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QUARTERLY MAGAZINE OF THE ACTUARIAL ASSOCIATION OF EUROPE

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  GOOD POLICY STARTS                   HOW TO PRIORITISE            DECISION-MAKING
  WITH GOOD DATA                       VACCINATION                  IN UNCERTAINTY

                                  12                                                     18
                                       THEME:
                                       HEALTH
  EIOPA OPINION ON SOLVENCY II
  REVIEW: CONCERNS OF AAE

                                  15                           16

                                                                    COLUMN:
                                                                    SOLVENCY II REVIEW

N O 25                  XIII ITALIAN   THE 2020 AAE
               ACTUARIAL CONGRESS      PRESIDENTS' MEETING
MAR 2021
HEALTH THEME: Actuarial ...
INTERVIEW

  GOOD POLICY
  STARTS WITH
  GOOD DATA                                        INTERVIEW BY
                                                  ANDRÉ DE VOS

         The Dutch handling of the
        corona pandemic is driving
            Maurice de Hond crazy.
            According to this Dutch
          political pollster, medical
        professionals wield far too
     much power when it comes to
       curbing the virus. ‘We need
       to make decisions based on
     good data, not on the medical
       opinions of a small group of
                         specialists.’

   MAURICE DE HOND has
   a background in market
   research and runs his own
   polling agency View/Ture.
   He started publishing                           MAURICE DE HOND
   blogs and scientific
   publications on corona on
   his website Maurice.nl in
   March 2020.

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THE EUROPEAN ACTUARY NO 25 - MAR 2021        GOOD POLICY STARTS WITH GOOD DATA
HEALTH THEME: Actuarial ...
‘F
           irst they ignore you, then     De Hond had his ‘Eureka             in the lead. It’s virologists
           they ridicule you and in the   moment’ at the beginning of         and epidemiologists who are
           end they say they knew all     April 2020 when he saw a video      determing Dutch policy. They
     along.’ Maurice de Hond is not       by a Japanese professor that        have become very powerful
     the person to shy away from a        showed how aerosols move            because the government chooses
     public quarrel. De Hond became       around in a closed space. ‘That     to heed their advice exclusively.
     well-known in the Netherlands        video explained most convincingly   The dominant view in the medical
     with his method for predicting       how the virus is spread and why     profession is that every Covid-
     the outcome of general elections.    all these ‘superspreader events’    death is one too many. Hence the
     Since then he has been in the        always occur indoors. And           lock-down, the closing of schools
     Dutch media with an array of         why good ventilation systems        and shops, the 1.5 metre rule.
     topics ranging from proposals        are essential. In Japan and         Even though we don’t know how
     for the improvement of the           many other countries this was       effective each measure is.’
     educational system to trying to      the dominant theory from the
     revoke a conviction in a murder      beginning. In the Netherlands we
     case.                                stuck to the droplet-theory, and    ‘Virologists and epidemiologists
                                          based all corona measures on it.    are scaring people, the media
                                          Mistakenly so.’                     are making it worse, the general
     His interest in corona started                                           public gets scared and politicians
     when news of the outbreak in                                             feel forced to react with even
     Wuhan first hit the headlines.       It took a while before mouth        starker measures. The medical
     By the end of January 2020 he        masks were accepted in              approach hardly leaves room for a
     included a question about the        the Netherlands to prevent          different view. The mass hysteria
     novel virus in his own periodic      spreading. In the beginning they    is fuelled by doctors. They’ve
     poll amongst Dutch citizens. ‘Is     were regarded as useless by RIVM    become part of the problem.’
     this going to be as bad as the       and the government. Instead the
     Spanish flu?’                        focus was on hand washing and
                                          keeping a distance of 1.5 metres.   A good illustration is a recent
                                          Only recently and not quite         interview with a prominent
     He decided to dive into              wholeheartedly has RIVM, and        Dutch health official who cited
     international scientific research    the Dutch government, admitted      the death of a 17-year-old to
     on viruses and even launched         that aerosols might play a role     demonstrate that Covid-19
     a website where he publishes         in spreading the virus. And that    doesn’t only affect the elderly.
     his views and that of scientists     good ventilation is important.      ‘I checked the statistics in that
     from around the world. From the                                          period and there was only one
     beginning De Hond has been a                                             death under 25 in the whole of
     strong defender of the theory         ‘ The mass hysteria is             the Netherlands: exactly the
     that the coronavirus is spread                                           person that was mentioned by the
     through the air by aerosols rather
                                             fuelled by doctors.              official. You can’t use that as an
     than by small droplets that hit         They’ve become part              example! Unless your goal is to
     nose or mouth. The latter theory        of the problem.’                 scare people. I might counter with
     is the one that is embraced by                                           the case of the 90-year-old that
     the national Dutch institute                                             jumped from a balcony because
     for public health (RIVM) and         De Hond explains the                he couldn’t stand the isolation
     the World Health Organisation        stubbornness of the government      anymore.’
     (WHO). It’s also the theory upon     in ignoring alternative
     which official Dutch corona          explanations looking at the
     policy is based.                     Dutch approach to controlling       De Hond would rather see a
                                          the pandemic. ‘Doctors are          broad range of professionals

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THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                   GOOD POLICY STARTS WITH GOOD DATA
HEALTH THEME: Actuarial ...
advising the Dutch government         all kinds of relevant questions.         De Hond suggests the use of
     how to address the pandemic.          We would’ve had a gold mine of           open data that are accessible
     Not just virus specialists,           information by now, a database           to everybody. ‘Good data can
     but economists, behavioural           with 8 million responses, for good       be gathered. Good analysis is
     scientists, psychologists, data-      policy building. But even now we         difficult. We’re spending billions
     specialists, you name it. ‘The        are installing new regulations           on corona. I would surely spend
     problem with the current medical      without knowing how they will            a few millions more on data
     monopoly is that they don’t get       work out, and without knowing            analysts in every hospital. Make
     to see the drawbacks of the           how to get back to normal,               data accessible. You would be
     policy they are defending. Shops      because we haven’t got the right         surprised by the smart models
     and cafes that go under, the          data. When the contaminations            that even interested civilians can
     increasing number of children         go down, are we going to open up         come up with. Why not use that
     facing psychological and learning     the hairdressers, or the schools?        intellectual power?’
     problems because they can’t go to     Nobody knows.’
     school.’
                                                                                    The vaccination in the
                                            ‘ I would surely spend                  Netherlands – which only started
     ‘The medical focus on avoiding                                                 in the beginning of January – is
     every single Covid-death doesn’t
                                              a few millions more                   just as clumsily organized as
     make sense. Hundreds of traffic          on data analysts in                   the corona measures, says De
     deaths can be avoided every              every hospital. Make                  Hond. ‘At the beginning of the
     year if we start driving 30 km per                                             pandemic in 2020 we should have
                                              data accessible.’
     hour on our inter-city highways.                                               nationalised and centralized
     But nobody in his right mind                                                   health organisations. We would
     would suggest such a thing. Why                                                have been prepared for a second
     not have the same approach            The problem according to De              wave and vaccination. Now we
     to corona? The risks for under        Hond is that neither medical             make the same mistakes all over.
     60-year-olds aren’t that much         professionals nor their                  We have discussions on who
     bigger than those of a common         organisations are very good              to vaccinate first. It’s all very
     flu. There’s no need to keep all      with statistical data. ‘That makes       bureaucratic.’
     those people in lock-down. It’s       you miss out on a lot of relevant
     the over 60’s you want to protect.    information. Data are my job, my
     Base your policy on that.’            life, it’s what I do. It’s a different   De Hond didn’t contract corona
                                           angle altogether. At the beginning       himself. He keeps himself safe by
                                           of the pandemic you could see            avoiding badly ventilated and dry
     Good policy starts with good          the pattern that the regions             spaces. He carries a CO2-meter
     data, according to De Hond. And       most affected all had the same           that tells him if enough fresh
     that’s where he thinks it all went    climatic conditions: temperature         air is circulating. He agrees that
     wrong in the Netherlands. ‘Good       between 4 and 12 degrees, low            western countries can’t battle
     data have been lacking from the       humidity. That’s no coincidence.         Covid-19 the way China does. So
     beginning. The Covid-data in          It had been affirmed by a group          it will have to be done in a clever
     the Netherlands are still horrific.   of scientists that these are perfect     way. With the acknowledgment
     Only now do we get reliable daily     circumstances for the spread of          that it’s impossible to avoid all
     figures on the number of positive     corona. Based on these data I            corona deaths. ‘We need to learn
     tests per day. Ten months into        predicted that New York would            to cope with the risks of this virus.
     the pandemic! When we started         become the new Bergamo. The              As we do with traffic risk, or all
     testing in the spring, we could       data also explained why there            kind of other risks in daily life.’
     have asked each positive tested       were no extra deaths in Rome in
     person to fill out a survey with      March and April.’

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THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                          GOOD POLICY STARTS WITH GOOD DATA
HEALTH THEME: Actuarial ...
HOW TO PRIORITISE
     VACCINATION
      Remarkably, mankind has developed a range of vaccines in little more than 12
      months since the identification of the novel coronavirus in late 2019. The big
      issue as we enter 2021 is how should those vaccines most responsibly be rolled
      out? Stuart McDonald, Yifei Gong and John Roberts, three actuaries working on
      demographic and epidemiological data, have been to the fore of analysis of the
      benefits of the strategic distribution of early vaccines to the most vulnerable
      categories of the population. We set out here a summary of their recent work.

      IN THE UK, THERE WERE 9 PRIORITY
      GROUPS IDENTIFIED. BROADLY SPEAKING
      THEY WERE:
        1 residents in care homes, together with
           care home workers
        2 over 80s, together with health care staff
        3 over 75s
        4 over 70s and clinically vulnerable
        5 over 65s
        6 people under 65 with health issues
        7 over 60s
        8 over 55s
        9 over 50s
       10 the rest

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THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                   HOW TO PRIORITISE VACCINATION
HEALTH THEME: Actuarial ...
Using actuarial techniques, the groups were                                   The population of England was analysed to
          analysed to see what proportion of COVID-19                                   categorise the population by group and to
          deaths had occurred in each segment of                                        analyse the death data into the same groups.
          the population and what proportion of the                                     Some approximations were needed but the
          population fell into each category. Acquiring                                 majority of the age-related categories were easily
          suitable data in an emerging pandemic is                                      extracted. A table was then built up to show the
          difficult but Governments have collected                                      proportion of deaths that might have been saved
          copious material to enable them to monitor the                                with an effective vaccine having been delivered
          situation. The modelling was done on the basis                                to that category. Clearly, the vaccine might not
          of COVID-19 attribution featuring on certificates                             be totally effective and vaccination not carried
          of death as a reasonably objective piece of                                   out to the full, but the relative impact of each
          information.                                                                  category is clearly seen in the data.

                                                                                        At its simplest, how many vaccinations are
                                                                                        required to prevent one death:

                                      Priority Group              Percentage             Number of vaccines   Percentage of Lives
                                                                  of Population          required to save a   Saved (Cumulative)
                                                                  (Cumulative)           life
                                      1                           2%                     10                   32%
                                      2                           15%                    90                   67%
                                      3                           19%                    180                  78%
                                      4                           28%                    360                  88%
                                      5                           33%                    570                  93%
                                      6                           47%                    2000                 96%
                                      7                           50%                    900                  97%
                                      8                           55%                    1800                 98%
                                      9                           60%                    3500                 99%
                                      The rest                    100%                   23000                100%

                                FIGURE 1. DEATHS PREVENTED VS POPULATION VACCINATED BY PRIORITY GROUP
                                                                                                                              rest
                                    100%                                             
                                     90%                                 
                                                                   
                                     80%                   
                                     70%               
                                     60%
                                     50%
                                     40%
                    Death Averted

                                     30%         
                                     20%
                                     10%
                                      0%
                                        0%       10%       20%      30%      40%       50%      60%   70%     80%    90%     100%

                                          Population Vaccinated

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THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                                                        HOW TO PRIORITISE VACCINATION
HEALTH THEME: Actuarial ...
It can be seen that the first four priority groups         There is a logical order to studying the impact of
         (targeted by mid-February 2021 in the UK) cover            the virus. Cases precede hospitalisations (and in
         28% of the population but 88% of the probable              some cases intensive care), with deaths following.
         deaths.                                                    We also needed to build in the period before the
                                                                    vaccine becomes effective in preventing illness
         It is also important to note that there are good           – we know from the medical trial data that it is
         reasons to get vaccinated beyond reducing our              possible to be infected up to two weeks after the
         own risk. We get vaccinated to protect others, by          first shot. The impact of this additional period will
         breaking chains of transmission, as much as to             be important to understand, as an anxious public
         protect ourselves.                                         is waiting to see the first positive effects of the
                                                                    vaccination programme.
         This work also uses a simple analysis of death
         counts rather than an alternative such as Quality
         Adjusted Life Years (QALYs), which would place             INFLUENCING FACTORS
         more value on younger lives. Whilst a QALY                 The overriding influence is the prevalence of
         approach would have merit, a simple analysis               the virus. For simplicity, the analysis assumed
         seems appropriate here, given the relatively               constant prevalence, and so recent falls since
         short time interval expected between the                   the latest lockdown started will add to the
         different priority groups becoming eligible for the        benefit shown. The vaccination will not be
         vaccine and the likelihood that full population            100% effective, and neither will we see a
         vaccination will not be long delayed in any case.          100% take-up from those offered the vaccine.
                                                                    Vaccine effectiveness will also affect measures
         A further public debate has concluded in the UK            in different ways. For instance, an effectiveness
         with the decision to prioritise the first dose of a        of 70% may only reduce cases by that amount,
         two-dose vaccination programme on the basis                but would hopefully reduce serious illness and
         that it is likely (though not demonstrably certain)        death by a much greater percentage. In contrast,
         that most of the life-saving and hospital-saving           the take-up rate will affect each measure in a
         impact will arise with the first dose and that it is       consistent and intuitive way. However, as the
         better to administer one dose to twice as many             early phases are concentrated on the most
         people as two doses to the first groups. Clearly           vulnerable, and those who are caring for them,
         it is possible that the second dose to the highest         it is reasonable to assume that there will be a
         categories just might save more than the first             relatively high take-up rate – certainly greater
         dose to the accelerated lower categories but               than would typically be seen with the annual flu
         the data to demonstrate this does not exist and            vaccination programme.
         a political decision was taken in the UK unlike
         most other states.
                                                                    Cases
                                                                    The analysis considered how long it is likely to
         HOSPITAL ADMISSIONS                                        be before we start to see an effect in the various
         The public debate is further coloured by                   reported statistics. It should be noted that
         discussion about whether the focus should                  these are estimated average delay periods. In
         be on the avoidance of preventable deaths or               reality there is a spread of actual delays around
         hospitalisations and consequent pressures on               the mean. Allowing for the two-week period
         the health system, with the ensuing impact on              after vaccination before protection kicks in, a
         the conduct of non-urgent normal healthcare.               further three to four days is typical for the first
         Fortunately, the data does lend itself to further          symptoms to occur, and we should allow another
         analysis of the impact of vaccination on reducing          two to three days for a test to be taken and the
         hospital admissions.                                       results to be reported in the data published.
                                                                    Overall 20 days was assumed.

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THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                                   HOW TO PRIORITISE VACCINATION
HEALTH THEME: Actuarial ...
FIGURE 2. VACCINE EFFECT (GROUPS 1 TO 4 ONLY)

                                                           100%
                     Proportionate Effect on Key Metrics

                                                           80%

                                                           60%
                                                                      Cases
                                                                      Admissions
                                                           40%
                                                                      ICU
                                                                      PHE Reported Deaths
                                                           20%
                                                                      ONS Reported Deaths

                                                            0%

                                                             01 Jan   15 Jan      29 Jan      12 Feb     26 Feb       12 Mar    26 Mar

     Hospitalisations                                                          in some instances. However,               and an even smaller impact on
     Added to the two-week                                                     given that the majority of deaths         intensive care (ICU) admissions,
     effectiveness delay, following                                            are recorded within a week,               where very few of the oldest
     infection there is typically a                                            the analysis assumed a further            patients will be considered
     10-day period before admission                                            delay of 3 days. Adding this to           clinically to benefit from the
     to hospital, plus two days for                                            the 31 days from the hospital             treatment available.
     reporting which translated to an                                          deaths estimate above gives a
     assumption of 26 days.                                                    total period of nearly nine weeks         This is a moving subject and one
                                                                               produced an assumption of 47              where actuaries have been able
                                                                               days.                                     to produce information of critical
     Hospital deaths (PHE)                                                                                               importance to public policy
     These are on average 6 to 8 days                                          The modelling then took these             decision-making, particularly
     after hospitalization plus around                                         periods of time and identified            by elected politicians making
     3 days for reporting delays which                                         these with the schedule for               a balance of judgments. There
     resulted in an assumption of 34                                           vaccination drawn up by the               will be more decisions to take on
     days.                                                                     authorities for these priority            the way and the speed at which
                                                                               groups in order to show the likely        society’s normal behaviour
                                                                               impact on the reported data               can commence again and
     ONS Deaths                                                                and the implied pressures on              professional actuarial modelling
     (National Statistics)                                                     hospitals and their Intensive care        of this kind should enable better
     With a focus on excess deaths, as                                         facilities.                               judgments to be made.
     reported by ONS, it is also useful
     to understand the additional                                              The graph above shows the
     delay period before these begin                                           currently estimated timescale
     to be impacted. Registrations                                             impact from vaccinating the first
     are reported weekly, with a 10                                            four priority groups on the likely
     to 16 (average 13) day lag from                                           reduction both in deaths and in
     registration, to which the period                                         hospitalisations. It shows clearly
     between death and registration                                            that whilst we should expect a
     should be added. This latter                                              rapid fall in deaths, the first four
     delay can be very variable,                                               priority groups will have a lesser
     and extend into many weeks                                                impact on hospital admissions,

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THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                                                                    HOW TO PRIORITISE VACCINATION
HEALTH THEME: Actuarial ...
DECISION-MAKING
    IN UNCERTAINTY
     BY PETER KINGSLEY                  The finance, pensions and insurance sectors have long relied
                                        on data and mathematical models to justify decisions, many
                                        backed by the authority of actuarial practice. Everything
                                        from projecting life expectancy to aligning long-term pension
                                        obligations and capital allocation decisions are measured,
                                        creating a shared set of norms. Risk is traded. Value exchanged.

                                        T
                                               he problem is that these      based assessments of possible
                                               models are cultural           —distinct from probable—
                                               constructs rooted in          outcomes.
                                        historical experience. They
                                        rely on collective confidence.       This challenges tradition and
                                        In ‘edge of chaos’ conditions        convention. After all, one of the
                                        dominated by high levels of          assumptions in financial markets
                                        interdependence, complexity          is that history-based modelling
                                        and uncertainty, this confidence     has predictive authority. This
                                        is under growing threat.             may work in the short-term,
                                                                             but when it matters most—in
                                        If actuarial and risk modelling      political, market or financial
                                        is to remain relevant,               crisis—models fail. History is a
                                        anticipation is paramount.           poor guide to possible futures
                                        Above all, practices shared by       when shocks begin to cascade
                                        actuaries, financial analysts and    through tightly coupled systems.
                                        investors are necessary but no       Models fail to capture real-world
                                        longer sufficient to meet the        complexity, particularly in crisis
                                        challenges facing leadership         when base-level assumptions
                                        teams in government, financial       break down.
                                        institutions and corporations.

                                                                             DATA ARE OFTEN INCOMPLETE
                                        THE CLIMATE CRISIS AND               and inaccurate, giving little help
                                        COVID-19 show that if strategic      to decision-makers in preventing
                                        advice is to be relevant to policy   system failures. This can be a
                                        and board-level decision-makers,     matter of life and death.
                                        it must both anticipate potential    In extreme conditions, options
                                        shocks and make intelligence-        narrow at exponential rates and

                                                        9
THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                     DECISION-MAKING IN UNCERTAINTY
HEALTH THEME: Actuarial ...
‘
                             These realities cannot be modelled
                             or forecast in conventional, logical,
                             rational, statistical, or probabilistic
                             terms.

                                                                          wait for definitive evidence and
                                                                          certainty, they are destined to
                                                                          deliver ‘too little, too late’. Faced
                                                                          with radical uncertainty, they
                                                                          have to make imaginative, pre-
                                                                          emptive judgments.

                                                                          NOR ARE EMERGING SOLUTIONS
                                                                          to these challenges necessarily
                                                                          the answer. The most recent
                                                                          artificial intelligence applications
                                                                          have great value and potential,
                                                                          but the machine learning
                                                                          paradigm is narrow, brittle and
                                                                          limited to specialised tasks
                                                                          that cannot adapt to changing
                                                                          system dynamics. Even the
                                                                          most advanced models are
                                                                          fragile in chaotic environments,
                                                                          as some quantitative funds
                                                                          have discovered. They are
                                                                          typically based on ‘small world’
                                                                          perspectives that focus on
                                                                          what can be measured, rather
                                                                          than what is essential. They
                                                                          often fail to capture, to take
                                                                          one example, how weak signals
                                                                          gain momentum, or how social
                                                                          interaction shapes behaviour.

     PETER KINGSLEY                                                       MACHINES DO NOT YET REASON,
                                                                          or model cause and effect. There
                                                                          is not even a consensus about
     leave little room for manoeuvre.   THE VIRUS HAS SPREAD by           what ‘reason’ means. A growing
     COVID-19 has illustrated that      the time signals are picked up,   body of research suggests that
     data are too often lagging         data validated, and models        human reason is not about how
     indicators.                        developed. If policymakers        to deal with abstract logical

                                                        10
THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                   DECISION-MAKING IN UNCERTAINTY
‘
                             The underlying challenge for financial
                             professionals is that, to recap,
                             anticipation, not measurement,
                             is paramount for leadership teams.

     problems but rather to meet the       markets depend ‘nearly entirely    THE UNDERLYING CHALLENGE
     challenges of living in collaborate   on human imagination and           for financial analysts, fund
     social groups.                        emotion.’ We act in the present    managers and actuaries is
     In other words, decision-making       on imagined futures. Or fail to.   that, to recap, anticipation, not
     leadership teams are embedded         Asset values in low lying cities   measurement, is paramount for
     in social environments and            like Miami will collapse long      leadership teams.
     shaped by cultural forces.            before rising sea levels make      Decision-makers are searching
     To compound the problems,             them uninhabitable.                for answers to the problem of
     decisions are influenced by how                                          how to deliver resilience in a
     individuals and groups imagine                                           world of well forecast ‘wild card’
     the future. These are primary—if      TAKE ANOTHER EXAMPLE, in           shocks such as COVID-19 and
     not dominant—cultural realities.      December 2016, the first signs     the momentum of weak signals
     Imagined futures shape political      that major energy companies        suggesting runaway climate
     decisions, policy, corporate          would come under sustained         change is underway. They are
     stewardship, sustainability and       investor pressure emerged          asking how they can imagine,
     set innovation agendas. These         when they were asked to explain    navigate and make stewardship-
     realities cannot be modelled          their long-term strategies in      based judgments about the long-
     or forecast in conventional,          the context of climate change.     term and hedge against worst-
     logical, rational, statistical, or    Primary asset owners began         case scenarios.
     probabilistic terms.                  to project transitions to
                                           autonomous electric vehicles,      If the actuarial profession is
                                           solar and wind power five, ten     to meet these challenges and
     DECISIONS ARE MADE NOT                and more years ahead. The          remain relevant at the highest
     SIMPLY by careful cost-benefit        pressure was rooted in imagined    levels, it has to think about how
     analysis, but by leadership teams     futures and the narratives that    to combine imaginative foresight
     looking for stories that make         described them. The future         with traditional strengths. After
     sense of volatility, particularly     once again showed it can deliver   all, professional services firms
     in times of crisis and when the       shocks in the here and now.        have to re-invent themselves,
     future is deeply uncertain. When                                         leading, not following, their
     the stories change and new ones       Too much attention focuses on      clients. If they cannot picture the
     gain momentum, financial and          fine-tuning data, measurements     long-term, they will struggle to
     economic shocks emerge.               and models, rather than on how     offer strategic advice.
                                           real-world decision-makers use
     To illustrate, we might assume        them. Models can act as anchors
     that financial analysts are           but are often ignored or used                   PETER KINGSLEY is
     interested only in data, even         to give legitimacy to intuitive                 Chairman of The Oracle
     in low volatility conditions.         judgments. More often, they are                 Partnership.
     The reality, as David Tuckett         challenged, poorly understood,                  https://
     points out, is that financial         or deliberately distorted.                      oraclepartnership.com/

                                                          11
THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                      DECISION-MAKING IN UNCERTAINTY
EIOPA OPINION ON
     SOLVENCY II REVIEW:
     CONCERNS OF AAE
      BY JENNIFER BAKER

                                        I
        This article is a summary of         n February 2021, the                However, the primary demand
      the official AAE Position Paper        Actuarial Association of            for the insurance sector to better
                                             Europe (AAE) set out its            serve the long-term needs for
                                             main positions regarding            European citizens and to act
                                             the Solvency II 2020 review.        as long-term investors requires
                                                                                 an appropriate valuation of
                                                                                 long-term business and a
                                        While acknowledging that                 risk-adequate treatment of
                                        Solvency II is intrinsically a           long-term investments as well.
                                        well-functioning, risk-based             It is a requirement that such
                                        framework, the AAE believes that         a valuation aims at reducing
                                        the experience of the past five          volatility and thus prevents
                                        years of application, along with         procyclical behaviour. An
                                        the low interest environment,            appropriate valuation of the
                                        reveal a need to change parts of         obligations resulting from
                                        the current framework.                   the contracts in a portfolio is
                                                                                 indispensable.

                                        The overall aim is to ensure
                                        policyholders protection and             Solvency II together with the
                                        financial stability in Europe,           Long-term guarantee (LTG)-
                                        and as such it is important not          measures has worked well
                                        to change the fundamental                in terms of safeguarding the
                                        principles of the Solvency II            policyholders in the past and
                                        framework, such as confidence            should not be jeopardised by
                                        level underlying calibration             inappropriate new requirements.
                                        of capital requirements or the           Our main concerns are related
                                        market-consistent basis for the          to: the treatment of long-term
                                        valuation of the balance sheet.          business with guarantees;

                                                       12
THE EUROPEAN ACTUARY NO 25 - MAR 2021                                       EIOPA OPINION ON SOLVENCY II REVIEW: CONCERNS OF AAE
the enabling a well-diversified,   An identified last liquid point           the role of the UFR caused
     sustainable and persistent         (LLP) is the starting point for an        by waiving the convergence
     investment strategy; and the       extrapolation. Currently, for the         requirements. Convergence
     proposed extensions of the         Euro, this LLP is 20 years and            to the UFR is determined by
     Solvency II framework by           should not be changed, as that            the last liquid forward rate
     macroprudential elements.          would have a significant market           (LLFR) and a mean reversion
                                        impact which needs to be taken            factor alpha, which is – without
                                        carefully into account.                   scientific justification – set to
        ‘The availability                                                         10%. The LLFR aims to take
         of deep, liquid                                                          into account information from
                                        Another essential criterion is            DLT-markets post-LLP and
         and transparent
                                        the requirement to reach the              is the starting value for the
         (DLT) markets is               Ultimate forward rate (UFR)               extrapolation. It can be highly
         a precondition                 within a given convergence                volatile and affects the entire
         for the required               period (currently 40 years for            RFR. Convergence is modelled
                                        the Euro) with a given tolerance.         independent from capital
         market-consistent              This UFR reflects a long-term             markets by applying fixed
         valuation in the               expectation or a mean-reversion           factors depending solely on the
         current framework.’            level, annually determined by             mean reversion factor. Therefore
                                        EIOPA in accordance with the              the method cannot compensate
                                        method published in 2017.                 short- or mid-term distortions
                                                                                  of capital markets (e.g. resulting
     The availability of deep, liquid                                             from ECB-activities, Covid-19).
     and transparent (DLT) markets is   The alternative extrapolation             These are carried forward to the
     a precondition for the required    method proposed to the                    entire RFR and thus increase
     market-consistent valuation in     European Commission leads                 volatility of undertakings’
     the current framework.             to a significant weakening of             capital position.

                                                        13
THE EUROPEAN ACTUARY NO 25 - MAR 2021                                        EIOPA OPINION ON SOLVENCY II REVIEW: CONCERNS OF AAE
Particularly in a low interest rate   In terms of interest rate stress,        regard to recovery, resolution
     environment a more volatile           we see the need for corrections,         and IGS, different treatments
     and significantly lower risk-free     as currently no stress is applied        across Europe could lead to
     rate, might prevent insurers          to negative interest rates.              flaws in policyholder protection.
     from maintaining their long-          Considering the one-year                 Harmonisation should consider
     term business model, holding          horizon required by Solvency             cross-border business, already
     long-term investments in a            II, risk parameters should only          available solutions and
     sustainable way and offering          be applied to the liquid part of         proportionality aspects.
     products with guarantees.             the extrapolated curve. This
                                           stressed liquid part should be
                                           extrapolated. First stress – then        Coherence of the Solvency II
        ‘ In terms of interest             extrapolate!                             framework should be considered.
          rate stress, we                                                           Additional burden for the
                                                                                    undertakings resulting from
          see the need
                                           We welcome the attempt to                macroprudential measures to
          for corrections,                 reduce the risk margin by                reduce risk should be assessed
          as currently no                  introducing a factor lambda to           together with the existing
          stress is applied to             attenuate the impact of future           prudential framework in order
                                           SCR. The proposed floor should           not to go beyond the current
          negative interest                be omitted as the margin needs           99.5% VaR requirement.
          rates.’                          further analysis, especially on
                                           the way it works for long-term
                                           insurance liabilities.                   In short, the Solvency II review,
     Volatility adjustment needs                                                    should aim for an appropriate
     reconsideration. EIOPA’s                                                       valuation of long-term liabilities
     proposal is still based on a          Same risk, same capital is a basic       but also offer better possibilities
     reference portfolio calibrated        principle of Solvency II. Therefore      to support a sustainable relaunch
     on EU-level. Considering              neither green supporting,                of the EU economy in the
     undertaking specific aspects          nor brown penalising factors             aftermath of Covid-19. We must
     in the ALM and liquidity              should be introduced. Capital            also ensure that new, emerging
     application ratios plus a quicker     requirements should consider             risks are properly considered.
     and smoother activation of            the quality of investments and           But the focus must remain on
     the country component aims            the inherent risk.                       policyholder protection and the
     at better consideration of                                                     prevention of insolvency risk – it
     undertakings risk. It leads to a                                               is important not to overstretch
     higher degree of complexity,          Solvency II is a risk-based –            Solvency II and to preserve it as a
     but this will not remedy the          although microprudential                 principle-based framework.
     identified deficiencies on over       – framework, and EIOPA
     or undershooting resulting from       acknowledges that risks for
     differences between own assets        financial stability, liquidity           Position papers of the aae can
     and the reference portfolio.          risk, etc. in insurance are not          be found here: https://actuary.
     Taking own assets as a basis          comparable to those observed in          eu/publications/positions-
     should still be definitively part     banks. Any extension of Solvency         discussion-papers/
     of the Risk Management System         II should be based on a thorough
     and ORSA exercise.                    analysis of current options. With

                                                           14
THE EUROPEAN ACTUARY NO 25 - MAR 2021                                          EIOPA OPINION ON SOLVENCY II REVIEW: CONCERNS OF AAE
XIII ITALIAN ACTUARIAL
                   CONGRESS POSTPONED

                   T
                           he XIII Italian Actuarial Congress        It is at the same time a step forward
                           was announced early for June              especially for the mentality and a
                           2020 and postponed due to the             confirmation of the Italian strategy, that
                   Covid situation. We now aim to organize           is to consolidate the traditional fields
                   it for November 2021 (10-12) in Milan.            (insurance, pension) and in parallel to
                                                                     develop the wider fields.
                   The title will be:
                                                                     In this context all the sessions are
                       Technological innovation                      oriented in this direction. Moreover
                       and systemic risks: actuary                   some specific sessions are reserved
                       as a global assessor of                       to the international topics with the
                       uncertainty.                                  participation of IAA, AAE, AFIR-ERM,
                                                                     ASTIN; another session is dedicated to
                                                                     the topic of "governance" where the
                    It is a logical evolution of the Italian         Actuary is more and more present. Other
                   strategy for the actuarial profession's           important sessions will concern IFRS17,
                   development and the congress is a very            IORP2, Welfare. We will keep you up to
                   important moment to take stock of the             date on developments.
                   situation, but also to launch messages
                   for the future. The message in this case                                 Giampaolo Crenca
                   will be very ambitious: from Manager
                   Actuary to the Global Actuary, in order
                   to enlarge actuarial minds and activities
                   especially towards systemic risks and the
                   wider fields.

                                                                15
THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                       XIII ITALIAN ACTUARIAL CONGRESS POSTPONED
THE 2020 AAE
     PRESIDENTS' MEETING
                                                                          BY GIAMPAOLO CRENCA

            In 2020 this important meeting was held over two days, in two parts and virtually, due
            to the Covid situation. The first meeting was on the 12th of November and the second
            on the 4th of December.

     T
             he AAE Presidents'         • climate change,                 ON THE FIRST DAY three
             Meeting is a moment                                          topics were discussed: climate
             of confrontation and       • communication,                  change, communication, and
     discussion among all the                                             professionalism (particularly
     Member Associations (MAs) and      • professionalism                 education). About climate
     so it assumes a strategic value.     (particularly education),       change the answers to the survey
                                                                          were observed and substantially
                                        • mutual recognition              all the countries think that it is
     Particularly in this case            agreement (MRA),                an important and strategic topic
     five important topics were                                           for actuaries and AAE. Moreover
     introduced by the AAE's Board      • the role of the actuary.        it is clear that it belongs to the
     and discussed during the two                                         wider world of the wider fields
     meetings:                                                            because it is a systemic risk. Is
                                                                          this just about measurement

                                                       16
THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                 THE 2020 AAE PRESIDENTS' MEETING
or also a model ? This question     A VERY IMPORTANT TOPIC                to develop the wider fields also
     was very deeply debated and         was the role of the actuary,          with the support of very strong
     the conclusion was that if we       especially about the legal role,      communication work.
     develop models we can also          because under the AAE there
     focus on one or more indices,       are different situations from
     thus satisfying both. AAE could     country to country. The goal is       Other interesting discussions
     organise a congress about this      to find, if possible, a same legal    followed with two experiences
     topic.                              role valid for all the MAs and        related to Hungary and Denmark.
                                         officially recognized in the whole
                                         of Europe.
     THE SECOND TOPIC was                                                      THE AAE'S PRESIDENT,
     communication, absolutely                                                 Wilhelm Schneemeier,
     strategic and strictly connected    ON THE SECOND DAY of the              encouraged everyone to follow
     with the Board that set up a        meeting there were two                this already well-designed path.
     specific working group just         important discussions, the
     for developing this project.        first concerning the "Legal
     Communication is internal           recognition workstream Task
     as well as external. External       Force Roles of Actuaries" and
     concerns many different             the second "Wider Fields". Both
     stakeholders and we must try        were a logical deepening of
     to reach everyone with different    the topics discussed during the
     channels, approaches and            first part. The speakers in the
     languages. Channels are very        first discussion emphasized the
     important and the AAE could         importance of understanding
     use with greater intensity the      well the situation in each MA, and
     communication tools already         so a consultation process was in
     available (for instance the         course. Afterwards the goal is to
     magazine The European Actuary,      evaluate the following steps and
     Actuview) and, if necessary,        to individuate a legal role for the
     identify other tools.               actuary in Europe valid for each
                                         MA.

     THE THIRD TOPIC,
     professionalism, resulted           THE SPEAKER about wider fields
     in a discussion concerning          emphasized the importance of
     education and, in particular, the   this topic that is now in its own
     contents of the core syllabus       right under the AAE's strategy.
     and the implementation by the       He indicated some of these
     Member Associatons (MAs).           fields and the need to be very
     MRA must be reviewed for            prepared to face this challenge
     some reasons, Brexit the most       especially addressing education                    GIAMPAOLO CRENCA
     important, especially now that      needs. So, the strategic proposal                  is Past President Consiglio
     an agreement with the UK was        is to consolidate and develop                      Nazionale Attuari.
     found about their staying in the    the traditional fields (insurance,
     AAE.                                pension) and at the same time

                                                         17
THE EUROPEAN ACTUARY NO 25 - MAR 2021                                                      THE 2020 AAE PRESIDENTS' MEETING
18
                                              COLUMN                    COLOPHON
                                                                        The European Actuary (TEA) is the
                                                                        quarterly magazine about international
                                                                        actuarial developments. TEA is written for
HOW TO PREDICT THE INTEREST RATE                                        European actuaries, financial specialists
IN 2081?                                                                and board members. It will be released
                                                                        primarily as e-mail newsletter.
                                                                        The Editorial Board welcomes comments
Predicting the market 60 years into the future is extremely             and reactions on this edition under
                                                                        info@theeuropeanactuary.org.
uncertain. There is no market information available that can
be used as a basis for such an estimate. Hence, analysis has to         THE EDITORIAL BOARD CONSISTS OF
be based on models and expert judgement and has to consider             Pierre Miehe, France
experience of the last 60 years. Without any doubt we have been in      (Pierre.Miehe@Milliman.com)
a low interest rate environment for more than 10 years. This was        Peter Tompkins, United Kingdom
certainly intensified by ECB’s quantitative easing programme in         (PeterDGTompkins@aol.com)
the last years. So the biggest challenge is to compensate this effect   Birgit Kaiser, Germany
because it cannot be continued over the next 60 years.                  (Birgit.Kaiser@aktuar.de)
                                                                        Robert van Leeuwen, The Netherlands
Looking at Omnibus II, the approach for this crucial estimate is (for   (leeuwer@hotmail.com)
currency Euro) to have an extrapolation method starting at year         Giampaolo Crenca, Italy
                                                                        (g.crenca@studio-cea.it)
20 (the last point in time with a market deep and liquid enough to
                                                                        Gunn Albertsen, Norway
be used as an estimator for the risk-free rate) and being after 40      (gunn.albertsen@storebrand.no)
years near the Ultimate Forward rate (UFR) with a maximum 3bp
difference.

Now EIOPA’s opinion on the Solvency II review has been published.
The AAE agrees with many of the changes proposed (see also
Article on p. 12), like the introduction of negative interest rate      Actuarial Association of Europe
stress and not to change year 20 as last liquid point. But it is        Maison des Actuaires
certainly not justified to use swap positions (without underlying)      1 Place du Samedi
between years 20 and 50 to propose an extrapolation method              B-1000 Brussels, Belgium
which deliberately does not ensure that the UFR will be reached         https://actuary.eu/publications/
after 60 years with a predefined difference. This proposal will have    the-european-actuary/
extreme consequences for long term life and pension insurance           For futher informations contact
business and will increase capital requirements significantly.          Monique Schuilenburg
                                                                        (moniques@actuary.eu)
Overall, the proposals will lead to a weakening of the financial
positions of insurers, as a balancing of the outcome will not           Lay-out Manager: Linda van den Akker
                                                                        Magazine Manager: Frank Thooft
be possible. Another consequence will be a significantly lower
capacity for investment in sustainable assets. Undertakings will
                                                                        NEXT ISSUE:
refrain from offering products with guarantees and thus shift           The next issue will appear 1 June 2021.
higher performance risk to policyholders. This can result in an         Suggestions can be e-mailed
increase of the pension gap once these clients retire (and the          to info@theeuropeanactuary.org
current gap is already too high).                                       The deadline is 1 May 2021.

The AAE advises not to change the convergence target at year 60         EUROPEAN AGENDA
                                                                        Please check
and not to implement EIOPA’s extrapolation proposal. A wide and
                                                                        http://actuary.eu/event-calendar/
deep impact study can help to balance all aspects: Solvency II          for the most actual forthcoming events.
should safeguard clients. There is no convincing reason to change
this fundamental element of the Omnibus II Directive shortly after      ADVERTISING IN THE
the start of Solvency II.                                               EUROPEAN ACTUARY
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Wilhelm Schneemeier                                                     financial professionals throughout Europe.
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THE EUROPEAN ACTUARY NO 25 - MAR 2021
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