developments in deferred acquisition costs (dac) for variable annuities secession 59pd - may 29,...
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Developments in
Deferred Acquisition Costs (DAC) for
Variable Annuities
Secession 59PD - May 29, 2003
Developments in
Deferred Acquisition Costs (DAC) for
Variable Annuities
Secession 59PD - May 29, 2003
Bradley Barks, FSA, CPA, MAAACFO and Senior Vice PresidentGlobal Preferred Holdings, Inc.
Bradley Barks, FSA, CPA, MAAACFO and Senior Vice PresidentGlobal Preferred Holdings, Inc.
Presentation SummaryPresentation Summary
I. Recent Results of Public CompaniesII. Comparison of Methods to Address Equity
Market VolatilityIII. Sales Inducements - Long Duration SOPIV. Loss Recognition IssuesV. Internal Replacements SOP
I. Recent Results of Public CompaniesII. Comparison of Methods to Address Equity
Market VolatilityIII. Sales Inducements - Long Duration SOPIV. Loss Recognition IssuesV. Internal Replacements SOP
Recent Results of Public CompaniesRecent Results of Public Companies
Recent Results of Public CompaniesRecent Results of Public Companies
Summary
Methods and Assumptions DAC “Adjustments”
Summary
Methods and Assumptions DAC “Adjustments”
Recent Results of Public CompaniesMethods & Assumptions
Recent Results of Public CompaniesMethods & Assumptions
(in millions unless otherwise stated)
Company (Symbol) Method
Long Term Yield
AssumptionYield
Limitations
Years Yield Adjustments
Made
Underlying Assets
(in billions)Aegon (AEG) (US Business)
Mean Reversion 9%; 9.5% prior to 4Q02
12%; 14.5% prior to 4Q02
5 € 31
Allmerica (AFC) Mean Reversion 8% 12% 5
American International Group (AIG)
Traditional NA NA NA
Hartford Financial Services (HFS)
Traditional: unless "the present value of future gross profits" falls outside a reasonable range.
9% NA NA $64
John Hancock (JHF) Mean Reversion 8%; 9% prior to 4Q02
13%; mid-teens prior to 4Q02
5 $30
Lincoln National (LNC) Mean Reversion 9%; 14% prior to 4Q02
1% and 14.5% 8.6 $34
Met Life (MET) Mean Reversion
Nationwide (NFS) Mean Reversion 8% 0% and 15% 3 $32
Prudential (PRU) Modified Mean Reversion 9% < 15% 4 $15
Source is from 12/31/2002 Form 10K or 20-F and Insurance Industry Analyst Reports
Recent Results of Public CompaniesAdjustments to DAC Balances
Recent Results of Public CompaniesAdjustments to DAC Balances
(in millions unless otherwise stated) Adjustments to DAC for Year ended 12/31/2002
Company (Symbol)
Total Due to Equity Market
Decline
Total for Variable Products
Total for Variable Annuities
Total Reduction in
Income Due to Equity Market
Decline
Total DAC Balance at
12/31/02 (in billions)
2002 DAC Adjustments as
% of Consolidated DAC Balance
Aegon (AEG) (US Business)
€ 450 € 14.089 3.10%
Allmerica (AFC) $629 $698 $1.242 33.63%
American International Group (AIG)Hartford Financial Services (HFS)
$0 $6.689 0.00%
John Hancock (JHF) $64 $49 $36 $3.996 1.58%Lincoln National (LNC) $89 $49 $2.971 2.91%Met Life (MET) $111 $11.727 0.94%
Nationwide (NFS) $347 $328 $3.027 10.29%
Prudential (PRU) $137 $7.031 1.91%
Source is from 12/31/2002 Form 10K or 20-F and Insurance Industry Analyst Reports
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Summary
Basis of Long-term Assumptions and Methods How Far Out on the Tail Are We? How Bad Might It Be 5 to 10 Years from Issue? “Ideal Method” – Achieves Best Matching Comparison of Methods to the “Ideal”
Summary
Basis of Long-term Assumptions and Methods How Far Out on the Tail Are We? How Bad Might It Be 5 to 10 Years from Issue? “Ideal Method” – Achieves Best Matching Comparison of Methods to the “Ideal”
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
0
50
100
150
200
-90% -60% -30% 0% 30% 60% 90% 120% 150%
Annualized S&P 500 Return
3 Month
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
0
50
100
150
200
-90% -60% -30% 0% 30% 60% 90% 120% 150%
Annualized S&P 500 Return
1 Year
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
0
50
100
150
200
-90% -60% -30% 0% 30% 60% 90% 120% 150%
Annualized S&P 500 Return
3 Year
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
0
50
100
150
200
-90% -60% -30% 0% 30% 60% 90% 120% 150%
Annualized S&P 500 Return
5 year
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
0
50
100
150
200
-90% -60% -30% 0% 30% 60% 90% 120% 150%
Annualized S&P 500 Return
7 Year
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
0
50
100
150
200
-90% -60% -30% 0% 30% 60% 90% 120% 150%
Annualized S&P 500 Return
10 Year
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
S&P 500 Index
0
500
1,000
1,500
200219921982197219621952
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
0
100
200
-90% -60% -30% 0% 30% 60% 90% 120% 150%
3 Year
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Hypothetical Fund Value (Starting at 8/1/00)
$0$2,000$4,000$6,000$8,000
$10,000
2000 2002 2004 2006 2008 2010
Worst 5yrs Worst 10yrs S&P 500
4.17% return 2.83% return
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Principles of Amortization Methods
Match Revenue and Expense Revenue is EGP Expense is DAC (GMDB, Sales Inducements) Problem: We don’t know what the future EGPs
will be AND they are extremely volatile in the short-term but less volatile in the long-term.
Principles of Amortization Methods
Match Revenue and Expense Revenue is EGP Expense is DAC (GMDB, Sales Inducements) Problem: We don’t know what the future EGPs
will be AND they are extremely volatile in the short-term but less volatile in the long-term.
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
How to Compare Different Methods?
If we knew what the EGPs would be, we would have a perfect match of Revenue and Expense.
The Ideal Method would be the “Crystal Ball” Method
Comparison Can Be Made Relative to The “Crystal Ball” Method.
How to Compare Different Methods?
If we knew what the EGPs would be, we would have a perfect match of Revenue and Expense.
The Ideal Method would be the “Crystal Ball” Method
Comparison Can Be Made Relative to The “Crystal Ball” Method.
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Numerical Comparisons
Assumptions Single Premium $10,000 Avg. Long-term Fund Performance
9% M&E Charges 140 b.p. Expenses 50 b.p. Issue Expenses 7% of Prem. Surrender Charges 7%,6%,5%,4%,3%,2%,1%,0% thereafter Surrender Rates 4% except 15% in year 8
Numerical Comparisons
Assumptions Single Premium $10,000 Avg. Long-term Fund Performance
9% M&E Charges 140 b.p. Expenses 50 b.p. Issue Expenses 7% of Prem. Surrender Charges 7%,6%,5%,4%,3%,2%,1%,0% thereafter Surrender Rates 4% except 15% in year 8
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Numerical Comparisons
Summary of Methods Crystal Ball – Assumes that actual gross profits were known at
issue. Results in perfect matching. Traditional Method – Assumes that expected gross profits are
based on the current fund value projected at the average long-term fund performance rate.
Mean Reversion (modified for simplicity) – Traditional method except that the average long-term fund performance rate is increased or decreased to a cap (14%) or floor (0%) until the FV equals the FV projected at issue. Thereafter, the average long-term fund performance rate is used.
Credibility Method – Assumes that EGPs projected at each valuation date are given 10% weight with the the rest of the weight given to the original EGPs. All EGPs given equal weight after year 10.
Numerical Comparisons
Summary of Methods Crystal Ball – Assumes that actual gross profits were known at
issue. Results in perfect matching. Traditional Method – Assumes that expected gross profits are
based on the current fund value projected at the average long-term fund performance rate.
Mean Reversion (modified for simplicity) – Traditional method except that the average long-term fund performance rate is increased or decreased to a cap (14%) or floor (0%) until the FV equals the FV projected at issue. Thereafter, the average long-term fund performance rate is used.
Credibility Method – Assumes that EGPs projected at each valuation date are given 10% weight with the the rest of the weight given to the original EGPs. All EGPs given equal weight after year 10.
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Crystal Ball Method Level 9%
$0
$50
$100
$150
$200
$250
1 6 11 16 21 26
Year
Gross Profit Crystal Ball
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Crystal Ball Method S&P - 1995-2002
$0
$50
$100
$150
$200
$250
1 6 11 16 21 26
Year
Gross Profit Crystal Ball
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods S&P - 1995-2002
$0
$20
$40
$60
$80
$100
$120
$140
$160
$180
1 6 11 16 21 26Year
Crystal Ball Mean Reversion Credibility Traditional
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Numerical Comparisons
Observations: Crystal Ball – Results in perfect matching. Overall
All methods perform well when market performance is constant. 75% of the 12–month periods had returns greater than 15% or less
than 5%. 85% of 3-month periods were outside of this range. (Using S&P 500 for periods starting at beginning of the month from
1950 thru 2002.) Traditional Method –Results in very poor matching in volatile
markets. Mean Reversion – Effectively dampens poor matching
associated with the Traditional method. Tends to become volatile toward end of amortization period.
Credibility Method – Good matching over entire amortization period.
Numerical Comparisons
Observations: Crystal Ball – Results in perfect matching. Overall
All methods perform well when market performance is constant. 75% of the 12–month periods had returns greater than 15% or less
than 5%. 85% of 3-month periods were outside of this range. (Using S&P 500 for periods starting at beginning of the month from
1950 thru 2002.) Traditional Method –Results in very poor matching in volatile
markets. Mean Reversion – Effectively dampens poor matching
associated with the Traditional method. Tends to become volatile toward end of amortization period.
Credibility Method – Good matching over entire amortization period.
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods Alternate between 5% and 15%
$0
$20
$40
$60
$80
$100
$120
1 6 11 16 21 26Year
Crystal Ball Mean Reversion Credibility Traditional
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods to Address Equity Market Volatility
Comparison of Methods Level 7%
$0
$10
$20
$30
$40
$50
$60
$70
$80
$90
$100
1 6 11 16 21 26Year
Crystal Ball Mean Reversion Credibility Traditional
Sales Inducements to Contract Holders - Non-traditional Long-duration
Statement of Position (NTLD SOP)
Sales Inducements to Contract Holders - Non-traditional Long-duration
Statement of Position (NTLD SOP)
Sales Inducements - NTLD SOPSales Inducements - NTLD SOP
Summary Definition of Sales Inducements Accounting Treatment Disclosures Effective Date and Transition
Summary Definition of Sales Inducements Accounting Treatment Disclosures Effective Date and Transition
Sales Inducements - NTLD SOPSales Inducements - NTLD SOP
Definition Insurer must demonstrate that amounts are
Incremental to amounts credited on similar contracts without sales inducements, AND
Higher than the contract’s expected ongoing crediting rates for periods beyond the inducement, as applicable, AND
Must be part of the original contract Examples: Day-one bonus, persistency bonus,
enhanced credited rate Applies to UL and Investment Contracts
(Deferred Annuities)
Definition Insurer must demonstrate that amounts are
Incremental to amounts credited on similar contracts without sales inducements, AND
Higher than the contract’s expected ongoing crediting rates for periods beyond the inducement, as applicable, AND
Must be part of the original contract Examples: Day-one bonus, persistency bonus,
enhanced credited rate Applies to UL and Investment Contracts
(Deferred Annuities)
Sales Inducements - NTLD SOPSales Inducements - NTLD SOP
Accounting Treatment Recognized as part of the liability for policy
benefits Cannot reflect surrenders in determining
amounts to defer or amounts included in Liability for Policy Benefits
Deferred and amortized New item: “Deferred Sales Inducements” Amortization same methodology and assumptions as
DAC Amortization is included as a component of benefit
expense Surrender assumption is included in
amortization.
Accounting Treatment Recognized as part of the liability for policy
benefits Cannot reflect surrenders in determining
amounts to defer or amounts included in Liability for Policy Benefits
Deferred and amortized New item: “Deferred Sales Inducements” Amortization same methodology and assumptions as
DAC Amortization is included as a component of benefit
expense Surrender assumption is included in
amortization.
Sales Inducements - NTLD SOPSales Inducements - NTLD SOP
Disclosure Requirements
Nature of costs capitalized and amortization method
Amounts capitalized and amortized Unamortized balances
Disclosure Requirements
Nature of costs capitalized and amortization method
Amounts capitalized and amortized Unamortized balances
Sales Inducements - NTLD SOPSales Inducements - NTLD SOP
Transition Rules and Effective Date
Effective for fiscal years beginning after December 15, 2003
Initial costs deferred prior to adoption are not adjusted
Unamortized balances amortized according to SOP at initial application
Cannot retroactively capitalize sales inducements not previously deferred
Prospective No cumulative effects Must Adopt Retroactive to Beginning of a Fiscal
Year
Transition Rules and Effective Date
Effective for fiscal years beginning after December 15, 2003
Initial costs deferred prior to adoption are not adjusted
Unamortized balances amortized according to SOP at initial application
Cannot retroactively capitalize sales inducements not previously deferred
Prospective No cumulative effects Must Adopt Retroactive to Beginning of a Fiscal
Year
Loss Recognition IssuesLoss Recognition Issues
Loss Recognition IssuesLoss Recognition Issues
Summary
Impact of GMDB Cost Sales Inducements Effect: Loss Recognition is permanent
vs. DAC unlocking can be recaptured
Summary
Impact of GMDB Cost Sales Inducements Effect: Loss Recognition is permanent
vs. DAC unlocking can be recaptured
Proposed SOP: Deferred Acquisition Costs On Internal Replacements
Proposed SOP: Deferred Acquisition Costs On Internal Replacements
DAC on Internal ReplacementsDAC on Internal Replacements
Summary
Background Supporting Literature Definition of Internal Replacement Accounting Treatment Effective Date and Transition
Summary
Background Supporting Literature Definition of Internal Replacement Accounting Treatment Effective Date and Transition
DAC on Internal ReplacementsDAC on Internal Replacements
Background Proposed Statement of Position released 3/14/03 Comments Due 5/14/03 Applies to DAC, Unearned Revenue Liability and Sales
Inducements Note: Sales Inducements incurred because of a
modification (i.e., were not contemplated in the original contract) can be deferred if the new contract is “Not Substantially Different.” (Contrary to NTLD - SOP)
FINAL STATEMENT MAY CHANGE
Background Proposed Statement of Position released 3/14/03 Comments Due 5/14/03 Applies to DAC, Unearned Revenue Liability and Sales
Inducements Note: Sales Inducements incurred because of a
modification (i.e., were not contemplated in the original contract) can be deferred if the new contract is “Not Substantially Different.” (Contrary to NTLD - SOP)
FINAL STATEMENT MAY CHANGE
DAC on Internal ReplacementsDAC on Internal Replacements
Supporting Literature SFAS 60, Par. 28 SFAS 97, Par. 26,70-72 AICPA Practice Bulletin #8 (11/90) SFAS 91-Accounting for Non-refundable Fees and Costs
Associated with Originating and Acquiring Loans and Indirect Costs of Leases
SFAS 120 – Accounting and Reporting by Mutual Life Insurance Enterprises and for Certain Participating Contracts
SFAS 140 – Accounting for Transfers and Servicing of Financial Assets and Extinguishment of Liabilities
EITF # 96-19 – Guidance on Extinguishment of Debt Instruments
Supporting Literature SFAS 60, Par. 28 SFAS 97, Par. 26,70-72 AICPA Practice Bulletin #8 (11/90) SFAS 91-Accounting for Non-refundable Fees and Costs
Associated with Originating and Acquiring Loans and Indirect Costs of Leases
SFAS 120 – Accounting and Reporting by Mutual Life Insurance Enterprises and for Certain Participating Contracts
SFAS 140 – Accounting for Transfers and Servicing of Financial Assets and Extinguishment of Liabilities
EITF # 96-19 – Guidance on Extinguishment of Debt Instruments
DAC on Internal ReplacementsDAC on Internal Replacements
Definition of Internal Replacement: Modification of the Contract “Substantially Different” “Inherent Nature” Changed
Definition of Internal Replacement: Modification of the Contract “Substantially Different” “Inherent Nature” Changed
DAC on Internal ReplacementsSchematic of Statement Of Position
DAC on Internal ReplacementsSchematic of Statement Of Position
Is the Is the Modification an Modification an
Internal Internal Replacement?Replacement?
NoNo
YeYess
Is at least one of the Is at least one of the criteria of criteria of
“substantially “substantially different” (Par. 11) different” (Par. 11)
met? Also use met? Also use examples in Par. 13-18.examples in Par. 13-18.
““Not Not Substantially Substantially
Different” Different” Accounting Accounting TreatmentTreatment
YeYess
NoNo
““Substantially Different” Substantially Different” Accounting TreatmentAccounting Treatment
Is there a Is there a Modification to Modification to the Contract?the Contract?
NoNo
YeYess
DAC on Internal ReplacementsDAC on Internal Replacements
Modifications not considered an Internal Replacement Both Contemplated in the Original Contract AND
Does Not Change the Inherent Nature of the Contract
Examples in the SOP (Safe Harbors): Changes in Rates or Charges within Ranges Outlined in
Original Contract without Changes in Benefits Changes in Allocations among investment alternatives
(100% allocation is all right) Addition of Investment Alternative (only if Contract
already has multiple alternatives) Election of an Inflation Adjustment Benefit Purchasing Paid-Up Additions
Modifications not considered an Internal Replacement Both Contemplated in the Original Contract AND
Does Not Change the Inherent Nature of the Contract
Examples in the SOP (Safe Harbors): Changes in Rates or Charges within Ranges Outlined in
Original Contract without Changes in Benefits Changes in Allocations among investment alternatives
(100% allocation is all right) Addition of Investment Alternative (only if Contract
already has multiple alternatives) Election of an Inflation Adjustment Benefit Purchasing Paid-Up Additions
DAC on Internal ReplacementsDAC on Internal Replacements
“Not Substantially Different” (must meet all conditions)
No additional deposit, premium or charge is required above amounts contemplated in the contract
No net decrease in Policy Balances No change from SFAS 60 to SFAS 97 or to
SFAS91 or visa versa New Benefit does not become Primary Benefit Modification does not change “Inherent Nature”
of Contract (more subjective)
“Not Substantially Different” (must meet all conditions)
No additional deposit, premium or charge is required above amounts contemplated in the contract
No net decrease in Policy Balances No change from SFAS 60 to SFAS 97 or to
SFAS91 or visa versa New Benefit does not become Primary Benefit Modification does not change “Inherent Nature”
of Contract (more subjective)
DAC on Internal ReplacementsDAC on Internal Replacements
“Inherent Nature” of Contract Consider any change including rider, amendment,
exchange of contract or “election of a feature within an existing contract”
Most significant Factors Kind and Degree of Mortality or Morbidity Risk Rights and Provisions for Determining Investment
Return
Legal Form of Change does not matter “Election of Existing Feature” may be Problematic
“Inherent Nature” of Contract Consider any change including rider, amendment,
exchange of contract or “election of a feature within an existing contract”
Most significant Factors Kind and Degree of Mortality or Morbidity Risk Rights and Provisions for Determining Investment
Return
Legal Form of Change does not matter “Election of Existing Feature” may be Problematic
DAC on Internal ReplacementsDAC on Internal Replacements
“Inherent Nature” – Safe Harbors (examples) Additional Investment Alternatives (same as
above) Addition of MVA provision (change only effects
surrender charge) Addition of LTC Rider to Disability Contract (No
Change in Primary Benefit) Addition of Enhancement of GMIB, GMAB or
Annuitization Guarantee (Only Affects Benefits After Termination)
“Inherent Nature” – Safe Harbors (examples) Additional Investment Alternatives (same as
above) Addition of MVA provision (change only effects
surrender charge) Addition of LTC Rider to Disability Contract (No
Change in Primary Benefit) Addition of Enhancement of GMIB, GMAB or
Annuitization Guarantee (Only Affects Benefits After Termination)
DAC on Internal ReplacementsDAC on Internal Replacements
“Inherent Nature” – Failures (examples) Replace Term Life with Whole Life (adding
Significant Component) Add GMDB to Contract with Insignificant Death
Benefit or Visa Versa Replace Disability Contract with LTC Contract
(Changes nature of Morbidity Risk) Replace UL with Life Contingent Payout Annuity Change from Discretionary to Formulaic
Investment Crediting Methodology Replacement of Variable Contract with Fixed
Contract or Visa Versa
“Inherent Nature” – Failures (examples) Replace Term Life with Whole Life (adding
Significant Component) Add GMDB to Contract with Insignificant Death
Benefit or Visa Versa Replace Disability Contract with LTC Contract
(Changes nature of Morbidity Risk) Replace UL with Life Contingent Payout Annuity Change from Discretionary to Formulaic
Investment Crediting Methodology Replacement of Variable Contract with Fixed
Contract or Visa Versa
DAC on Internal ReplacementsDAC on Internal Replacements
Transition
Effective Date: For Replacements in Fiscal Years beginning on or after December 15, 2003
Prospectively applied Prior balances should not be adjusted prior to
year of adoption Must Adopt Retroactive to Beginning of a Fiscal
Year
Transition
Effective Date: For Replacements in Fiscal Years beginning on or after December 15, 2003
Prospectively applied Prior balances should not be adjusted prior to
year of adoption Must Adopt Retroactive to Beginning of a Fiscal
Year