Insurers, unlikely retirement funds, have to hold risk-based capital against the risks inherent in their investments. This makes it more difficult to underestimate the risks and services as a deterrent to large allocations.

Infrastructure assets can play a part in linked funds for life insurers, where the investment risk is passed straight back to the policyholders and no market risk capital is held by the insurer.

Under this policy construction, the risks can be similar to a defined benefit retirement fund. These include the practical challenges of pricing and valuation, and conduct and fairness issues of managing investment and divestment prices, liquidity with large withdrawals and transparency of pricing.

These liquidity constraints also make this a poor investment for non-life insurers or smaller life insurers, especially where they primarily write risk business.

Where are alternative assets used in insurance?

The three areas where infrastructure assets have a meaningful place to play in insurance are:

1. As a part of a portfolio of assets for long-dated, predictable and illiquid annuity liabilities.

2. Part of a with-profits portfolio, whether this is accumulation phase or with profit annuities in payment.

3. Part of large, well-capitalised insurer’s shareholder portfolio, subject to risk appetite constraints.

How are infrastructure assets treated for insurers for regulatory purposes

In 2014, EIOPA started to consider whether the Solvency II regulations would discourage insurers to invest in infrastructure assets. It was carefully phrased as “removing disincentives† but the line between that and deliberate incentives for insurers to invest in infrastructure assets is invisible.

Right towards the end of the development of South Africa’s Solvency Assessment and Management (SAM) regulatory overhaul, Task Groups of the SAM project were asked whether any adjustments were recommended.

Technical Provisions adjustments for infrastructure assets

The answer from the Technical Provisions Task Group was “no†. Technical Provisions were intended to be market consistent and, with possible exceptions for illiquidity premium / matching adjustments (already a part of the regulations) returns on assets should not, in general, affect the measurement of liabilities.

The illiquidity premium is still very much relevant. Up to 50bps can be added to the risk-free yield curve for discounting life annuity cash flows, provided the backing assets are a good cash flow match and are managed separately from the rest of the portfolio. The illiquidity premium is calculated as 50% of the spread achieved on the matching assets.

In South Africa, most of the available corporate paper available to generate spreads has a term of five years or less. This greatly reduces the effective average spread that can be applied. Longer-term (20 or 40 year) infrastructure debt-based investments are very welcome in this scenario.

This allowance is not specific to infrastructure assets, but is important as part of the overall capital assessment of infrastructure assets.

It’s worth mentioning that the European Solvency II “matching adjustment† is far more generous. I regularly experience actuaries or consultants from the UK talking up great plans for assets in a SAM environment, assuming that the rules are the same in South Africa as they are across Europe.

(The volatility adjustment in theory also has a place in this discussion, but that’s a bigger topic and typically a smaller impact in any case.)

Solvency Capital Requirement (SCR) adjustment for infrastructure assets

The Capital Requirements Task Group followed the European lead and allowed reductions in the equity shock and spread shock that would be applied to qualifying, high quality, infrastructure investments.

• 33% shock for equity (which is 77% of the “SA equity† shock, or about 70% of “Other Equities† shock, which I’d argue would be the most typical classification in the absence of an infrastructure asset class)
• Symmetric adjustment = 77% of SA equity
• 70% of spread shock for debt
• 65% illiquidity premium shock

The 65% shock to the illiquidity premium is not specific to infrastructure. It’s also complete irrational and greatly reduces the benefit of the very limited illiquidity premium in the first place.

• The stated risk here is a narrowing of the illiquidity premium, but this could only be realized through an increase in the relevant asset prices, matched with an increase in liabilities with no net impact. Since the shock is defined as “A 65% fall in the value of the illiquidity premium used in the valuation of technical Provisions† there is no offset for the asset of this calculation.
• The actual risk, if there were one, would be an increase in illiquidity premiums in the market, resulting in a decrease in asset values, only partially offset by a decrease in liability values due to the 50bps cap.) 

Impact of SCR relief

The impact of lower SCR on after cost-of-capital investment returns needs to be calculated for the specific portfolio and how it interacts with other risks within the business. One might expect a 1% to 2% increase in penalized returns.

Qualifying criteria

To qualify as an “infrastructure asset† and benefit from the lower capital charges, a fairly lengthy set of criteria must be met. For insurers already intended to invest in only high quality (and therefore lower return) infrastructure assets, these criteria may overlap with existing due diligence and investment analysis processes.

Non risk-based criteria

Risk-based criteria

The Infrastructure project entity can meet its financial obligations under sustained stresses that are relevant to the risk of the project.

• Must be externally rated (in theory it doesn’t have to be, but in practice it really should be and questions would be asked by the Prudential Authority if it weren’t.)
• The off-taker must be either the South African government, or there must be a large number of, ideally independent, diversified customers.

• The Infrastructure assets and Infrastructure project entity are governed by a contractual framework that provides debt providers and equity investors with a high degree of protection
• For bond investments, significant additional covenants are required
• The cash flows that the Infrastructure project entity generates for debt providers and equity investors are predictable. This must be demonstrated through one of the following:
  • Availability based revenues
  • Rate of return regulation covering revenues
  • Take or pay contract
  • Output or usage and price imply low risk

Should insurers invest in infrastructure?

It’s unhelpful to say “it depends†, but of course it does. However, with appropriate due diligence and consideration of the financial and capital implications, life insurers with large with profits or annuity books can benefit shareholders and policyholders, as well as potentially the country as a whole, by investing judiciously in infrastructure assets.

The risk is that they are outbid by retirement funds with less risk sensitivity to the investments.

Many researchers are comfortable with a range for Equity Risk Premiums of between 3% and 5%. Many corporate finance practitioners use a range from 5% to 8% or even higher. My nearly eight-year-old blog post on mis-estimating the ERP covered these differences in detail.

This post is a little different. Forget about what theory says, what are the implications of using a high risk discount rate (RDR) when calculating embedded values and then trying to maximise value.

Solvency II and SAM suggest a 6% (excess over risk-free) cost of non hedgeable capital. Most South African insurers calculating real-world embedded values use risk-free + 3.5% as their RDR.

Some insurers want to use an RDR closer to 15% or even 20%. The problem here is one of conviction. If the cost of capital was truly felt to be 20%, then capital optimisation, value optimisation and therefore reinsurance decisions should be made with this in mind.

It will almost always be the case that reinsurance will have an implied cost of less than 20%. Thus, the consistent action would be to grab as much reinsurance as possible, at least up the point where the reinsurer was concerned about skin in the game.

I don’t see this happening in practice.

Some insurer will argue that they don’t want to give away all their profits to a reinsurer. This fundamentally misunderstands how reinsurance is priced and the impact of return and profit commissions to facilitate reasonable commercial terms.

Similarly, the pursuit of greater investment returns usually results in more risk and more capital required. At a 20% return on capital requirement, pretty much no avoidable market risk should be retained. Yet I still see insurers opting to take on more credit risk (even at current depressed credit spreads) in pursuit of a little extra yield.

We can have a debate about the range of reasonable RDRs to use. But there is a credibility problem if this rate isn’t also used to decide on reinsurance and investment strategies.

One report indicates this change may roll back a year of expected mortality improvements. So perhaps those optimistic stories about “the first person to live to 200 1,000 has already been born” will fade for a while.

The thing is, it’s no utterly crazy to think about extreme life extension for currently living people. We don’t need to solve ageing in the next 40 years for a 40-year-old to live to 200 or 1,000. In the next 40 years, we need to extend life by enough time to allow the research for the next 40-year extension and so on.

I’m feeling a little old myself with a milestone birthday coming up in a couple of days. For now, 50 years still feels like a long time, although Asimov’s The Foundation series and the Long Now crowd would likely shame me into thinking I am a super myopic actuary.

Turnout was good, but not great, but the discussion and points raised were all fantastic. Plenty more to do from here onwards, but I thought it might be useful to include the presentations somewhere publicly available.

Some of the concepts that were on the agenda

• Swaps vs Bonds, the theory as well as practical implications for insurers, banks and the capital markets
• Extrapolation methods and what challenges this creates for practitioners
• Identifying and measuring illiquidity premiums, credit spreads and the difference between Expected Default Loss and Credit Risk Premiums
• European developments on Matching Adjustments and Countercyclical Premiums. Should we follow their path? Is bottom-up or top-down more practical?
• Do we need a methodology for nominal and/or real yield curves?
• Non-South African countries – what is the practical answer to requiring multiple yield curves?
• Reducing regulatory arbitrage between banks and insurers for credit and market risk on swaps and bonds

Panel Members:

• David Kirk
• Ian Marshall
• Philip Harrison
• Brian Kipps
• Lance Osburn
• Lindy Schmaman
• Louis Scheepers

Presentations (reproduced with permission from the authors)

Risk free rate workshop outline November 2012

Position Paper 40 (v 3)

Philip Harrison – Risk Free SAM Workshop

Risk free yield curves Brian Kipps

Risk-free rate workshop_LSchmaman

SAM Risk Free 29 Nov012 Louis Scheepers

SAM Workshop 20121129 Lance Osburn

They are restricting questions to areas that have changed or where final decisions haven’t been made, which I suppose is also fair enough and ensures focus is on the key new areas.

Re-exposure for a period, analysis of comments, reworking of any sections as a result of those comments… There is still a fair amount of work to be done!

Implementation 2016 / 2017 is most likely.

Part of the deal is a “50% loss for private investors”. Which is part true and part nonsense but will be an effective Greek default when enacted / agreed. (I don’t care how “voluntary” it may be, it’s a default and almost all definitions of default include restructuring of debt in any way that isn’t what was originally promised.)

Why is it only partly true? Well it’s not necessarily a “loss” for private investors. The probability of default on Greek bonds has been just about 100% for a while now. This probability of default is derived from market prices for Greek bonds and market spreads on Greek Credit Default Swaps (CDS) and an assumed Loss Given Default or Recovery Rate for investors when the bonds do default. Actual Recovery Rates vary widely, but often analysts plug in the average Recovery Rate over most of this century on unsecured debt which is around 40%.

So if market prices for Greek bonds assumed 100% default probability and a 40% recovery, then a 50% recovery doesn’t sound so bad. The potential downside is that Greece may still (need to) default on these written-down bonds at some point in the next two decades.

So the real question is what will the new probability of default be? Then we will know whether investors “took a loss” and perhaps gain the market’s view on how successful the deal really will be.