japan’s insurance market - toare.co.jp · pdf filetrends in the insurance business law...
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To Our ClientsTeruhiko Ohtani
President and Chief Executive, The Toa Reinsurance Company, Limited 1
1. Trends in Japan’s Non-Life Insurance Industry and Aioi’s Management StrategiesTadashi Kodama
Representative Director and President, Aioi Insurance Co., Ltd. 2
2. Trends in the Insurance Business Law and Related Legislation - The Events of Fiscal 2007 - Masaaki Oishi
President and CEO, Center for Insurance Studies in Japan (CIS) 12
3. Lessons from Solvency II for the Japanese Insurance MarketJames Vickers
Chairman, Willis Re International 21
4. CSR in Japanese Corporations and the Trend in the Insurance IndustryMitsuo Ogawa
President, Craig Consulting 30
5. Trends in Japan’s Non-Life Insurance IndustryUnderwriting & Planning Department
The Toa Reinsurance Company, Limited 37
6. Trends in Japan’s Life Insurance IndustryLife Underwriting & Planning Department
The Toa Reinsurance Company, Limited 41
Supplemental Data : Results of Japanese listed non-life insurance companies
for fiscal 2007, ended March 31, 2008 48
Japan’s Insurance Market 2008
Contents Page
©2008 The Toa Reinsurance Company, Limited. All rights reserved. The contents may be reproduced only with the written permis-sion of The Toa Reinsurance Company, Limited.
1
Teruhiko OhtaniPresident and Chief Executive,The Toa Reinsurance Company, Limited
To Our Clients
It gives me great pleasure to have the opportunity to welcome you to our 2008 brochure, which is now
in its twelfth year. It is encouraging to know that over the years our brochures have been well received even
beyond our own industry's boundaries as a source of useful, up-to-date information about Japan's insurance
market, as well as contributing to a wider interest in and understanding of our domestic market.
During fiscal 2007, the year ended March 31, 2008, the Japanese economy continued to grow at a mod-
est pace supported by improved corporate earnings and an increase in capital investment. However, declining
residential investment and soaring energy and raw material prices put a brake on the Japanese economy
toward the end of the fiscal year.
In the non-life insurance industry in Japan, while economic growth had a positive impact on premium
income from marine insurance for corporate customers, premium income from mainstay motor insurance
and fire insurance was sluggish because of declines in automobile sales and housing starts.
In the reinsurance market, although reinsurance premium rates continued to soften somewhat during
the year under review, many reinsurance companies recorded favorable results because there were relatively
few major disasters around the world.
The environment surrounding Toa Re is being transformed by the increasing complexity of risks posed
by climate change, as well as structural changes in the Japanese non-life insurance industry, including the cre-
ation of a scheme for small-claims short-term insurance providers, and trends in the international regulatory
environment for reinsurance.
By responding to these changes in the business environment in a timely and effective manner, Toa Re is
vigorously developing business based on appropriate risk management in non-life reinsurance, which is our
mainstay business, as well as in life reinsurance and co-operative reinsurance, where we are strengthening our
position in a bid to diversify sources of profit and to expand the scope of our business.
In PROCEED 2008, the medium-term management plan launched in fiscal 2006, Toa Re sets out its
vision: “As a professional reinsurer, we are striving to become a corporate group that continues to provide
high quality products and services and is trusted by customers in Japan and overseas.” To this end, in the
final year of PROCEED 2008, we are implementing various measures in Japan and overseas from six view-
points, namely, Customers and marketing, Products and underwriting, Process and risk management,
Corporate finance, Corporate social responsibility, and Organizational and corporate culture, in order to
achieve development of the entire Group and to enhance our enterprise value.
By endeavoring to act as an exemplary reinsurance company, we are resolved to fulfill our mission:
“Providing Peace of Mind.”
In conclusion, I hope that our brochure will provide a greater insight into the Japanese insurance market
and I would like to express my gratitude to all who kindly contributed so much time and effort towards its
making.
2
Japan’s insurance market has changed significantly since I became president
in 2004. In particular, the past two to three years have been a critical period, with
the industry experiencing many problems, further liberalization of financial regula-
tions and the appearance of new rules. The resulting changes are ushering in a
new era in the Japanese insurance culture, which had been in place for more than
100 years.
In 2005, Japan’s non-life insurance industry experienced several major prob-
lems involving the very foundation of the insurance business, including incidental
unpaid insurance claims, inappropriate non-payment of third-sector products, and
incorrect setting of premiums for fire insurance and other products. The industry
reflected on these problems, thoroughly analyzed the causes and prepared the
infrastructure for measures to prevent recurrence. Through these and other steps,
insurance companies worked on their highest management priority: restoring
trust.
Furthermore, the Program for Further Financial Reform was introduced in
April 2005 following the completion of financial regulation to deal with nonper-
forming loans. This program promoted liberalization and the preparation of sys-
tems with emphasis on user needs and enhanced convenience. At the same time,
various initiatives were implemented, strengthening existing rules and formulat-
ing new ones to protect users, improve governance, and enhance risk management.
In addition, “The plan for strengthening the competitiveness of Japan’s financial
and capital markets” was announced in December 2007. This plan is intended to
improve regulation, and The Principles in the Financial Services Industry
announced in April 2008 are central components of the plan, which emphasizes
self-discipline and self-reliance among financial institutions.
I would like to briefly touch upon the Japanese insurance industry’s recent
issues, their impact on the non-life insurance market, and Aioi’s initiatives.
(1) Measures aimed at restoring consumer confidence
The industry as a whole, and companies individually, have implemented vari-
ous measures to restore confidence following the problems I mentioned earlier. An
overview of measures implemented by the industry as a whole since 2005 follows
below.
■ Appropriate payment of claims
• Formulation of “Self-Imposed Guideline on Payment for Insurance Claims”
• Formulation of “Guidelines for 3rd Sector Insurance Products”
• Creation of guidance from report of claims to receipt of payments
■ Provision of products that are easier to understand
• Publication of “Guideline on making Insurance Policy Wordings more cus-
tomer-friendly”
1. Tadashi Kodama Representative Director and President, Aioi Insurance Co., Ltd.
Trends in Japan’s Non-Life Insurance Industryand Aioi’s Management Strategies
1. Conditions in Japan’sNon-Life InsuranceMarket
Introduction
3
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
■ Promoting consumer understanding of Insurance
• Publication of a buyer’s guide for non-life insurance policies
• Formulation of “Guideline for Description of Solicitation Materials, etc”
■ Improving the quality of agents/solicitors
• Improvement of examinations
• Introduction of a renewal system (every five years) for agents/solicitors
credentials
As this overview shows, the insurance industry has worked to raise quality
throughout its processes. Efforts to restore trust have required detailed changes in
the way the entire non-life insurance industry does business, from sale to payment,
from entry to exit. For example, in the past insurance companies tended to
respond passively to claims, and paid them without sufficient prior explanation or
guidance. Insurance companies are now implementing improvements so that they
make detailed responses and carefully explain payment conditions to customers to
eliminate incidental unpaid claims.
In addition, the insurance industry is promoting improvements to support
accurate understanding of insurance. In the past, contracts and brochures exten-
sively used technical terminology and were difficult for ordinary consumers to
understand, but now the use of plain language, large type and other features are
making contract details and specifications easy to understand. Moreover, a broad
array of significant reforms is changing the way the overall insurance industry has
historically operated. Not only insurance companies, but also agencies that sell
insurance products and write contracts are now improving themselves under a
recently introduced system for the renewal of qualifications, this being for the first
time in the history of agency system, such reforms have taken place.
One of the causes of the problems the insurance industry experienced is, in
my understanding, the intensifying competition in Japan’s insurance market since
its liberalization in 1996. Companies rushed to expand sales by competing on the
basis of product development and rates, but the coordination between product
development sections and claim sections was insufficient. Today, however, the
series of problems has caused the industry to change fundamentally to prioritize
quality over competitive conditions. In our case, Aioi Insurance has broken away
from the customs and assumptions of the insurance industry of the past to become
a customer-oriented company that is resolutely promoting changes.
Aioi Insurance has formulated a medium-term management plan for fiscal 2007
and 2008, “AIOI Quality for the Customer,” that is centered on this resolve. As the
following chart shows, our values position the regard, trust and support of customers
as our priority in everything we do. We have dramatically reformed all business
processes, from insurance product development to sales, administration and claims
payment, from the viewpoint of customers. With this as a base, we will increase cus-
tomer relationships as we work to generate sustained growth and expand earnings.
4
(2) Key Trends in Insurance Regulation
Following the completion of many years of efforts to resolve nonperforming
loans, the Program for Further Financial Reform was announced in December
2004 and implemented over the course of two years starting in April 2005. This
program promoted liberalization and the preparation of systems to enhance user
convenience and protect users. Naturally, it also significantly changed the com-
petitive environment of the insurance industry.
One change was the lifting of all restrictions on bancassurance. Up to that
time, bancassurance had been limited to products with a connection to banking
operations, such as long-term fire insurance and loan repayment insurance bun-
dled with mortgage loans, as well as some types of personal accident insurance.
The range of products expanded in December 2005, and all restrictions were lifted
in December 2007. This allowed bank branches throughout Japan to become
insurance agencies, which enhanced user convenience. However, it also created
concerns about user inconvenience, such as high-pressure sales at banks and the
adequacy of the response to automobile accidents and other incidents. Therefore,
the restrictions were lifted in stages with the authorities discussing and carefully
1. Trends in Japan’s Non-Life Insurance Industry and Aioi’s Management Strategies
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
5
monitoring the process.
Ironically, as the insurance industry was experiencing the problems already
mentioned at the same time, the result was that banks were not really to handle
direct sales of complex non-life insurance products. In the future, however, factors
such as the development of bancassurance products that are easy to sell and an
increase in the number of bank employees with knowledge of insurance will lead
insurance companies to strengthen their relationships with banks and promote
sales, centered on life insurance and third-sector products.
Moreover, the privatization of Japan’s postal service executed in October
2007 split the former Japan Post Public Corporation into Japan Post Holdings
Co., Ltd. and four operating companies, with Japan Post Network Co., Ltd. per-
forming commissioned services for Japan Post Service Co., Ltd., Japan Post Bank
Co., Ltd. and Japan Post Insurance Co., Ltd. Every post office throughout Japan
is now able to provide postal, financial and insurance services. At the same time,
the approximately 24,000 post offices nationwide handled by Japan Post Network
Co., Ltd. became non-life insurance agencies. This expanded channels for selling
non-life insurance, and as in the case of bancassurance, was a legislative develop-
ment that exerted a significant impact on the non-life insurance operating environ-
ment. Looking forward, the industry is keeping an eye on trends to see whether
the government will finally backpedal to maintain an equal footing with private
companies, and how the insurance business will develop in this environment.
Legal reform enacted from the viewpoint of protecting customers has also
affected the insurance market. Such reform from the perspective of consumer pro-
tection has presented problems for the non-life insurance industry, and in April
2006 the revision of the Insurance Business Law instituted regulations for small-
claims short-term insurance providers. The new regulations now place all insur-
ance companies under the Insurance Business Law, except for affinity groups with
specified limits on the number of members. During the two-year transitional peri-
od, affinity groups not controlled under a specific law had to select one of four
options:
(1) continue as affinity groups within a single corporation, labor union affinity
groups or small-scale affinity groups (excluded from the scope of application of
the Insurance Business Law);
(2) continue operating as a small-claims short-term insurance provider*;
* Small-claims short-term insurance provider:Insurance operations within a designated scale operating under the Insurance Business Law canunderwrite small amount, short-term insurance.(Primary Conditions)• Annual premium income: ¥5.0 billion or less• Insured period: Non-life insurance: 2 years or less
Life insurance or medical care insurance: 1 year or less• Sum insured: ¥10 million or less per individual insured
6
(3) acquire certification as an insurance company; or
(4) cease operations.
Consequently, as of March 2008, among 430 affinity groups not controlled
under a specific law, 179, or 41.6 percent, selected option (1); 60, or 14.0 percent,
selected option (2); 5, or 1.2 percent, selected option (3); and 186, or 43.3 per-
cent, selected option (4).
Those companies that elected to cease operations switched over their con-
tracts to insurance contracts, or to group insurance contracts with insurance com-
panies, a method that allowed insurance companies to serve as a backup and con-
tinue coverage. In other cases, insurance companies took small-claims short-term
insurance providers as their subsidiaries. Thus the connection between coopera-
tives in Japan’s insurance market will move in new directions in the future.
Moreover, in June 2006 a legal system that cuts across various business sec-
tors to protect customers with investment-oriented financial products was codified
as the Financial Instruments and Exchange Law, which took effect in September
2007. This law established regulations for non-life insurance companies for the
suitability of derivatives transactions (weather and typhoon derivatives) and
explanatory reports before and after transactions. In conjunction with the
Financial Instruments and Exchange Law, the Insurance Business Law being
restructured, the investment-type products of insurance on foreign currency basis
and variable annuity products were additionally regulated.
Thus the Program for Further Financial Reform upgraded and strengthened
various regulations. The problems the insurance business experienced triggered
the strengthening of regulations, with the result that laws were revised and rein-
forced for the further protection of customers.
The Program for Further Financial Reform was completed in March 2007.
In December 2007, the Plan for Strengthening the Competitiveness of Japan’s
Financial and Capital Markets was announced. This plan is the most extensive
reform of Japanese finance since Japan’s version of the Big Bang. The plan has the
objective of enhancing the functionality and reliability of Japan’s capital markets
in order to strengthen the international competitiveness of Japan’s financial insti-
tutions. It is projected to significantly liberalize business regulations, including
those for the insurance industry, under the theme of internationalization.
The Principles in the Financial Services Industry were announced in April
2008 to improve regulation. They are similar to the supervisory policies and tech-
niques used in the United Kingdom. Moreover, the International Association of
Insurance Supervisors, the International Accounting Standards Board and other
organizations have debated solvency systems and the market value of insurance lia-
bilities for international institutions. In tandem with this, Japan is currently
studying the revision of solvency standards and the implementation of internation-
al accounting standards in promoting the preparations needed to create an interna-
1. Trends in Japan’s Non-Life Insurance Industry and Aioi’s Management Strategies
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
7
tional level playing field in Japan’s insurance market.
As a result of such regulatory liberalization and preparation, management will
have greater freedom and more options in the future, and will therefore have to be
more self-disciplined and self-reliant, with stronger capital and risk management.
Looking forward, the strategic application of these changes in the rules and
required changes to the management base are key issues. Approaches to strength-
ening capital and risk management will have to be more sophisticated in the
future, and will include the effective use of reinsurance.
(3) Overview of Results for Japanese Non-Life InsuranceCompanies
At this point I would like to present data about Japan’s non-life insurance
market. As you know, this market is the fourth largest in the world in terms of
premium income, but challenging conditions have impacted growth over the past
several years.
Japan’s economy has continued to expand moderately, but last year’s turmoil
in global capital markets stemming from the subprime mortgage crisis, the appre-
ciation of the yen versus the dollar and other currencies, the rising price of oil and
other factors are causing increasing concern about corporate earnings, which has
added to uncertainty about the future of the economy. The number of vehicle
sales and housing construction has slipped, and insurance companies have been
preparing the infrastructure required to prevent recurrence of non-payment of
claims while placing the highest priority on quality in deploying human, physical
and financial resources. The operating environment has remained challenging as a
result of these and other factors.
The interim results for fiscal 2007 of the 22 companies of The General
Insurance Association of Japan, which were announced in December 2007, reflect-
ed this environment. Net premium income decreased 0.1 percent, or ¥3.1 billion,
compared with the same period a year earlier to ¥3,785.1 billion, primarily
because of lower revenues among mainstay motor and fire insurance. Net claims
paid increased 0.8 percent, or ¥17.1 billion, compared with the same period a year
earlier to ¥2,092.5 billion. Compared with the same period a year earlier, the loss
ratio increased 0.8 percentage points to 59.9 percent and the expense ratio
increased 0.5 percentage points to 32.4 percent.
On the other hand, underwriting profit totaled ¥9.1 billion, compared with
an underwriting loss for the same period a year earlier of ¥25.5 billion. The
change was primarily the result of reduced claims payment for typhoon losses.
Full-year net premium income for fiscal 2007 appears to be headed lower
because of factors such as the reduction of the rate under Compulsory Automobile
Liability Insurance that began in February 2008.
8
(1) Aioi’s Results
Amid this challenging operating environment, Aioi increased fiscal 2007
interim net premium income 0.4 percent, or ¥1.6 billion, compared with the
same period a year earlier to ¥428.6 billion, and maintained its number four
position in the industry. Net claims paid decreased 0.2 percent, or ¥0.5 billion,
compared with the same period a year earlier to ¥234.6 billion. Compared with
the same period a year earlier, the loss ratio decreased 0.4 percentage points to
58.8 percent, and the expense ratio increased 0.3 percentage points to 32.7 per-
cent. Underwriting profit increased ¥4.1 billion compared with the same period
a year earlier to ¥5.8 billion.
The medium-term management plan I mentioned earlier places the highest
management priority on reforming the Company. As a result, Aioi continued to
increase premium income. Although our growth rate was comparatively lower
than in the past, it was among the highest in the industry. Moreover, we dealt
with the non-payment problem while achieving a loss ratio and a combined ratio
that were among the best in the industry.
Next, I would like to discuss the business strategies Aioi will execute as it
works to be the best company in the industry.
(2) Aioi’s Growth Strategy
The key point in our growth strategy is our strategy for motor insurance,
which is our main product. Toyota Motor Corporation owns 33.4 percent of
Aioi’s shares, making it the Company’s largest shareholder. Cooperation with
Toyota in domestic and overseas markets is a strategy unique to Aioi and one of
the Company’s greatest strengths.
In Japan, Aioi cooperates with Toyota’s financial businesses to develop
unique motor insurance with enhanced convenience for automobile users, and
primarily sells this insurance through Toyota dealerships. In August 2005, Aioi
developed and began selling the Lexus Owners Motor Insurance Plan to meet
insurance needs among luxury car owners, and sales have increased steadily. As a
result, our objective is to increase our share of the domestic Toyota dealership
market to 40 percent.
1. Trends in Japan’s Non-Life Insurance Industry and Aioi’s Management Strategies
2. Aioi’s Business Strategy
10
Aioi is also developing other kinds of unique, leading-edge insurance prod-
ucts. One type is PAYD (Pay-As-You-Drive) insurance, which uses mobile termi-
nals installed in automobiles for intelligent transport system (ITS) technology to
collect driving distance information and adjusts premium payments on actual dis-
tance driven. Moreover, Aioi is the only insurance company in Japan with the col-
lision experiment facilities. We utilize this facility and evaluate vehicle damage
susceptibility and ease of repair in order to offer discounts on physical damage
insurance of up to 15 percent. In the future, Aioi will make full use of its close
relationship with an automobile manufacturer to enhance the excellence of its
main motor insurance products.
Overseas, Aioi operates in 17 countries and regions in Europe, Asia and
Australia using its unique business model through cooperation with Toyota
Financial Services to enable integrated finance and insurance operations. This
business will drive future growth, and Aioi will expand the number of countries in
which it operates through proactive investment of resources.
1. Trends in Japan’s Non-Life Insurance Industry and Aioi’s Management Strategies
11
The last two to three years have been a period of transition for the attitudes
that underlie Japan’s non-life insurance industry. It is not easy to transform think-
ing that dates back more than a century. That is a challenge for both insurance
companies and insurance agencies. We must, however, remember that trust and
credit that took 100 years to build can quickly erode.
We understand that serious problems have emerged in the industry, and that
these problems have greatly troubled our customers. In my view, the problems
have taught some salutary lessons to insurance companies in Japan, and have
served as catalysts for reforms at a time when preparations for the globalization of
Japan’s financial markets are underway. I believe the problems have prompted
Japanese insurance companies to reconsider their practices and increase their com-
petitiveness in terms of operational quality, and to compete openly and fairly with
other players around the globe.
Insurance companies in Japan, including Aioi, are now committed to
improving their operational quality. Once changes have been fully implemented,
they will have true strength, creating a market that provides customers with securi-
ty and that offers the kind of reliable, refined and extensive services that are char-
acteristic of Japan. I am convinced that the establishment of this kind of market is
fundamental to the further development of Japan’s non-life insurance business to
move on to achieve new growth.
(Written in April, 2008)
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
Conclusion
Local Finance New/Company Name Bureau Registration Date Specific Class of Business
(1) Shinsai Partners Inc.(2) Pet & Family Small-amount Short-
term Insurance Company(3) ExcelAid Co., Ltd.(4) UB Kyosaikai Co., Ltd.(5) re-plus insurance inc. (6) MC S.S. INSURANCE CO., LTD.(7) Aeterna SSI Corporation(8) IKIIKI SEDAI Inc. (9) Millea Nihon Kosei SS Insurance
Co., Ltd.(10) A-1 Insurance Co., Ltd.(11) ASSOCIA inc.(12) Japan Animal - Club Co. Ltd. (13) Takken Family Co., Ltd.(14) Zenchi Kyosai Co., Ltd.(15) Nihon Jutaku Insurance Co., Ltd.(16) Broad-minded Co., Ltd.(17) Zenkankyo Kyosaikai Co., Ltd. (18) Relo Kyosai, Ltd.(19) Memolead Life Co., Ltd. (20) NP Insurance Co., Ltd.
(21) Ipet Co., Ltd.
Kanto No.1
Kanto No.2
Kanto No.3
Kinki No.1
Kanto No.5
Kanto No.6
Kanto No.7
Kanto No.8
Kanto No.10
Kinki No.2
Kanto No.11
Tohoku No.1
Kanto No.12
Kanto No.14
Kinki No.3
Kanto No.15
Kanto No.16
Kanto No.17
Kanto No.18
Kanto No.19
Kanto No.20
October 27, 2006
November 29, 2006
June 21, 2007
July 25, 2007
October 25, 2007
November 14, 2007
November 20, 2007
November 22, 2007
December 10, 2007
December 12, 2007
December 28, 2007
January 31, 2008
February 4, 2008
February 5, 2008
February 25, 2008
March 17, 2008
March 17, 2008
March 19, 2008
March 19, 2008
March 19, 2008
March 21, 2008
New
Specific
New
Specific
New
New
New
Specific
Specific
Specific
New
Specific
Specific
Specific
Specific
Specific
Specific
Specific
Specific
Specific
Specific
Earthquake expenses
Pets
Life and healthcare
Household effects and liability
Household effects and liability
Life, healthcare and liability
Household effects and liability
Healthcare
Household effects and liability
Household effects and liability
Household effects and liability
Pets
Household effects and liability
Life, healthcare and liability
Household effects and liability
Life and healthcare
Household effects and liability
Consolation payment
Life and healthcare
Consolation payment, life, andhealthcare
Pets
12
(1) Registration of Small-Claims and Short-Term Insurance Companies
A list of small-claims and short-term insurance companies as of April 1,
2008 is provided below. The companies are listed in order of their dates of regis-
tration. In the column headed “New/Specific,” “Specific” signifies businesses
that have converted from specific insurance businesses to small-claims and short-
term insurance companies. The word “New” is given in the column to small-
claims and short-term insurance companies which are newly established business-
es. The use of the form of transition called comprehensive transition, including
portfolio and business transfer provisions as prescribed under the Insurance
Business Law, is not separately identified in the table below; however, it has been
announced that Zenkankyo Kyosaikai Co., Ltd., listed as No.17, has used com-
prehensive transition. Other transitions appear to have been carried out inde-
pendently.
Small-claims and short-term insurance businesses denote insurance business-
es approved in line with the revision of the Insurance Business Law enforced in
April 2006. Unlike life and non-life insurers, small-claims and short-term insur-
ance businesses are simplified insurance businesses with a minimum capital of 10
million yen, a maximum insurance amount of 10 million yen, and an insurance
policy period of two years at most.
2. Masaaki Oishi President and CEO, Center for Insurance Studies in Japan (CIS)
Trends in the Insurance Business Law andRelated Legislation — The Events of Fiscal 2007 —
1. Events Relating tothe InsuranceBusiness Law
13
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
The small-claims and short-term insurance companies listed in the above
table include 13 household-related businesses, five pet-related businesses, and five
businesses associated with the mutual aid society for ceremonial occasions. A
detailed analysis of the products of these companies is omitted. Many household-
related businesses underwrite fire insurance. Businesses associated with the mutu-
al aid society for ceremonial occasions consist of two categories: businesses
engaged in mortality risks and businesses involved in living benefits and the pro-
vision of healthcare benefits.
(2) Life Insurance Companies and Non-Life InsuranceCompanies Approved in Fiscal 2007
Insurance companies approved under Articles 3, 185 and 271 of the
Insurance Business Law as of April 20, 2008 are listed in the table given below.
This table was prepared based on documents published, from July 2007 to April
2008, on the Measures & Policies page of the Financial Services Agency website.
Company Name Approval Date Types Remarks
(1) The Dai-ichi Frontier Life Co., Ltd.
(2) HDI Versicherungs AG
(3) H.S. Insurance Co., Ltd.
(4) SBI Insurance Co., Ltd. (5) Anicom Insurance, Inc.(6) Anicom International, Inc.
(7) Mitsui Sumitomo Insurance GroupHoldings, Inc.
(8) Allianz Life Insurance Japan Ltd.(9) Adlick Insurance Company, Ltd.
(10) SBI AXA Life Insurance Co., Ltd. (11) LIFENET INSURANCE
COMPANY
July 31, 2007
September 13, 2007
October 26, 2007
December 26, 2007 December 26, 2007December 26, 2007
March 5, 2008
March 7, 2008March 21, 2008April 2, 2008April 10, 2008
Life insurance
Foreign non-lifeinsurance businessNon-life insurance
Non-life insuranceNon-life insuranceInsurance holdingcompanyInsurance holdingcompanyLife insuranceNon-life insuranceLife insuranceLife insurance
Wholly owned by the Dai-ichi MutualLife Insurance CompanyThe headquarters is located in theFederal Republic of Germany.The company offers overseas travel per-sonal accident insurance only.
The company offers pet insurance only.The company was approved as an insur-ance company at the same time.
The company seeks to sell productsthrough the internet.
(22) Fuji Insurance Co., Ltd.(23) A-Life Co., Ltd.(24) ACE Chintai SSI (25) Pet Medical Support Co., Ltd.(26) SC Insurance Co., Ltd.(27) Floral Kyosai Co., Ltd.(28) Motto Gyutto Hoken Co., Ltd.(29) LEOPALACE INSURANCE CO., LTD.(30) Namiki Chaochao Kyosai Co., Ltd.(31) Bell Insurance Co., Ltd.
Kanto No.21
Kanto No.22
Kanto No.23
Kanto No.24
Chugoku No.1
Tohoku No.2
Kanto No.25
Kanto No.26Kanto No.27
Fukuoka(Branch) No.1
March 21, 2008
March 21, 2008
March 25, 2008
March 26, 2008
March 27, 2008
March 31, 2008
March 31, 2008
March 31, 2008March 31, 2008
March 31, 2008
Specific
Specific
Specific
Specific
Specific
Specific
Specific
NewSpecific
Specific
Accident, life, and healthcare
Household effects and liability
Household effects and liability
Pets
Life and healthcare
Life and healthcare
Pets
Household effects and liabilityHousehold effects and liability
Life and healthcare
14
2. Trends in the Insurance Business Law and Related Legislation — The Events of Fiscal 2007 —
(3) Status of the Transitions from Specific InsuranceBusinesses
Projected transitions as of March 31, 2008, announced by the Financial
Services Agency are as follows:
Projected transitions in specific insurance business(as of March 31, 2008)
(Note 1) Examples of exemption from application- Provision of congratulatory or condolence payments to the extent considered appro-
priate in light of normal social conventions.- The number of policyholders is limited to not more than 1,000. - The business is managed in accordance with the provisions associated with the
exemption from application of the Insurance Business Law by changing operationsto mutual-aid for one working place, and by adopting other measures.
(Note 2) An asterisk “*” means that the business as a mutual-aid business is expected to close.(Total 186 companies [43.3%])
The Financial Services Agency stated in the above table that 88.1% as
described in [A] represented the number of companies that were helped to con-
tinue their businesses instead of ending up being “Kyosai (mutual-aid) refugees.”
The point that requires close attention is the total number. The number of spe-
cific insurance businesses was given as 389. However, the number has increased
to 430. No information about the reasons for this increase has been made public.
It is presumed that the same number of specific insurance businesses were late for
registration, but the Financial Services Agency accepted their registration even
though the registration period had expired.
These figures for projected transitions in specific insurance businesses wereprepared as at March 31, 2008, and they may change in the future.
Transition Types As at the End of March 2008
a. Companies converting to insurance companies
b. Companies converting to small-claims and short-terminsurance businesses
c. Companies that continue to operate mutual-aid business,exempted from application of the Insurance Business Law(Note 1)
d. Companies that continue to provide insurance services topolicyholders by establishing group contracts with otherinsurance companies
e. Companies that transfer mutual-aid contracts to otherinsurance companies
Total number of companies that continue to provide insuranceservices to policyholders [A](a + b + c + d + e)Companies that simply withdraw from insurance business [B]
Total [A] + [B]
5(1.2%)60(14.0%)179(41.6%)
114(26.5%)*
21(4.9%)*379(88.1%)
51(11.9%)*430(100.0%)
15
2. Trends in 0therRelated Legislation
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
(1) Companies Providing Guarantees against HousingDefects
To protect people from housing defects, it has become possible since April
2008 to establish a company that provides guarantees against housing defects. Six
companies are reported to have begun consulting with the Ministry of Land,
Infrastructure, Transport and Tourism of Japan to become designated
corporations.
The features of this insurance are as follows:
- The insurance can be arranged only for those houses that have passed inspec-
tions carried out before the houses are completed.
This procedure is considered to be similar to that of the British Engine.
- The obligations of the insurance companies are set out in law; they include loss
prevention, the collection of related information, information provision, and
inspection and research.
- The system has been structured such that individual customers are also protect-
ed from losses caused by deliberate acts or gross negligence on the part of con-
struction companies, the insured. This feature represents a fundamental differ-
ence compared to insurance companies that are governed by the Insurance
Business Law.
(2) Consumer Cooperative Law
The Consumer Cooperative Law has been in effect since April 1, 2008. The
mutual aid business based on the Consumer Cooperative Law manages both life
and non-life insurance, including the risks of mortality, fire, earthquake and
motor accidents. This is the same as the above small-claims and short-term insur-
ance businesses. Companies that provide guarantees against housing defects are
also permitted to manage the insurance business as well as other businesses.
According to documents published as a partial amendment to the Consumer
Cooperative Law, the aggregate sums insured are stated as 1,091,586 billion yen,
the number of policyholders was 100.63 million, and the paid losses under the
mutual aid programs amounted to 651.3 billion yen for fiscal 2004.
The Consumer Cooperative Law has adopted the principle of specialized
operations, the same as that adopted by the Insurance Business Law, for large
cooperative to ensure sound operation. Consequently, the cooperative are
required to employ a mutual-aid actuary, to provide documentary evidence of
their calculation methods, and to appoint an accounting auditor. On the whole,
although these requirements are transitional, it is appropriate to point out that
regulations for large-scale mutual-aid businesses, which are similar to those for
small-claims and short-term insurance businesses, have been strengthened.
2. Trends in the Insurance Business Law and Related Legislation — The Events of Fiscal 2007 —
16
(3) Laws Associated with the Reform of Public Corporations
Public corporations are defined in the Civil Code, and there is a movement
to revise the Civil Code for the first time in one hundred years. In addition,
some public corporations are engaged in commercial activities, it has been deter-
mined that the principles of main government offices and the principles associat-
ed with the establishment of public corporations are to be revised. These revi-
sions are expected to be effective from December 2008. Following the revisions,
public corporations will be broadly categorized as a general foundation and gener-
al foundations and as general incorporated associations. Moreover, by adopting a
new system of recognition for public corporations, judgment as to the public
interest will be made objectively. In addition, a predetermined standard of pref-
erential tax treatment will be applied. As of April 2008, there are more than
20,000 public corporations. Several thousand of them are believed to be manag-
ing mutual-aid businesses. To be recognized as public corporations, these compa-
nies are required to have more than 50% of their overall operations for the public
benefit, as described below.
ARatio of operations for the public benefit =A + B + C
A = Amount calculated in accordance with provisions stipulated in Cabinet
Office regulations as expenses incurred from the execution of operations for
the public benefit
B = Amount calculated in accordance with provisions stipulated in Cabinet
Office regulations as expenses incurred from the execution of profit-earning
operations
C = Amount calculated in accordance with provisions stipulated in Cabinet
Office regulations as current expenses incurred from management of the rele-
vant public corporation
As a result, it is necessary for those who seek to obtain recognition as a new
public corporation to increase the present amount described in A, or to meet the
required ratio by increasing the total amount of A, B and C.
(1) Letters of Request to the Life InsuranceAssociation of Japan (LIAJ) and the GeneralInsurance Association of Japan (GIAJ)
The Financial Services Agency announced the “Supervisory notes following
the termination of the transition period associated with specific insurance busi-
nesses” on March 7, 2008. The details of the notes are as follows.
I. Following the introduction of the revised Insurance Business Law, the sys-
tem of small-claims and short-term insurance businesses has been adopted
3. Stance of theFinancial ServicesAgency
17
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
since April 2006. In line with this, the Financial Services Agency has pre-
pared and published the “Comprehensive Supervisory Policies for Insurance
Companies (Supplementary Volume) (Supervisory Policies for Small-Claims
and Short-Term Insurance Businesses),” a summary of supervisory notes asso-
ciated with small-claims and short-term insurance businesses.
In November 2006, Local Finance Bureaus who oversee specific insurance
businesses were given instructions to take appropriate measures in accordance
with supervisory policies to ensure that specific insurance businesses manage
operations appropriately, and that policyholders can confidently buy insur-
ance products.
In the “Overview of Annual Supervisory Policies for Insurance Companies
for Program Year 2007” (http://www.fsa.go. jp/en/news/2007/
20071119-1.html), it was stated that, with respect to an actual understanding
of specific insurance businesses and the smooth transition to small-claims and
short-term insurance businesses, the protection of policyholders needs to be
prioritized as an important supervisory issue through appropriate supervisory
measures during the transition period.
II. In accordance with the provisions set out in the supplementary provisions
of the revised Insurance Business Law, specific insurance businesses can carry
on their business until the end of March 2008, the end of the transition peri-
od. Moreover, specific insurance businesses which have filed applications for
an insurance license or applications for the registration of small-claims and
short-term insurance businesses before the end of the transition period, can
continue to carry on the specific insurance operations during the examination
period.
On the other hand, if no applications are submitted, they will not be able
to underwrite new policies after April 1st 2008. In this case, while continuing
to manage operations such as claims payment, the business will close by the
end of March 2009, in principle, by taking measures including the transfer
of insurance policies held by the relevant company to other insurance
companies.
Developments before and after the end of the transition period are illus-
trated as below.
(Please see “Attachment”)
2. Trends in the Insurance Business Law and Related Legislation — The Events of Fiscal 2007 —
18
III. The transition period associated with specific insurance businesses ended atthe end of March 2008. As described in II above, however, the length of theperiod during which specific insurance businesses can carry out a specific insur-ance business after the end of the transition period varies depending on thenature of each specific insurance business. The period for the portfolio transferof specific insurance businesses who elected to close their businesses also varies.
In response to this environment, it was decided to take the following meas-ures to ensure the smooth transfer of specific insurance businesses to small-claims and short-term insurance businesses, and the protection of policyholders. 1. Local Finance Bureaus are given instructions to take measures for specific
insurance businesses, including the provision of repeated explanations aboutthe procedures that need to be taken in accordance with the status and tran-sition types of specific insurance businesses.
2. To ensure that policyholders are fully aware of points to note following theend of the transition period, the details related to small-claims and short-term insurance businesses on the website of the Financial Services Agencywill be updated and improved regularly.
3. Requests are sent to LIAJ and GIAJ to examine measures that facilitate thesmooth transfer of specific insurance businesses.
The specific details are as follows:
19
1. Stance on specific insurance businessesThe instructions in (1) to (3) below are given to Local Finance Bureaus whichsupervise specific insurance businesses to ensure that, following the end of thetransition period, the Bureaus issue an explanation to specific insurance businessesonce again, taking into account the actual conditions and the action that needsto be taken in the future based on the nature of each specific insurance business,in compliance with the Insurance Business Law and supervisory policies. (1) Stance on businesses that file registration applications for small-claims and
short-term insurance businessesIf specific insurance businesses filed registration applications by the
end of March 2008, they can continue to execute the specific insurancebusiness until the relevant applications are rejected. After the registrationsare completed, specific insurance businesses can receive preferential meas-ures associated with insured amounts. The limitation on insured amountsunder non-life insurance associated with small-claims and short-terminsurance business that used to be specific insurance businesses has beenrelaxed to five times the upper limit of the ordinary insured amount, sub-ject to the implementation of reinsurance arrangements.
Specific insurance businesses, who are seeking to receive the measuresduring the transition period, must be fully aware of the above details, andexplanations are given once again as needed on the measures that need tobe taken and on individual issues in view of laws and ordinances andsupervisory policies.
(2) Stance on businesses that do not file registration applications for small-claims and short-term insurance businesses
When no registration applications are filed by the end of March 2008,explanations will be given once again as needed. For instance, the under-writing of new policies, including the renewal ones, cannot be executedfrom April 1, 2008, and certain measures must be taken, including thetransfer of existing ones, before March 31, 2009 (or before the dates thatare determined by supervisory agencies, if any unavoidable reasons arerecognized), and that, during the above period, it is possible to manageoperations associated with the in-force policies (such as the receipt ofinstallment payments of insurance premiums, and the making of claimspayment).
(3) Due consideration to policyholders when specific insurance businesses areclosed
When specific insurance businesses cease their business, explanationswill be given once again as needed about the need to obtain approvals fromsupervisory agencies in advance, and examinations that are carried out bythe supervisory agencies to see if there are any problems from the perspec-tive of protecting policyholders.
In addition, when a so-called simple closure is expected, as muchinformation as possible will be provided; including how businesses whoexecute the same business continue to provide coverage (through otherinsurance companies and group insurance of mutual-aid organizations).
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
20
2. Trends in the Insurance Business Law and Related Legislation — The Events of Fiscal 2007 —
2. Stance on policyholders To ensure that policyholders are fully aware of the issues associated with theoperations of specific insurance businesses after the end of the transition period,the content on the website of the Financial Services Agency (For the Public - ForPolicyholders - “Mutual-Aid Associations Without Governing Laws”) will beregularly updated.(1) Legal positions of insurance businesses under the transition
The legal position of insurance companies, small-claims and short-term insurance businesses, and specific insurance businesses will bedescribed clearly.
(2) The main points to note when contracts are concluded with specific insur-ance businesses and mutual-aid associations without governing laws
Points to note, such as what kind of measures are taken by specificinsurance businesses, and what will happen to insurance policies that areconcluded with specific insurance businesses, will be described.
(3) Questions & Answers associated with mutual-aid associations without gov-erning laws and small-claims and short-term insurance businesses
Frequently asked questions and answers associated with the outline ofthe system of the small-claims and short-term insurance business, and spe-cific insurance businesses will be presented. In addition, the contactaddress details of each Local Finance Bureau for inquiries will be presented.
3. Requests to LIAJ and GIAJThe Life Insurance Association of Japan and General Insurance Association ofJapan will be asked to examine measures that facilitate the smooth transfer ofspecific insurance businesses, in accordance with the purpose of the Associationsto serve the public interest.
(2) Other Trends of the Financial Services Agency
Following the above transition measures, business-suspension orders and busi-ness-closure orders have begun to be issued to specific insurance businesses that areinsolvent or that have a number of problems with their solicitation methods.Examples of the above include the case of Zenkoku Yogo Fukushikai in February2008, and the case of FJ Kyosaikai in April 2008.
(3) Missions of the Small-Claims and Short-Term Insurance Business
One of the problems of the third sector identified by the Financial ServicesAgency is that there is no standard rate that is similar to the mortality rate used as theindustry standard. The only methods of addressing this data shortage are to collectdata and to deal with the situation by varying provisional insurance premium rates.A structure that enables considerable flexibility in changing insurance premium rates,the second of the above methods, is found in the small-claims and short-term insur-ance business. Consequently, a number of new registrations are expected to be filedas small-claims and short-term insurance businesses in fiscal 2008.
21
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
3. James Vickers Chairman, Willis Re International
Lessons from Solvency II for the JapaneseInsurance Market
It is tempting to ask why Japanese Insurance Companies, other than those with
subsidiary companies in the EU, should pay any particular attention to the regulatory
changes being proposed by the EU Commission under the overall heading of Solvency
II. One response would be to point out that approximately a third of the global Non
Life Premium income and 40% of the Global Life premium income will come under
the control of Solvency II. Another answer to this question is that at a time when vir-
tually every local regulator is looking to update and enhance their own local insurance
regulations the Solvency II project represents the largest and most ambitious regulato-
ry change attempted to date. The unique features of the EU and its desire to har-
monise regulation across the whole of the EU gives the Solvency II project some very
particular features, which are not necessarily applicable to other countries. However,
the underlying technical applications and the process of implementation, which are
being followed, offer many important lessons for the Japanese Insurance Industry and
other national markets as they start to implement their own regulatory reforms.
Rating Agencies are paying very close attention to Solvency II and the International
Association of Insurance Supervisors (IAIS) is similarly monitoring progress and seek-
ing to promote the best practices coming out of the Solvency II project on a global
basis. Finally, there is strong investor interest, particularly as to how Solvency II will
assist in the development of an Enterprise Risk Management culture within the regu-
lated insurance companies in which they are shareholders.
Solvency margins in EU member countries are regulated under the current
Solvency I Directive, which provides for a capital buffer to provide policyholder pro-
tection. Whilst Solvency I has been successful in providing policyholder protection, it
has fallen short in some other areas and the following are the key perceived drawbacks:
• Current regulation lacks sufficient risk sensitivity. This leads to sub-optimal out-
comes by imposing inconsistent f inancial requirements on some
organisations/classes of business.
• Does not provide regulators with the tools to foster higher quality risk manage-
ment and control
• Current national regulation restricts the proper functioning of the single market
for insurance within the EU
• There are inefficiencies in the supervision of Groups with operations in different
EU member countries
• International accounting and regulatory standards are developing and these are not
properly reflected in current regulation.
The Solvency II project is designed to address the shortcomings of Solvency I
and to achieve a number of broad objectives
• Deepen the single market for insurance services
• Enhance policyholder protection through capital requirements which can provide
early warning of deterioration in solvency levels
• Improve the (international) competitiveness of EU insurance organisations
Introduction
Solvency II Objectives
22
• Promote further and better regulation by stimulating further improvements in the
quality of risk management
The Solvency II regime is designed to offer incentives, in the form of reduced
capital requirements, which support the implementation of appropriate risk manage-
ment systems and sound internal controls. The EU Commission is proposing that
Solvency II follows the Basel II regime covering Banks in setting up a three pillar
structure for regulatory purposes. Each of the three pillars covers a different aspect of
the Solvency II requirements and approach:
Pillar 1 contains two capital requirements, the Minimum Capital Requirement
(MCR) and the Solvency Capital Requirement (SCR). The SCR reflects the amount
of capital required for a firm to continue to write business with no interference from
the regulator. The MCR represents the absolute minimum level of capital required
below which the regulator has the authority to effectively shut down the company.
Between the MCR and SCR will exist a layered ladder of supervisory intervention.
Pillar 2 will focus on the supervisory activities of regulators with the aim of iden-
tifying firms with a higher risk profile. Those identified firms may be required to
hold capital at a higher level than suggested by the SCR calculation and/or reduce cer-
tain risks. Pillar 2 also refers to the supervisory review process, which complements
the capital requirements (Pillar 1) and disclosures (Pillar 3).
Pillar 3 requires the disclosure of additional information that supervisors feel
they need in order to perform their regulatory functions.
Solvency II will introduce an economic risk based approach that will reward good
risk management and enhance policyholder protection. At the same time it will place
emphasis on the responsibility of senior management to manage their businesses in a
responsible fashion. It will also help to foster one of the EU Commission’s key objec-
tives: greater supervisory convergence across the entire EU community.
3. Lessons from Solvency II for the Japanese Insurance Market
23
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
The objectives of the Solvency II project, are simple to grasp and in line with the
aspirations of many other regulators around the world. However there is one key
aspect that differentiates the Solvency II project and this is the method of consultation
and implementation the EU Commission are adopting.
As always in the case of major regulatory reform, there are many interested par-
ties all of whom have a legitimate interest in the outcome. These interested parties
include both the insurance industry itself, individual EU member state experts, con-
sulting professionals and CEIOPS (The Committee of European Insurance and
Occupational Pensions Supervisors).
To start with, the EU Commission have adopted a fully transparent timeline set-
ting out all the key milestones. The timeline incorporates a feedback process called
Qualitative Impact Studies (QIS) in which input from insurance organisations is
actively sought. The overall timeline is as set out below though the planned target
date for full implementation has been put back to 2012.
The aim of the QIS questionnaires is to fine-tune the approach to the assess-
ment of liabilities and capital requirements of insurance companies and to ensure that
any unintended or unanticipated consequences are minimised or eliminated.
Overview of QIS 3 The Third Quantitative Impact Study (QIS 3) focus was primarily on suit-
ability, practicality, and reliability with the intention to:• Identify the potential balance sheet impact of applying the standard model• Further test the suitability, calibration and applicability of suggested calibrations• Encourage feedback on the effect of applying QIS 3 specifications to insurance groups• Encourage feedback on calibration of internal models to standard calculation.
The key issues, which arose from the QIS 3 study, were:
• Methodology / Calibration for non-life underwriting risk• Lapse Cat risk component for linked business• Annuity provisions - are these market consistent?• Recognition of Market Risk mitigation techniques• Design of Minimum Capital Requirement (MCR)
Solvency II Process
24
3. Lessons from Solvency II for the Japanese Insurance Market
• Use of Internal models• Modelling of Non-Life Catastrophe risk• Methods allowable for taking advantage of reinsurance• Reinsurance default risk capital charge
How to treat the use of internal models is one of the delicate technical issues,which is being addressed under Solvency II. In their QIS 3 response, many firms pro-vided supplementary information from their own internal models. This provided aninvaluable insight into both the accuracy of the standard calculation, and the effectthat the widespread use of internal models could have on the industry capital reten-tion. In order to try to address the problem of how regulators view the use of internalmodels it was agreed that CEIOPS set up an Internal Model Expert Group to advisethe Commission on the implementing measures that will flesh out the detail of theinternal model regulatory requirements.
The broad principle being adopted is that the SCR standard formula should pro-duce a higher capital charge than an internal model equivalent in order to provide afinancial incentive for firms to invest in the (hopefully) more accurate internal modelapproach. However, if this difference is disproportionately large, smaller firms whosimply do not have the resources to go down the internal modelling route will then bepenalised thus producing a distortion in the market which the EU wish to minimise.The findings from the QIS3 responses suggested that the internal model SCR calculat-ed capital risk charge was considerably lower than the standard calculation result - byas much as a factor of 50% for both Life and Non-Life companies.
This can be attributed to four broad reasons:(1) Increased sophistication and granularity of internal models,(2) General calibration issues within the standard formula,(3) Necessary conservatism of the standard formula calibration, and(4) Internal models providing a better fit to risk for certain types of firm (e.g. spe-
cialist writers)
Overview of QIS 4As a follow up to the QIS 3 study QIS 4 was released in April 2008 with a
response deadline of the end of July and the first consultation on the results beingreleased in September/October. The two primary targets for QIS 4 are :• Finalise the standard solvency calculation element of Solvency II • Finalise group supervision considerations
The key changes in the standard calculation methodology being proposed underQIS 4 are:— Non-Life underwriting risk factors were considered penal under QIS 3, resulting ina significant proportion of firms being classed as insolvent despite fulfilling currentregulatory requirements. As a result of the QIS 3 response, these risk factors havechanged, both up and down, on 8 of the 15 business types in QIS 4. For example,motor risk factors have decreased, whilst those relating to credit and surety haveincreased.— In QIS 3 the European market average reserving factors were not influenced by his-torical data, unlike the corresponding premium factors. In QIS 4, reserving factors canbe modified, subject to local supervisory approval.
25
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
GroupsQIS 4 provides the first opportunity to focus on group issues and the identification ofgroup diversification effects, which can be split into three constituent parts:— Non-Life Geographic Diversification,— Third Country Diversification and— Operational Risk Diversification.
The level of diversification benefit available to groups in respect of the Solvency IIcapital requirement could have a significant bearing on the capital efficiency of groupsversus stand alone enterprises. This has further implications within the industry withrespect to competition and consolidation.
Although it is expected, that many groups will utilise the internal modellingoption, QIS 4 will go some way to defining the level of diversification allowed throughany modelling approach. The resulting conclusions drawn from the QIS 4 responsecould have significant ramifications for the entire industry as it was recognised that thetreatment of Groups under QIS 3 could lead to a distortion in the market.
— QIS 3 feedback indicated that participants found the Eligible Capital three tier clas-sifications confusing. QIS 4 is clarifying this by developing a list of six characteristicsthat define which tier a capital instrument belongs to. Additionally, QIS 4 provides asummary table of characteristics, key features, and instruments to further explain thethree tiers structure. Instruments considered include:— Paid up capital— Subordinated mutual member accounts— Hybrid capital instruments— Subordinated debts— Unbudgeted mutual calls— Letters of credit
ProportionalityQIS 4 proposes a significant development of the solvency calculation methodolo-
gy, allowing more calculation options for (re)insurance companies, and defining thesimplified calculation options as part of its proportional approach. The full simplifiedapproach can be used in calculating a firm’s technical liabilities or SCR where the com-puted result falls below €50m for Life companies or €10m for Non-Life companies. Apartially simplified approach can be applied to minor risk areas, which are defined ascomprising no more than 5% of the total gross technical provisions / SCR This is sub-ject to an overall cap of 15% of the total gross technical provisions / SCR being calcu-lated using the simplified approach.
QIS 4 also provides a bridge between the standard calculation and the partialinternal model, by allowing firms to use company-specific parameters for non-lifeunderwriting risk. These can be incorporated in the standard calculation, subject tolocal supervisory approval. There are now six broad modelling steps available to firms:(1) Small firms exempted from Solvency II, with gross premiums of less than €5 mil-
lion.(2) The SCR simplified approach, which replaces sections of the standard calculation
with more basic formulae.(3) The SCR standard calculation, which takes the form of the QIS spreadsheet
released by CEIOPS.
26
3. Lessons from Solvency II for the Japanese Insurance Market
(4) The SCR entity specific calculation, where firms can replace factors within thestandard calculation, based on their understanding and experience of their ownrisk.
(5) The SCR partial internal model, where firms can internally model risk sections andcombine them with the standard calculation.
(6) The SCR full internal model, where firms can internally model their entire risk.
Minimum Capital Requirement (MCR)The Minimum Capital Requirement (MCR) calculation methodology is also
closely linked to the future of group supervision. The current draft Solvency IIrequires all subsidiaries to hold their MCR locally, whilst all capital in excess of theMCR can be held centrally. The Minimum Capital Requirement (MCR) calculationmethodology has changed in QIS 4 to a linear factor-based approach, which can besimply calculated independently of the SCR by the local regulator. There are someconcerns with the linear approach, as it loses risk sensitivity by excluding certain keyrisks whilst not rewarding or encouraging good risk management. By divorcing theMCR from the SCR calculation, a ladder of supervisory intervention becomes difficult,as firms will have different relative gaps between their MCR and SCR. It also creates thepossibility that in certain cases the MCR could theoretically be greater than the SCR.
The QIS process has lived up to the expectation of the EU commission as the num-
ber and quality of response has grown as the process developed. Over 1,000 responses to
QIS 3 were received and a considerable increase in this number is anticipated for QIS 4.
The responses have highlighted some of the practical issues and unintended consequences
at each stage of the Solvency II development and have allowed the EU commission to
make amendments, which largely reflect the views of the respondents.
In broad terms, the rating agencies welcome the introduction of Solvency II as they
see that it has the potential to deliver more intelligent and risk sensitive supervision as
well as helping to embed ERM techniques into individual organisations. Other positive
benefits include more transparency of information under Pillar 3 as at present regulatory
returns are currently only public documents in a limited number of EU member coun-
tries.
However, there are some negatives as rating agencies do anticipate that there may be
an increase in the number of insurance company failures under Solvency II compared to
the excellent record to date in continental Europe. This is because the regulation as draft-
ed provides a greater level of risk tolerance than many European supervisors and
Governments have historically been prepared to grant. Against this background one rat-
ing agency estimates that approximately 25% of the EU’s insurers will need to
• Raise capital
• Buy more reinsurance of other risk mitigants
• Reduce risk
• Write less business
• Merge or be acquired
• Close to new business
Rating Agency Perspective
27
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
There are concerns that Solvency II will accelerate consolidation with the EU
but it is also fair to point out that regardless of Solvency II the ability of an insurer to
survive as an independent organisation depends on:
• Being very good at what they do, and either
• Having scale and/or diversity, or
• Having a defendable niche
At the same time, rating agencies are wary about the highly political nature of
the Solvency II project and the ultimate control/influence over national insurance
markets. These include issues of national policyholder guarantee schemes, the possi-
ble rise in uninsurance/unaffordable risks, as insurance companies become more risk
sensitive (e.g. earthquake, flood, construction defects etc) and disincentives for insur-
ers to hold equity investments. They are also concerned over the ability of the EU
insurance industry and regulators to execute the implementation of Solvency II.
There is a shortage of experienced actuaries in the EU and in many cases, insurers’ IT
systems will require overhaul. Supervisors are also under resourced and under skilled,
particularly as regards reviewing the internal models which insurers that are more
sophisticated will wish to utilise. The use of internal models is also likely to be chal-
lenging for rating agencies who will have to invest additional resource to rate the effec-
tiveness of individual companies’ internal models, which will ultimately be reflected
an insurers’ overall rating.
Although Solvency II is a European standard, there is considerable interest from
many other countries as the globalisation of financial markets creates a strong incen-
tive for consistent regulatory standards. Solvency II is not the first principles based
regulatory regime supported by a risk-based capital requirement. Australia and
Switzerland already have such regimes and some captive domiciles (e.g. Isle of Man
and Guernsey) have been subject risk based capital since the early 1980’s.
As a representative Body, counting regulators and supervisors from other 190
jurisdictions the IAIS works to actively promote are working to promote financial sta-
bility. They issue papers and provide guidance and training support on issues related
to best practice insurance supervision on a global basis. The IAIS are developing
Insurance Solvency Requirements (ISRs) as follows
• Structure of Regulatory Requirements
• Capital resources for Solvency Purposes
• The Valuation of Assets and Liabilities, including Technical Provisions for solven-
cy purposes
• Asset Liability Management
• Enterprise Risk management for Capital Adequacy and Solvency Purposes
• The use of internal models for Risk and Capital management Purposes by Insurers
• The Role of the actuary
These ISRs are all well represented in the Solvency II proposals. In this regard,
the IAIS are supportive of Solvency II and are closely monitoring the Solvency II
process to help refine their own guidelines. Through the incorporation of the lessons
InternationalAssociation of InsuranceSupervisors (IAIS)
28
3. Lessons from Solvency II for the Japanese Insurance Market
from Solvency II into their best practice guidelines, the IAIS will be an active global
promoter of Solvency II to regulators non-EU countries such as Japan.
ERM is rapidly gaining acceptance as the benchmark best practice Risk manage-
ment technique and by participating in the QIS questionnaires and preparing for the
implementation of Solvency II, European Insurance Companies are building a strong
platform for their own Enterprise Risk Management (ERM) strategies. Whilst there
are a number of iterations of ERM at its’ heart lies the ability of management to
embed into their organisations an holistic view of the risks the organisation is facing as
a whole and to manage their organisation on a daily basis to mitigate the risks in the
most efficient fashion. ERM has been enthusiastically taken up by many insurance
companies but also by other stakeholders such as shareholders and importantly by reg-
ulators.
Firstly, the actual process itself with a very public feedback system as represented
by the QIS process has been of great help in engaging market participants and fine
tuning proposals. The Japanese insurance market has a number of insurance associa-
tions, which provide input to supervisory authorities, but the value, which can be
gained by making the feedback process even more open, is being clearly demonstrated
by the QIS questionnaires.
The treatment of Groups is a growing issue in Japan as a number of the larger
insurance companies have started to take advantage of recent legislation changes to
amend their corporate structures into holding companies. The drive behind this
move has primarily been a desire by management to diversify their business activities
by line of business and by territory. Having previously, regulated single entity insur-
ance organisations Japanese insurance regulators now face the issue of dealing with
Groups. As has been seen in QIS 3 and QIS 4 the regulation of capital in Insurance
Groups needs to be sensitive to ensure that it does not lead to smaller single insurance
entities being discriminated and market competition being distorted. The changes the
EU Commission will introduce following the completion of the QIS 4 feedback will
provide a valuable insight for all regulators in how to manage this issue.
The globalisation of the Japanese insurance industry requires the management of
Japanese insurers to study Solvency II to ensure that their European subsidiaries are
fully compliant. Similarly, the Japanese FSA needs to enhance their co-operation with
EU regulators to ensure the smooth regulation of the European subsidiaries of
Japanese Insurance Groups. Cross-national co-operation of insurance supervisors is
another of the challenges being addressed under Solvency II. Insurers want the effi-
ciency of being subject to only one regulator whereas national regulators have a keen
interest in protecting their own national policyholders’ interests. The concept of a
“supervisory college” which brings all supervisors under one umbrella for one group is
being discussed in the EU and its development needs to be carefully monitored by
Japanese Regulators.
The perceived reliability of internal models in the banking industry has been put
under pressure with the recent global credit crisis. Against this background, a move to
Lessons for the JapaneseInsurance Market
Enterprise Risk Management
29
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
promote the further use of internal models in the insurance industry is bound to be
controversial and require additional detailed study. In particular, the processes of ver-
ification and the implementation of internal models will need great care. An evolu-
tionary approach is likely to be the best way forward as insurance organisations and
regulators build up their experience of working with internal models. At the same
time regulators have to take care that smaller organisations who are not able to devel-
op their own internal models and have to rely on industry standard models are not
excessively disadvantaged as compared to larger groups who have the resources to
build their own more sophisticated internal models. The treatment of models is a key
area where an exchange of information between the EU insurance industry and the
Japanese insurance industry will greatly assist the Japanese insurance industry as the
use of internal models develops in the Japanese market.
The application of Minimum Capital Requirements (MCR) and Solvency
Capital Requirements (SCR) and the layered ladder of supervisory intervention
between the two, is another key issue for all regulators. On one side is the need for
absolute clarity in the technical calculation of MCR and SCR requirements and the
appropriate level of intervention. These needs have to be balanced against the inter-
ests of policyholders and other stakeholders in an insurance company. Finding an
appropriate balance is another area where the Solvency II project is able to offer valu-
able insights to the Japanese Insurance Industry.
This article has only given a brief overview of the debate surrounding the
Solvency II project but it is clear that there are a myriad of valuable lessons for the
Japanese insurance industry to learn. The unique nature of the EU and the conse-
quent need to obtain support from a wide range of companies and national regulators
is making the process both very open and very thorough. Careful study of the
Solvency II project will provide all members of the Japanese insurance industry with a
deep insight into the issues to be faced when seeking to update and modernise insur-
ance regulation. Ultimately, Japan must adopt its own regulatory practices, which
reflect its own legal system and cultural background and not seek to replicate a
European derived system. However, the process of Japan’s own regulatory develop-
ment will be greatly assisted by learning from Solvency II, adopting some of its better
practices and avoiding some of its pitfalls.
30
In Japan, corporate social responsibility (CSR) is already a feature of many
companies. The system as it stands has become a feature of such companies in the
last five years or so. During which “What is CSR?” became a matter of enquiry,
but even before that Japanese companies had already incorporated environmental
initiatives and compliance measures with some zeal. Thus, question of how CSR
differs from the existing system has often been raised.
Presently, it is becoming a commonly held notion that CSR is an integral
aspect of management. Since CSR contains great deals in their stakeholder, it is
easy to bind company’s operation, organizational strategy, HR strategy, supply
chain management together. In the leading companies, CSR is not handled by the
general affairs or the compliance sections, but instead, held in the departments
that are closer to actual management, such as the management planning depart-
ment.
Where CSR is concerned, there are no textbooks. International guidelines
exist, such as the Global Reporting Initiative (GRI), but observing these is no
guarantee of a “success.” With Japanese companies, there are many who observe a
“triple bottom line” (corporate actions are evaluated with respect to economic
implications, social implications, and environmental implications), but that is by
no means indispensable. In other words, CSR is an idea and a set of actions han-
dled by each enterprise, and it is a creative set of management actions.
In reality, there are some Japanese companies that are strategically undertak-
ing CSR, and activating their employees. They are obtaining the support of cus-
tomers and shareholders. If we evaluate the matters from this point of view,
Japanese companies are currently enhancing their brands through CSR, and in
fact, it can probably be said that a bipolarization is apparent between those compa-
nies improving the corporate brand through CSR, and those that are failing to
achieve proper results.
There are also probably many companies who consider the implementation of
CSR actively for handling scandals. As CSR incorporates elements of governance
and compliance, many Japanese companies have used it as a means of enhancing
their compliance as well.
There are many companies putting compliance departments and setting man-
uals for dealing with these scandals. But with only these measures, it is difficult to
tackle the problems arising effectively. The incidents currently arising in Japan are
not just composed of criminal conduct such as embezzlement and breach of trust,
instead, there are many cases where the perpetrator feels they are acting for the
good of the company. And cases where simply following the orders of superiors
without personal responsibility leading to the scandal. This kind of incident can-
not be adequately tackled simply by the compliance manuals. To deal with such
corporate scandals, the company’s vision and missions must be bound together
with the actual means of doing business. For example, it would be a desirable out-
come for corporations if an employee can judge by oneself whether the course of
action is right or not. In other words, it is desirable that the compliance is highly
4. Mitsuo Ogawa President, Craig Consulting
CSR in Japanese Corporations and the Trendin the Insurance Industry
1. CSR Activity Connected toCorporate Value
2. The Reaction to Corporate Scandals
31
recognized in the corporate culture, so that the employees unconsciously incorpo-
rate the regulations into their work. This suggests the use of CSR to deal with the
scandals.
Among the leading companies, it is not just a matter of settling on a CSR
vision and clarifying the direction of the company. The leading companies are
opening dialogues with stakeholders (calling in experts from outside the company
and launching a discussion of company initiatives) and hearing the voices from
third parties for improving the direction of the company. For example, in
Japanese insurance companies, where sales through agents are common, there are
moves to ensure that customer voices are heard directly by setting up new depart-
ments to collect feedback, so as to ensure through stakeholder dialogue that the
voice of the common customer is fully understood.
Additionally, there are now many cases where NPOs and NGOs are taking
issue with corporate management. There are examples where assertive NGOs
investigate corporate actions and then announce their findings directly via the
Internet. There is one example where NGOs investigated corporation’s sub-
sidiaries, finding that they used child labor in its Asian manufacturing. This was
then announced in the public and it led to a boycott against the company, causing
much brand damage. It should be recognized that corporations not fully incorpo-
rating CSR are facing these kinds of management risks as well.
What sorts of activities are being undertaken by Japanese corporations?
The types of actions being undertaken by each company are detailed in CSR
reports and corporate homepages, so it is comparatively easy to find out the whole
picture. As the above suggests, CSR varies with each company, and there is an
infinite variety of CSR systems in evidence. But speaking generally, it is common
to start with CEO’s message, CSR vision with missions and CSR reports relating
to the areas important to the company and for the stakeholders.
When analyzing the activity of each company, two types of activity emerge;
policies which must be established as being open to the public (“Must” items), and
measures appropriate to the company (“Want” items).
Regarding “Must” items, they are commonly categorized by each stakeholder.
For example, where Japanese companies are concerned, each company may man-
date diversity and a work-life balance (a balance between “work” and “family and
leisure”) as the “Must” items. These “Must” items can be evaluated according to
the degree of employee participation, and the durability of the activities. For this
reason, the company might be announcing a policy of encouraging volunteer
work, however, it is difficult to obtain recognition of such activity from those out-
side the company unless quantitative evidence of its effectiveness comes to light in
the form of participant numbers and years of continuous operation.
On the other hand, “Want” items represent suitable activities for the company.
In Figure 1, the representative CSR activities in Japan are summarized. A
good example will be the volunteer group run by Toyota, “omocha no shu-rizu.”
This group is formed by Toyota’s retired employees, and they utilize their crafts-
3. The CSR in LeadingEnterprises
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
32
manship to repair children’s toys for free. Obviously, this kind of activity is well
suited to Toyota’s manufacturing oriented culture.
The “Want” items possess an originality of the company. Also, this is by no
means a compulsory activity, but with the degree of independent participation
being a key point.
Denso is a major manufacturer of industrial parts, and they are also a leading
company where CSR is concerned. They have a program called “Denso Eco-
Ranger 21.” They use mountains near their factories for children’s field trip,
allowing children to experience nature fully. The guide will be a company
employee. This program is a fine example of CSR since it contains important ele-
ments of CSR like nature, employee participation and youth education.
Mazda Motor Corporation’s “Mazda Specialist Bank” is a program where
employees have their particular skills such as, storytelling and sleight of hand,
recorded in a company’s database. They are then dispatched to appropriate places
for volunteer opportunities according to their skills. Mazda’s program has a strong
regional element, and it skillfully incorporates employee participation and regional
service into a good example of CSR. Their activities and accomplishments are col-
lected for publication on their homepage.
Figure. 1 The activities of the leading companiesCompany Name Policies & Emphasis Examples of CSR Activity
Toyota
Mazda
Denso
IBM Japan
NEC
Shiseido
Sompo Japan
Aeon
Know-how in Toyota manufacturing andpeopleContributing to the invigoration of regionaleconomies and industriesManufacturing and communication
Contributing to IT technology in globalsociety to the maximum extent possibleUtilizing IT and networks, realizing a ubiq-uitous society, solution of global problemsSelective CSR areas: Makeup, Women,Cultural capital (aesthetics)
Emphasizes: Welfare, Environment, Art
Regionally integrated social activity
Omocha no shu-rizu, collaboration withNPOs, introduction of children to artistsMazda Specialist Bank
Denso MuranBoys and Girls Development ClubWorld Community GridEducational improvement programNEC IT education for mothers with childrenNEC enterprise social developmentPersonal grooming lessons for the elderlyBeauty consultancyHanatsubaki FoundationSeiji Togo Memorial Sompo Japan Museumof Art, and similar contributions to artYellow receipt happiness campaign
4. CSR in Japanese Corporations and the Trend in the Insurance Industry
33
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
CSR must be a sustainable action. In other words, for the company incorporat-
ing CSR, it is undesirable to undertake donations or reforestation activities only
when they gain profit, but abandon them when their profits slide. In the 1980s, cor-
porate patronage of the arts was common in Japan. They donated money to muse-
ums, galleries and local music ceremonies. However, once their business went slow,
these activities did not last long. As a result of these experiences, CSR is emphasized
that it should be a sustainable action.
So what can be done with regard to continuing CSR irrespective of corporate
earnings? As much as possible, the corporation should stick to social activities close
to its main business activities. The most sustainable approach to CSR is through
using the technologies and business model acquired by the main corporate activities,
which are strengths or competencies of the company. The reason for this is that
with CSR having a close connection to daily business, CSR in turn has a positive
feedback on its business which is a different from the one time contribution
explained in the above.
As Figure. 2 explains, Japanese companies are striving for maximizing their
profit in 1980s. Companies with good earnings were recognized as good companies
at that time. (Figure. 2 - ①) However, rather than a devotion to the profits, voices
rose in support of a new view that companies should also have a social significance.
(Figure. 2 - ②) An example is the legally mandated compliance requirement to
employ disabled persons. Even if there is a social meaning to this, companies gradu-
ally came to realize that it was something they must do, and that there are advantages
to the enterprise from undertaking socially responsible activities on a sustainable
basis. (Figure. 2 - ③) In other words, it came to be realized that CSR brings advan-
tages to the enterprise but, if these are not coupled with economic gains, then CSR is
difficult to continue in a sustainable manner.
4. Activities through theCore Business
Figure. 2 Compatibility with corporate and social merit
34
It was also realized that relying just on the enthusiasm of a few volunteering
employees is also not sustainable. As the above mentioned, Toyota and Denso schemes
may be a basic model, but the point will be that the companies utilize their strengths
and build mechanisms for their employees to cooperate and take the action voluntarily.
The development of CSR in the Japanese insurance industry is remarkable, espe-
cially in the non-life insurance market. For example, Tokio Marine Nichido Fire
Insurance has long been involved in mangrove planting. The president of the compa-
ny has been involved in planning the planting in South East Asia. In recent years, a
100-year mangrove planting proclamation was announced. This was a strong declara-
tion to the effect that, whatever happened, mangrove planting would continue for
100 years, and this tree planting is becoming a trademark feature of the company.
Having company members with actual planting stories assist in school environmental
education and speaking directly to students, was a great aid in this practice.
Another effort worthy of mention by the same company is that they relate to
the industrial cooperation with academic research into the arrest of global warming.
(See Figure. 3)
Tokyo University and others are conducting simulations into the consequences
of global warming, particularly with regards to possible consequences for Japan in
terms of the increased incidence of typhoons when global warming continues. This
kind of collaborative research is not just a matter of research contributions; but also
involving company members’ participation in the research. The results are not just
the dissemination of research findings into global warming. As global warming is set
5. CSR Activity in theJapanese InsuranceIndustry
4. CSR in Japanese Corporations and the Trend in the Insurance Industry
Figure. 3 Tokio Marine & Nichido’s global warming research
35
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
to influence on a global scale, the company can participate in developing these find-
ings as a good reference for new businesses. Also, it is not difficult to imagine what
kind of effects these kinds of programs might have on raising employee motivation.
Therefore, such “Want” items can be evaluated as favorable long-term investments
which improve corporate value directly.
In Sompo Japan, a CSR vision of a following statement comes straight from the
top; “In my tenure, I promise Sompo Japan will become the best company for
women to work comfortably.” Needless to say, a work-life balance is heavily con-
cerned for the issue of female employment, but the company also investigated how
CSR training might be fulfilled in its corporation. A CSR literacy-training program
was instituted for new employees. There are another CSR training where employees
freely express their opinions on both the CSR reports of own company and those of
others. These CSR trainings are diffused throughout different levels of the employ-
ment. This sort of policy in which increasing internal corporate understanding,
directly contributes to achieving the goals of senior management mentioned above.
Non-life insurance companies, in the same manner as Tokio Marine Nichido
Fire Insurance, are active in climate change research. Emissions trading and carbon
offsets (to offset carbon dioxide emitted) are an aspect of handling global warming
likely to be subject to particularly proactive activities for them.
Also, if we observe the activities of overseas reinsurance companies, for example
in Lloyds, statistically minded underwriters are assisting with mathematics education
in local elementary schools. By utilizing their own knowledge of risk management,
they conduct educational activities using their “know-how” from their core business,
and they can also contribute to society through environmental education at their
local schools. Such a system can also be anticipated from Japanese non-life insurance
companies in the future.
Compared with non-life insurance companies, life insurance companies in
Japan have yet to regularize their CSR. Infectious diseases and ecological effects are
greatly influenced by the effects of global warming. Life insurance companies have a
great deal of leeway in tackling social problems given their competencies in these
areas. Much can be expected of them.
As has been seen, Japanese CSR is diverse. It encompasses many issues, and
places corporate strengths and special competencies center stage. Corporations are
ridding themselves of the view that CSR activities must be tangential to the main
business, and that they merely comprise corporate giving. Instead, CSR can be
thought of as part of a corporate strategy, improving corporate value in the final
analysis. So, what are the issues emerging hereafter?
The major issue is not to allow CSR to be restricted to the HQ and concerning
only some of the employees, but instead, making CSR to permeate every level of the
company. If it is simply viewed by regional offices as yet another new initiative from
head office, its penetration rate will be unable to increase in the company and this
will impair the growth in corporate value, even they have a great policy in CSR.
Obviously, the most important factor in CSR is the employee element. If
6. The Issues from Hereon
36
employees cannot be made active partners in CSR, then there is no way that cus-
tomers, clients, and shareholders can be brought on board. The effectiveness of even
the most well leveraged brand or market opportunity will be halved unless CSR is
accompanied by employee mobilization.
As stated previously, CSR policy can be divided into “Must” and “Want” items,
but this also means that the “Want” item is connected to the solution to social prob-
lems through the application of management resources. How the CSR activity is
connected to employee efforts is a key point if success is to be attained.
So, how is CSR activity related to improvements in employee motivation? The
key is to involve employees in the activity. As it is a system of employee participa-
tion, much of the content yields a contribution to society at large.
As stated, performing the social activities in a manner that engages the strengths
of the enterprise is what constitutes a sustainable activity. It is thus possible to con-
tribute to such issues as environmental problems, youth development and regional
issues, while engaging every aspect of the corporation’s management resources, and
employing the corporation’s business models and technology. Utilizing employee
action in the same manner is also necessary.
If employees participate in making contributions to the society, opportunities
can be created for them to make use of their accumulated skills and experience. In
other words, they will come to see the skills and techniques they acquired as being
useful to society and will therefore be delighted to possess them. There is nobody
who fails to be moved when their actions are appreciated by those around them. If
we put it rather grandiloquently, their lives thus far are affirmed, and they gain self-
confidence when they engage in these activities.
If this is the case, they will come to want to further their skills for the good of
society and be further encouraged by those around them. The motivating factors
behind the efforts of the young people of today are not just wages and promotion,
there is also a desire for personal development, and an urge to do good for the world
and for others. CSR activities can have a direct influence on this new motivation for
work.
If employees can utilize their skills and experience in social activities, then they
can come to see their company as a place where they can accomplish this, and so take
pride in it. Pride in one’s company aids employee attachment, and the positive
effect on other employees of having more of these highly motivated co-workers is
great. With this, CSR activity can engender the creation of a virtuous cycle.
A highly developed corporate culture can be created from the positive work atti-
tude engendered by CSR. Pride in one’s skills and experience, pride in one’s post,
colleagues, and company, all of these make the employee think well of the company
to the extent that they wish to tell others outside the company, which in turn is likely
to have a positive effect on the company’s reputation with society at large. If the joys
of participation in CSR activity can be embedded in the company, then the scandals
mentioned at the beginning can be avoided through the corporate culture, as embod-
ied in thoughts such as “this kind of activity is unacceptable,” based on values which
are held unconsciously by the employees. This is the ultimate aim of CSR.
4. CSR in Japanese Corporations and the Trend in the Insurance Industry
37
5. Underwriting & Planning Department The Toa Reinsurance Company, Limited
Trends in Japan’s Non-Life Insurance Industry
(1) Trends in the Domestic Market
Japan's non-life insurance industry recorded sluggish premium income for fiscal
2007, reflecting lower housing starts in the wake of the amendments to the Building
Standards Act, which adopted stricter building certification standards, and lower sales
of automobiles. Meanwhile, premium income rose for commercial insurance, such as
liability insurance and marine insurance, supported by the buoyant business perform-
ance of corporate customers.
Subprime-related losses that initially raised concern have turned out to be on the
whole modest, with the exception of certain domestic non-life insurance companies
recording considerable loss provisions.
New developments in the industry included the entry of three new insurance
companies: H.S. Insurance, established by HIS Co., a major travel agent, and others;
SBI Insurance, a joint venture between SBI Holdings, a financial holding company,
and Aioi Insurance; and Adlick Insurance, a joint venture between Advance Create, a
non-life insurance agent, and Aioi Insurance. In addition, Mitsui Sumitomo Insurance
announced that it would establish Mitsui Sumitomo Insurance Group Holdings, a
holding company, and list its shares on the stock exchange, also announcing the inclu-
sion of three group life and non-life insurance companies among its subsidiaries.
(2) Expansion into Overseas Markets
In response to a decline in the size of the domestic market, reflecting the falling
birthrate and an aging population, Japanese non-life insurance companies have been
taking steps to strengthen their overseas operations. In fiscal 2007, active overseas
initiatives included the acquisition of Kiln Ltd. by Millea Holdings (Tokio Marine
Holdings) of the United Kingdom. Recent major overseas initiatives are summarized
as follows
1. Industry Trends
Date Company Name Recent Overseas Initiatives
June 2007 NIPPONKOA Establishment of a representative office in New DelhiInsurance
June 2007 Aioi Insurance Acquisition of a license to operate branches in Tianjin, China
September 2007 Sompo Japan Insurance Acquisition of permission to establish a Shanghai branch ofSompo Japan China
October 2007 Mitsui Sumitomo Announcement of the commencement of non-life insurance Insurance operations for local companies in Germany
November 2007 Tokio Marine & Establishment of Tokio Marine Middle East in the Dubai Nichido Fire Insurance International Financial Centre
December 2007 Mitsui Sumitomo Commencement of operations of Mitsui Sumitomo Insurance Insurance (China)
December 2007 Tokio Marine & Establishment of a Takaful joint venture company in EgyptNichido Fire Insurance
March 2008 Millea Holdings Acquisition of Kiln Ltd. of the United Kingdom
(Tokio Marine Holdings)
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
38
(3) Product Development Trends
Primary insurance companies have been simplifying their products to prevent the
recurrence of problems associated with the nonpayment of claims, for example by consol-
idating products whose coverage overlaps that of other policies, and abolishing special
clauses with low demand.
As these primary insurance companies will continue to promote products and spe-
cial clauses that entertain strong demand, the consolidation is expected to have almost no
impact on premium income. While simplifying the details of products, primary insur-
ance companies have been shoring up their sales agents' training to prevent administra-
tive errors in product explanation, contract management and claim payment obligations.
(4) Sales Channel Trends
Restrictions on bancassurance sales have been phased out since April 2001 as part of
the liberalization of financial regulation. They were finally removed altogether in
December 2007 with the end of restrictions on products including whole life insurance,
term insurance, medical care insurance and motor insurance. With the slowdown in the
loan business, banks have been actively promoting sales of insurance from which banks
can generate commission income. Regional banks are characteristically focusing on prod-
ucts with reasonably simple insurance details, such as medical care and cancer insurance,
so that bank staff can easily explain products to customers. On the other hand, major
banks sell not only medical care and cancer insurance, but a wide range of other prod-
ucts, such as mortality insurance and nursing care insurance.
Japan Post, which was privatized in October 2007, has also begun bancassurance
sales of the motor insurance of seven primary insurance companies.
(5) Trends in Small-Claims and Short-Term Insurance Businesses and Unregulated Co-Operatives
The Insurance Business Law has not in the past been applicable to unregulated co-
operatives, even though they sell insurance-type products, because such services were con-
sidered to be mutual aid among specific parties. These unregulated co-operatives were
requested to initiate procedures to become insurance companies or small-claims and
short-term insurance businesses, or to terminate their operations, by March 2008.
Consequently, many co-operatives are expected to terminate their operations because
they cannot provide the human resources or systems that are required for registration, or
because their products do not meet the requirements. Small-claims and short-term insur-
ance businesses are a new category of insurance company that has been approved in line
with the revision of the Insurance Business Law enforced in April 2006. Although the
sum insured and period of products they can handle are restricted, establishing small-
claims and short-term insurance businesses is easier than establishing insurance compa-
nies as the minimum capital required is 10 million yen, whereas capital of 1 billion yen is
required for insurance companies.
Companies that have launched small-claims and short-term insurance businesses
5. Trends in Japan’s Non-Life Insurance Industry
39
have characteristically developed niche markets, in which major life and non-life insur-
ance companies have not been operating, including earthquake insurance not linked with
fire insurance (stand-alone EQ), pet insurance and insurance for people with diabetes.
The combined fiscal 2007 revenue of the 25* companies in the General Insurance
Association of Japan decreased due to lower revenues in the core motor and fire insurance
sectors. Factors such as increased expenses caused ordinary income and net income to
decrease as well.
Net premium income decreased 0.9 percent, or ¥67.1 billion, compared with the
previous fiscal year to ¥7,470.0 billion. Marine insurance remained strong because of
energetic shipping activity, but premium income decreased in the core motor and fire
insurance sectors.
Net claims paid decreased ¥0.7 billion, compared with the previous fiscal year to
¥4,336.7 billion. Although there was an increase in claims paid in the motor and person-
al accident insurance sectors, claims paid in the fire insurance sector decreased because of
fewer typhoons and other natural disasters. These factors counterbalanced each other,
resulting in net claims paid that were essentially unchanged from the previous fiscal year.
Operating and general administrative expenses related to insurance underwriting
increased 5.3 percent, or ¥61.8 billion, compared with the previous fiscal year to
¥1,222.8 billion. Factors included expenses incurred as companies upgraded internal sys-
tems to restore trust after problems including the non-payment of claims. Moreover, the
expense ratio increased 1.0 percentage point to 33.2 percent.
Although net premium income decreased, the total underwriting loss of ¥63.9 bil-
lion represented an improvement of ¥40.9 billion compared with the total underwriting
loss of ¥104.7 billion for the previous fiscal year, due to a reduction in payout of insur-
ance benefits due to typhoons and other natural disasters.
Ordinary income including investment income decreased ¥36.4 billion compared
with the previous fiscal year to ¥378.4 billion. Net income decreased ¥14.2 billion com-
pared with the previous fiscal year to ¥236.8 billion.
* Adlick Insurance Company, Limited is not included in the above 25 members of the GeneralInsurance Association of Japan because it began operations in fiscal 2008.
(1) Better Regulations
The Financial Services Agency has set the so-called “better regulation,” an improve-
ment in the quality of financial regulations, as one of the major themes of its financial
administration. “Better regulation” is a supervisory method based on the principle of a
more advanced supervisory regime that monitors compliance based on rules, which mon-
itors whether insurance companies voluntarily improve structures for business manage-
ment and operational executions in accordance with more sophisticated principles and
goals. In accordance with the above policy, the Financial Services Agency will take meas-
ures to improve communication with financial institutions, strengthen the capacity of the
provision of information, enhance cooperation with overseas supervisory organizations,
strengthen market research capabilities, and improve the quality of staff.
2. Overview of Results for Fiscal 2007
3. Regulatory Topics for Fiscal 2007
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
40
5. Trends in Japan’s Non-Life Insurance Industry
(2) Review of the Calculation Method of Solvency Margin Ratio
The solvency margin ratio represents the level of capacity of insurance companies to
make payments against risks that exceed ordinary projections. This ratio was introduced
when the Insurance Business Law was revised in 1996. Since the further revision of the
Insurance Business Law in 1999, should the ratio fall below 200 percent, the FSA directs
the companies to take early remedial action.
The method of calculating the solvency margin ratio has been reviewed when neces-
sary in the past, and the FSA is currently reviewing it again to ensure that the present cal-
culation standards reflect the present state of the financial markets, and to identify
improvements that need to be made to the method to bolster risk management and the
financial strength of insurance companies. In accordance with the proposal to revise the
calculation method, insurance companies are required to deal with risks of fluctuations of
the prices of shares and bonds held with a low probability by taking into account risks
that could take place once in twenty years, instead of taking into account risks that could
take place once in ten years as practiced currently.
(3) Revision of the Insurance Law
The Ministry of Justice has submitted a proposal to revise the Insurance Law, which
sets out the basic rules of insurance contracts, for the first time in a hundred years.
As the current Law does not define third sector insurance products, such as cancer,
hospitalization, and nursing care insurance, these products have been handled in accor-
dance with the clauses of the policy provisions of insurance companies. The revised
Insurance Law will set out prescriptions associated with third sector products, in addition
to non-life and life insurance. Moreover, with respect to disclosure, at present, the details
that should be notified to insurers are not clearly defined, and violations of the duty of
disclosure, caused by failing to submit notification, have resulted in cases of non-pay-
ments of claims. To rectify these problems, the method of notification will be changed
in that policyholders will henceforth reply to questions asked by insurance companies.
Losses from major natural disasters during fiscal 2007 were as follows.
(1) Earthquake
(2) Wind and Flood Damage
Not applicable
Although only a few natural disasters took place during the period, a series of large
fires occurred, including those of Shin-Etsu Chemical and Mitsubishi Chemical, adverse-
ly affecting performance in the fire insurance sector. Primary insurance companies are
looking closely into this issue.
4. Fiscal 2007 Data on Losses from MajorNatural Disasters
Name of Loss Date of Loss Claims Paid (JPY Million)
2007 Niigata Chuetsuoki July 16, 2007 7,798Earthquake
41
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
6. Life Underwriting & Planning Department The Toa Reinsurance Company, Limited
Trends in Japan’s Life Insurance Industry
In one of the most significant events to impact the Japanese life insurance
industry in recent years, restrictions on bancassurance sales were completely lifted in
December 2007. Until then, bancassurance sales had been limited to products such
as individual annuity insurance, single payment endowment insurance and single
payment whole life insurance. However, banks are now able to sell every type of
insurance, and a succession of life insurance companies that use bancassurance sales
as their primary sales channel have been established. Moreover, intensifying compe-
tition in the life insurance industry has spurred activity such as alliances, group
restructuring and capital increases.
An overview of newly established life insurance companies, alliances and other
major developments since April 2007 follows.
(1) Japan Post Insurance Established
On October 1, 2007, the Postal Privatization Law established the Japan Post
Group, and member company Japan Post Insurance Co., Ltd. began operations.
With total assets of approximately JPY112 trillion, Japan Post Insurance surpassed
Nippon Life Insurance Company as Japan’s largest life insurance company.
However, sales of its main product, endowment insurance, have been sluggish due to
the impact of low interest rates. The annual aggregate of sums insured under new
contracts has decreased for 11 consecutive years, with the result that Japan Post
Insurance has moved to acquire new contracts by relaxing age restrictions and
increasing the maximum policy limit from JPY10 million to JPY20 million. Japan
Post has submitted an application to sell such new products. At the same time,
Japan Post Insurance has also received authorization as part of its strategic plan to
conduct commission sales of corporate insurance products covering senior managers
that are underwritten by eight life insurance companies.
(2) Demutualization and Public Listing of Dai-ichiMutual Life Insurance
In October 2007, Sony Financial Holdings Inc., the holding company of Sony
Life Insurance Co., Ltd., conducted a public offering. Subsequently, one of Japan’s
four major life insurance companies, Dai-ichi Mutual Life Insurance Company,
announced its intention to become a stock company and list its shares in 2010.
Other formerly mutual life insurance companies that became stock companies to
facilitate fund procurement and improve management transparency to market are
Daido Life Insurance Company in 2002, Taiyo Life Insurance Company in 2003
and Mitsui Life Insurance Company Limited in 2004.
1. Life Insurance Industry Trends
42
(3) Newly Established Life Insurance Companies
A succession of new life insurance companies was established as a result of the
lifting of all restrictions on bancassurance in December 2007. As of June 2008,
there were 44 Japanese life insurance companies.
a) Dai-ichi Frontier Life Insurance Co., Ltd.
Dai-ichi Mutual Life Insurance Company established this wholly owned subsidiary,
with no proprietary sales network, to specialize in the supply and underwriting of
bancassurance products. Initially, it is handling individual annuity insurance prod-
ucts. It is the first wholly owned domestic life insurance subsidiary established by a
Japanese life insurance company.
b) Crédit Agricole Life Insurance Company Japan Ltd.
France-based Crédit Agricole Group established this wholly owned subsidiary in
anticipation of the lifting of bancassurance sales in Japan. It is the first entry to the
Japanese life insurance market for approximately five years. Its initial strategy was to
sell variable annuity insurance for the mass retirement of Japanese baby boomers.
c) Allianz Life Insurance Japan Ltd.
The Germany-based Allianz Group also established a wholly owned subsidiary,
Allianz Life Insurance Japan Ltd., to sell variable annuity insurance through the ban-
cassurance channel.
d) SBI AXA Life Insurance Co., Ltd.
Three companies established SBI AXA Life Insurance Co., Ltd.: SBI Holdings Inc.,
AXA Japan Holding Co., Ltd., and SOFTBANK CORP. It is the first life insurance
company in Japan to specialize in Internet sales, and handles term insurance and
medical care insurance.
e) Lifenet Insurance Company
Lifenet Insurance Company was licensed as a life insurance company, which deals
with term insurance for death benefit and whole life insurance for medical care using
the internet as its main sales channel. Financial institutions and investment partner-
ships established the company, and there is no insurance company among its share-
holders.
(4) Corporate Restructuring
Several companies also restructured internal group businesses due to the lifting
of restrictions on bancassurance. As a result of the merger of the AXA Group and
the Winterthur Group, Winterthur Swiss Life Insurance Co., Ltd., which had
already become a wholly owned subsidiary of AXA Japan Holding Company
Limited, changed its name to AXA Financial Life Insurance Co., Ltd. Going for-
ward, it will work with AXA Life Insurance Co., Ltd. as both companies restructure
sales channels in stages with a policy of specializing in bancassurance sales through
financial institutions.
6. Trends in Japan’s Life Insurance Industry
43
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
In the meantime, 80 percent of the shares of The Kyoei Kasai Shinrai Life
Insurance Company, Limited were acquired by Fukoku Mutual Life Insurance Co.,
and the company began selling insurance under the new name Fukokushinrai Life
Insurance Company, Limited. The new entity will take over sales of the life insur-
ance products that Fukoku Mutual Life had been retailing through financial institu-
tions.
(5) Alliances
The alliance between the newly privatized Japan Post Insurance and Nippon
Life Insurance Co. was the largest announced during fiscal 2007. Nippon Life will
provide Japan Post Insurance with its expertise in new product development, admin-
istration, systems development and risk management. In addition, the alliance will
strengthen Nippon Life’s relationship with Japan Post Insurance’s main sales chan-
nel, Japan Post Holdings and its group companies.
Other companies also worked on alliances. Sompo Japan Insurance Inc. and
Dai-ichi Mutual Life Insurance invested in their respective subsidiaries Sompo Japan
DIY Life Insurance Co., Ltd. and Dai-ichi Frontier Life Insurance Co., Ltd. to
strengthen an alliance covering life and non-life insurance. Sony Life Insurance Co.,
Ltd. and Sony Bank Inc. created an intragroup alliance, and Meiji Yasuda Life
Insurance Company and The Bank of Tokyo-Mitsubishi UFJ, Ltd. formed an
alliance between industries with the objective of expanding transactions with small
and medium-sized companies by referring customers to each other.
(6) Insurance Companies that Increased Capital
A number of companies increased capital, primarily the life insurance sub-
sidiaries of non-life insurance companies, due to factors including more stringent sol-
vency margin regulation, which governs the guaranteed minimum benefit for vari-
able annuities. An overview follows.
Sompo Japan Himawari Life Insurance Co., Ltd. JPY20.0 billionTokio Marine & Nichido Financial Life Two increases totalingInsurance Co., Ltd. JPY15.0 billionMitsui Sumitomo MetLife Insurance Co., Ltd. JPY5.1 billionSumitomo Life Insurance Co. JPY50.0 billion*Aioi Life Insurance Co., Ltd. JPY10.0 billionSompo Japan DIY Life Insurance Co., Ltd. JPY3.5 billionING Life Insurance Japan Co., Ltd. JPY10.0 billion
* Sumitomo Life is a mutual company, and increased its capital through subscriptions rather thanissuing shares.
44
The fiscal Year 2007 results for 40 life insurance companies in Japan are as follows:
• Total Amount of New Contracts
During fiscal year 2007, the total insured amount under new individual insurance
contracts for all 40 companies decreased 13.7% from the previous fiscal year to
JPY58.6 trillion, due to continuing weakness in the market for death benefit prod-
ucts. Sales of individual annuities, which had been positive until the previous fiscal
year, also decreased 10.2% to JPY8 trillion because of stagnating sales through
bancassurance channels.
• Business in Force
As of the end of fiscal year 2007, individual insurance contracts in force decreased
4.5% to JPY979.4 trillion. Results at foreign-affiliated companies and subsidiaries
of non-life insurance company were solid, although the performance of large com-
panies was sluggish. On the other hand, individual annuities in force increased
2.5% from the previous fiscal year to JPY87.9 trillion, the fifth consecutive annual
increase. Group insurance in force, which decreased in fiscal year 2006, increased
3.4% to JPY374.2 trillion. And group annuities decreased 2.4% to JPY32.3 tril-
lion.
• Annualized Premiums
The total of annualized premiums from the new contracts of individual insurance
and individual annuities decreased 10.2% from the previous fiscal year to JPY2.2
trillion. In-force business produced a steady result in annualized premiums, rising
1.4% from the previous fiscal year to JPY19.6 trillion, due to an increase in indi-
vidual annuity but a drop in death benefit products.
• Premium Revenues
Premium revenues decreased, for the second consecutive fiscal year, 1.8% to
JPY27.9 trillion, because of sluggish sales of increasing term life insurance for cor-
porate owners due to a change in the Japanese tax system.
• Total Assets
Total assets, which are posted at the price current at the end of the fiscal year,
decreased 2.8% to the level of JPY213 trillion due to the drop in stock prices.
All restrictions on bancassurance were lifted in December 2007, but variable
annuities continued to account for a large percentage of new products launched for
that channel. The number of new death benefit and medical care products launched
for the channel remained limited. Standards for the sales system for death benefit
and medical care products are not yet fully in place at financial institutions, and so
future developments remain a subject of interest.
Fiscal 2007 trends for other main products are outlined below.
(1) Increase in Products with Less Declaration
With the continued decline in new contracts, life insurance companies are work-
ing to attract senior citizens who had difficulty buying conventional products because
2. Life Insurers: Trends in BusinessPerformance
6. Trends in Japan’s Life Insurance Industry
3. Product Trends
45
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
of pre-existing physical conditions. In 2005, Sumitomo Life became the first to
launch a product with a reduced number of declaration items, the whole life insur-
ance product Senkyaku Banrai. In fiscal 2007, five companies launched six such
products, primarily in the medical care segment. Among them, American Life
Insurance Company launched a whole life insurance product and a bancassurance
medical care insurance product limited to two declaration items, the smallest number
ever. Moreover, in fiscal 2008 the Japan Mutual Insurance Federation of Agricultural
Cooperatives launched a cooperative medical product with less declaration.
SBI AXA Life Insurance Co., Ltd., a newly established company that specializes
in the Internet channel, launched a term insurance that is not a product with less
declaration but does offer a sum insured of up to JPY40 million depending on the
declarations. This is the first product of its kind, as the typical sum insured for poli-
cies written according to declarations alone is JPY15 million.
(2) Variable Annuities
While all restrictions on bancassurance have been lifted, variable annuities
remain the main bancassurance product. However, formerly brisk sales of individual
annuities weakened, with the sum insured for new contracts written in fiscal 2007
decreasing 10.2 percent compared with the previous fiscal year. Moreover, the suc-
cessive establishment of life insurance companies to serve the bancassurance channel,
primarily with variable annuity products, indicates that competition will intensify.
Two types of variable annuity products are now available, one with minimum
guarantees for items such as accumulated capital and death benefit, and another that
is simplified guarantee expenses in order to increase fund management efficiency.
For the first type in particular, companies are using various features to differentiate
their products from those of other companies. Products include those with ratchet-
type for accumulated capital and death benefit, products that set asset management
targets when the contract is written and secure the gains when these targets are
achieved, and roll-up products that have a policy reserve guarantee minimum that
increases every year at a fixed rate until it reaches a cap.
(3) Cancer Insurance
Fiscal 2007 was notable for the introduction of a large number of cancer insur-
ance products.
Zurich Life Insurance Company launched a product that only pays a single
diagnosis benefit if the insured is diagnosed with cancer. The diagnosis benefit
increases in stages every year, and if the insured is not diagnosed with cancer during
the term of indemnity, the policy pays a no-claim benefit equivalent to total premi-
ums paid.
Sumitomo Life launched a product that allows a policyholder diagnosed with
incurable cancer to claim the sum insured under a whole life policy without refer-
ence to life expectancy. For some time, many companies have been selling living
needs riders that allow policyholders to claim the sum insured if diagnosed with a
46
six-month life expectancy, but doctors found such life expectancy declarations diffi-
cult. A key feature of the Sumitomo Life product is the lack of reference to length of
life expectancy, although a fixed amount such as interest and premiums for 3 years is
deducted from the sum insured.
(4) Products with Claim Payments Easily Understood byPolicyholders
An important topic in the life insurance industry during fiscal 2007 was the
investigation to life insurance companies ordered by the Financial Services Agency
(FSA) into the non-payment of claims. The FSA demanded a report on whether
additional payments were needed for specified benefits or obligations in all instances
requiring payment of claims and other disbursements over the past five years. As a
result of this investigation, all life insurance companies strengthened claims examina-
tion systems to ensure appropriate payment of insurance benefits, and also took steps
such as adding system check functions to prevent nonpayment. Some companies
also recognized that the products themselves had become too complex because of
their many riders, and moved to simplify products. For example, the Japan Mutual
Insurance Federation of Agricultural Cooperatives placed indemnity in riders within
the master contract. In other examples, Dai-ichi Mutual Life Insurance linked the
payment of surgical operation benefit to the operations covered by public medical
care insurance, and Tokio Marine & Nichido Life Insurance simplified its cancer
insurance into diagnosis and hospitalization benefits.
(5) Expenses for Obtaining Medical Certificates
Although not a new product, the number of companies that pay a set JPY5,000
for policyholders to obtain a health certificate has increased. This expense is paid to
policyholders if they could not receive the claim, benefit or other issue although they
applied. More than 10 companies, centered on foreign-affiliated firms such as three
companies in the AIG Group, are paying this expense to make payment of insurance
claims more appropriate and to lighten the burden of expense for policyholders mak-
ing claims. On the other hand, Sumitomo Life has taken steps such as accepting a
death certificate in lieu of a medical certificate in a specific form for applications for
death benefits in working to lighten the burden on policyholders by limiting the
instances in which policyholders must obtain a medical certificate from a doctor.
Although new overseas developments were less numerous than in fiscal 2006,
Dai-ichi Mutual Life Insurance concluded a contract with India’s national bank,
Bank of India, and Union Bank of India to establish a joint venture life insurance
company. This was the first time a Japanese life insurance company has invested in
the Indian primary market.
Elsewhere, Tokio Marine & Nichido Fire Insurance, which is another member
of Tokio Marine & Nichido Life Insurance’s holding company’s group, decided to
6. Trends in Japan’s Life Insurance Industry
4. Overseas Strategies ofLife InsuranceCompanies
47
The Toa Reinsurance Company, Limited — Japan’s Insurance Market 2008
cooperate with Egypt Kuwait Holding Company, S.A.E. to establish two Takaful
joint ventures in Egypt. One is a general Takaful, corresponding to a non-life insur-
ance company, and another is a family Takaful, corresponding to a life insurance
company.
The Insurance Business Law was amended in April 2006. As a result, in order
to enhance business soundness and protect consumers, co-operatives not controlled
under any specific law must acquire approval to become either an insurance compa-
ny or a small-claims short-term insurance provider during a transitional period, or
else transfer existing contracts to another company and terminate operations. At the
March 31, 2008 deadline for registration applications, 31 life and non-life had regis-
tered. Among them, 10 companies handle life and medical care insurance.
Limitations on the products of small-claims short-term insurance providers
include a maximum death benefit of JPY3 million according to disease and a maxi-
mum term for life insurance and medical care insurance of one year. At the same
time, the operating and minimum capital requirements for small-claims short-term
insurance providers have been relaxed compared with ordinary insurers.
Consequently, new companies have been established, such as MC S.S. Insurance
Co., Ltd., established jointly by Mitsubishi Corporation and Aon Affinity Japan Ltd.
However, reserves, solvency margin ratio and other requirements are set at the same
level as those for insurance companies.
For several years, FSA supervision of insurance companies has characteristically
focused on enhancing policyholder protection, including the appropriate sales struc-
ture and the structure of systems for payout of insurance benefits.
In addition an insurance law proposal was passed in May 2008. While insur-
ance contract is regulated under the Commercial Code, the new proposal seeks to
create a separate law for insurance contracts. The Commercial Code only specifies
life insurance and non-life insurance, so new insurance definition has been added for
medical care and personal accident insurance.
In addition, over the past several years regulations governing reserves have been
strengthened to enhance insurance company soundness in the areas of medical care
and personal accident insurance risk and the risk associated with the guaranteed min-
imum benefit for variable annuities. However, a significant revision of the method
of calculation of the solvency margin ratio, which is an indicator of the soundness of
insurance companies, is also planned. It will entail revision of the risk coefficient
based on performance, and includes an increase in the confidence level from 90 per-
cent to 95 percent.
6. Trends in theSupervision ofInsurance Companies
5. The Small-ClaimsShort-Term InsuranceBusiness
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48