Appointed actuary thematic review

Appointed actuaries have an important statutory role in the New Zealand prudential supervision regime for insurers, with a connection to all three pillars of supervision. The appointed actuary’s independent advice to boards on the financial condition and solvency of insurers assists the self-discipline pillar. The appointed actuary’s section 78 report that is required to be attached to annual financial statements assists the market discipline pillar. The appointed actuary’s sign-off of solvency reporting, annual financial condition report, and whistle-blowing requirements assists the regulatory discipline pillar.

Over the past few years the Reserve Bank has stated its intention to undertake a thematic review of the appointed actuary regime. The review is now in progress. The objectives are to:

  1. better understand how the appointed actuary role works in practice for insurers, actuaries and supervisors; and
  2. identify potential areas for improvement (e.g. policy changes or guidance) to make the role and regime more effective for insurers, actuaries and the Reserve Bank. Note any policy changes will require consultation.

We received much constructive and useful feedback on the draft plans for the review from insurers, actuaries, and other stakeholders. Some aspects of feedback have been incorporated into the finalised plans, while other feedback will assist our ongoing supervision and the IPSA review.

Contact the Thematic Review team

Email: insurancethematicreview@rbnz.govt.nz.

Submit documents using our insurer secure upload facility and select “Insurer thematic review” in the submission drop-down list.

Overview of how we will conduct the review

This description is a high-level overview of our finalised plans for the review, following discussion and feedback on our draft plans. Our plans may need revising as the review progresses. We will advise if there are any substantial changes.

Confidentiality

  • The review is subject to confidentiality provisions under section 135 of the Insurance (Prudential Supervision) Act 2010.
  • Public feedback will not disclose information specific to any insurer or actuary.
  • To promote open dialogue with us, we also undertake to be careful and sensitive in dealing with any information given in confidence. This includes private feedback.

What are we looking at?

  • Purpose of the appointed actuary statutory role.
  • How does the appointed actuary fulfil their statutory role?
  • How effective is the appointed actuary?
  • How do they engage with the board, senior management, the parent or group (if applicable), auditors, RBNZ?
  • The insurer’s processes for appointment, absences and replacement.
  • Suggestions for improvements.

Taking part in the review

  • 15 insurers and their appointed actuaries are selected to participate in the review. They cover a wide range of circumstances.
  • We are also in regular contact with industry and actuarial bodies, and other regulators. Some people may wish to provide anonymous feedback through their industry or actuarial bodies.
  • Other stakeholders can provide input on a voluntary basis using our email and upload facility (the contact details are set out above).

Information required

  • The selected insurers and their appointed actuaries are required to complete short fact-based surveys, and some insurers will also be required to provide some relevant documents. For transparency we have set these out below.
  • The selected insurers will receive a cover letter and a section 121 notice specifying the required information and due date (generally 7 June 2019).
 PDF  Specified documents to be supplied
 XLS  Survey for insurer
 XLS  Survey for their appointed actuary

Desk-based review (June – July 2019)

  • We will prepare for the on-site visits by considering the information supplied, and relevant existing information and reporting.
  • For some insurers this will include a review of the key reporting by the appointed actuary provided to RBNZ – namely the financial condition report, solvency return, and section 78 report.

On-site visits (August – October 2019)

  • We will endeavour to schedule the on-site visits to minimise inconvenience. For example, we’ll try to avoid busy periods around balance dates and when responses to our conduct & culture thematic review are due.
  • For each selected insurer we will have a series of meetings over two days at their premises. We will have separate meetings with the appointed actuary and the key people we expect they regularly interact with. This includes (as applicable) a couple of directors, CEO, CFO, CRO.
  • The discussion will include questions we have prepared as well as an open invite for feedback on the appointed actuary regime and any suggestions for improvement. See indicative agenda below:
    • RBNZ introduction, confidentiality
    • Opportunity for any feedback, comments, suggestions
    • RBNZ questions
    • Further comments, closing

Timeline

March – April 2019

  • Meetings with industry and stakeholder groups to discuss the draft plans for the review and seek feedback.

May 2019

  • Published finalised plans on this page.
  • Issue letters and information requests for the insurers and appointed actuaries selected to participate in the review.

June– July 2019

  • Desk-based review by RBNZ.

August – October 2019

  • On-site visits for the selected insurers and appointed actuaries.

November – December 2019

  • We will compare across insurers and appointed actuaries to identify good practices and weaknesses.
  • We will consider other statutory actuarial regimes for insurers (e.g. in Australia).
  • We will consider areas for improvement to address identified weaknesses or issues.
  • We will have regard to the diversity in the sector.

February – March 2020

  • Publish a report with generalised findings, good practices, and suggestions for possible changes to the appointed actuary regime.
  • The selected insurers will also get private feedback on how they compare generally as well as any specific concerns for them.
  • We will meet with industry to discuss.
  • RBNZ policy and supervision teams to consider the suggestions. There will be consultation for any policy changes.