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Risk Appetite – When is change good?

Effective risk management in insurance relies on well-defined risk appetite measures and limits. These frameworks guide organisations in assessing and managing their risk exposure, ensuring alignment with strategic objectives. However, the reasons for adjusting these measures can significantly influence an organisation’s effectiveness in navigating risks.

Risk Appetite Measures and Limits

Risk appetite articulates the level of risk an organisation is willing to accept in pursuit of its goals. This encompasses various metrics and limits that inform decision-making, balancing the pursuit of opportunities with sound risk management. Clear and transparent risk measures empower organisations to evaluate their risk exposure and make informed decisions.

Common measures might include SCR cover, Earnings at Risk, Maximum Single Loss, Maximum and Minimum claims ratios, among others.

Good vs. Bad Reasons to Change Risk Appetite Measures

Organisations frequently confront pressures to adjust their risk measures. Understanding the motivations behind these changes is crucial for effective governance.

Bad Reasons to Change Risk Measures

  1. Risk Normalisation: Organisations can become desensitised to risk, gradually accepting higher levels as “normal.” This often surfaces when:
    • Risk indicators linger in amber or red for extended periods without corrective action.
    • Erosion of margins is attributed to market conditions rather than acknowledged underlying issues.
    • Management pressures lead to subjective adjustments of risk ratings to green, creating a façade of control.
    This normalisation breeds complacency, masking potential crises that may arise when unaddressed risks materialise.
  2. Strategic Helplessness: When organisations cite perceived limitations—such as outdated systems or legacy portfolios—as reasons for inaction, they fall into a trap of strategic helplessness. Research by Power, Ashby, and Palermo indicates that this can lead to:
    • Ignoring legacy challenges until they escalate to critical levels.
    • Cultivating a culture that discourages acknowledging risks, perpetuating a cycle of poor decision-making.
  3. Cultural Complacency: When risk management becomes an afterthought, adjustments to risk measures may reflect organisational inertia rather than genuine risk appetite. This can result in:
    • Diminished engagement from risk teams who feel sidelined in decision-making.
    • A growing disconnect between stated risk appetites and actual practices.

Good Reasons to Change Risk Measures

In contrast, there are valid motivations for revisiting risk appetite measures:

  1. Regulatory Changes: New regulations can necessitate adjustments in risk management practices. The introduction of IFRS 17, for example, represents a significant shift in how insurers recognise earnings and assess risk, prompting a thorough reassessment of existing measures.
  2. Evolving Market Conditions: Shifts in the external environment, such as economic fluctuations or emerging risks, may require organisations to recalibrate their risk appetite to remain competitive and responsive.
  3. New Data and Insights: Advances in data analytics and innovative thinking can enhance calibration processes, enabling organisations to refine their risk measures more accurately. Incorporating new methodologies allows for a more nuanced understanding of risk exposure and leads to more informed decision-making.
  4. Strategic Objectives: As organisations evolve and pursue new goals, reassessing risk appetite becomes essential to ensure alignment with broader business strategies.

Example: IFRS 17

The implementation of IFRS 17 demands changes in limits relating to profit, presenting an opportunity for a broader overhaul of risk management frameworks.

Changes to Earnings Recognition and Volatility

IFRS 17 alters earnings recognition by replacing compulsory margins, zeroisation, and discretionary margins—with potentially dramatic impacts on investment guarantee reserves and related insurance contracts—with the Contractual Service Margin (CSM). Key implications include:

  • The CSM applies only to profitable contracts and offsets non-economic assumption changes, potentially increasing overall volatility.
  • Insurers with minimal prior margins may experience a decrease in volatility as a result of these changes.
  • Different choices regarding risk adjustment levels and classifications of directly attributable expenses will impact the size of the CSM, affecting the assessment of onerous contracts and the degree to which severe stresses can deplete the CSM.

IFRS 17 introduces significant complexities related to risks arising from the CSM:

  • Matching the CSM is particularly challenging, especially with how it accrues interest based on forward rates locked in over prior decades.
  • Insurers now face more intricate decisions regarding whether to hedge Embedded Value (EV), solvency, or IFRS earnings, necessitating a reevaluation of existing risk management strategies.

These changes may require risk limits to adjust with a new subjective acceptance of risk or could place greater pressure to manage risk elsewhere to offset this new volatility.

By recognising these shifts, organisations can make informed decisions about adjusting their risk appetite measures and limits in a manner that reinforces governance and accountability.

Conclusion

Effective risk management in insurance requires a sophisticated understanding of risk appetite measures and the motivations behind changes to these frameworks. By distinguishing between detrimental reasons for adjustment—such as the pitfalls of risk normalisation and strategic helplessness—versus constructive motivations like regulatory changes, shifts in the market, and additional data for calibration, risk functions can seize the opportunity to enhance their risk management systems.


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