Document and Reporting Requirements Hypothetical PBR Report Presenters: Donna Claire, MAAA, FSA, CERA Tim Cardinal, MAAA, FSA, CERA
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Document and Reporting Requirements Hypothetical PBR Report Presenters: Donna Claire, MAAA, FSA, CERA Tim Cardinal, MAAA, FSA, CERA
IMPORTANT NOTE: This is a sample, hypothetical report and does not necessarily cover all requirements of VM-20. It has been designed as an illustration of the type of information required for documentation of a Principle-Based Reserve Actuarial Report (PBRAR). The hypothetical report is not complete and should not be used as a template for developing a PBRAR. CONFIDENTIAL SURAK LIFE INSURANCE COMPANY PBR ACTUARIAL REPORT ON POLICIES SUBJECT TO PBR VALUATION As of December 31, 2018 1
CONFIDENTIAL Surak Life Insurance Company February 28, 2019 This report is confidential and for the exclusive use of the management and state insurance examiners of the Surak Life Insurance Company.
CONFIDENTIAL Surak Life Insurance Company February 28, 2019 TABLE OF CONTENTS I. OVERVIEW .................................................................................................................................................... 1 1. INTRODUCTION ....................................................................................................................................... 1 2. PRODUCT DESCRIPTIONS OF POLICIES SUBJECT TO PBR REQUIREMENTS ............................................. 1 3. TABLE NET OF REINSURANCE .................................................................................................................. 2 4. TABLE OF RESERVES ................................................................................................................................ 4 5. DESCRIPTION OF MATERIAL RISKS FOR PBR CONTRACTS....................................................................... 5 6. RELIANCES ............................................................................................................................................... 5 7. VALUATION ASSUMPTIONS AND MARGINS ............................................................................................ 5 a. METHODS USED TO DETERMINE RISK FACTORS ............................................................................. 5 b. CHANGES FROM PRIOR YEAR .......................................................................................................... 6 c. KEY REPORTING ITEMS .................................................................................................................... 6 d. METHODS USED TO DETERMINE MARGINS .................................................................................... 6 e. SIGNIFICANT CHANGES IN METHOD TO DETERMINE MARGINS ..................................................... 7 f. METHODS INCONSISTENT WITH RISK ANALYSIS.............................................................................. 7 g. OTHER .............................................................................................................................................. 7 8. ASSETS ..................................................................................................................................................... 7 a. ALLOCATION TO MULTIPLE SEGMENTS ........................................................................................... 7 b. PORTFOLIO DESCRIPTION ................................................................................................................ 8 9. HEDGING ................................................................................................................................................. 9 10. MATERIALITY OF ASSUMPTIONS........................................................................................................... 9 11. CERTIFICATION ...................................................................................................................................... 9 12. CLOSING PARAGRAPHS .................................................................................................................. 9 II. PBR LIFE REPORT ........................................................................................................................................ 11 1. TABLE OF LIFE PRODUCTS .................................................................................................................. 11 a. Deterministic, Not Stochastic Reserves ......................................................................................... 11 b. Stochastic Reserves........................................................................................................................ 12 2. SUMMARY OF VALUATION ASSUMPTIONS ....................................................................................... 12 MORTALITY ASSUMPTIONS ................................................................................................................... 12 LAPSE ASSUMPTIONS............................................................................................................................. 13 EXPENSES ............................................................................................................................................... 14 PREMIUM PERSISTENCY ........................................................................................................................ 15
CONFIDENTIAL Surak Life Insurance Company February 28, 2019 3. CASH FLOW MODEL ........................................................................................................................... 15 a. MODELING SYSTEM USED .............................................................................................................. 15 b. MODEL SEGMENTS ........................................................................................................................ 15 c. GROUPING FOR DETERMINISTIC RESERVES .................................................................................. 15 d. STOCHASIC GROUPING .................................................................................................................. 16 e. VALIDATION OF MODEL ................................................................................................................. 16 f. PROJECTION PERIOD ...................................................................................................................... 16 g. POLCY LOANS ................................................................................................................................. 16 h. REINSURANCE ................................................................................................................................ 16 i. GENERAL ACCOUNT EQUITY INVESTMENTS .................................................................................. 17 j. SEPARATE ACCOUNT FUND GROUPING ........................................................................................ 17 k. ASSET INVESMENT STRATEGY........................................................................................................ 17 l. NOT LESS THAN ALTERNATIVE INVESTMENT STRATEGY ............................................................... 18 m. NUMBER OF SCENARIOS ............................................................................................................ 19 n. SCENARIO TECHNIQUES ................................................................................................................. 19 4. MORTALITY ........................................................................................................................................ 19 a. DESCRIPTION OF MORTALITY SEGMENTS ..................................................................................... 19 b. SUBSEGMENTS ............................................................................................................................... 19 c. UNDERWRITING SCORING PROCEDURE ........................................................................................ 19 d. SOURCE OF DATA OTHER THAN OWN COMPANY ......................................................................... 20 e. ADJUSTMENTS TO COMPANY EXPERIENCE ................................................................................... 20 f. LEVEL OF CREDIBILITY .................................................................................................................... 20 g. COMPANY EXPERIENCE MORTALITY .............................................................................................. 20 h. INDUSTRY BASIC MORTALITY USED ............................................................................................... 20 i. MORTALITY IMPROVEMENT .......................................................................................................... 21 j. SUBSTANDARD LIVES ..................................................................................................................... 21 k. ADJUSTMENTS TO COMPANY EXPERIENCE ................................................................................... 21 l. MARGINS ....................................................................................................................................... 21 m. ACTUAL TO EXPECTED ANALYSIS ............................................................................................... 21 5. POLICYHOLDER BEHAVIOR................................................................................................................. 22 a. SOURCE OF DATA ........................................................................................................................... 22 b. WHEN DATA WAS NOT FULLY CREDIBLE ....................................................................................... 22 c. ANTICIPATED EXPERIENCE ............................................................................................................. 22 d. ACTUAL TO EXPECTED ANALYSIS ................................................................................................... 22 e. MARGINS ....................................................................................................................................... 22
CONFIDENTIAL Surak Life Insurance Company February 28, 2019 f. IMPACT OF CHANGES TO NON‐GUARANTEED RATES ................................................................... 23 g. SCENARIO DEPENDENT DYNAMIC FORMULA ................................................................................ 23 h. CHANGES SINCE LAST REPORT ....................................................................................................... 23 i. PREMIUM PAYMENT ASSUMPTION............................................................................................... 23 j. ADJUSTMENTS TO LAPSES AND MORTALITY FOR ANTI‐SELECTION .............................................. 23 6. EXPENSES ........................................................................................................................................... 24 a. EXPENSE ALLOCATION METHODOLOGY ........................................................................................ 24 b. ALLOCATION TO SEGMENTS .......................................................................................................... 24 c. MARGIN METHODOLOGY .............................................................................................................. 24 7. ASSETS................................................................................................................................................ 24 a. STARTING ASSETS .......................................................................................................................... 24 b. SELECTING ASSETS ......................................................................................................................... 24 c. MARKET VALUE OF ASSETS ............................................................................................................ 25 d. FOREIGN CURRENCY EXPOSURE .................................................................................................... 25 e. NET SPREAD ADJUSTMENT FACTOR .............................................................................................. 25 f. NET EARNED RATES BY SEGMENT ................................................................................................. 25 g. INVESTMENT EXPENSES ................................................................................................................. 25 h. PREPAYMENT, CALL AND PUT FUNCTIONS.................................................................................... 26 i. ASSETS IN 2% COLLAR .................................................................................................................... 27 j. DERIVATIVES .................................................................................................................................. 27 8. REVENUE SHARING ASSUMPTIONS ................................................................................................... 27 a. REVENUE SHARING AGREEMENTS ................................................................................................. 27 b. INCOME FROM AGREEMENTS ....................................................................................................... 27 c. MARGIN FOR UNCERTAINTY .......................................................................................................... 28 9. REINSURANCE ASSUMPTIONS ........................................................................................................... 28 a. REINSURANCE AGREEMENTS ......................................................................................................... 28 b. REINSURANCE CASH FLOWS IN MODEL......................................................................................... 28 c. ADDITIONAL ANALYSIS................................................................................................................... 28 d. MULTIPLE REINSURANCE TREATIES ............................................................................................... 28 e. WHY ADDITIONAL TESTING IS NOT NEEDED ................................................................................. 28 10. NON‐GUARANTEED ELEMENTS ..................................................................................................... 29 a. MODELING NGEs............................................................................................................................ 29 b. MARGIN FOR CONSERVATISM ....................................................................................................... 29 c. PAST MANAGEMENT PRACTICES ................................................................................................... 29 d. CONSISTENCY OF ASSUMPTIONS................................................................................................... 29
CONFIDENTIAL Surak Life Insurance Company February 28, 2019 e. CONDITIONAL EXCLUSIONS ........................................................................................................... 29 11. DETERMINISTIC AND STOCHASTIC EXCLUSION TESTS ................................................................... 30 a. POLICIES USED IN EXCLUSION TESTS ............................................................................................. 30 b. STOCHASTIC EXCLUSION ................................................................................................................ 30 c. RESULTS OF STOCHASTIC EXCLUSION TEST ................................................................................... 30 d. STOCHASIC RESERVE DEMONSTRATION........................................................................................ 30 e. CERTIFICATION ............................................................................................................................... 30 f. RESULTS OF DETERMINISTIC EXCLUSION TEST .............................................................................. 30 12. OTHER ............................................................................................................................................ 31 a. IMPACT OF MARGINS .................................................................................................................... 31 b. COMBINED IMPACT ....................................................................................................................... 31 c. IMPACT OF IMPLICIT MARGINS ..................................................................................................... 31 d. SENSITIVITY TESTS .......................................................................................................................... 31 e. RISKS NOT FULLY REFLECTED ......................................................................................................... 31 f. IMPACT OF AGGREGATION ON RESERVES ..................................................................................... 32 g. EARLIER TESTING PERIOD ............................................................................................................ 32 h. APPROXIMATION AND SIMPLIFICATIONS ...................................................................................... 32 i. COMPETITOR RATE ........................................................................................................................ 32 j. FUND PERFORMANCE AND STOCHASTIC PATHS ........................................................................... 32 k. INTEREST CREDITING STRATEGY .................................................................................................... 33 13. CERTIFICATION FROM INVESTMENT OFFICER ............................................................................... 33 14. CERTIFICATION FROM SENIOR MANAGEMENT ............................................................................. 33 BASIC RESULTS ............................................................................................................................................... 34 RESULTS FOR ACCUMULATION UL............................................................................................................. 35 RESULTS FOR UL WITH SHADOW ACCOUNT ............................................................................................. 37 VARIABLE UL RESULTS ............................................................................................................................... 40 MARGINS ....................................................................................................................................................... 43 APPENDIX A: MORTALITY FACTORS ............................................................................................................... 44 APPENDIX B: PREMIUM PATTERN ................................................................................................................. 47 APPENDIX C: LAPSE STUDY ........................................................................................................................... 48 APPENDIX D: EXPENSES ................................................................................................................................ 49 ADDENDIX E: RELIANCE STATEMENT FROM ASSET OFFFICER ....................................................................... 50 APPENDIX F: SENIOR MANAGEMNT SIGN‐OFF ............................................................................................. 51
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2014 I. OVERVIEW 1. INTRODUCTION I, Claire R. Martin, FSA, MAAA am a Vice President and Actuary of Surak Life Insurance Company. I am a Fellow of the Society of Actuaries and a Member of the American Academy of Actuaries. I was appointed by the Board of Directors of Surak Life Insurance Company to render this opinion. A copy of the Board Resolution, dated December 15, 2017, was sent to notify the Commissioner of this appointment. I meet the qualification standards for rendering the opinion and am familiar with the PBA valuation requirements applicable to life and health companies. This report has been prepared on the Surak Life Insurance Company in conjunction with the Actuarial Certification on the policies subject to a PBR valuation. This report details all of the disclosure items for a PBR valuation as required by [insert applicable section] of the Valuation Manual for Surak Life for year-end 2018. 2. PRODUCT DESCRIPTIONS OF POLICIES SUBJECT TO PBR REQUIREMENTS The Surak Life Insurance Company has been determining the reserves for the products listed below on a PBR basis since 2017: Accumulation UL with no secondary guarantees UL with shadow account 20 year level term products Variable UL This report covers these products. The policies and assets examined were those in-force on December 31, 2018. A brief description of each of these products is given below: Accumulation UL with No Secondary Guarantees The Accumulation Universal Life policies are flexible premium policies. There are two death benefit options: Option 1 pays a death benefit at the Specified Amount plus the increase in the fund value since the last Anniversary Day; Option 2 has a death benefit equal to the Specified Amount plus the fund value. The fund value is accumulated as the total of: premiums plus 1
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 interest credited less premium expense charges less partial surrenders less monthly deductions. The cash value equals the fund value less a fund charge. The fund charge is a percentage of fund value: 10% in the first year, grading down by 1% a year to 0 in years 11 and later. The guaranteed interest rate is 4%. Excess interest may be credited in a manner determined by the Company. Policy loans are made at the credited rate plus two percent. There are monthly deductions for the cost of insurance plus the monthly expense charge. UL with Secondary Guarantees The Universal Life product with Secondary Guarantees is similar to the Accumulation UL product, except that there is a shadow account guarantee. This shadow account guarantee is for the life of the policy. The shadow account guarantees that, as long as the premiums paid plus interest are greater than amounts specified in the policy, the policy will not lapse, even if the fund account were to go to zero. 20 Year Term The 20 year term product has level premiums over the 20 year period. There is no renewal option after the 20 years. There are no cash values on this product. Variable UL The Variable UL product is similar to the Accumulation UL product, but there is no minimum interest rate guarantee on the cash values - investment risk on funds held in separate accounts backing variable life insurance is borne by the policyholder. 3. TABLE NET OF REINSURANCE The table below shows the reserves for both PBR and non-PBR business in the Company. 2
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 IF using PBR, Current first Year year Premium Face Amount Product Name used (in $1,000s) (in $1,000s) Life Insurance Issued prior to the operative date of the Manual Term 500,000 500,000,000 Non‐participating Whole Life 1,000,000 100,000,000 Participating Whole Life n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ Universal Life Without Secondary Guarantees 2,500,000 250,000,000 Universal Life With Secondary Guarantees 1,000,000 100,000,000 Variable Universal Life 450,000 45,000,000 Variable Life n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ Indexed Life n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ Other n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ TOTAL 5,450,000 995,000,000 Life Insurance Issued on or after to the operative date of the Manual Term 2017 25,000 25,000,000 Non‐participating Whole Life n/a ‐‐‐‐‐ ‐‐‐‐‐‐ Participating Whole Life n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ Universal Life Without Secondary Guarantees 2017 125,000 12,500,000 Universal Life With Secondary Guarantees 2017 50,000 5,000,000 Variable Universal Life 2017 45,000 4,500,000 Variable Life n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ Indexed Life n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ Other n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ TOTAL 245,000 97,000,000 Annuities Fixed n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ Variable Other n/a ‐‐‐‐‐‐ ‐‐‐‐‐‐ TOTAL Accident and Health Insurance n/a ‐‐‐‐‐ ‐‐‐‐‐ Deposit Type Contracts n/a ‐‐‐‐ ‐‐‐‐‐‐‐ 3
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 4. TABLE OF RESERVES (Numbers in $1,000s) Assumed Direct Ceded Net Reserve Annual Statement Item Reserve Reserve (1) Reserve (3) (1)+(2)-(3) (2) Life Insurance and Annuity Life Insurance-Issued prior to the operative 5,300,000 ______ 800,000 4,500,000 date of the Valuation Manual Life Insurance-Issued on or after the operative date of the Valuation Manual Policies stochastically modeled per VM-20 450,000 _____ 13,000 437,000 Policies deterministically modeled (not 257,000 _____ 231,298 25,702 stochastically modeled) per VM-20 Policies not modeled (non-PBR) 0 0 0 Net Premium Reserve per VM-20 _____ _____ _____ _____ Other policies _____ _____ _____ _____ Annuities Supplementary Contracts Involving 29,000 _____ 0 29,000 Life Contingencies Accidental Death Benefit 1,298 _____ 0 1,298 Disability – Active 2,000 _____ 0 2,000 Disability – Disabled 5,000 _____ 0 5,000 Miscellaneous 0 _____ 0 0 Total Life Insurance and Annuity 6,044,298 0 1,044,298 5,000,000 Accident and Health Insurance 0 0 0 0 Active Life Reserve _____ _____ _____ _____ Claim Reserve _____ _____ _____ _____ Deposit Type Contracts _______ ______ ______ _______ TOTAL PRINCIPLE-BASED RESERVES 707,000 0 246,298 462,702 TOTAL RESERVES (PBR + Non-PBR) 6,044,298 0 1,044,298 5,000,000 4
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 5. DESCRIPTION OF MATERIAL RISKS FOR PBR CONTRACTS Surak Life only has life insurance policies which are covered under PBR. A material risk to these contracts is mortality. Lapse is also an important risk, especially for the universal life contracts with guarantees. Lapses can depend on what the rate credited is compared to the market rate, so the dynamic lapse factor and the interest crediting methodology is also explained. To a lesser extent, expenses can impact results. For the universal life product, including the Universal Life products with secondary guarantees as well as those without secondary guarantees, and the Variable Universal Life product. There is also some reliance on the reinsurance of these PBR contracts. 6. RELIANCES I relied upon asset data prepared under the direction of Ay Set, Vice President - Investments and liability data prepared under the direction of Li Ability, Vice President - Corporate Actuarial, as certified in the attached statements. I evaluated that data for reasonableness and consistency. I also reconciled that data to Schedules A, B and D, Page 3, Exhibits 5 - 8 and Pages 48 and 50 (IMR & AVR) of the company's current annual statement. In other respects my examination included such review of the actuarial assumptions and actuarial methods and such tests of the actuarial calculations as I considered necessary. 7. VALUATION ASSUMPTIONS AND MARGINS a. METHODS USED TO DETERMINE RISK FACTORS In determining risk factors, Company experience was used to the extent credible. For mortality, Company experience was blended with industry experience to develop the factors used. The base lapse rates were developed using Company data where credible. Where the data was partially or not credible, industry data was used, as well as some actuarial judgment based on data of similar products. For items related to the lapse factors, such as the dynamic lapse factors and the market rates, studies of industry data were done. The assumed interest crediting spreads were based on pricing spreads, which management has adhered to in the past. Expenses are based on a Company study. 5
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 Premium persistency is based on a Company study. b. CHANGES FROM PRIOR YEAR In general, all methodology was similar to those used in the prior year. . Note that although the total expenses did not change significantly, there was a revision to how the company allocated expenses between per policy and per $1000 expenses. The result was an increase in the per policy expenses and a decrease in the per $1000 expenses. These new expenses were used in the reserving, which resulted in a slight increase in overall expenses for UL insurance, and a decrease in expenses for term insurance (less than $1000). c. KEY REPORTING ITEMS The key reporting items which are tracked on a policy level basis include lapses, mortality, premium persistency. On a Company basis, expenses are tracked. d. METHODS USED TO DETERMINE MARGINS Margins are based on the credibility and volatility of data. For mortality, factors were added in the form of a factor divided by the expectation of life to take into account that Surak Life does not have fully credible data. For lapses, a study was done to determine whether higher or lower lapses were more conservative, and a margin was added based on this study. The margin was higher for universal life with secondary guarantees (lowering the assumed lapses) because the experience was not credible. Also, in years where the experience was less credible, margins were added for conservatism. For expenses, a flat 5% margin was added. This is based on actuarial judgment, looking at the variation in expense factors over the last 20 years. For premium persistency, only slight margins were added, since the rates have been relatively stable. 6
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 e. SIGNIFICANT CHANGES IN METHOD TO DETERMINE MARGINS There were no significant changes made from the prior year to determine margins. f. METHODS INCONSISTENT WITH RISK ANALYSIS All assumptions used in the PBR testing are generally consistent with the risk analysis and management techniques used by the Company. There are two exceptions: a) Mortality improvement is typically included when reviewing results for management, while mortality improvement was not included when analyzing mortality for PBR reserves. b) Actual investments would average an A rating as opposed to the requirement that the reinvestment assumption be 50% AA and 50% A rated bonds. g. OTHER This is only the second year of PBR. The Company generally used methodology similar to those used for asset adequacy testing. The only exceptions were where VM-20 specifies a methodology. The Accumulation UL and the UL with a shadow account credits interest above the minimum at a rate declared by the company. The goal is to earn a spread of 180 basis points over the portfolio rate. This is the Company’s current spreads, and the Company expects to maintain this in the future. There is no explicit margin in this spread. This factor will be examined at least once a year. 8. ASSETS a. ALLOCATION TO MULTIPLE SEGMENTS In support of the Asset/Liability Management Process, Surak Life has segmented its investment portfolio. There is a segment specifically for the PBA products. This action, along with continued refinements of the segments, should facilitate the management of investment risks associated with the various lines of business. However, it should be understood that all assets of the company back all liabilities of the company. 7
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 b. PORTFOLIO DESCRIPTION The majority of invested assets backing PBA reserves in Surak Life are investment grade corporate bonds, both public and private placements. The portfolio also includes a substantial holding in CMOs and other mortgage backed securities. The majority of the CMOs are government or agency backed. The portfolio is rounded out with commercial mortgages and residential mortgages. The Table at the end of this section lists of assets by type and by product. The assets backing the general account segments used for term insurance and UL are given below: ASSETS BACKING PBA PRODUCTS Total Bonds 397,705 85.9% Commercial Mortgage Loans 20,000 4.3% Residential Mortgage Loans 20,000 4.3% Cash & Short Term 10,000 2.2% Miscellaneous 5,000 1.1% Policy Loans 10,000 2.2% Total 462,705 100% RATING OF BONDS HELD Long Term Bonds Amount % of Total Exempt Obligations 21,705 4.6% NAIC 1 225,000 48.6% NAIC 2 130,000 28.1% NAIC 3 10,000 2.2% NAIC 4 5,000 1.1% NAIC 5 5,000 1.1% NAIC 6 1,000 0.2% DURATION OF ASSETS 1-5 years 37,705 5-10 years 210,000 10-20 years 190,000 20+ years 25,000 TOTAL 462,705 8
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 9. HEDGING There are no specific hedging programs in place to hedge the PBA portfolio. 10. MATERIALITY OF ASSUMPTIONS Surak Life defines materiality with respect to the PBA portfolio as items that could have an impact of 2.5% or more on the reserves being set up for PBR. At year-end 2018, the total PBR reserves were $462,702,000. These reserves were roughly 5% of the total reserves of the Company. The surplus of Surak Life at year-end 2018 was $300,000,000. We therefore feel a 2.5% of PBR number is reasonable and conservative. 11. CERTIFICATION I certify that the PBR reserve calculation: a. Was calculated in accordance with VM-05 and VM-20; and b. The assumption and margins used in the testing were prudent estimates. 12. CLOSING PARAGRAPHS The reserves and related items, when considered in light of the assets held by the company with respect to such reserves and related actuarial items including, but not limited to, the investment earnings on such assets, and the considerations anticipated to be received and retained under such policies and contracts, make adequate provision, according to presently accepted actuarial standards of practice, for the anticipated cash flows required by the contractual obligations and related expenses of the company. The actuarial methods, considerations and analyses used in forming my opinion conform to the appropriate Standards of Practice as promulgated by the Actuarial Standards Board, which standards form the basis of this statement of opinion. This opinion is updated annually as required by statute. To the best of my knowledge, there have been no material changes from the applicable date of the annual statement to the date of the rendering of this opinion which should be considered in reviewing this opinion. 9
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 The impact of unanticipated events subsequent to the date of this opinion is beyond the scope of this opinion. The analysis of PBA reserves portion of this opinion should be viewed recognizing that the company's future experience will not follow all the assumptions used in the analysis. Claire R. Martin, FSA, M.A.A.A., CERA Vice President and Actuary Surak Life Insurance Company 100 Accuracy Avenue Littletown, New York 11746 (631) 269-1501 February 28, 2019 10
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 II. PBR LIFE REPORT 1. TABLE OF LIFE PRODUCTS The tables below show the reserves under PBR. Table (a) shows those reserves calculated on a deterministic basis, while Table (b) shows those calculated on a stochastic basis. Table (c) shows the policies where principles-based reserves were not calculated. All the lie reserves since 2017, when PBR when into effect, are calculated on a PBR basis. There are no policies which were subject to PBR but which both the deterministic and stochastic exclusion test was passed. The 20 year term product was tested using a stochastic testing in June of 2010. There was less than a 1% difference between the deterministic test and stochastic testing, so it was concluded that a stochastic test was not needed. For all the UL products, stochastic testing was done. a. Deterministic, Not Stochastic Reserves Net Deferred Premium Deterministic Premium Reported Product Reserve Reserve Asset (3) Reserve (1) (2) (4) Term 25,000 25,500 202 25,702 Non-participating 0 0 0 0 Whole Life Participating Whole 0 0 0 0 Life Universal Life 0 0 0 0 without secondary guarantee Universal Life with 0 0 0 0 Secondary Guarantee Variable Universal 0 0 0 0 Life Variable Life 0 0 0 0 Indexed Life 0 0 0 0 Other 0 0 0 0 TOTAL 25,000 25,500 202 25,702 11
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 b. Stochastic Reserves Net Deferred Premium Deterministic Premium Reported Product Reserve Reserve Asset (3) Reserve (1) (2) (4) Term 0 0 0 0 Non-participating 0 0 0 0 Whole Life Participating Whole 0 0 0 0 Life Universal Life 95,000 90,000 6,000 100,000 without secondary guarantee Universal Life with 249,000 250,000 10,000 247,000 Secondary Guarantee Variable Universal 80,000 85,000 4,000 90,000 Life Variable Life 0 0 0 0 Indexed Life 0 0 0 0 Other 0 0 0 0 TOTAL 424,000 425,000 20,000 437,000 2. SUMMARY OF VALUATION ASSUMPTIONS The valuation assumptions used in PBR modeling are given below: MORTALITY ASSUMPTIONS Surak Life does mortality studies yearly. One component of our expected mortality assumption is the results from the current rolling 5 year average mortality study. The current study was for the period 2010-2015. This is the basis for the experience mortality curve. These assumptions did not change since the last year. In computing the mortality, the first step was to determine the underwriting score by applying the Underwriting Criteria algorithm to our current preferred underwriting rules. Using this score (“45”) we chose a published industry mortality table without margin table for scores in the range 35-50. This table (“Industry Table 35-50) is used as expected mortality. Surak Life does not have full credibility for mortality. It was assumed that 1000 deaths were needed for full credibility. The actual number of deaths were 123, so the Total Credibility Factor was .35 (the square root of 123 divided by 1000). Since all policies issued have essentially the same face amount, I have excluded the effect of the variance in face amount when calculating the Total 12
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 Credibility Factor. Credibility was assigned to subsegments using the Normalized Credibility Methodology. A summary of the mortality for term insurance is found in Appendix A. This produced mortality factor of 1.0614 for age 45 year olds, and 1.034 for 65 year olds. Note that Surak Life had experience through 10 years. Therefore, the credibility weighted mortality curve for durations 11 through 20 was set equal to 1.04 times the Industry Table 35-50. In addition, a margin was added to the mortality of 9.375 deaths per 1000 divided by ex. This is to add conservatism to reflect the possible variance in results. Reserves computed with the credibility weighted mortality curves, including the margins, were compared to reserves using standard industry mortality table with margins. It was determined that the valuation mortality table that most resembled these results was the 2010 Table D. This table was therefore used to compute reserves. LAPSE ASSUMPTIONS A lapse study is done yearly for each product. The latest lapse study and the lapse assumptions used are shown in Appendix C. There was only 10 years of credible information on lapses for most products; for the UL with shadow account there was only 5 years of data. Beyond the year credible data is available, a conservative assumption was made. For UL, the lapse study currently does not break out the lapses by premium pattern. Therefore, an estimate was made as to the lapses by premium pattern, taking into account the fact that those paying lower premiums would likely lapse their products more than those who paid a level or single premium. For the term products and UL with secondary guarantees, the PBA products tested show worse results with lower lapses. Therefore, for these products I determined that a 30% lower lapse factor would be used as a reasonably conservative estimate. For the Accumulation UL and Variable UL, the products were marginally worse off with higher lapses, so 30% higher than expected lapses was used as a baseline. These assumptions did not change since last year. DYNAMIC LAPSE FORMULA For general account universal life, the excess lapses were assumed to be triggered off of the following formula: (Competitor rate-credited rate)*1.75. There were no dynamic lapses assumed for the 20 year term business or the variable UL business. 13
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 Our best guess as to the dynamism of lapses based on information received from our reinsurer would use a factor of 1.6; the factor used was increased slightly for conservatism. We will continue to review industry data for this factor annually. COMPETITOR RATE For testing UL excess lapses, it was assumed that the competitor rate was assumed to be equal to the 5 year Treasury rate in any given scenario less 25 basis points. This formula was based on a comparison of interest rates of our competitors over the last 10 years. We will continue to examine this formula at least annually INTEREST CREDITING The 20 year level term product is fully guaranteed. The Accumulation UL and the UL with a shadow account credits interest above the minimum at a rate declared by the company. The goal is to earn a spread of 180 basis points over the portfolio rate. This is our current spread, and the Company expects to maintain this in the future. There is no explicit margin in this spread. This factor will be examined at least once a year. VARIABLE ACCOUNT ASSUMPTION The variable UL product does not have a fixed bucket, so there is no risk of money moving to or from a fixed account to select against the company. Therefore, we do not need to develop assumptions for movement between the fixed and variable account. The variable account funds were modeled based on the NAIC C-3 Phase 3 scenario generator, which is updated once a year. No additional margins were added to this assumption. EXPENSES Expenses are shown in Appendix D. They were loaded 5% from the best estimate assumptions. Expenses are reviewed annually. Note that although the total expenses did not change significantly, there was a revision to how the company allocated expenses between per policy and per $1000 expenses. The result was an increase in the per policy expenses and a decrease in the per $1000 expenses. These new expenses were used in the reserving, which resulted in a slight increase in overall expenses for UL insurance, and a decrease in expenses for term insurance (less than $1000). Expenses are reviewed annually. There is also an explicit per policy expense inflation factor used, which is based on the 90 day Treasury rate, with a minimum rate of 2%. 14
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 PREMIUM PERSISTENCY The UL products may continue without a premium payment each period. The results differ slightly depending on which premium assumption is used. The actual premium payment patterns are given in Appendix B, along with the baseline assumption used for this. The premium payment assumption was based on the actual premium persistency patterns seen by studying the business for the last 10 years. As these numbers have been relatively constant over the last 10 years, no margins were added to the results. We will continue to study this factor annually. 3. CASH FLOW MODEL a. MODELING SYSTEM USED Surak Life uses the SuperPBA modeling system, a commercial software system owned by Whynot, for determining reserves. This system models both assets and liabilities. This is the same system that is being used for asset adequacy analysis at Surak Life. There were a few modifications that Surak Life made to the model in order to capture all the risks of their contracts for PBA reserving, such as reflecting different potential premium payments for UL insurance. These changes have now also been incorporated into the asset adequacy testing model. b. MODEL SEGMENTS Surak Life models its major product lines separately, as there are some differences expected in assumptions. This means that Surak Life looks at is term products, Universal Life products without secondary guarantees, universal life products with secondary guarantees, and Variable Universal Life products separately. For the assets, there is one PBR portfolio segment, since it was felt that the asset needs of the products are similar. c. GROUPING FOR DETERMINISTIC RESERVES Each major product class was assigned a pro-rata portion of the assets in the PBR portfolio. The assets were modeled on a seriatim basis. With respect to modeling the liabilities, the same grouping was used as is used in asset adequacy testing. This bands the policies by issue quarter, sex, 5 year age groups, underwriting class, and, for the UL policies, premium payment pattern. 15
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 d. STOCHASIC GROUPING The grouping for stochastic testing is the same as described above for deterministic reserves. e. VALIDATION OF MODEL The result of this grouping is compared to the actual net premium reserves held for the policies, which are done on a seriatim basis, and are within 0.25% of these amounts. f. PROJECTION PERIOD The projection period used in the modeling in 30 years, at which time less than 5% of the business is assumed to remain in force. g. POLCY LOANS Policy loans were included with the policies they are associated with. Since policy loans are charges at the credited rate plus two percent for the effected policies, policy loans do not have a large impact on these products. h. REINSURANCE Depending on the type of reinsurance, reinsurance could impact the results for PBR. However, Surak Life is only using YRT reinsurance. There were several reinsurance treaties in effect at the end of 2018 on Universal Life. These treaties were all for amounts of insurance in excess of the retention limit and are reinsured on a YRT basis. The 20 year term product was 90% coinsured with VerySafe Reinsurer. There is no financial reinsurance. The overall effect of reinsurance is to reduce the volatility of future benefit payment amounts by replacing the reinsured risk with a reinsurance premium. For conservatism, Surak Life assumed that the reinsurance premiums would be equal to the mortality assumed in the modeling times a factor of 10%, which were added to the expenses in the modeling. 16
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 i. GENERAL ACCOUNT EQUITY INVESTMENTS The General Account backing the PBR segment has no equity investments. j. SEPARATE ACCOUNT FUND GROUPING There are only three variable account choices for UL: an indexed S&P 500 fund, a bond fund, and an international fund. It is assumed these funds would earn rates consistent with those developed for the standard scenario for variable annuities, as specified in VM-21. k. ASSET INVESMENT STRATEGY PORTFOLIO DESCRIPTION The majority of invested assets backing PBA reserves in Surak Life are investment grade corporate bonds, both public and private placements. The portfolio also includes a substantial holding in CMOs and other mortgage backed securities. The majority of the CMOs are government or agency backed. The portfolio is rounded out with commercial mortgages and residential mortgages. The Table at the end of this section lists of assets by type and by product. The assets are modeled on a seriatim basis. The assets backing the general account segments used for term insurance and UL are given below: ASSETS BACKING PBA PRODUCTS Total Bonds 397,705 85.9% Commercial Mortgage Loans 20,000 4.3% Residential Mortgage Loans 20,000 4.3% Cash & Short Term 10,000 2.2% Miscellaneous 5,000 1.1% Policy Loans 10,000 2.2% Total 462,705 100% 17
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 Long Term Bonds Amount % of Total Exempt Obligations 21,705 4.6% NAIC 1 225,000 48.6% NAIC 2 130,000 28.1% NAIC 3 10,000 2.2% NAIC 4 5,000 1.1% NAIC 5 5,000 1.1% NAIC 6 1,000 0.2% INVESTMENT ASSUMPTIONS As the chart above shows, most of the assets are in investment grade corporate bonds. The investment philosophy for the PBR segment is to invest in assets with a maturity of about 10 years. The chart below shows the actual assets in this portfolio at year-end 2018 (after its second year): Duration of Assets 1-5 years 37,705 5-10 years 210,000 10-20 years 190,000 20+ years 25,000 TOTAL 462,705 It is required in VM-20 that the investment assumption be based on 50% AA rated bonds and 50% A rated bonds, which is more conservative than the actual investments of the Company. Therefore, in the modeling, it is assumed that all cash will be invested in 10 year non-call bonds, rated NAIC 1, 50% AA-rated and 50% A-rated. DISINVESTMENT ASSUMPTION For disinvestment, it is assumed that the company can borrow up to $1 million at the 90 day Treasury rate plus 2%. Additional disinvestment would be on a pro-rata slice of the remaining assets. This disinvestment assumption is consistent which what the Chief Investment Officer has stated is the disinvestment strategy. l. NOT LESS THAN ALTERNATIVE INVESTMENT STRATEGY For conservatism, the alternative investment strategy mentioned in VM-20 was used as the basic investment strategy. 18
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 m. NUMBER OF SCENARIOS For stochastic testing 1000 scenarios were used. As a test, another 1000 scenarios were run, and the answers were within 0.1% of those on the base scenario. n. SCENARIO TECHNIQUES No scenario reduction techniques were used for the 2018 testing. 4. MORTALITY a. DESCRIPTION OF MORTALITY SEGMENTS The term insurance products are in one segment. All UL products are in a segment together. These plans were sold to the same type of policyholders, and have the same underwriting standards. The average size and age of these three plans are similar. b. SUBSEGMENTS Subsegments are made of the mortality based on 10 year age groups. Surak Life did a test to show that the weighted segments together produce the total number of expected claims which is greater than the company experience for the aggregate claims (Note: if this were a real report, I’d include a table showing this in the Appendix.) c. UNDERWRITING SCORING PROCEDURE In computing the mortality, the first step was to determine the underwriting score by applying the Underwriting Criteria algorithm to our current preferred underwriting rules. Using this score (“45”) we chose a published industry mortality table without margin table for scores in the range 35-50. This table (“Industry Table 35-50) is used as expected mortality. (Note: if this were a real report, each class would be explained.) 19
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 d. SOURCE OF DATA OTHER THAN OWN COMPANY The sources of mortality data was Surak’s company experience, which was blended with the SOA 2014 VBA table. (Note: if other data is used, one must explain the source, the similarities of products, adjustments made to account for differences, and the number of deaths and death claim amounts). e. ADJUSTMENTS TO COMPANY EXPERIENCE Other than adding a margin, no adjustments were made to company experience due to underwriting. The Company has strict rules regarding underwriting, and does not allow exceptions for any reason. (Note: if exceptions are made, the Company needs to explain the rationale for the adjustments, the summary of studies to support exceptions, documentation of the mathematics used to support the adjustments, and summary of any other relevant information.) f. LEVEL OF CREDIBILITY i. Surak Life does not have full credibility for mortality. It was assumed that 1000 deaths were needed for full credibility. For term insurance, the actual number of deaths were 123, so the Total Credibility Factor was .35 (the square root of 123 divided by 1000). Since all policies issued have essentially the same face amount, the company has excluded the effect of the variance in face amount when calculating the Total Credibility Factor. Credibility was assigned to subsegments using the Normalized Credibility Methodology. This methodology was recommended in the AAA Practice Note on VM- 20. ii. A summary of the mortality for term insurance is found in Appendix A. The adjustment varies by ten year age groups. The produced mortality factor of 1.0614 for age 45 year olds, and 1.034 for 65 year olds. g. COMPANY EXPERIENCE MORTALITY Appendix A shows [a sample of] the actual company mortality. h. INDUSTRY BASIC MORTALITY USED Where industry data was used, it was based on the 2014 VBA Table. The factors are based on the Underwriting Criteria Scores. 20
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 i. MORTALITY IMPROVEMENT For conservatism, no mortality improvement factors were used to bring the industry mortality factors up to the valuation date. j. SUBSTANDARD LIVES All substandard lives used mortality factors consistent with the Table rating; e.g., 125% of baseline for Table A, 150% for Table B, etc. k. ADJUSTMENTS TO COMPANY EXPERIENCE i. Company experience was graded to100% of industry tables at the earlier of age 95 or 20 years after policy underwriting. ii. The basic table used was the 2014 VBA Table, 45% for the UltraPreferred [etc.] iii. Tables were smoothed using the Jenkins modified fifth difference oscillatory interpolation formula iv. All rates were checked to ensure consistency. No adjustments were needed. v. The anticipated experience used for the reserve mortality assumption is conservative. When the mortality factors used for the reserve calculation are compared to the actual experience, there is margin. [if this were real, I’d include a table showing this in Appendix A]. l. MARGINS The table ignores mortality improvements. In addition, a margin was added to the mortality of 9.375 deaths per 1000 divided by ex . This is to add conservatism to reflect the possible variance in results. m. ACTUAL TO EXPECTED ANALYSIS The Company performs actual to expected analysis each year. [Sample] results are included in Appendix A. 21
CONFIDENTIAL Report of the PBR Reserves for Surak Life February 28, 2019 5. POLICYHOLDER BEHAVIOR a. SOURCE OF DATA The Company uses its own experience on the products for the base lapse assumption. There was only 10 years of credible information on lapses for most products; for the UL with shadow account there was only 5 years of data. Beyond the year credible data is available, a conservative assumption was made. b. WHEN DATA WAS NOT FULLY CREDIBLE When actual data was not available, pricing assumptions were used as a baseline, with margins added for conservatism. Pricing assumptions are typically based on company experience where applicable, or industry data, such as the LIMRA/SOA lapse study, where this is not the case. c. ANTICIPATED EXPERIENCE Anticipated experience was calculated based on actual data, with margins for conservatism as explained above. d. ACTUAL TO EXPECTED ANALYSIS A study of actual to expected analysis is done annually. e. MARGINS When data was not fully credible, a margin for conservatism was added. For the ULSG product, it was determined that lower lapses were conservative, so the assumed lapse rates were reduced by 30%. For the Accumulation UL, Variable UL and term insurance, the products were marginally worse off with higher lapses, so 30% higher than expected lapses was used as a baseline. For UL, the lapse study currently does not break out the lapses by premium pattern. Therefore, an estimate was made as to the lapses by premium pattern, taking into account the fact that those paying lower premiums would likely lapse their products more than those who paid a level or single premium. 22
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