In this exploration of liquidity and solvency risks in insurance companies, we’ll examine how these risks interact, often in surprising ways. We’ll challenge common assumptions about insurance company risks and explore how modern insurance practices have evolved traditional risk profiles.

Understanding the Basics: Banks vs Insurers

The classic banking model of liquidity risk is straightforward: banks transform short-term deposits into long-term loans. This maturity transformation creates inherent liquidity risk – even a perfectly solvent bank can face a crisis if too many depositors demand their money simultaneously. This fundamental risk drives the existence of central banks as lenders of last resort.

Insurance traditionally operated differently. With predictable claims patterns, regular premium income and unoptimised balance sheets, insurers weren’t thought to face significant liquidity risks. However, modern insurance practices and product designs have created more complex liquidity dynamics that challenge traditional frameworks. These liquidity-risk-increasing practices include some risk management choices (hedging and use of derivatives) and balance sheet sweating.

Sources of Liquidity Risk for Insurers

Insurance companies face several distinct sources of liquidity risk, some traditional and others emerging from modern practices:

Derivatives and Modern Asset Management

Modern investment strategies create significant liquidity demands:

• Use of illiquid assets through debt origination, greater use of corporate paper in general to provide higher yields for annuities and guaranteed/fixed bond products, private equity and other alternatives seeking additional yield
• Variation margin calls on derivatives require immediate cash as markets move
• Derivative roll risk creates periodic liquidity needs
• Rolling medium term corporate paper maturities into new instruments has elements of liquidity risk as part of the broader roll-risk universe
• Repo arrangements require careful liquidity management
• Hedging programs, while reducing other risks, increase liquidity demands

Policy Surrenders and Lapses

The liquidity impact of surrenders and lapses varies significantly by product type:

• Savings policies backed by liquid assets present limited liquidity risk
• Corporate policies often include liquidation notice periods
• Market value adjustments can share losses with policyholders
• Risk policies with negative liabilities create complex dynamics – while lapse might improve solvency ratios, the loss of positive cash flows can create future liquidity strains
• Loss of shareholder value is still likely the major risk for lapses and surrenders – and as a result it usually gets plenty of attention without the liquidity risk lens.

Internal Hedging and Optimisation

Insurance liquidity isn’t just about having assets to meet claims. Insurers often use positive cash flows from some policies (particularly risk policies with negative liabilities) to fund claims on other, especially older or maturing policies. This practice, while potentially efficient in normal times, creates hidden liquidity risks.

If these positive cash flows diminish (through lapses or reduced new business), the liquidity characteristics of the underlying assets become crucial. An insurer might appear to have strong liquidity based on expected premium inflows, but this can quickly change if those inflows reduce or stop.

Further, using negative liabilities (from profitable, early duration risk policies) to match positive ones (e.g., guaranteed savings products) creates hidden liquidity risk. This practice is another example of the “improvement” of an old, “lazy” matching approach that missed this opportunity for internal hedging, but perhaps reduces implicit buffers we may have come to rely on.

Claims Concentration

Sudden spikes in claims can create liquidity pressure:

• Natural catastrophes affecting property insurance
• Pandemic-related death claims
• Industrial accident clusters
• Legal or regulatory changes triggering multiple claims

Throughout these claim concentration risks, the performance of reinsurance and cash timing is also critical.

Premium Collection Disruption

Disruption to premium income can occur through:

• Economic downturns affecting customer ability to pay
• Operational disruptions to collection processes (South Africa experienced this a few years ago with the failure of a notable, concentrated exposure to a single premium collector)

Investment Portfolio Liquidity

Asset liquidity can become constrained through:

• Property/Real Estate holdings requiring time to sell
• Private equity/debt with limited secondary markets
• Complex structured products becoming illiquid in stress scenarios
• Market-wide liquidity stress affecting even traditionally liquid assets
• Money market fund holdings proving less liquid than assumed when stressed

Regulatory plans for improved liquidity risk management and reporting for insurers

Regulators are understandably keen to get a better handle on liquidity risk within the insurance sector – and are keen for insurers to take liquidity risk more seriously. Existing measures are widely considered imperfect (at best).

While we don’t want perfect to be the enemy of the good, there seems to be an opportunity to aim for better than current proposals.

The High-Quality Liquid Assets (HQLA) Paradox

A crucial distinction between banks and insurers lies in their access to central bank facilities. Banks can convert HQLA to cash via central bank discount windows, making these assets effectively cash equivalents. Insurers, lacking this access, face a different reality: even “highly liquid” assets can become illiquid during market stress. Insurers and other non-bank financial institutions may want access to the discount window, but my understanding is that this idea is a non-starter.

This creates an interesting regulatory paradox. Bank-style liquidity reporting, with its focus on monthly reporting, micro bucketing of asset maturities, but with implicit and assumptions about central bank access, may be suboptimal for insurers. Yet some regulatory frameworks still look to apply bank-centric thinking to insurer liquidity management.

Systemic Risk and Money Market Funds

A particular concern arises with money market funds, often assumed to be perfectly liquid. While an individual investor can usually liquidate their money market holdings easily, this isn’t true for the market as a whole. If the underlying instruments become illiquid, large-scale redemptions become impossible.

This creates a systemic risk: the appearance of liquidity in normal times masks the potential for market-wide liquidity crises. When multiple institutions rely on the same sources of apparent liquidity, the system becomes more fragile.

Testing Liquidity – Easier Said Than Done

Testing the ability to liquidate assets remains challenging. Current approaches to estimating liquidation costs are still maturing in many markets. Desktop exercises and historical analysis of liquidity crunches provide insights but have limitations.

Testing available liquidity by transacting in large volumes under normal conditions is expensive and, more importantly, tells us little about the ability to transact in disrupted markets. Tests of notional volumes may generate a false sense of security rather than inform real liquidation measures.

The true test of liquidity often only comes during stress events – precisely when you most need it to work.

When “Liquidity” Masks Solvency Issues

Some apparent liquidity crises are actually solvency issues in disguise. A prime example is minimum surrender guarantees in a rising rate environment. When interest rates rise significantly, policies with guaranteed surrender values can become deeply unprofitable. Each surrender crystallizes a real economic loss – no amount of liquidity support solves this underlying problem.

Policyholders can withdrawn their funds, benefit from the rising interest rate environment and re-invest in a new policy or other structure taking advantage of higher interest rates. It should be no surprise that this is the result of the dangerous combination of higher interest rates and guaranteed surrender values. (There are ways, complex, expensive ways, to manage this risk, but that first requires an appreciation of the risk. This requires at least adequate liability measurement, robust scenario testing that doesn’t assume prior low volatility periods will continue, and consideration of dynamic policyholder behaviour.)

Is this a liquidity risk? Firstly it is a solvency risk. Th value of “matching” assets has declined while the value of liabilities has not. A liquidity risk is only a liquidity risk if the provision of liquidity solves the problem.

When measuring liabilities and therefore solvency, it seems dangerous to rely on assumed policyholder irrationality (expecting them not to surrender when it’s clearly in their financial interest to do so) to support solvency calculations. Good risk management and appropriate liability measurement must recognize that policyholders will likely act in their financial interests, especially when the benefits of doing so become obvious.

Now there may also be a liquidity risk. If surrenders require liquidation of illiquid assets that may further depress asset prices, increasing yields and/or spreads. Resultant concerns around insurer solvency can also lead to a run on the insurer. It’s a mistake to think of all of this as a liquidity risk.

Implications for Risk Management

Liquidity risk is real, and may still be underestimated by many insurers. Insurers should be carefully evaluating their risk management systems for adequate coverage of liquidity risk.

These complexities demand sophisticated risk management approaches:

• Regular stress testing must consider both solvency and liquidity impacts
• These stress tests must be severe enough and must consider interactions
• Liability measurement needs to incorporate realistic policyholder behavior assumptions
• Investment strategies must balance efficiency with liquidity needs
• Liquidity buffers should consider both immediate and slow-burn scenarios
• Risk frameworks must recognize the limitations of market liquidity assumptions
• Consider when your sources of liquidity (money market fund contractual promises) may necessarily fail in systemic liquidity challenges