insurance contracts and investment contracts. The term ‘investment contract’ is an informal term used for ease of discussion. It refers to a financial instrument that does not expose the issuer to significant insurance risk and so does not meet the definition of an insurance contract. The example does not illustrate all possible circumstances. Throughout the example, the phrase “fair value measurement is required” indicates that the issuer of the contract is required:
(a)to measure the embedded derivative at fair value and include changes in its fair value in profit or loss.
(b)to separate the embedded derivative from the host contract, unless it measures the entire contract at fair value and includes changes in that fair value in profit or loss.
IG Example 2: Embedded derivativesType of embedded derivative / Treatment if embedded in a host insurance contract / Treatment if embedded in a host investment contract
2.1Death benefit linked to equity prices or equity index, payable only on death or annuitisation and not on surrender or maturity. / The equity-index feature is an insurance contract, because the policyholder benefits from it only when the insured event occurs. Fair value measurement is not required (but not prohibited). / Not applicable. The entire contract is an insurance contract (unless the life-contingent payments are insignificant).
2.2Death benefit that is the greater of:
(a)unit value of an investment fund (equal to the amount payable on surrender or maturity); and
(b)guaranteed minimum. / Excess of guaranteed minimum over unit value is a death benefit (similar to the payout on a dual trigger contract, see 2.18 below).
This meets the definition of an insurance contract and fair value measurement is not required (but not prohibited). / Not applicable. The entire contract is an insurance contract (unless the life-contingent payments are insignificant).
2.3Option to take a life-contingent annuity at guaranteed rate (combined guarantee of interest rates and mortality charges). / The embedded option is an insurance contract. Fair value measurement is not required (but not prohibited). / Not applicable. The entire contract is an insurance contract (unless the life-contingent payments are insignificant).
2.4Embedded guarantee of minimum interest rates in determining surrender or maturity values that is out of the money (or at the money) on issue, and not leveraged. / Fair value measurement is not required (but not prohibited).
The guaranteed minimum is an embedded deposit component. However, an insurer is not required to unbundle contracts if the insurer’s existing accounting policies mean that it recognises all liabilities to pay benefits to policyholders (paragraph 8 of the [draft] FRS). This may be the case for many traditional life insurance contracts with surrender values. / Fair value measurement is not permitted (paragraph A7(b) of Appendix A of [draft] FRS 39).
2.5Embedded guarantee of minimum interest rates in determining surrender or maturity values: in the money on issue, or leveraged. / The embedded guarantee is not an insurance contract (unless the embedded guarantee is life-contingent). Fair value measurement is required (paragraph A4(b) of [draft] FRS 39). / Fair value measurement is required (paragraph A4(b) of [draft] FRS 39).
2.6Embedded guarantee of minimum rates of annuity payments if the annuity payments are contractually linked to investment returns or asset prices (GMIB or guaranteed minimum income benefit):
continued…
IG Example 2: Embedded derivatives
Type of embedded derivative / Treatment if embedded in a host insurance contract / Treatment if embedded in a host investment contract
(a)guarantee relates only to payments that are life-contingent. / The embedded guarantee is an insurance contract and fair value measurement is not required (but not prohibited). / Not applicable. The entire contract is an insurance contract (unless the life-contingent payments are insignificant).
(b)guarantee relates only to payments that are not life-contingent. / The embedded derivative is not an insurance contract.
Fair value measurement is required (unless the guarantee is an unleveraged interest floor that is at or out of the money at inception). / Fair value measurement is required (unless the guarantee is an unleveraged interest floor that is at or out of the money at inception).
(c)policyholder can elect to receive life-contingent payments or payments that are not life contingent, and the guarantee relates to both. / The embedded option to receive life-contingent payments is an insurance contract. Fair value measurement is not required (but not prohibited).
The embedded option to receive payments that are not life-contingent is not an insurance contract. Fair value measurement is generally required. Because this option and the life-contingent option are alternatives, their fair values are interdependent.
If the insurer cannot measure reliably the fair value of the embedded non-insurance option, it measures the whole contract at fair value (paragraph 26 of [draft] FRS 39). / Not applicable. The entire contract is an insurance contract (unless the life-contingent payments are insignificant).
2.7Embedded guarantee of minimum equity returns on surrender or maturity. / The embedded guarantee is not an insurance contract (unless the embedded guarantee is life-contingent) and is not closely related to the host insurance contract.
Fair value measurement is required. / Fair value measurement is required.
2.8Equity-linked return available on surrender or maturity. / The embedded derivative is not an insurance contract (unless the equity-linked return is life-contingent) and is not closely related to the host insurance contract. Fair value measurement is required. / Fair value measurement is required.
2.9Embedded guarantee of minimum equity returns that is available only if the policyholder elects to take a life-contingent annuity. / The embedded guarantee is an insurance contract, as the policyholder can benefit from the guarantee only by taking the annuity option (whether annuity rates are set at inception or at the date of annuitisation). Fair value measurement is not required (but not prohibited). / Not applicable. The entire contract is an insurance contract (unless the life-contingent payments are insignificant).
continued…
IG Example 2: Embedded derivatives
Type of embedded derivative / Treatment if embedded in a host insurance contract / Treatment if embedded in a host investment contract
2.10Embedded guarantee of minimum equity returns available to the policyholder as either (a) a cash payment, (b) a period-certain annuity or (c) a life-contingent annuity, at annuity rates prevailing at the date of annuitisation. / The option to take the life-contingent annuity does not create insurance risk until the policyholder opts to take the annuity. Therefore, the embedded guarantee is not an insurance contract and is not closely related to the host investment contract. Fair value measurement is required. / Fair value measurement is required.
2.11Embedded guarantee of minimum equity returns available to the policyholder as either (a) a cash payment (b) a period-certain annuity or (c) a life-contingent annuity, at annuity rates set at inception. / The whole contract is an insurance contract from inception. The option to take the life-contingent annuity is an embedded insurance contract, so fair value measurement is not required (but not prohibited).
The option to take the cash payment or the period-certain annuity is an embedded derivative and is not an insurance contract, so it must be separated. Because this option and the life-contingent option are alternatives, their fair values are interdependent. If the insurer cannot measure reliably the fair value of the embedded non-insurance option, it measures the whole contract at fair value. / Not applicable.
2.12Policyholder option to surrender a contract for a cash surrender value specified in a schedule (i.e. not indexed and not accumulating interest). / Fair value measurement is not required (but not prohibited: paragraph 6 of the [draft] FRS).
The [draft] FRS does not require an insurer to unbundled the surrender value in a traditional life insurance contract (paragraph 8). / The surrender option is closely related to the host contract if the surrender value is approximately equal to the carrying amount at each exercise date (paragraph A4(g) of [draft] FRS 39). Otherwise, the surrender option is measured at fair value.
2.13Policyholder option to surrender a contract for account value based on a principal amount and a fixed or variable interest rate (or based on the fair value of a pool of interest-bearing securities), possibly after deducting a surrender charge. / Same as for a cash surrender value (2.12). / Same as for a cash surrender value (2.12).
2.14Policyholder option to surrender a contract for a surrender value based on an equity or commodity price or index. / Fair value measurement is required (paragraph 5 of the [draft] FRS). / Fair value measurement is required (paragraph A4(d) and (e) of [draft] FRS 39).
2.15Policyholder option to surrender a contract for account value based on the fair value of a pool of equity investments, possibly after deducting a surrender charge. / Same as for a surrender value based on an equity price or index (2.14). / Same as for a surrender value based on an equity price or index (2.14).
continued…
IG Example 2: Embedded derivatives
Type of embedded derivative / Treatment if embedded in a host insurance contract / Treatment if embedded in a host investment contract
2.16Persistency bonus paid at maturity in cash (or as a period-certain annuity). / The embedded derivative (option to receive the persistency bonus) is not an insurance contract (unless the persistency bonus is life-contingent). Insurance risk does not include lapse or persistency risk (paragraph B15 of the [draft] FRS). Fair value measurement is not required (but not prohibited). / An option or automatic provision to extend the remaining term to maturity of a debt instrument is not closely related to the host debt instrument unless there is a concurrent adjustment to the approximate current market rate of interest at the time of the extension (paragraph A4(c) of [draft] FRS 39). If the option or provision is not closely related to the host instrument, fair value measurement is required.
2.17Persistency bonus paid at maturity in the form of an enhanced life-contingent annuity. / The embedded derivative is an insurance contract. Fair value measurement is not required (but not prohibited). / Not applicable. The entire contract is an insurance contract (unless the life-contingent payments are insignificant).
2.18Dual trigger contract, e.g. payment that is contingent on a breakdown in power supply that adversely affects the holder (first trigger) and a specified level of electricity prices (second trigger). / The embedded derivative is an insurance contract.
A contract that qualifies as an insurance contract, whether at inception or later, remains an insurance contract until all rights and obligations are extinguished or expire (paragraph B25 of the [draft] FRS). Therefore, although the remaining exposure is similar to a financial derivative after the insured event has occurred, the embedded derivative is still an insurance contract and fair value measurement is not required (but not prohibited). / Not applicable. The entire contract is an insurance contract (unless the contingent payments are insignificant).
UNBUNDLING A DEPOSIT COMPONENT