International Association

of Insurance Supervisors

Insurance and Financial Stability

© International Association of Insurance Supervisors (IAIS) November 2011

 Table of content

1. Introduction and executive summary .............................................................................. 3

2. Salient insurance characteristics..................................................................................... 6
2.1 The insurance business model .............................................................................. 6
2.2 The funding model ................................................................................................. 6
2.3 The insurance balance sheet ................................................................................. 8
3. The business spectrum of insurers and insurance groups............................................ 11
3.1 The traditional insurance business ...................................................................... 11
3.2 Non-traditional and non-insurance business activities ......................................... 12
3.3 Interim conclusion ................................................................................................ 16
4. Market structure and industry size ................................................................................ 17
4.1 Market structure ................................................................................................... 17
4.2 Industry size by assets and market capitalisation ................................................ 20
5. Insurance in the financial system .................................................................................. 23
5.1 The investment function ....................................................................................... 23
5.2 Reinsurance ......................................................................................................... 25
5.3 Insurers and systemic risk ................................................................................... 30
6. Potentially systemic insurers and policy measures ....................................................... 32
6.1 Identifying systemic relevance ............................................................................. 32
6.2 Policy measures .................................................................................................. 32
7. Concluding remarks ...................................................................................................... 34
References ............................................................................................................................. 35
Appendix ................................................................................................................................ 36
A1: Insurance runs in Hong Kong and Singapore ...................................................... 36
A2: State intervention in the Netherlands ................................................................... 37
A3: The Failure of AIG’s CDS Business ..................................................................... 39
A4: Swiss Re’s experience in CDS underwriting ........................................................ 41
A5: Equitable Life ....................................................................................................... 42
A6: Equitas ................................................................................................................. 43
A7: Securities lending at AIG ..................................................................................... 44
A8: Market contagion caused by fire sales ................................................................ 45
A9: The failure of HIH ................................................................................................. 46

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1. Introduction and executive summary
1. This paper presents a supervisory perspective on the (re)insurance sector and
on financial stability issues. It analyses the sector’s role in the financial markets, including
its interaction with other financial institutions, and its impact on the real economy. In addition,
the International Association of Insurance Supervisors (IAIS) endeavours to clarify the
rationale of its proposed methodology to identify any institutions “whose disorderly failure,
because of their size, complexity and systemic interconnectedness, would cause significant
disruptions to the wider financial system and economic activity.”1

2. The business model exposes insurers to unique risks, which are not typically
found in banking. Unique in insurance underwriting are, for example, mortality, morbidity,
property and liability risks. Insurers are, however, also exposed to risks found in other finan-
cial institutions including credit risks, operational risks, and market risks related to equity
investments as well as movements in interest rates and exchange rates. While these risks
are not unique to insurance, they can arise in unique ways as result of the specific business
model.

3. The financial crisis of 2008/09 has shown that, in general, the insurance
business model enabled the majority of insurers to withstand the financial crisis better
than other financial institutions. This reflects the fact that insurance underwriting risks are,
in general, not correlated with the economic business cycle and financial market risks and
that the magnitude of insurance liabilities are, in very broad terms, not affected by financial
market losses.2 Moreover, insurers’ investment portfolios, which are selected largely to
match the underlying characteristics of insurance liabilities, were able to absorb sizeable
losses. Similarly, the nature of insurance liabilities, and the fact that payments to policy-
holders generally require the occurrence of an insured event, makes it less likely for insurers
engaged in traditional activities to suffer sudden cash runs that would drain liquidity. While
impacted by the financial crisis, insurers engaged in traditional insurance activities were
largely not a concern from a systemic risk perspective.

4. However, insurance groups and conglomerates that engage in non-traditional

or non-insurance activities are more vulnerable to financial market developments and
importantly more likely to amplify, or contribute to, systemic risk. Examples of non-
traditional and non-insurance activities include credit default swaps (CDS) transactions for
non-hedging purposes or leveraging assets to enhance investment returns. In addition, the
continually evolving marketplace is resulting in products and activities that blur the lines bet-
ween traditional insurance and bank-type (or investment bank-type) activities. The recent
financial crisis has revealed that even financially strong insurance groups and conglomerates

1
This adopts the FSB definition given in: “Reducing the moral hazard posed by systemically important financial
institutions”, Financial Stability Board (FSB), October 2010. The methodology to determine the potential
systemic importance of insurance-focused groups and conglomerates will likely differ from the banking
approach to reflect the specific nature of the insurance business.
2
The exception being special lines, such as Lenders Mortgage Insurance, Directors & Officers (D&O) coverage,
Credit Insurance and Trade Credit Insurance, or certain activities defined as non-traditional in section 3.2 of
this paper, such as Financial Guarantee Insurance (FGI), which by their nature are closely related to the
business cycle and to financial market volatility.

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operating on a core of traditional lines of business may suffer significant distress and become
globally systemically important when they expand significantly in non-traditional and non-
insurance activities. In this context, it is important to distinguish between those activities that
are regulated as insurance and those that are not.

5. Insurance markets are competitive. While the insurance business is considered to

be predominantly local, competition in most lines of business, especially in traditional insu-
rance, tends to be strong. The larger groups are exposed to global competition only in the
context of large risk covers. These dynamics suggest that substitutability, or the continuation
of supply of insurance coverage after a failure of a single entity, is likely a less material issue
in insurance than in banking.

6. Exceptions may arise through high supplier concentrations in certain market

niches. In monopolistic or oligopolistic market niches the failure of a dominant insurer could
create temporary distortions materialising in the unavailability of cover and sharp price in-
creases. However, such distortions tend to be limited to local markets and they are generally
of short duration (see the case study on HIH in appendix A10). Considerable price fluctu-
ations in non-life insurance have been observed also after capacity losses caused by large
natural catastrophes. But capacity tends to be restored quickly. The restoration of capacity
tends to occur to a large part through the inflow of new capital, since barriers to market entry
tend to be low in many lines of business. The restored supply capacity exerts downward
pressure on prices, and in most cases they return to previous levels (see also discussion in
point 42 below).

7. Insurers connect to the financial markets through their investment, capital

raising and debt issuance activities. In Europe, insurance groups hold a sizeable portion
of their investments in securities issued by other financial institutions, predominantly debt
instruments, and to a very small degree, equity securities.3 The ability – and willingness – of
insurers to make such investments provides an important contribution to the financial sound-
ness of banks and more broadly to financial stability.4 In a similar fashion insurers are also
allocating capital to the real economy by purchasing debt securities of industrial companies
or through real estate investments. These activities underscore the importance of a finan-
cially sound and stable insurance sector. In turn, investment activities expose insurers to the
volatility of the sectors in which they invest.

8. Just as the insurance business model is different from the banking model, the
impact of insurance failures on other financial institutions and the real economy is
different. The reasons for the differences in impact reside in the particulars of the insurance
business model; in the disciplined implementation of a predominantly liability-driven invest-
ment approach; in the nature of insurance claims that in many cases allow the management
of cash outflows over an extended period of time (from weeks to months to years, depending
on the line of business); and in the high degree of substitutability, allowing for a comparati-
vely ease of market entry into most lines of business.

3
“Systemic Risk in Insurance, An analysis of insurance and financial stability,” Geneva Association 2010.
4
This point was taken up in a study by the Basel Committee on the Global Financial System (CGFS); see:
“Fixed income strategies of insurance companies and pension funds,” CGFS papers, June 2011. It should be
noted that the holdings of debt securities issued by other financial institutions varies considerably between
jurisdictions.

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9. The answer to the question whether insurers could cause systemic risk is ulti-
mately an empirical issue. However, based on information analysed to date, for most lines
of business there is little evidence of traditional insurance either generating or amplifying
systemic risk within the financial system or in the real economy. Of course, empirical
assessments about the systemic importance of insurers and insurance groups may change
over time. A benign record in the past does not ensure the absence of a systemic risk
potential in the future. That is why the IAIS is committed to reviewing the pace of innovation
and changes in insurance business models as well as in the complex interactions within
insurance groups at regular intervals. It will also continue to analyse the role of reinsurers in
the context of financial stability.

10. The differences between insurers and banks in the impact of failures suggest
inter alia that requirements for loss absorbency and resolution regimes for insurers
should accept these salient differences and propose solutions that differentiate
accordingly. In most jurisdictions supervisors already command a wide range of options for
the monitoring and enforcement of capital and provisioning requirements for traditional
insurers and they have well-established methodologies for supervising insurers in resolution.
In the near future, the impact of non-insurance and non-traditional business activities in
insurance groups will be analysed in more detail. If deemed necessary, the results of the
analysis will be reflected in IAIS Standards relating to resolution regimes and, where
appropriate, recommendations will likely be made for loss absorbency.

11. In recent years, the IAIS has stepped forward to promote group-wide supervi-
sion. As part of the revisions of the Insurance Core Principles (ICPs), which were first pub-
lished in 2003, the IAIS has enhanced its supervisory material addressing the supervision of
insurers on a group-wide basis, including material relating to cooperation and coordination on
both a cross-border and cross-sectoral basis as well as the treatment of unregulated entities
in group-wide supervision. The revised ICPs were adopted on 1 October 2011.

12. The IAIS has also launched work to building a common framework for the
supervision of internationally active insurance groups (ComFrame). ComFrame is direc-
ted at about 50 insurance groups that meet the criteria for internationally active insurance
groups (IAIGs) as defined by the IAIS. It is designed to make group-wide supervision operati-
onal by addressing the risks these institutions are exposed to. ComFrame addresses also
both the group-wide and host supervisors’ perspectives by defining roles for cooperation and
interaction, including the establishment of supervisory colleges.

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2. Salient insurance characteristics

2.1 The insurance business model

13. The traditional business model of insurance builds on the underwriting of

large diversified pools of mostly idiosyncratic and uncorrelated risks (see the treatment
on p. 10 ff. for the differences between traditional and non-traditional as well as non-insuran-
ce business activities). Based on such a business model, traditional insurance is unlikely to
become a source of systemic risk. The arguments in support of this derive mainly from the
nature of insurance liabilities and the fact that in the normal course of business insurers do
not use excessive leverage, while investments are funded in general by premium income and
are held-to-match liabilities.

2.2 The funding model

14. One characteristic of the insurance business is its inverted production cycle.
Policyholders pay premiums upfront, and contractual payments are generally made only if
and when an insured event has occurred. This means that the large majority of insurance
liabilities are not prone to sudden withdrawals. One example of an exception is related to
certain life insurance products with demand deposit features. However, an important feature
of many life insurance products is that they come with surrender penalties that dampen the
incentive for policyholders to cash in their policies prematurely.5 The appendix presents an
exceptional case where life insurers suffered temporary runs on their business caused by a
loss of confidence in the financial strength of the institution (AIA in the Hong Kong and
Singapore markets). In these cases the runs on the affected life insurance companies were
of limited duration and scope. They did not cause significant liquidity stress, and no discerni-
ble contagion effects were observed on policyholders, other insurers, or the financial system
as a whole.

15. The inverted production cycle and the contractual premium payments of poli-
cyholders allow for a stable cash flow to insurers. In fact, the operating activities of insu-
rers tend to generate sizeable positive net cash flows. Traditional insurance businesses
generally do not depend on short-term funding to finance liquidity or parts of their business
operations.

16. In traditional insurance, liquidity risk is typically an operational rather than a

strategic issue. This is observed also after large catastrophes, for which claims tend to get
settled over an extended period. Figure 1 shows that it took seven quarters for the settlement
of the reinsurance claims attributed to the loss of hurricane Katrina (2005) to reach 60% and
11 quarters for the settlement of the losses of the World Trade Center (2005) to reach the

5
It is important to note that there are also products where this is not the case. In certain markets, single
premium investment-linked policies are such an example. An initial fee may or may not have been levied, but
there are no surrender penalties in later stages. Usually the backing investments are liquid, but there can also
be exposure to relatively illiquid assets, such as property and infrastructure investments. Moreover, there are
other reasons for not surrendering a life insurance policy, such as loss of cover, which may be difficult or
expensive to replace.

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same threshold. And it took approximately another three quarters for Katrina-related payouts
to reach 80%, while WTC claims took a total of 24 quarters to reach 80% of the ultimate
payouts. The extended claims payment period gives insurers and reinsurers time to plan the
necessary funding. During this period, insurers and reinsurers typically continue to receive
premium income, which further dampens the need for urgent liquidity measures through the
fire sales of financial assets.

Figure 1: Catastrophe reinsurance loss payments in per cent of ultimate losses

100%
Katrina
WTC
80%

60%

40%

20%

0%
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Quarters after event

Source: Reinsurance Association of America; assumed reinsurace losses

17. The historical evidence of insurance runs is limited. In the appendix we present
the experience of one life insurer in Asia that came under pressure at the time of the financial
crisis. The facts underscore that the percentage of actual surrenders and redemptions
against the total number of policies in force was small and that the company did not face
liquidity constraints.

18. In traditional insurance the risk of a liquidity shortage is small. Cash outflows (or
claims payments) are tied to the occurrence of an insured event. In the case of large cata-
strophes these payments tend to be stretched out over an extended period (as noted earlier).
However, the case may be different with respect to non-traditional or particularly risky
funding strategies as the securities lending programme of one large American insurance
group has revealed (see appendix A8). That said, the financial crisis of 2008/09 has shown
that liquidity can dry up unexpectedly and very rapidly. Quite often it is driven by abruptly
changing market conditions, which then can pose particular challenges in the presence of
large asset-liability maturity mismatches and in those situations where maturity
transformation has become an important part of non-traditional or non-insurance business
activities.6 Furthermore, cross-border activities of groups and conglomerates may give rise to
special liquidity issues. Particularly in those cases where national regulations and other legal
restrictions constrain the transfer of liquid funds, a group or its parent may not be able to
access otherwise available liquid funds in a timely manner.7

6
See Marc Philippe Radice: “Assessing the potential for systemic risks in the insurance sector”, FINMA
Working Paper, June/2010.
7
See M. Radice (2010), op cit.

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2.3 The insurance balance sheet

19. An insurance balance sheet is essentially the result of current and past
underwriting activity. Under normal conditions the sound underwriting of policyholder risk
creates a steady premium flow, with future claims tied to the occurrence of an insured event.
Cash inflows from premiums not immediately used to pay policyholder claims are invested in
various assets to match the technical provisions for the payment of future claims. Claims
(other than surrenders and early withdrawals) 8 typically materialise only in connection with
an insured event. Such events tend to be idiosyncratic and are generally not related to the
business cycle or financial market developments. Exceptions are various forms of credit risk
insurance, trade risk insurance and financial guarantee insurance (see also paragraph 3 and
the related footnote). Financial market impacts are also seen to some degree in the
dependency on interest rates in life insurance.

20. The insurance business model requires a careful actuarial modelling of tech-
nical provisions to meet claims and unexpired risk. The technical provisions constitute
the largest block of insurance liabilities (see figure 2). Providing accurate actuarial estimates
of provisions and ensuring the quality and safety of invested assets in support of these provi-
sions comprise the core functions of the traditional insurance business. Under the model, in-
surers often pursue also an appropriate duration matching of assets to liabilities (see also
section 5.1 on the investment function in traditional insurance).9

21. Insurance regulation requires technical provisions and capital on an insurer’s

balance sheet to be sufficient to withstand severe yet plausible events. In addition,
supervisors employ a variety of tools to monitor the financial health of insurers and provide
an early warning of financial difficulties. In general, such requirements and monitoring of
ongoing changes help ensure a sufficient time horizon for identifying and addressing the
problems of potentially troubled firms, while promoting an efficient allocation of capital com-
mensurate with the risk of failure. The technical provisions and capital regulation regimes in
traditional insurance are therefore designed to provide sufficient loss absorbency capacity
and reduce the negative externalities associated with insurance failures.

8
See the box on AIA in the appendix for a discussion of surrender issues at the time of the financial crisis.
9
In practice, one observes a wide variety of ALM approaches. In many cases it may simply not be possible to
match very long-term liabilities with assets of equal long duration. In other cases an insurer may deliberately
choose to invest in short durations. The crucial point is however that supervisors will require an appropriate
capital buffer against the risk of an asset-liability mismatch.

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 Figure 2: Synthetic balance sheet for European life/non-life insurance groups

6% Equities

56%
74%
Fixed
Technical
income
provisions Companies selected
Reinsurance
 Allianz
2%
recoverable
 Aviva
36%
18%
 AXA
Other
Other  Generali
Shareholders liabilities
assets
equity 8%
 Prudential
 Zurich
Assets Liabilities

Source: Company reports for 2010 aggregated by IAIS

22. Size and geographical diversification generate diversification benefits. The

larger an insurer’s balance sheet, the more options are available to underwriting a variety of
idiosyncratic risks.10 In general, insurers endeavour to operate on a balance sheet where
risks diversify over lines of business, geographies, and time. Specifically, large international
insurance groups may gain diversification benefits that are not available to smaller firms
whose range of business is limited to national boundaries. Thus, size in insurance can be a
driver of increased capital efficiency. When calculating capital requirements, due
consideration will have to be given to such benefits, especially geographical diversification
benefits.
23. Insurers are, of course, not immune to failure. As a proxy for failure we provide
in figures 3 and 4 a summary of the major factors to cause financial impairments11 of US life
and health insurers and US non-life insurers over a 40-year period. For non-life insurers
neither investment losses, which could stand as proxy for financial market exposure, nor
reinsurance failures, a proxy for potential systemic interconnectedness, top the list of primary
impairment causes. While reinsurance failures also do not factor significantly in the life and
health insurance segment, investment losses are clearly more important, reflecting the larger
investment portfolios held in that segment.
Perhaps more interestingly, two major impairment factors both for life and non-life
insurers are deficient loss provisioning and inadequate pricing – the most important causes
in both segments – and rapid growth, which in many cases was coupled with deficiencies in

10
This argument abstracts, of course, from the recognition that size may also be the result of risk concentration.
11
The data is based on A.M. Best’s annual financial impairment studies. In the studies, insurers are designated
“as a Financially Impaired Company as of the first official regulatory action taken by an insurance department,
whereby the insurer’s ability to conduct normal insurance operations is adversely affected; capital and surplus
have been deemed inadequate to meet legal requirements; and/or general financial condition has triggered
regulatory concern.” The definition of financial impairment is also given in A.M. Best: “Best’s Impairment Rate
and Rating Transition Study – 1977–2009”, p.3, May 2010.

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risk management as well as in sound and balanced governance. These causes tend to be
interrelated. Inadequate prices, either as result of poor actuarial work or in the wake of ag-
gressive pricing in order to compete for market share, materialise often in deficient reserving.

Figure 3: Primary causes of financial impairments Figure 4: Primary causes of financial impairments
US non-life companies, 1969 - 2009 US life and health companies, 1969 - 2009

Reinsurance failure Reinsurance failure

Investment 3.7%
losses
7.0% 2%
Rapid growth Investment
Affiliate losses Rapid growth
impairment
14.3% 15%
7.9% Alleged fraud 15%
Alleged fraud
8.1% Affiliate 9%
impairment
7.6% Catastrophe 18% Miscellaneous
38.1% losses
9.1% 5% 9%
Deficient loss provisions / 27%
inadequate pricing Miscellaneous

Deficient loss provisions

4.2% inadequate pricing

Change in business
Change in business

Source: A.M. Best Co

Source: A.M. Best Co

The appendix discusses three cases illustrating insurers in financial distress. The
first case on Equitas relates to the London market in the early 1990s, which struggled to
meet pay-outs due to large catastrophes, such as Piper Alpha and Hurricane Andrew, and a
rising tide of asbestos claims. The second case discusses Equitable Life, which was found to
have inappropriately managed products with terminal bonuses. As a consequence, it was
inadequately reserved and unable to meet its obligations to policyholders. And the third
reports on HIH, whose poor underwriting, chronic under-reserving and under-pricing, abuse
of reinsurance, and severe deficiencies in corporate governance contributed to the largest
insurance failure in Australia. These cases underscore why supervisors tend to stress – and
monitor – the adequacy of provisions in order to ensure appropriate loss absorbency under a
variety of adverse scenarios.

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3. The business spectrum of insurers and insurance groups

3.1 The traditional insurance business

24. The insurance business builds on the premises of insurability.12 Among other
criteria insurability requires losses to be well defined. They must be accidental, i.e. not con-
trolled by the insured, they must occur randomly, and they must be subject to the law of large
numbers. The pooling of a large number of similar or homogenous exposures is essential to
the technique of insurance. It allows the insurer to manage risks and offer a valuable
proposition to its policyholders. The notion of insurability may evolve over time. What was
uninsurable in the past might be insurable today, and what is insurable today might become
uninsurable in the future. Also, what is uninsurable in the view of one firm may well be
insurable for another carrier.

25. Insurance accounting accommodates the uncertain and often long-term con-
tractual obligations in the insurance business. Especially in life insurance, but also in
certain lines of non-life insurance, there may be a long time between the receipt of premiums
and the payment of claims. This is a major difference in comparison with other industries,
and it creates the need for a special accounting treatment. The sector-specific insurance
accounting uses actuarial estimates of future liabilities to render an appropriate picture of
solvency and profitability. Although this approach is not exclusive to insurance, it covers inter
alia also industry-specific needs with respect to the recognition of premiums, claims,
reserving (or provisioning), and commissions, such as deferred acquisition costs in life
insurance.

26. Insurance laws refer in many cases to the notion of insurable interest.
Insurable interest can be defined as an interest in a person or a good that will support the
issuance of an insurance policy; an interest in the survival of the insured or in the
preservation of the good that is insured.13 The notion of insurable interest dates back to the
Middle Ages and it was English common law until the Life Assurance Act of 1774. In that Act
the Parliament of Great Britain sought to prevent the abuse of life insurance and differentiate
it from gambling or purely speculative behaviour. It specifically “prohibited the making of any
policy on the life of a person by anyone with no interest in the insured life or for gaming or
wagering purposes.”14 Today, the speculative behaviour that the Act of 1774 sought to
prevent is often associated with financial derivatives that are wrongly equated with insurance.
Financial derivatives are not considered insurance for regulatory purposes.

27. Hence, traditional insurance is a business concerned with interests that meet
at least the principles of insurability based on insurance techniques and that is
subject to insurance accounting. The majority of life and non-life insurance business lines

12
A standard reference is Baruch Berliner: “Limits of Insurability of Risks”, Prentice-Hall, 1982.
13
This definition is owed to the Princeton WordNet.
14
See the 2006 proceedings of the Society of Actuaries under the title “You Bet Your Life.” In that session new
forms of life insurance – such as Investor Owned Life Insurance (IOLI), an investment vehicle involving an
insured life, a life insurance company, a lender, and investors – were discussed in which insurable interest is
either de minimis or entirely absent.

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– such as mortality and morbidity risk in life insurance or automobile and fire risk in non-life
insurance – meets these criteria. They comprise the core of the insurance business. The bulk
of traditional insurance risks are idiosyncratic. They tend not to be correlated with each other
and, more importantly, they are in general not correlated with the economic business cycle
and financial market developments. These are salient features that set insurers apart from
other institutions in the financial sector.

3.2 Non-traditional and non-insurance business activities

28. In contrast, there are business activities that either deviate from, or miss
entirely some of, the criteria mentioned above. In life insurance, for example, non-
insurance features, such as different types of guarantees or the absence of penalties for
early surrenders, have been added to traditional products. These non-traditional features
materially change the risk profile of the combined product. Similarly, life insurance products
with savings and investment features are characterised as non-traditional by a number of
supervisors. As for reinsurance, the underwriting of reinsurance contracts is a traditional
function. However, reinsurance contracts with limited or no risk transfers can change the risk
profile, making at least part of the insurance business non-traditional or even non-insurance.

29. Over time a number of insurance-based groups have become engaged in acti-
vities with no direct connection to insurance. Conceptually, the various activities can be
allocated to two broad categories – insurance (including traditional investment and funding
functions, but sometimes mixed with non-traditional features and thus called non-traditional
insurance business), and non-insurance. It should be clear from the outset that there can be
no clear-cut assignments of activities to the various fields.

30. While the separation of insurance from non-insurance activities may be compara-
tively easy, the demarcation between traditional and non-traditional lines of business
(or products) can be blurry. Different jurisdictions may allocate different activities to
different fields. For example, a number of jurisdictions would classify variable annuities closer
to traditional life insurance, while others, in light of the dominant investment component in
these products, would see them closer to non-traditional insurance activities. That said, it
should also be understood that in many jurisdictions solo insurance companies are confined
to traditional insurance activities, or only to very limited non-insurance activities. Table 1 on
the next page provides an illustrative allocation of various business activities, while trying to
capture the many shades of grey between traditional and non-traditional insurance activities.

31. Certain non-insurance activities were revealed systemically relevant. This was
certainly true for the large volume of credit default swaps underwritten by a non-insurance
subsidiary of AIG in combination with a significant leverage of the group and its large invest-
ments in illiquid securities. However, it is important to underscore that non-insurance activi-
ties are not necessarily of systemic importance. This is the case in particular for third-party
asset management. In most jurisdictions it is not subject to insurance regulation or insurance
accounting, two characteristics that put third-party asset management into the non-insurance
category. 15 Aside from considerations with respect to operational risk, it should be readily

15
However, in many jurisdictions third-party asset management is reflected in the approach to group-wide
supervision.

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apparent that third-party asset management does not put the equity capital of insurers at risk.
This is in contrast to the investment function arising from the insurance business, which is
supported by a risk-based allocation of capital. Hence, the likelihood for the third-party asset
management activity to trigger a shock of systemic proportion is limited to non-existent.

Table 1: Illustrative allocation of activities conducted by insurance-focused groups16

Traditional Non-traditional

Underwriting  Most life and non-life  Life insurance and  Alternative risk trans-
(re)insurance busi- variable annuities fer (ART), incl. Insu-
ness lines with additional gua- rance-linked securi-
rantees ties (ILS)
 Mortgage guarantee  Financial guarantee
insurance insurance
 Trade credit insu-  Finite reinsurance
rance
Insurance

Investments  Proprietary invest-  Proprietary and  Purely synthetic

and funding ment function (ALM) derivatives trading investment portfolios
(non ALM)
 Hedging for ALM  Cascades of repos
purposes  Property manage- and securities len-
ment (related to ding
 Funding through investment portfolio)
equity and debt  Scope and scale of
issues; also secu- activities beyond
rities lending insurance remit

 CDS/CDO underwriting
Non-insurance

 Capital market business

 Banking, incl. investment banking and hedge fund activities
 Third-party asset management
 Industrial activities

32. One lesson of the financial crisis was that the systemic relevance of insurance
groups is correlated with the influence of activities outside of the traditional insurance
business field. Moreover, the systemic importance may increase to the extent that entities
on the traditional insurance business side have committed to supporting either explicitly or
implicitly activities in the non-traditional and/or non-insurance side. One example was the
CDS business written in a non-insurance subsidiary of AIG, which made the world’s largest
insurance group a source of global systemic risk (see also appendix for a summary of the

16
The allocation of activities is illustrative and the list is not meant to be exhaustive. A number of activities would
be allocated differently by different supervisors. Further differentiation may be called for when assessing the
methodology for identifying global systemically important financial institutions (G-SIFIs) and related measures.

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AIG case). Other examples, although with a lower degree of systemic importance, were bond
insurers such as Ambac17 and MBIA, whose loss of AAA status created problems for the
holders of municipal bonds and were one of the many contributing factors leading to the
collapse of investments known as auction rated securities.18 In light of severe losses and
subsequent rating downgrades, the US Financial Stability Oversight Council concluded that
“the future viability of the financial guarantee segment (monoline insurers) remains uncertain,
with only one monoline group actively writing insurance.”19

33. Figure 5 provides an illustrative example of activities possibly undertaken in

an insurance group or insurance conglomerate. Non-life insurance marks the traditional
pole of the spectrum; capital market activities (such as CDS transactions) mark the opposite
end (note that insurers are currently net buyers of CDS). Moving along the horizontal axis

Figure 5: Insurance activities and financial market interconnectedness

* Total outstanding
2,500 2,330 ** Total outstanding, mostly XXX and
embedded value (EV) securitisation
*** Monolines, credit, surety, mortgage insurance
Global premium volume in USD bn

2,000
Life annuities, est.

**** Insurers are currently net-buyers of CDS

1,735
Time deposit insuranceest.

1,500

Credit default spwas****

FG insurance, est.***
Non-life insurance

Life insurance

1,000
Non-life ILS*

Life ILS**

700

500

15 22 30 23
0

Increasing degree of financial interconnectedness -139

-500

Source: BIS, Sigma, IAIS calculations; data for 2009

from left to right leads to higher degrees of financial interconnectedness and, to a certain
extent, presumably also to a higher degree of potential systemic relevance. However, the
diagram does not capture investment activities and the complexity of insurance products.
(Again, this statement is illustrative and not based on exact quantification; to draw robust
conclusions one would have to monitor changes in various business models over a longer
period.) Life insurance tends to be more prone to financial interconnectedness than non-life
insurance due to much larger investment portfolios and certain product characteristics such
as the embedded options inherent in almost all products. Similarly, due to the inherent cha-
racteristics of embedded value (EV) and Regulation (A) XXX securitisation, securities linked
to life insurance tend to be more exposed to financial market risks than securities linked to
non-life insurance. However, the total return swap underlying most ILS transactions can

17
Ambac filed for bankruptcy protection under Chapter 11 of the US Bankruptcy Code on 8 November 2010.
18
“The Financial Crisis Inquiry Report”, Washington, January 2011, pp 277–278.
19
Financial Stability Oversight Council: “2011 Annual Report”, Washington, DC, 2011.

14/47
potentially expose both vehicles to financial interconnectedness.20 Measured by premium
volume (nominal notional outstanding for CDS) it becomes clear that the core traditional
products in life and non-life insurance make up the dominant bulk of the business undertaken
by insurers.

34. Bankassurance can present yet another form of closer interrelation between
insurance and banking. 21 The combination of banking and insurance activities may gene-
rate, in principle, risk diversification benefits. While such benefits were observed in some
countries during the recent financial crisis, the case study on bankassurance (see appendix
A3) shows that they were not present in the Netherlands. Against a backdrop of severe
stress and an overall loss in confidence in financial markets, the banking side had become
vulnerable to the risk of large withdrawals of deposits, and both banks and life insurers sus-
tained a sharp decrease in the value of investment portfolios, which in turn led to declining
solvency ratios. In order to strengthen financial buffers and secure continued access to finan-
cial markets, the Dutch government eventually decided to recapitalise a number of these
institutions.

35. The loss of confidence in insurance groups or conglomerates could possibly

spill over to other financial institutions and the real economy. In the heat of the financial
crisis it became difficult for the Dutch supervisory authority to ascertain whether the source of
systemic contagion was located in the banking or insurance activities. In the end, the Dutch
government feared that problems residing in the insurance segment could spill over too and
result in a loss of confidence in the banking arm and subsequently in the group as a whole. It
should be underscored however that the Dutch experience appears to have been unique. No
systemic spillovers were observed in other jurisdictions with an active bankassurance sector.

20
This was driven home after the collapse of Lehman Brothers, which had been counterparty to four total return
swaps guaranteeing four different ILS transactions. Industry practice with respect to collateralisation has
materially changed since.
21
There are various definitions of bankassurance. By focusing on production, a bankassurer can be defined as a
financial group or conglomerate that includes both bank credit origination and insurance underwriting. But
bankassurance can be limited to distribution agreements only in which a bank merely distributes third-party
insurance products in a contractual agreement with an insurer and does not own the underwriting factory.

15/47
3.3 Interim conclusion

36. The characteristics of the insurance business model including insurance tech-
niques make it very unlikely for traditional insurance to be systemically relevant. While
traditional insurers can suffer episodes of distress and failure, their business model builds on
stable financing and adequate loss provisioning. In the past, runs on (life) insurance com-
panies have been the exception rather than the rule. And in those few locations where in the
wake of the financial crisis insurance runs were observed, they turned out to be of short
duration. The liquidity outflows and the number of affected policyholders were small; there
was little or no contagion; and the runs had no systemic implications.

37. However, today’s business reality is more complex. Over the years non-traditio-
nal and/or non-insurance activities with potentially increasing systemic features have emer-
ged. Without appropriate regulation, they may turn those parts of the groups and other parts
of the groups that are supporting the non-insurance business – as AIG illustrated – into sys-
temically important activities. The systemic relevance will likely depend on the size and
scope of the non-traditional and/or non-insurance activity and whether the business dimensi-
ons are local or global.

16/47
4. Market structure and industry size

4.1 Market structure

38. In 2009, global insurance markets reported annual premiums of USD 4.1 trillion
(see figures 6 to 9). Of this total 70% was recorded in the mostly advanced economies of
Europe and North America. More than half of the premiums came from life insurance
(USD 2.3 trillion); USD 1.7 trillion from the non-life insurance segment. With total premiums
of USD 197 billion, global reinsurers comprise a relatively small market. On average, less
than 5% of global primary premiums were ceded to reinsurers. In life insurance the cession
rate was 2%; in non-life insurance it amounted to 9% of primary premiums. 22

Figure 6: Global view of the life insurance Figure 7: Global view of the non-life insurance
market - USD 2.3 trillion market - USD 1.7 trillion

Africa Asia and

1% Oceania
North
17%
America
North
Asia and 23%
America
Oceania 40%
33%

Europe
Europe 38%
Latin
41%
America
2%

Africa Latin
1% America
4%

Source: Sigma 2/2110 Source: Sigma 2/2110

Figure 8: Global view of the life reinsurance Figure 9: Global view of the non-life reinsurance
market - USD 45 billion market - USD 152 billion

Africa
Asia and
2%
Oceania
8% Asia and
Oceania
21%
North
Europe
America
26% North
39%
America
63%

Europe
Africa
33%
3%
Latin
Latin
America
America
1%
4%

Source: Sigma 2/2110 Source: Sigma 2/2110

22
Premiums are not an ideal metric to measure the size of the non-life (including reinsurance) sector. A single year’s
premium may not capture risks associated with catastrophe covers, or financial and mortgage guarantee covers.

17/47
39. In general, non-life insurance markets tend to be fragmented and competitive.
For focus we concentrate selectively on nine markets in advanced economies. Figures 10
and 11 show industry concentration rates in these major markets. Concentration rates for the
top five non-life insurers are relatively small with the exceptions of Japan, France and
Switzerland. However, the Herfindahl index23 numbers indicate a comparatively high degree
of competitiveness even in these markets.

Figure 10: Non-life insurance market concentration rates Figure 11: Life insurance market concentration rates

100 0.26 100 0.26

Top 5 Market share Top 5 Market share
90 0.23 90 0.23
Top 10 Market Share Top 10 Market Share
Market share in % of total

80 0.21

Market share in % of total

Herfindahl Index 80 Herfindahl Index
0.21
70 0.18 70 0.18

Herfindahl Index

Herfindahl Index
60 0.16 60 0.16
50 0.13 50 0.13
40 0.10 40 0.10
30 0.08 30 0.08
20 0.05 20 0.05
10 0.03 10 0.03
0 0.00 0 0.00
GER JPN FRA ESP GBR SUI USA ITA AUS GER JPN FRA ESP GBR SUI USA ITA AUS

Source: National data; IAIS calculations Source: National data; IAIS calculations

40. Market concentration rates are slightly higher in life insurance. This is particularly
true for Germany, Japan, and Switzerland where the top five competitors achieve cumulated
market shares of 60% and more and where also the Herfindahl indices point to a slightly
elevated degree of concentration.

Figure 12: Concentration rates in the US non-life market

100 0.09
Market share top 10 in % of total

90 0.08
80 0.07
Herfindahl Index

70 0.06
60
0.05
50
0.04
40
30 0.03
20 0.02
10 0.01
0 0.00
Other
Fire & allied
Personal

Commercial

Commercial

General

Medical MP
Homeowners

Workers'
liability

comp
auto

auto

MP

Source: Robert Klein (2011)

23
The Herfindahl index measures the distribution of market shares reflecting the existence of dominant market
players. Its values range from 0 to 1. They increase with increasing market power and the concomitant decrease in
competition.

18/47
41. Even more indicative is a market concentration analysis by lines of business.
Figure 12 (above) reports the situation in the US non-life sector for nine lines of business.24
These markets are quite competitive. In 2006, more than 1,200 companies were active with
several hundred insurers competing in each line of business (LOB). In line with the aggre-
gate numbers reported for Europe (see figures 11 and 12) the LOB market shares of the 10
largest US non-life insurers range between 40% and 50%, with the peaks reaching 65%.
However, Herfindahl index values are lower than 0.09, which is well below the level that
would indicate market power.25

42. The high degree of competition supports the finding that a loss of insurance
capacity (due to catastrophes, for example) tends to be replaced quickly. A loss of non-
life insurance capacity may lead to rate increases in certain lines of business (so-called
market hardening). The higher rates tend to attract new capacity quickly as barriers to market
entry tend to be low in most lines of business. This drives down rates (contributing to a
market softening), making rate spikes in most cases of rather short duration. This pattern is
visible in figure 13, which depicts quarterly rate changes in two US commercial business

lines. Since 2001, the general trend has materialised first in declining and then negative rate
changes for both commercial property and workers compensation. In commercial property,
the soft market was interrupted only in the aftermath of the exceptional hurricane season
2005, which inflicted three major hurricanes on the US Gulf coast (Katrina, Rita, and Wilma –
KRW). However, the subsequent period with positive rate changes lasted for only two
quarters, ending in the third quarter 2006. The trend reversal can be explained with the inflow
of new capital. According to industry estimates, the reinsurance sector was able to replace
more than 80% of the estimated KRW losses with new funds coming in the form of equity,
start-ups, or sidecars and catastrophe bonds.26 While the absolute magnitude of negative

24
Robert W. Klein: “Principles for Insurance Regulation: An Evaluation of Current Practices and Potential
Reforms”, The Geneva Papers on Risk and Insurance, GPP/IIS Awards Edition, June 2011.
25
Klein (2011) reports that the U.S. Department of Justice and the Federal Trade Commission consider markets
with Herfindahl index values lower than 0.15 to be not concentrated. These type of concentration thresholds
appear to be market-specific. A more detailed analysis would be required to ascertain whether markets in
Europe, for example, are more or less concentrated than US markets.
26
Communication to the RTG, July 2011.

19/47
rate changes has diminished beginning in 2008, signs of a slightly hardening market (i.e. po-
sitive quarterly rate changes) have become visible in the second quarter of 2011. The overall
finding however remains unchanged that, in general, even an exceptional loss of insurance
capacity will be replenished quickly. Lack of substitutability does not appear to be an issue in
the insurance industry. To some extent, this finding is also supported by the HIH case study
presented in appendix A10.

43. These admittedly few and selective examples support nevertheless the con-
clusion that insurance markets tend to be competitive. The number of suppliers is often
quite large, and many markets, particularly on the LOB level, tend to be fragmented. The
large number of suppliers and the high degree of competition suggests that substitutability
does not appear to be an issue in most national insurance markets, and probably even less
so in global markets. That said, substitutability issues cannot be ruled out in certain market
niches to be served by one insurer with a very high or even a monopolistic market share. Ex-
amples of such special niches could potentially be found in export credit insurance, aviation
coverage, and certain reinsurance lines of business.

4.2 Industry size by assets and market capitalisation

44. Total insurance assets represent approximately one third of the banking
industry’s assets, and a similar relation holds for industry-wide capitalisation num-
bers. One striking point of figures 14 and 15 is that the top three banks are as large as the
top ten insurers if measured by total assets. By market capitalisation, the largest bank is
almost as large as the top ten insurers together. The reinsurance sector is comparatively
small. By assets, the ten largest reinsurers are smaller than the one top primary insurer, and
by market capitalisation the whole reinsurance sector equals the two top primary insurers.

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 Figure 14: Total assets; USD billion (2010) Figure 15: Market capitalisation; USD billion (2010)

25,000 1,200

1,000
20,000

800
15,000

600

10,000
400

5,000
200

0 0
Top 10 Banks Top 10 Insurers Top 10 Reinsurers Top 10 Banks Top 10 Insurers Top 10 Reinsurers

Source: Company reports, IAIS calculations Source: Bloomberg

Top 10 insurers: ING, AXA, Allianz, Metlife, AIG, Aviva, Top 10 Banks: BNP Paribas, Deutsche Bank, HSBC,
Generali, Prudential, Legal & General, Aegon Barclays, RBS, Bank of America, Mitsubishi, Crédit
Top 10 reinsures: Munich Re, Swiss Re, Hannover Re, Agricole. JP Morgan, ICBC (China)
QBE, Scor, Reinsurance of America, Partner Re,
Everest Re, Transatlantic, Alterra

45. The 25 largest insurers in the world combine USD 10.7 trillion in total assets.
The total of insurance assets is about one quarter of the USD 44.3 trillion that the world’s 25
largest banks combine on their balance sheets (see figures 16 and 17). The size of banks
appears to be more homogenous than the size of insurers. BNP Paribas, the largest bank is
about three times larger than Commerzbank, the number 25 bank in our sample. In
insurance, however, AXA is more than five times larger than Ping An, the smallest in the
sample of the world’s 25 largest insurance groups.

46. The compact size distribution (relative to insurance) in the banking sector
accounts also for the fact that insurers play a minor role in the global ranking of large
financial institutions. The three largest insurance groups AXA, Allianz and MetLife would
rank among the world’s 35 largest financial institutions (all with balance sheets in excess of
USD 700 billion) on positions 26, 29 and 34, respectively.27 And if we extend the sample to
the world’s 50 largest financial institutions, only six insurance groups would be added – AIG,
Aviva, Generali, Prudential, Legal & General, and Aegon. This underscores the considerable
scale difference among the world’s largest bank and insurance groups.

27
These numbers do not include off-balance sheet items. If one were to include them for banks and insurance
groups, the size difference between the cohorts of the largest banks and the largest insurers would be even
bigger.

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Figure 16: The top 25 global insurance groups (listed companies only)
Rank 1- 13 Rank 14-25
AXA Zurich
Allianz Berkshire H.
Metlife Dai-Ichi Life
AIG Hartford
Aviva
Munich Re
Generali
Standard Life
Prudential
Swiss Re
Legal & General
China Life
Aegon
ING Insurance
Sun Life

CNP Lincoln National

Manulife Tokio Marine

Prudential Ping An

0.0 0.5 1.0 1.5 2.0 2.5 3.0 0.0 0.5 1.0 1.5 2.0 2.5 3.0
Total assets in USD trillion Total assets in USD trillion
Source: Bloomberg Source: Bloomberg

Figure 17: The top 50 global financial institutions

Rank 1 - 25) Rank 26 - 50

BNP Paribas
AXA
Deutsche Bank Goldman Sachs
HSBC Intesa Sanpaolo
Barclays
Allianz
RBS Morgan Stanley
Bank of America Nordea Bank
Mitsubishi Dexia
Crédit Agricole BBVA
JP Morgan Metlife
ICBC Royal Bank of Can
Citigroup AIG
Mizuho Nat Aust Bank
CCB Natixis
Banco Santander Toronto Dom Bank
Bank of China Bank of Comm. Insurers
ABC Westpac bank
Lloyds Aviva Banks
Société Générale Danske Bank
UBS Generali
SMFG CBA
Wells Fargo Prudential
ING Bank Bank of Nova Scotia
Unicredity Standard Charter

Credit Suisse Legal & General

Commerzbank Aegon

0.0 0.5 1.0 1.5 2.0 2.5 3.0 0.0 0.5 1.0 1.5 2.0 2.5 3.0
Total assets in USD trillion Total assets in USD trillion
Source: Bloomberg Source: Bloomberg

22/47
5. Insurance in the financial system

5.1 The investment function

47. The insurance sector is one of the largest institutional investors in the world
with invested financial assets of nearly USD 24 trillion. Insurance assets account for
12% of all global financial assets, which places insurers in the same category as pension
funds and mutual funds. This strong market presence makes the insurance sector an im-
portant player in the financial system. Particularly in light of the large proportion of fixed
income securities on their balance sheets, one would expect insurers as a whole to play an
elevated role as predictable and stable providers of long-term funds for the primary fixed
income market. And indeed a summary statistic for the five largest European insurance
groups shows that these groups were net buyers of financial assets in the period 2007 to
2009.28 This would suggest that the insurance sector exerted a stabilising effect on financial
markets – at least at the margin – at a critical and highly unstable time.

48. The bulk of insurance investments is in life insurance. With nearly USD 19 trilli-
on, life insurers hold almost five times the financial assets of non-life insurers (see figures 18
and 19 for investments by insurers domiciled in Asia, Europe and the Americas). Roughly
three quarters of insurance investments are held in Europe and the United States.

49. In considering the investment function in insurance companies, one must em-
phasise the relevance of asset-liability management (ALM).29 Insurance investments
must cover the provisions for expected claims and policyholder benefits. In many cases, and
especially in life insurance, these liabilities are longer-term in nature and thus help to insulate
insurers from short-term shocks to the financial system. The longer time horizons, however,
do not imply that insurers pursue mere buy-and-hold strategies. ALM is more nuanced, and
insurers may choose to make investments that are not subject to strict ALM practices.

50. The starting point for any asset-liability management consists in determining
the optimal asset mix to manage key risk factors on an insurer’s balance sheet. In a
perhaps more narrow liability-driven investment (LDI) approach the insurer can choose either
matching liabilities with assets whose cash flows are identical (cash flow matching) or
matching the interest rate sensitivities of assets and liabilities (duration matching). Such
strategies differ substantially from strategies pursued by asset managers who endeavour to
exceed the returns of a given benchmark. One more recent development is that financial
innovation has offered a broader range of tools to facilitate the ALM task. These tools include
mostly swap and hedging operations to mitigate inflation, volatility, currency and counterparty
risk that transfer insurance and/or market and credit risk to third parties and in certain
circumstances allow for the enhancement of expected investment return.

51. The large investment portfolio and associated hedging activities expose insu-
rers to financial market and credit risk and make them recipients of financial market

28
Based on annual reports of Allianz, Aviva, Axa, Generali and ING.
29
See also Committee on the Global Financial System (CGFS): “Fixed income strategies of insurance
companies and pension funds,” pp. 13–16, June 2011.

23/47
shocks. In figure 20 we show that European insurers hold nearly one third of their assets in
various exposures to other financial institutions. While the bulk of these financial sector
assets is held in investment-grade bonds, severe market dislocations will undoubtedly have
an adverse impact on insurers.

52. In light of their investment portfolios, it is not surprising that insurers can be
affected by financial shocks. The sharp and sizeable declines in asset prices experienced
during the financial crisis had an appreciable impact also on insures. Fortunately, the ad-
verse impact turned out to be temporary. Over the course of 2009, financial markets in ad-
vanced economies recovered, at least partly, and so did the balance sheet and solvency of
most insurers. Most entities engaging in traditional insurance activities weathered the shocks
caused by the financial crisis relatively unscathed.

Figure 18: Global view of life insurance Figure 19: Global view of non-life insurance
investments - USD 18.7 trillion investments - USD 3.9 trillion
Latin Latin
America, America,
3% 4%

Asia, 13%
Asia, 25%
Europe,
45% Europe,
45%
North
North America,
America, 34%
27%

Source: Sigma 5/2010 Source: Sigma 5/2010

Figure 20: Investment portfolio of European

insurance groups

Non-FS FS equities
equities 3%
Cash 3% Other 12%
12%

FS
Sovereign corporate
bonds,36% bonds 26%

Non-FS
FS = financial sector corporate
bonds 8%

Source: Oliver Wyman

53. Another question is whether the investment behaviour of the insurance sector
as a whole could create adverse spillovers for other financial institutions. In the appen-
dix we report the results of an event study looking at the interlinkages between UK banks

24/47
and life insurers at a time of stock market distress in the 2001 to 2003 period. It concluded
that, in general, there was no materially significant contagion between insurers and banks.
However, to the extent that minor contagion was observed, it turned out to be linked to con-
centrated bank investments in the life insurance sector and to direct ownership of life insu-
rance businesses by UK banks.

5.2 Reinsurance

54. Reinsurers provide insurance for primary insurance companies. They apply the
same business model as primary insurers, and they are subject to the same principles of
provisioning and asset-liability matching. Like primary insurers, reinsurers endeavour to
exploit the benefits of diversification over time, geographies and between different lines of
business. While diversification reduces the overall risk, the law of large numbers makes vari-
ations in the pattern of actual losses more predictable.

55. One key difference in the business model is that reinsurers provide services
to professionals only. It is a business-to-business (B2B) or wholesale relationship, which
may impact behaviour. The scope of services offered can go beyond the services offered by
primary insurers. Offerings by reinsurers to primary insurers may also include consulting
support for portfolio optimisation.

56. Reinsurers were first to develop models for the securitisation of insurance lia-
bilities and insurance assets. In light of the low correlation between some of the securi-
tised insurance liabilities (e.g. property catastrophe risks) and financial market risks,
institutional investors have shown growing demand for these instruments. While primary
insurers have now also begun to offer ILS instruments, the market for insurance-linked secu-
rities (ILS) continues to be very small in comparison to other securitisation markets and, in
general, it does not generate additional underlying risks. ILS markets serve as distribution
mechanism for parts of insurance risks for which (re)insurers remain ultimately liable. (Re)in-
surers continue to have “skin in the game.” This adds a risk governance component, which
limits the potential for systemic risk. Of course, risk securitisation based on poor underwriting
and inadequate risk management may potentially create systemic issues similar to the ones
observed with the securitisation of sub-prime loans prior to 2007. That is why supervisors will
continue to monitor the growth of the ILS market (which up until now has been very small)
and the standards adhered to by the issuing entities.

57. Reinsurers are often believed to be contributing to systemic risk in insurance.

One argument builds on the view that the interbank market and the reinsurance market are
morphologically equivalent. It implies that reinsurance shocks could cascade as quickly
through the insurance sector as shocks in the highly interconnected banking sector.
However, there is one important structural difference. Figure 21 depicts a stylised picture of
the insurance-reinsurance market.30 While primary insurers link to reinsurers, interlinkages
among primary insurers are comparatively limited. In other words, links between entities in
the insurance market are almost entirely hierarchical, and there is no network-like inter-

30
The argument follows Marc Philippe Radice: “Assessing the potential for systemic risks in the insurance
sector”, FINMA Working Paper, June/2010.

25/47
insurance market similar to the interbank market, for which we show a stylised representation
in figure 22.31 As a result, there are fewer feedback mechanisms to create non-linearity and a
potential for systemic risk within the insurance sector. Figure 21 also shows linkages bet-
ween reinsurers. However, these connections are weak. Reinsurers have little incentive to
cede parts of their main business lines to competitors. They are more prepared to cede
certain specialty lines in which they may have a particularly high concentration of risk. In
such cases, retrocession is likely to generate diversification benefits and contribute to an
improved capital management. However, one should recognize that these cessions cover
only a small proportion of the total reinsured risks.

58. The degree of interconnectedness within the (re)insurance sector is small,

although “intra-connectedness” within an insurance group or a financial conglome-
rate is not negligible. The absence of feedback loops implies that the likelihood of poten-
tially non-linear systemic reactions is small. This is another way of stating that the (re)insu-
rance market has built-in circuit breakers. To be sure, the failure of one reinsurer would
adversely impact its cedants. But the failure of one reinsurer does not necessarily cascade
through the market and cause the failure of other reinsurers or retrocessionaires.

Figure 21: The hierarchical structure of the (re)insurance market

Retro
Retro
Retro

R1 R3
R2 R4 (. . .) RN

Primary insurers Reinsurers

Source: FINMA / IAIS

Figure 21 (above) represents a stylised picture of interconnections in the (re)insurance sec-

tor. Circles representing primary insurers, reinsurers, and retrocessionaires are not drawn to
scale. The larger primary insurers write annual premiums in excess of USD 100 billion, while
the market leaders in reinsurance write about USD 40 billion. In total, primary insurers write
more than USD 4 trillion in premiums. Of this global volume roughly 5% is ceded to
reinsurers and about 0.6% to retrocessionaires. That said, it should be noted that static
considerations based on premiums written and ceded by primary insurers do not reflect the
dynamics arising from the confluence of several major catastrophe events that would stress
one (or several) reinsurer(s) and possibly impair the quality of reinsurance recoverables.

31
As more data becomes available, it is expected that evidence will confirm the predominantly hierarchical
network architecture of the (re)insurance sector. Ideally, the data should also help in assessing the degree of
interconnectedness between reinsurers and insurers.

26/47
Figure 22 (below) depicts a stylised picture of the interbank market.32 The blue circles in
various shapes denote differently sized financial institutions, while the lines indicate their
direct business connections, with the thickness of the lines representing the intensity of the
business interaction. The representation makes clear that the banks are part and parcel of a
complex network. From theoretical considerations we know that feedback mechanisms in
such networks are likely to amplify shocks that can propagate through the whole market and
create systemic crises in the process. The financial crisis of 2008 delivered a practical
example and it showed in particular that even shocks emanating from comparatively small
market participants may have systemic consequences.

Figure 22: The network structure of the global interbank market

Denotes individual
financial institution

Source: Bank of England / IAIS

59. In recent years, the IAIS has placed a particular focus on the macroprudential
surveillance of the reinsurance sector. Major work was done under the auspices of the
Reinsurance Transparency Group (RTG), which was tasked to monitor, among other items,
the potential risk transfer between banks and reinsurance companies. Over the years, the
RTG has expanded its scope and collected and analysed data on the
 Size and structure of the global reinsurance market
 Structure and profile of reinsurance risk assumed
 Credit risk transfer activity (including the use of financial derivatives)
 Counterparty risks and linkages to other sectors
 Profitability, capital adequacy, and sector-wide investment patterns.

Since 2004, RTG findings have been published in the now semi-annual Global Reinsurance
Market Report (GRMR). Some of the recurrent themes dealt with in recent GRMR issues are
summarised in points 59 to 61 below.

60. The record suggests that the evidence for global systemic risk to arise from
reinsurance failures has been small or non-existent so far. The RTG has repeatedly

32
The information for this representation draws from Andrew G. Haldane: “Rethinking the Financial Network,”
Bank of England, April 2009.

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reviewed various issues with a bearing on systemic risk. The following summarises three
findings.
 Concentration of reinsurance recoverables among primary insurers. In 2010,
the top US property and casualty (P&C) groups, for example, held 37% of recoverab-
les with the three biggest global reinsurers, with the allocation going in near equal
proportions to Swiss Re, Berkshire Hathaway, and Munich Re. Another 28% of reco-
verables was allocated to the numbers four through ten in the “Top 10” list of global
reinsurers; 35% went to the remainder of the reinsurance segment.33 The distribution
of reinsurance recoverables suggests that the US P&C industry has spread insurance
risks very broadly and on a global scale.

 Extreme loss scenarios. At the end of 2010, the capital of global reinsurers was
about USD 440 billion, equivalent to a solvency ratio of more than 250%. For the sol-
vency ratio to drop to 100%, it would require an aggregate reinsurance industry loss
of more than USD 260 billion, equivalent to economic losses of USD 2,000 billion. To
put such a number in perspective, one should recall that the economic loss from
hurricane Katrina was about USD 125 billion and that all great world-wide natural ca-
tastrophes that have occurred in the 60 years between 1950 and 2010 amounted to
USD 2,100 billion (in 2010 dollars). 34 These observations corroborate also with the
record of the severe 2011 catastrophe year. The Asia-Pacific region in particular ex-
perienced an exceptional sequence of natural catastrophes, which the global reinsu-
rance industry has weathered well. Comparatively large second quarter losses repor-
ted by major reinsurers appear not to have materially impacted aggregate solvency.
While recent renewal rounds show sharp rate hikes for catastrophe coverage in the
region, there has been little evidence so far of broad-based global reinsurance rate
increases.

 Reinsurance failures. Individual reinsurers are, of course, not immune to failures.

The record lists 29 such failures between 1980 and January 2011. In this period fell
three major catastrophic events (hurricane Andrew, the terrorist attacks of 9/11, and
hurricanes Katrina, Rita and Wilma); at their time they were all considered the largest
loss events in history. Assuming that the loss caused by the 29 failures was equal to
the premium volume before insolvency, the cumulated loss would amount to about
USD 1.8 billion, which represents 0.43% of the freely ceded premiums between 1980
and January 2010. 35

61. The record and stress scenarios scrutinised by the RTG correspond also to
the results of a study commissioned by the Group of Thirty. It found reinsurers in terms
of capital to be both robust and resilient and concluded that “the reinsurance industry is
unlikely to be a significant source of systemic instability in its broadest manifestation.”36 The
Group also thought it unlikely for retrocession spirals similar to the LMX spiral that the
London market experienced in the early 1990s to occur again.37 In short, so far no evidence

33
Industry communication to the RTG, July 2011.
34
Industry communication to the RTG, July 2011.
35
Industry communication to the RTG, July 2011.
36
Group of Thirty: “Reinsurance and International Financial Markets”, Washington 2006, p. 39.
37
LMX stands for London Market Excess of Loss. This market experienced a reinsurance spiral when
syndicates inadvertedly and repeatedly underwrote their retroceded risks. An unprecedented series of large

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has been unearthed that would point to reinsurers as a source of systemic risk. Of course,
the failure of a large reinsurance company could cause – like the failure of the Australian
insurer HIH discussed in appendix A10 – short-term market disruptions and it could impose a
high cost for individual counterparties. But the historical record does not show signs of
systemic contagion on a global scale.

62. Reinsurers have reduced their exposure to non-insurance CDS activities. The
B2B characteristic of reinsurance appears to foster a bias toward offering financial solutions
to insurers and non-insurers that tend to transcend the traditional reinsurance business.
Such an example is the underwriting of credit default swaps (CDS), which the RTG has been
tracking since 2003, and for which this report provides a specific example in appendix A5.
Figure 23 (below) reproduces global RTG data for CDS bought and sold (notional outstan-
ding) by reinsurance firms. The data show that over the last seven years, reinsurers have
continuously reduced the notional amount of CDS protection sold from a high of USD 20.3
billion in 2003 to a low of USD 4.0 billion in 2010 (estimate). At the same time they increased
the amount of protection bought from a low of USD 1.2 billion in 2006 to USD 4 billion
(estimated) in 2010. The volume of CDS protection sold should be compared to the market-
wide notional amount of sold CDS contracts of USD 22.2 trillion outstanding in the second
half of 2010.38 From the grand total one can conclude that reinsurers contributed less than
0.02% to the global market’s supply of CDS protection.

Figure 23: Credit default swaps bought and sold by reinsurers

25
Notional outstanding in USD bn

20
Bought Estimate
Sold
15

10

0
2003 2004 2005 2006 2007 2008 2009 2010

Source: Global Reinsurance Market Report 2010; IAIS estimates

63. The IAIS continues to be committed to the analysis and the macroprudential
surveillance of the reinsurance industry. Data collected by the IAIS in the future may shed
light on questions that in the past could be explored only through plausible a priori reasoning.
This is true, for example, for the study of risks arising from the concentration of risk exposu-
res. By the very nature of their business, reinsurers are exposed to the same class of risks

catastrophe losses highlighted the instability of the spiral, and the subsequent failure of a number of
syndicates led to changes in regulation in the United Kingdom and beyond. One step was to exclude
retrocessional business from reinsurance covers protecting direct insurance accounts. Furthermore, the
procedures, and in particular the way reinsurers in the London market and elsewhere keep track of their
potential exposures, were reformed in line with new regulatory requirements.
38
Bank for International Settlements (BIS): “OTC derivatives market activity in the second half of 2010”, Basel,
May 2011. The BIS data show also that the insurance sector as a whole has been a net buyer of CDS protec-
tion through all reporting periods.

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 as primary insurers. Risk concentrations may arise on the side of reinsurers, because they
are one step removed from the underwriting of primary insurers, and they may receive
incomplete risk information from their primary cedants. Exposure concentrations may thus
arise without reinsurers necessarily being fully aware of them. For this reason, most reinsu-
rers estimate their exposures in a different way than primary insurers, and they take steps to
limit their total exposure. That said, the answer to the question whether reinsurers are
exposed to high and potentially systemic exposure concentrations can only be given based
on data that include detailed information about the risk profile of the primary business ceded
to reinsurers.

64. In addition to the macroprudential surveillance activity the IAIS plans to look
into more specific reinsurance issues. A report scheduled for completion in early 2012 will
likely discuss risk concentration, retrocession spirals, and stress scenarios related to the
extreme catastrophe events that are typically absorbed by reinsurers. Finally, reinsurance
will continue to play a prominent role in the new Global Insurance Market Report (GIMAR),
which is scheduled for an inaugural release in the first half of 2012. It is designed to continue
the tradition set out by the Global Reinsurance Market Report by combining industry-wide
reinsurance data with newly assembled market data on primary insurers.

5.3 Insurers and systemic risk

65. The answer to the question whether insurers could cause systemic risk is ulti-
mately an empirical issue. In the following we summarise a few a priori considerations
without pre-empting an ultimately data-based decision on G-SIFI status.

66. The fundamentals of insurance suggest that size and the spread of global
activity by themselves should not be decisive indicators of systemic risk. Insurance is
based on the pooling of idiosyncratic risks and the law of large numbers. Consequently, risk
diversification benefits are expected to accrue with an increasing size of the business portfo-
lio and increasing global activities, although due consideration is necessary when accounting
for such benefits, especially geographical diversification benefits. To be sure, size and global
spread could potentially contribute to contagion. And size could be a good measure to reflect
the magnitude of systemic impacts given an insurer’s failure.

67. In insurance limited substitutability is unlikely to be systemically relevant in a

global context. In points 38 to 41 it was shown that market concentration rates in insurance
are generally small and competition is lively. Consequently, the loss of one carrier is unlikely
to cause widespread or systemic issues and problems for policyholders and the real eco-
nomy. On almost every occasion an insurer has failed in the past, the impact has been local.
The resultant gap was covered within a short period, and insurance capacity and substitu-
tability were quickly restored to pre-failure levels.39 That said, there might be lines of
business – for example in specialties, such as medical malpractice insurance or directors
and officers (D&O) liability cover – where certain carriers may have acquired quasi-
monopolistic positions. Their demise could cause at least temporary issues in the affected
sectors.

39
An often cited exception was the failure of HIH in Australia (see appendix A 10), but the short-lived impact was
contained to the local market.

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68. Interconnections between insurers and the banking system are relatively
weak. While insurers are exposed to investment risk through their holdings of fixed-income
and equity securities related to other financial market participants, the reverse appears not to
be true, although some banks are starting to provide derivative protection in relation to
insurance products that insurers offer to their customers. Insurers do not provide short-term
or long-term credit lines to banks and they are also not engaged in credit intermediation,
which would qualify them as part of the larger shadow banking system.

69. In contrast, recent crisis history suggests that insurance groups tend to suffer
distress as result of an increased exposure to non-insurance activities. These
activities, which at times were only lightly regulated or not at all, appear to be an important
source of risk that may become systemic. In the presence of intra-group commitments, such
exposures may contaminate the traditional business. While the lessons with respect to the
CDS underwriting (see case studies A4 and A5 in the appendix) and other financial products
are comparatively easy to draw, the task will certainly be more challenging when it comes to
non-traditional activities that defy quick classification. As the discussion on p. 10 ff. has
shown, insurance groups may offer a number of products and engage in a variety of non-
insurance business lines and they may include non-traditional features in their insurance
products. To the extent that these activities are not subject to insurance techniques and insu-
rance accounting, they qualify as non-insurance businesses. The identification of a systemi-
cally important insurance group therefore requires an appropriate understanding of the non-
insurance activities and their potential interaction with the traditional lines of business.

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6. Potentially systemic insurers and policy measures

6.1 Identifying systemic relevance

70. IAIS members are working on a methodology to identify global systemically

important financial institutions (G-SIFIs) in the insurance sector. The conceptual frame-
work follows broadly the approach developed by the Basel Committee on Banking Supervi-
sion.

71. The “non-traditional” data category is specific to the insurance sector given
the possibility of pursuing different businesses. From the discussion on the previous
pages it follows that non-traditional insurance business and non-insurance activities are likely
to play a pivotal role in the future G-SIFI methodology developed by the IAIS.

72. The methodology will be further refined in light of concrete data. It is the goal
of the IAIS to release the methodology for public consultation in the first half of 2012.

6.2 Policy measures

73. One key lesson of the financial crisis is that more weight should be given to
group-wide supervision. Such comprehensive supervision should account for all risk acti-
vities undertaken in a group and its entities. The need for such an integrated view was under-
scored most dramatically by the experience of AIG. It is probably fair to say that none of the
authorities engaged in the supervision of AIG was fully aware of the exposures entered into
by the subsidiaries of the holding company and that the supervisor in overall charge
inadequately monitored the underwriting of credit default swaps in the banking subsidiary.
The IAIS has launched several projects that address the issues highlighted by the AIG case.

74. The IAIS has revisited the material relating to group-wide supervision so that
the Insurance Core Principles better reflect the expectations for the supervision of in-
surers on a legal entity and group-wide basis. A revised version of the Core Principles,
including standards and guidance, was adopted by the IAIS General Meeting on 1 October
2011. Supervisory material was enhanced and added to set requirements and provide
guidance on establishing effective and efficient group-wide supervision frameworks,
encouraging and facilitating coordination and cooperation on a cross-border and cross-
sectoral basis (including in crisis situation), and dealing with unregulated entities in group-
wide supervision. Special attention was given to include the group-wide implications of a
number of issues such as direct or indirect participation, influence and/or other contractual
obligations, interconnectedness, risk exposure; risk concentration, and/or intra-group
transactions and exposures.

75. The IAIS has also launched work to building a common framework for the
supervision of internationally active insurance groups (ComFrame). As spelled out in
paragraph 10, ComFrame is directed at about 50 insurers which meet the criteria for inter-
nationally active insurance groups (IAIG) set by the IAIS. ComFrame is designed to make
group-wide supervision operational by addressing issues relating to IAIGs comprehensively.
And it addresses both the group-wide and host supervisors’ perspectives by defining roles for
cooperation and interaction, including supervisory colleges.

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76. ComFrame has the potential to advance the evolution of various roles in
cross-border supervisory cooperation. Developing ComFrame endeavours to facilitate in-
formation sharing between supervisors involved. Eventually, supervisors are expected to
establish a similar outcome to the key tasks of IAIG supervision.

77. ComFrame will also develop qualitative and quantitative requirements applica-
ble to the supervision of IAIGs. The qualitative requirements capture corporate governan-
ce, including the interaction between corporate bodies, and the setting up of processes for
risk management, actuarial work, internal audit and other processes. The quantitative
requirements will address – based on a comprehensive enterprise risk management
approach – liabilities and investments as well as valuation and capital adequacy.

78. Over the years, supervisors have developed a range of mechanisms to mana-
ge failing insurers that, in principle, should allow for orderly wind-ups. History shows
that none of the failures of typical insurers have resulted in developments that would meet
the definition of systemic events. In the case of failure it is often possible to partly or wholly
save the enterprise because lines of business are comparatively easy to define separately
and run off over time. If necessary, books of business can be transferred to other carriers. In
fact, it is almost a universal legal requirement that an insurer may not be closed down until its
policies have been run off or sold to third parties. As the case of Equitable Life illustrates
(see appendix A6), an insurer may carry on successfully in run-off, i.e. in managing a book of
business closed to new business that may last for another 40 years. And the case of Equitas
shows (see appendix A7) how a workable resolution can eventually be achieved when a
number of jurisdictions have a keen interest in the outcome.

79. IAIS members continue to debate the treatment of loss absorbency in insurers
and insurance groups. The result of the discussion will likely be shaped by insights gained
from the SIFI data collection. A number of important jurisdictions have embarked on reviews
and reforms of their solvency regimes. In the United States, for example, supervisors are re-
viewing the approach within the confines of the Solvency Modernization Initiative, while the
European Union is scheduled to implement the reformed Solvency II in 2014. Switzerland
has already introduced the Swiss Solvency Test (SST), which, though different in many
details, largely anticipates essential features to be finalised with Solvency II. On broad terms,
these review and reform processes have the potential to improve the understanding of risk in
insurance and draw a link to strengthened capital adequacy as well as loss absorbency.
However, the reforms are geared predominantly toward policyholder protection; preventing
systemic risk was not, and is not, their primary purpose. In the future, the impact of a non-
insurance business or non-traditional insurance activities in insurance groups will be analy-
sed in more detail and, if deemed necessary, reflected in resolution regimes and recom-
mendations for loss absorbency. First results will be discussed in a forthcoming IAIS paper
on resolution regimes together with the work coming out of the Joint Forum’s working group
on Principles for the Supervision of Financial Conglomerates.

80. Loss absorbency for insurers is captured, in general, by provisioning and risk
capital. However, extrapolating from the causes of financial impairment (see figures 3 and
4), inadequacy of reserves can be a major distress factor for traditional insurers. That is why
supervisors continuously monitor the adequacy of reserves or technical provisions and the
factors impacting them.

81. Any measure with respect to G-SIFI loss absorption in the insurance sector
must be based on the methodological lay-out sketched in table 1. Foremost, extending
the scope of surveillance to a non-insurance business or non-traditional insurance activities
will require a better understanding on how to treat activities supervised by other authorities

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and how to narrow or close regulatory gaps.40 In January 2010, the Joint Forum mapped out
a principle for further work. It stated “that the lack of a uniform global standard for capital
adequacy within each sector can contribute to regulatory arbitrage, competitive inequalities
across jurisdictions, and, in some cases, financial system instability.”41 The Joint Forum
suggested that more consistency in prudential frameworks across sectors would be desirable
“due to the increasing exposure of financial groups to similar risk factors and increasing
transfer of risks across sectors.” At the same time, it recognised that more convergence
within financial sectors would have to be achieved before consistent capital frameworks
could be established. It is essential to take into account the principles of the Joint Forum on
conglomerates to have an efficient supervision on dual activities. The IAIS agrees that
supervisory frameworks should minimize the scope for regulatory arbitrage. This may require
the implementation of banking regulation and supervision for appropriately identified and
ring-fenced bank-like activities conducted by insurance groups.

7. Concluding remarks
82. In this note we summarised why, in general, there is little conceptual reason
for life and non-life insurance activities to either trigger or amplify systemic risk. The
reasons have to do with the specific nature of the insurance business model and in the way
insurance liabilities are funded and claims are settled. As it is very unlikely for insurance
firms, or the whole sector for that matter, to experience rapid cash drains and outright runs,
liquidity risk appears to be well contained. And even in the case of insolvency, the long term
nature of insurance liabilities and their extended run-off profiles, along with the authorities
and tools available to regulators, typically provide for orderly resolutions of traditional
insurance firms.

83. This note has also provided some tentative evidence that substantial non-
insurance activities have the potential to distress even well-run insurance-dominated
groups. The financial market proximity of non-traditional activities may also contribute to
making insurance groups systemically important. However, more concrete answers to the
question of systemic relevance of particular insurers must be informed by concrete data.

40
In a number of jurisdictions, financial groups are subject to dual supervision by insurance and banking
authorities.
41
Joint Forum: “Review of the Differentiated Nature and Scope of Financial Regulation – Key Issues and
Recommendations”, January 2010.

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References
A.M. Best: “Best’s Impairment Rate and Rating Transition Study – 1977–2009”, May 2010.
Bank for International Settlements: “OTC derivatives market activity in the second half of
2010”, Basel, May 2011.
Berliner, Baruch: “Limits of Insurability and Risks”, Prentice-Hall 1982.
Committee on the Global Financial System (CGFS): “Fixed income strategies of insurance
companies and pension funds”, CGFS papers, June 2011.
Congressional Oversight Panel: “The AIG Rescue, its Impact on Markets, and the
Government’s Exit Strategy”, June 2010.
Financial Stability Board (FSB): “Reducing the moral hazard posed by systemically important
financial institutions”, October 2010.
Financial Stability Oversight Council: “2011 Annual Report”, Washington, DC, 2011.
Geneva Association: “Systemic Risk in Insurance; an analysis of insurance and financial
stability”, Geneva 2010.
Group of Thirty: “Reinsurance and International Financial Markets”, Washington 2006,
Haldane, Andrew G.: “Rethinking the Financial Network”, Bank of England, April 2009.
The HIH Royal Commission: “The Failure of HIH Insurance, Volume I: A corporate collapse
and its lesson”, Canberra 2003.
Joint Forum: “Review of the Differentiated Nature and Scope of Financial Regulation – Key
Issues and Recommendations”, January 2010.
Klein, Robert W.: “Principles for Insurance Regulation: An Evaluation of Current Practices
and Potential Reforms”, The Geneva Papers on Risk and Insurance, GPP/IIS Awards
Edition, June 2011.
National Commission on the Causes of the Financial and Economic Crisis in the United
States: “The Financial Crisis Inquiry Report”, Washington 2011.
De Nederlandsche Bank: “Overview of Financial Stability in the Netherlands”, May 2009/9.
Radice, Marc Philippe: “Assessing the potential for systemic risks in the insurance sector”,
FINMA Working Paper, June/2010.
Stringa, Marco and Allan Monks: “Inter-industry contagion between UK life insurers and UK
banks: an event study”, Working Paper no. 325, Bank of England, May 2007.
Swiss Re: “World insurance 2009”, sigma 2/2010.
Swiss Re: “Insurance investment in a challenging global environment”, sigma 5/2010.

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 Appendix

A1: Insurance runs in Hong Kong and Singapore

Market developments in Hong Kong

In light of media reports about the financial difficulties experienced by AIG, the
number of surrendered policies of the AIA, a collective name for American International
Assurance Company (Bermuda) Limited (“AIA(B)”) and American International Assurance
Company Limited (“AIA Ltd”)), on the first few days after the outbreak of the AIG crisis
increased slightly above long-term averages. In the week after the Insurance Authority of
Hong Kong imposed a ring-fencing requirement, the average number of surrendered policies
dropped and the number of surrendered policies continued to decrease in subsequent
months and maintained a stable level throughout 2009. After September, the number of
surrendered policies per working day was similar to that seen prior to the crisis in 2007.

Contained developments in Singapore

In Singapore, policyholder queues started forming at the Customer Service Center

of The news that AIG might be the next to fail following Lehman’s file for bankruptcy on 15
September 2008 resulted in a loss of confidence amongst some policyholders in Singapore.
By 16 September, queues had formed at the Customer Service Center of American
International Assurance Company Limited, Singapore Branch (“AIAS”). This was the first and
only “insurance run” experienced in Singapore to date. However, AIAS did not face any
liquidity constraints as the percentage of surrender redemptions against the total number of
policies in force was small.

The Monetary Authority of Singapore (“MAS”) issued press statements in the week
of the 15 September to assure that AIAS was meeting the regulatory capital requirements,
and was required under the Insurance Act (Cap. 142) to maintain statutory insurance funds
which were segregated from its Head Office and other shareholders’ funds. MAS also
cautioned policyholders against the disadvantages of the premature termination of insurance
coverage. AIAS issued its own press release to assure it had more than sufficient capital and
reserves to meet its obligations, and reiterated that the fund maintained in Singapore was
segregated from AIG. MAS imposed asset ring-fencing measures on AIAS.

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A2: State intervention in the Netherlands

In late 2008, during the height of the financial crisis, the Dutch government took
measures to restore confidence in the financial system. As part of the intervention, the
government committed itself to provide capital support to each financial institution that faced
difficulties because of the financial crisis, but was fundamentally healthy and viable. The
facility was part of a European action plan to calm financial markets. EUR 20 billion was
made available. ING Group, Aegon Group and SNS Reaal have used this facility for an
amount of EUR 14 billion in total.

These three financial institutions have in common that they all conduct both banking
and insurance activities, although the relative size of these activities differs per institution.
ING Group consists of a large bank with a balance sheet total of EUR 1000 billion and a
smaller insurer, but still very large insurer (EUR 300 billion), whereas on the other hand
Aegon (EUR 290 billion) is mainly an insurer with only limited banking activities (EUR 5
billion). SNS Reaal is a so-called symmetric financial conglomerate, with more or less the
same size of banking and insurance activities: SNS Bank (EUR 75 billion) and Reaal
Insurance (EUR 50 billion).42

Although the circumstances differ per institution, there are some general remarks to
be made about the rationale for government intervention.

First, against the backdrop of overall loss in confidence in financial markets, these
institutions faced acute liquidity problems. Banks were particularly hit when the money
market dried up and they were vulnerable to a sudden and large withdrawal of time deposits.
Insurers were less vulnerable to liquidity problems, due to the long-term nature of their
liabilities, but sustained large losses in investment portfolios. Especially for life insurers this
resulted in declining solvency ratios, as did their stock market value. The government
intervention was aimed at strengthening their financial buffers, inter alia in order to secure
access to financial markets.

Second, there were increased signs of reputational effects (loss of confidence), both
within financial conglomerates and to other financial institutions and the general financial
system and economy. Within financial conglomerates, confidence effects may cause
distress at the insurer to spread to the bank or vice versa, regardless of the level of actual
financial linkages between the bank and insurer. Problems at the insurance part could hence
easily result in a loss of confidence in the group as a whole or the bank. In addition, there
was the fear of reputational contagion to other financial institutions or the financial system as
a whole. This particular channel of systemic risk is exemplified by figure 21 below, which
shows the increased correlation in CDS spreads of ING and Aegon since the start of the
crisis in mid-2007.

42
All figures year-end 2008. Source: Annual reports.

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Figure 24: CDS-correlation: ING and Aegon
Moving correlation of 20-days

1.00

0.75

0.50

0.25

0.00

-0.25

-0.50

-0.75

-1.00
Jan-07 Jul-07 Jan-08 Jul-08 Jan-09 Jul-09 Jan-10 Jul-10 Jan-11

Source: Thomson Datastream, Bloomberg

Summary of Government support

ING Group

 October 2008: receives government capital injection of EUR 10 billion

- of which EUR 2.8 billion to ING Insurance

 June 2011: Remaining capital injection is EUR 3 billion

Aegon Group

 October 2008: Receives government capital injection of EUR 3 billion

 June 2011: Remaining capital injection of EUR 750 million fully paid back
SNS Reaal

 November 2008: Receives government capital injection of EUR 750 million and private
capital injection (from majority shareholder “Stichting beheer”) of EUR 500 million

- of which EUR 775 million to Reaal

 June 2011: Remaining capital injection is EUR 665 million

Sources: DNB, Press archive, http://www.dnb.nl/en/news/news-and-archive/

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A3: The Failure of AIG’s CDS Business43

In 2004, American International Group (AIG) was the largest insurance company in
the world as measured by stock market capitalisation and a number of other attributes. It was
a gigantic conglomerate with USD 850 billion in assets, 116,000 employees in 130 countries,
and 223 subsidiaries.

Starting in 1998, AIG Financial Products (AIGFP), a Connecticut-based unit with

major operations in London, figured out a new way to make money from the AAA credit
rating of AIG. Relying on the guarantee of the parent company, AIGFP became a major over-
the-counter derivatives dealer, eventually having a notional portfolio of USD 2.7 trillion.
Among other derivatives activities, the unit issued credit default swaps (CDS) guaranteeing
debt obligations held by financial institutions and other investors. In exchange for a stream of
premium-like payments, AIGFP agreed to reimburse the investor in such a debt obligation in
the event of any default.

AIGFP grouped its CDS business into three separate categories, based on the
underlying assets that were insured: corporate debt/CLOs (corporate arbitrage), regulatory
capital, and multi-sector CDOs. At its peak in 2007, these three groups represented an
aggregate CDS portfolio of USD 527 billion, amounting to just 20% of the unit’s overall
derivatives exposure of USD 2.66 trillion. Only USD 149 billion, or 6%, of AIGFP’s total
derivatives portfolio in 2007 was classified as arbitrage CDS, comprised of both the multi-
sector CDO and corporate debt/CLO components. Ultimately, these two portfolios accounted
for 99% of AIGFP’s unrealised valuation losses in 2007 and 2008. AIGFP’s multi-sector CDO
subset of the arbitrage portfolio, which represented approximately 3% of the notional value of
AIGFP’s total credit and non-credit derivatives exposure, accounted for over 90% of these
losses.

AIGFP did not post collateral when it wrote CDS contracts; but unlike monoline
insurers, AIGFP agreed to post collateral if the value of the underlying securities dropped, or
if the rating agencies downgraded AIG’s long-term debt ratings. While market conditions
remained similarly illiquid, ratings downgrades on the reference securities and valuation
losses by market participants helped establish two of the three primary triggers for collateral
payments. In 2007 AIG recognized an unrealized market valuation loss totalling USD 11.25
billion, which primarily occurred in the fourth quarter of 2007. As the value of the underlying
CDOs continued to decline thereafter, AIG—under mark-to-market accounting standards—
recorded valuation allowances on its contracts. While these losses were in almost all cases
unrealised non-cash valuation charges, they corresponded with collateral calls from
counterparties, which contributed to a drain on AIG’s cash resources. Predictably, valuation
write-downs into the billions of dollars and collateral calls from CDS counterparties intensified
pressure on AIG’s own credit rating, the third key component in the collateral calculation
cocktail. Subsequent downgrades of AIG’s credit rating in turn precipitated additional
collateral calls. This negative feedback loop exposed the firm’s securities lending business,
as trading partners worried about exposure to AIG chose to unwind USD 24 billion of
securities lending transactions in a matter of days, creating a liquidity shock for which the

43
The box draws from material presented in the report submitted by the Congressional Oversight Panel
(“The AIG Rescue, its Impact on Markets, and the Government’s Exit Strategy”) of June 2010.

39/47
programme was unprepared.

The demand for collateral calls accelerated in 2008 as a result of the rapid deterio-
ration of its multi-sector CDS portfolio. In the first and second quarters of 2008, AIG scramb-
led to post USD 20.8 billion in cash to meet its collateral obligations for this portfolio. In the
third quarter of 2008 (ending September 30, 2008), AIG had posted approximately USD 31.5
billion in collateral as a result of the deterioration in value of its multi-sector CDO portfolio.
The problems at AIG had reached crisis point. A sinkhole had opened beneath the firm, and
it lacked the liquidity to meet collateral demands. In only a matter of months AIG’s worldwide
empire had come near collapse, brought down by the company’s near-insatiable appetite for
risk and poor management of its own liabilities.

AIG’s near-collapse was possible because of the sweeping deregulation of over-the-

counter (OTC) derivatives, including credit default swaps, which effectively eliminated federal
and state regulation of these products. The OTC derivatives market’s lack of transparency
and effective price discovery exacerbated the collateral disputes of AIG and Goldman Sachs
as well as similar disputes with other counterparties. AIG had engaged in regulatory arbitrage
by setting up a major business in an unregulated product, locating much of the business in
London, and selecting a weak federal regulator, the Office of Thrift Supervision (OTS).

AIG was so interconnected with many large commercial banks, investment banks,
and other financial institutions through the relationships on credit default swaps and other
activities such as securities lending that its potential failure had created systemic risk. The
U.S. government concluded that AIG was too big to fail and committed more than USD180
billion to its rescue. Without this timely bailout, AIG’s default could have caused cascading
losses throughout the US and the global financial system.44

44
On 3 March 2009, in testimony to the US Senate Banking Committee, Ben Bernanke, the Chairman of the
Federal Reserve said, “A failure of AIG would have been devastating for the U.S. financial system,” and he
elaborated that in light of the company’s ties to major financial firms across the globe, its collapse would have
been “devastating to the stability of the world financial system.” And US Secretary of the Treasury, Tim
Geithner added, “And your government made the judgment back in the fall that there was no way that you
could allow default to happen without catastrophic damage to the American people.” See reporting in the
Washington Post, 4 March 2009.

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A4: Swiss Re’s experience in CDS underwriting45

On 19 November 2007, Swiss Re reported a CHF 1.2 billion before tax mark-to-
market loss arising from its credit underwriting activities following the sharp market
deterioration in October 2007. The source of the loss was the company’s exposure to two
related investment grade credit default swaps written by the Credit Solutions unit that had
provided protection for a client against a fall in the value of a portfolio of assets.

The severe ratings downgrades undertaken by rating agencies in October 2007, and
the lack of a truly liquid market for these securities, resulted in a significant and material
reduction of the value of the underlying assets. The portfolios protected through these credit
default swaps consisted largely of mortgage-backed securities in various forms, including
residential and commercial mortgage-backed securities. While the majority of the exposure
was to prime and mid-prime securities, there was exposure also to sub-prime and, more
importantly, to collateralised debt obligations or CDOs.

Thus, Swiss Re marked down these ABS CDOs to zero. The sub-prime securities
were written down to 62% of their original value. Other smaller adjustments were made to the
remainder of the portfolio. The market value of the portfolio was then at CHF 3.6 billion. The
transactions continued to be exposed to market value changes.

While Swiss Re absorbed sizeable losses caused by the credit default swaps written
by the Credit Solutions unit, no systemic implications were observed either with respect to
other insurers or the financial system as a whole.

45
Source: Press Release of Swiss Re of 19 November 2007.

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A5: Equitable Life

Equitable was and is a mutual company. An unusually high proportion of its policies
contained Guaranteed Annuity Rates (GARs). Its GARs were more generous and flexible
than most others in the market, and constituted a far greater proportion of its business than
its competitors. From 1993 onwards, the GAR rates were almost always higher than market
levels, so it became advantageous for policyholders to exercise this right. This inflicted a
heavy strain on Equitable’s capital, even though sales of new GAR policies had ended in
1988. With a far lower level of free assets than its peers and, as a mutual, no obvious access
to additional capital, the need to meet these GAR liabilities inevitably depleted the profits and
capital protection available to non-GAR policyholders.

To address this increasingly onerous liability, Equitable (and some other insurers)
introduced a “Differential Terminal Bonus Policy” (“DTBP”), whereby policyholders exercising
the GAR right received a lower terminal bonus than those who had non-GAR policies and
who would therefore receive market rate annuities. The DTBP was intended to equalise the
values of the different types of policy. However, as interest rates fell during the 1990s, the
differential between the terminal bonus rates necessarily widened. Faced with increasing
complaints from GAR policyholders, Equitable instigated legal proceedings on a test case
(“Hyman”) intended to establish the validity of its DTBP approach. Eventually, the House of
Lords held that Equitable was not entitled to operate the DTBP. This had devastating
consequences for Equitable as it immediately increased its liabilities by around GBP 1 billion.

Following unsuccessful attempts to sell itself, Equitable was forced to close to new
business in December 2000. During the next two years there followed a series of sharp
reductions in discretionary policy values which had been communicated to policyholders to
try to align them with Equitable’s available assets. It resulted in significantly lower payments
on maturity of policies and in annuity payments. Additionally, under a S425 Companies Act
agreement, Equitable bought out the GAR liabilities. Since then, it has sold off various parts
of its book to other insurers, but it continues to run off its remaining business, a process that
is likely to take more than 20 years to complete. Having had assets of about GBP 30 billion in
December 2000, Equitable’s balance sheet now stands at about GBP 8 billion. Importantly,
while it has been forced repeatedly to reduce policyholder benefits, Equitable has never
“failed” in the sense of defaulting on contractual liabilities or becoming insolvent. It has
remained in solvent run-off throughout.

The most recent of the string of inquiries into Equitable, the second investigation by
the Parliamentary Commissioner for Administration (the Ombudsman), found ten counts of
maladministration by the various regulatory bodies responsible for Equitable’s supervision
between the early 1990s and 2001 and recommended (without being specific) that
policyholders should be compensated for their losses. All findings have now been accepted
by the new Government, on behalf of the regulatory bodies, which have publicly apologised.
The Ombudsman report also led to a GBP 1.5 billion ex gratia compensation scheme being
put in place by the Government.

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A6: Equitas

A rising tide of asbestos and other pollution and catastrophe claims in the 1980s
meant that certain Lloyd’s syndicates were exposed to large losses, principally in the United
States. As part of the Reconstruction and Renewal Project, which was implemented with the
virtually unanimous consent of the names to address the problems caused by such losses,
Equitas, a special purpose reinsurer, was formed in 1996 to reinsure without limitation in time
or amount the 1992 and prior non-life obligations of Lloyd’s Names. As well as providing a
reinsurance vehicle for Names, the establishment of Equitas also effectively ring-fenced the
“old Lloyd’s” from the “new Lloyd’s”.

Even though they now had reinsurance cover, Names were still liable for the
underlying insurance policies in the event that claims exceeded Equitas’ reserves. In order to
provide finality to Names, in 2006 Equitas began a two-part total retrocession to NICO, a
subsidiary of Berkshire Hathaway. The first part involved reinsuring its claims obligations up
to a limit of USD 14.4 bn — USD 5.7 bn more that Equitas’ reserves at the time. The second
part took place in 2009 when the liabilities of the Names were transferred to Equitas in what
is known as a Part 7 transfer.46 Upon the transfer Equitas purchased a further USD 1.3 bn of
reinsurance from NICO for a premium of GBP 40 million, a provision of the retrocession
agreement conditional on the transfer taking place before the end of 2009. Names are now
no longer liable under English and EEA law for any future claims on 1992 and prior business.

In pursuing the Part 7 transfer, the FSA spoke with its United States, Canadian and
Australian counterparts. None of them objected to the transfer, as policy holders would not
be worse off and may even be better off under the new arrangements. However, Equitas did
not seek formal recognition of the Part 7 transfer in these jurisdictions. It means that in
theory, if claims exceeded the reinsured amount, or NICO/Berkshire became insolvent and
was unable to meet claims, American policy holders could try to claim against Names, but
only those in jurisdictions outside of the EEA. However the risk of either of these events
happening is considered to be low. If all else failed, US policyholders would still also have
potential recourse to the Joint Asset Trust Funds that Lloyd’s must maintain to do business in
the United States.

46
A Part 7 transfer, named for the Part of the Financial Services and Markets Act that allows for it, must be
approved by the Court. The application for transfer must be accompanied by an independent expert’s report
as to the likely effects on policyholders and other stakeholders of the transfer.

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A7: Securities lending at AIG47

The near failure of AIG, the world’s largest insurance conglomerate at that time, is
largely attributed to losses in AIG Financial Products’ (AIGFP) credit default swap (CDS)
book (see appendix A4). However, another financial stress existed by September 2008; AIG
had also incurred significant losses because of its securities lending programme. In hind-
sight, this programme was characterised “a blatant risk-management failure” (OR, p. 38).

What happened? The AIG securities lending programme was handled through an
approved investment pool managed by an affiliated non-insurer. Prior to 2005 the pro-
gramme had been reviewed and it was found to be a traditional programme with asset
durations similar to the durations of lending contracts. Unbeknownst to regulators the
investment philosophy was changed around 2005/2006. AIG used some of the “collateral to
buy residential mortgage-backed securities (RMBS), with the intention of maximizing its
returns. At the height of AIG’s securities lending program in 2007, the U.S. pool held USD 76
billion in invested liabilities, 60 per-cent of which were RMBS” (OR p. 34). Ironically, AIG had
changed the securities lending strategy at a time when AIGFP began to reverse its
engagement in the U.S. mortgage market.

When regulators became aware of the mismatch and the RMBS exposure in late
2007, they began working with management to create more liquidity and move toward an
orderly wind-down. By the end of September 2008, the pool had declined to less than USD
59 billion. Although the assets in the pool were performing, market values were dropping
rapidly as were most all RMBS. A run on the programme began when news broke that
potential rating agency downgrades would trigger billions of dollars of additional CDS
collateral posting requirements and force the holding company into bankruptcy.
Counterparties seeking to reduce exposure to AIG unwound USD 24 billion of securities
lending transactions from 12 September to 30 September. With RMBS values falling and the
market increasingly illiquid, the programme suffered a liquidity shock. Combined, the
collateral demands from AIGFP counterparties and the liquidity shock of securities lending
caught AIG in a “double death spiral” where “problems in AIGFP exacerbated the problems
in securities lending and vice versa…, as it struggled to meet its cash demands” (OR, p. 19)

Regulators believe that the insurance entities would have had sufficient liquidity to
terminate the pool had it been necessary. In fact, on September 16 the insurer did provide an
additional USD 6 billion of liquidity to prevent a default. Without the problems at AIGFP, the
counterparties of AIG might have indeed been more inclined to maintain their borrowing of
securities from AIG, while AIG’s management would have had the luxury of time to work
toward the orderly wind-down agreed with regulators. However, it is important to recognize
the pressures inherent in systemic crises and that AIG was in the middle of such a systemic
crisis.

47
The box draws from material presented in the reports submitted by the National Commission on the Causes of
the Financial and Economic Crisis in the United States (submitted in January 2011 and henceforth
abbreviated “CI”) and by the Congressional Oversight Panel (“The AIG Rescue, its Impact on Markets, and the
Government’s Exit Strategy”) of June 2010 and abbreviated “OR”. We also acknowledge substantial input
from the Texas Department of Insurance, the lead regulator of AIG’s life insurance operations in the United
States.

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A8: Market contagion caused by fire sales

It is a perennial question whether the investment behaviour of the insurance sector

as a whole could create adverse spillovers for other financial institutions. A sizeable decline
in asset prices, so the argument goes, could adversely impact the solvency of insurers,
which then would be forced to sell assets in a declining market in order to fulfil adequate sol-
vency requirements.

While definitive answers must remain elusive, the stock market decline experienced
in the UK between 2001 and 2003 provides an illuminating historical example. At that time,
UK life insurers, which by tradition were invested heavily in equities, came under pressure by
the prolonged and substantial fall in equity prices. To maintain adequate solvency they were
perceived to need to sell assets into an already declining market, thus seemingly exacer-
bating the market’s down force. In fact, the FSA applied forbearance twice to exempt life
insurers from then existing solvency requirements. Hence, the 2001 to 2003 period creates
an opportunity to examine market linkages between insurers and other financial institutions.

An event study48 of the interlinkages between UK banks and life insurers at that time
of distress concluded that, in general, there was no materially significant contagion between
insurers and banks. An exception were banks such as Lloyd’s, Abbey National, and HBOS,
which had substantial holdings in life insurance companies, making them vulnerable to ad-
verse events originating in the (life) insurance sector. Hence, the contagion did not arise with
insurers per se, but was rather a result of concentrated bank investments in the life insurance
sector. This finding is broadly consistent with the experience in the Netherlands in 2008
where the interconnectedness between various parts of financial conglomerates engaged in
bankassurance was pronounced to have systemic implications requiring government inter-
vention.

48
Marco Stringa and Allan Monks, “Inter-industry contagion between UK life insurers and UK banks: an event
study,” Working Paper no. 325, Bank of England, May 2007.

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A9: The failure of HIH

On 15 March 2001, the major companies in the HIH Insurance group, Australia’s
second largest insurer, were placed in provisional liquidation, and formal winding-up orders
were made on 27 August 2001. By then, the deficiency of the group was estimated to be
between AUD 3.6 billion and AUD 5.3 billion.49 The collapse of HIH qualified then as the
largest corporate failure in the history of Australia. According to the Royal Commission
appointed to examine the cause of the failure and its lessons, “the collapse of HIH has
reverberated throughout the community, with consequences of the most serious kind.”50

Incorporated in 1968, HIH started as provider of workers compensation cover in the

Victorian market. In the mid 1980s, after legislative changes had significantly reduced busi-
ness in Victoria and South Australia, HIH began to diversify mainly through acquisitions. By
2000, the group through its many subsidiaries had become a key player in Australian and
international non-life insurance markets with lines of business comprising workers compen-
sation; public and private liability; and property, industrial and commercial insurance.

While there were many factors contributing to the failure of HIH, the Royal Commis-
sion identified as key elements the lack of a clear and integrated group strategy, including a
poorly implemented growth strategy without adequate due diligence; poor underwriting; sys-
temic under-reserving and under-pricing; the use, and abuse, of reinsurance; and poor cor-
porate governance with an ineffectual board that did not adequately probe management.

Large corporate failures always have reverberations that go beyond the company’s
perimeter and at times even beyond the industry. In this context, three observations are rele-
vant for the discussion about insurance failures and their potential systemic impact.

 Economic losses: Although the government did not bail-out HIH, there were sub-
stantial economic losses accruing to HIH creditors and Australian taxpayers. Accor-
ding to a recent update of the Scheme Administrator51 for HIH Casualty and General
Insurance Limited (one of the eight companies of the former HIH group now in run-
off), so far creditors with insurance liabilities in Australia have received 31% of
estimated final Scheme Payments; creditors with insurance liabilities that are not
liabilities in Australia have received 26.4%; creditors with liabilities in Australia that
are not insurance liabilities have received 25%; and creditors with liabilities that are
neither liabilities in Australia nor insurance liabilities have received 20%. Following
the HIH collapse, the government established an HIH Claims Support Scheme

49
The HIH Royal Commission, The Failure of HIH Insurance, Volume I, A corporate collapse and its lesson,
Canberra 2003, p.xiii.
50
The HIH Royal Commission, op. cit. p. xiv.
51
A Scheme of Arrangement is a compromise or arrangement between a company and its creditors (or any
class or them), governed by Section 411 of the Corporations Act 2001 in Australia or section 425 of the
Companies Act in England. The Schemes of Arrangement are administered separately, but parallel to, the
Liquidations of the Scheme Companies. Instead of dealing with the Liquidators, the affairs of creditors are
handled by the Scheme Administrators.

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 designed to distribute some AUD 640 million to assist HIH policyholders who met
specific eligibility requirements. This Scheme was funded by taxpayers.52

 Contagion: While the HIH failure did not cause contagion for other financial services
providers, it did, in the view of the Royal Commission, “impose significant costs on
other sectors. For example, the building industry was seriously affected when HIH
collapsed, as builders found it difficult to find compulsory warranty insurance cover for
projects in some states. This was at least partly the result of the dominance of parts
of the builders warranty market by HIH.”53 According to the Royal Commission, “the
cost to the building and construction industry alone has forced state governments to
spend millions of dollars of public money to prevent further damage to the industry.”54

 Substitutability: The dominance of HIH of parts of the builders warranty market, as

pointed out by the Royal Commission in the previous bullet, suggests that the failure
of HIH led to certain substitutability issues. Although insurance markets tend to be
competitive, the under-pricing of risks by HIH had shut out a number of competitors.
They were reluctant to enter the market at the price level maintained by HIH, and
cover became available only after the market had accepted sizeable rate increases.
This market hardening occurred against the back-drop of a much broader global har-
dening in 2001 that was related to the terrorism events of 9/11, a series of natural
disasters, and the bursting of the dot-com bubble, which, in turn, fostered a significant
decline of global equity markets.

Although it should be clear that the demise of HIH did not have systemic impacts on
a global scale, one could argue that developments with respect to economic losses, conta-
gion, and substitutability displayed certain features of domestic systemic importance. While
the issues related to contagion and substitutability appear to have been limited both in size
and duration, the economic losses accruing to HIH policyholders, creditors and taxpayers
were certainly real and the pain inflicted on individuals was deep.

52
See the HIH Royal Commission, op. cit. p. 290. Some State statutory insurers, however, did introduce a
premium surcharge to recoup some of their costs and losses. In addition, a post-funded levy was imposed on
the industry to cover HIH claimants for any shortfall beyond the subrogated claims.
53
The HIH Royal Commission, op. cit. p. 200.
54
The HIH Royal Commission, op. cit. p. xv.

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