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Identified Risk Comment Possible Change
t No.
1 N/A From Missouri EIC and JL: It would be helpful if each element within the See Comment column
repository (risks, controls, control tests, and detail tests) were labeled
with a number or letter. Perhaps each risk could be assigned a number,
and each control within that risk assigned a capital letter, each control
test within that risk assigned a Roman numeral, and each detail test
within that risk assigned a lowercase letter. Going one step farther, it
would be great if the numbering/lettering system linked controls, control
tests, and detail tests together. It appears that the current document
links associated elements via formatting conventions (i.e., by lining up
associated elements), but this doesn't always work if, for example, one
detail test could be associated with several controls.
2 "The board of directors (or committee From Missouri EIC: "It never made sense to have 'establishing' as part of Change the wording of the risk to: "The board of directors (or committee thereof) is not involved
thereof) is not involved in establishing this risk. A Board of Directors would never 'establish' reserving in reviewing the insurer’s overall reserving practices or the reserves reported in the financial
and/or reviewing the insurer's overall practices...In common practice for P&C companies, the Board of Directors statements."
reserving practices." or a Reserve / Claims Committee of the Board will review reserving levels,
so it makes sense to add this to the risk."
JL comment on the above recommendation: Paragraph 1 of the 2018
Statement of Actuarial Opinion Instructions says, "The Appointed Actuary
must report to the Board of Directors each year on the items within the
scope of the Actuarial Opinion. The Actuarial Opinion and the Actuarial
Report must be made available to the Board of Directors. The minutes of
the Board of Directors should indicate that the Appointed Actuary has
presented such information to the Board of Directors and identify the
manner of presentation (e.g., webinar, in‐person presentation, written)."
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7 "The board of directors (or committee From Missouri EIC, recommended additional test of the "The board of See Comment column
thereof) is not involved in establishing directors (or committee thereof)..." control: "Obtain the packet of
and/or reviewing the insurer's overall information provided to Board members in advance of meetings and
reserving practices." determine if reserve levels are addressed in the financial reporting
information."
8 "New claims are not entered into the claims From Missouri EIC: "It is fine to keep this risk in the repository, but I Eliminate this risk. Consider whether any of the controls, control tests, and detail tests for this
management system." would delete it. I can’t think of a scenario where this would ever be a risk might be applicable to the "Claims data is incomplete…" risk.
material risk for an insurer. Maybe this risk is a relic from the past when
claims were submitted by paper forms and something could get If the FEHTG decides not to eliminate this risk, a Missouri EIC made the comment that the detail
misplaced or a backlog could occur. Currently, most P&C claims are test that begins "Select a sample of claim and expense payments..." should be moved from this
submitted by phone to the insur’s claim staff or the agent, or via the risk to the "Claims data is incomplete..." risk. This EIC noted that this detail test "has more to do
insurer’s website. A claim file is usually setup on the same day that the with cut‐off/accuracy of claim data entered and not whether new claims were entered into the
claim is reported. I guess you could have a fraud scenario in which system."
managemnt purposely delays setting up claim files in the system for
reported claims. However, this would only benefit cash flow and not the
overall financial condition since the actuarially determined reserves
would still drive the incurred loss / LAE for the period."
Another Missouri EIC expressed concerns about the feasibility of testing
controls or performing detail tests around this risk in the age of digital
claims systems. True completeness testing is impossible when there isn't
"a second record" against which to check the claims in the claims system.
Formerly, examiners could select a sample of paper files and ensure that
these claims were in the electronic system, but that type of testing isn't
possible today.
JL comment: This risk appears to be covered in the risk that begins
"Claims data is incomplete..."
9 "Claims data is incomplete or incorrectly From Missouri EIC, regarding the control "The claims system has Eliminate this control.
entered into the claims management automated controls that will not allow a claim to be entered without a
system." valid in‐force policy": "This control is not applicable to the risk. The risk is
that claims have been paid that have not been captured by the claims
system, ie, a completeness issue. This control is to prevent invalid claims
from being paid, which has nothing to do with the completeness of the
data."
10 "Claims data is incomplete or incorrectly From Missouri EIC, regarding the detail test "In situations where Consider eliminating this detail test and the corresponding control and control test.
entered into the claims management adequate segregation of duties is not apparent, obtain data to determine
system." whether any claims were set up by the same user who created the If the FEHTG does not eliminate these items, it might be helpful to clarify the connection
corresponding policy in the master file. If any instances are identified, between the control and the risk.
investigate the claim to ensure the claim exists and is supported by
underlying data.": "This does not seem to be relevant to the
completeness or accuracy of the paid claims data."
JL comment: The detail test referenced by the EIC corresponds to the
control "Segregation of duties exists..." and the control test "Obtain
claims set‐up and new policy set‐up..." So if the detail test is not related
to the risk, then the control and control test probably aren't either. It
sounds like the control and detail test might represent a way to search
for possible internal claim fraud, but the link between the risk and the
control isn't immediately apparent.
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11 "Claims data is incomplete or incorrectly From Missouri EIC, a recommended additional detail test: "Perform a See Comment column
entered into the claims management reconciliation to compare claims checks cleared from the bank account
system." with the claims paid in Schedule P. No variance or an immaterial
variance will indicate completeness of the Schedule P data." The EIC
notes, "This has been my default completeness test for years. It can be
cumbersome to get a proper apples to apples comparison from the bank
account to Schedule P, but it works well."
12 "The third‐party administrators (TPAs) or Wording change suggestion from Missouri EIC for the detail test that See Comment column
managing general agents (MGAs) are not begins "Determine, by a review of selected claims…": Change the wording
processing claims in accordance with the to "Determine, by a review of selected claims, whether the insurer
insurer’s claims procedures as outlined in the and/or TPA/MGA is/are settling its claims..."
TPA agreement."
13 "Claims under claims‐made liability policies From one Missouri EIC: "The risk 'Claims under claims made liability Eliminate this risk.
are improperly accepted (or rejected) by the policies are improperly accepted or rejected…' would be covered under
claims adjusters." the previous risk 'Claims are not processed accurately…'." If FEHTG decides not to eliminate this risk, JL recommends eliminating the control test that
begins "Perform a walkthrough…" and replacing it with something like "Perform a walkthrough
From another Missouri EIC: "This would not appear to be a material risk to ensure that claims under claims‐made liability policies are being properly administered." It is
in most scenarios. I would delete this risk. The risk has a very narrow not clear what the existing control test means, though it may be referring to extended reporting
focus. Further, there would seem to be the same immaterial risk for endorsement ("tail") coverage whereby claims can be reported after the expiration of the claims‐
occurrence basis policies and there is no risk in the repository for made policy. In such a situation, the insurer records claim amounts in Schedule P according to
occurrence policies." when the tail policy was issued, which might be what the control test is referring to when it
mentions reallocating the claim to the correct policy year. Regardless, I don't believe this tests
the "The insurer has a policy in place…" control.
14 "The claims data utilized by the actuary to From one Missouri EIC: "I recommend that the repository specifically 1) Change the wording of the risk to "The claims data utilized by the actuary to estimate reserves
estimate reserves does not correspond to address Schedule P: Reviewing the opining actuary’s test of Schedule P as does not correspond to the data in the insurer’s claims system and Schedule P."
the data in the insurer’s claims system and to a possible control test; Reconciling Schedule P as a possible substantive 2) Change the sentence in the control that begins "The insurer has established procedures to
the data in the insurer’s accounting records." test." reconcile actuarial data..." to "The insurer has established procedures to reconcile actuarial data
to the insurer’s claims system and Schedule P."
From another Missouri EIC: "It makes more sense that the risk refers to 3) Add the control "The appointed actuary reconciles the claims data used in the analysis to
Schedule P instead of a vague reference to the insurer’s accounting Schedule P Part 1." The associated control test would be to review the appointed actuary's
records. Even if the actuarial data matches with amounts in G/L reconciliation, and the associated detail test would be to perform an independent reconciliation.
accounts, it is still more important that the data matches what is 4) Delete the detail test that begins "Reconcile the insurer's actuarial report for losses..."
reported in Schedule P."
15 "Reinsurance is not properly taken into From Missouri EIC: "A couple of the risks relating to reinsurance seem Eliminate this risk. Consider moving the control that begins "The insurer has established
account in accumulating claims data." duplicative." procedures...", the control test that begins "Test the operating effectiveness…" and the detail
test that begins "Verify assumed reinsurance…" to the "The claims data utilized by the actuary…"
JL comment: Given the recommended controls, control tests, and detail risk.
tests, this risk appears to be covered by the previous risk ("The claims
data utilized by the actuary…").
16 "Initial case reserves are not established or From Missouri EIC: "There are two risks relating to claims reserves being Combine the two risks "Initial case reserves are not established or reviewed in accordance with
reviewed in accordance with the insurer’s established/updated that seem like they could be combined." the insurer’s standards" and "Case reserves are not updated accurately." The new risk could read
standards." and "Case reserves are not "Case reserves are not established, updated, or reviewed in accordance with the insurer's
updated accurately." standards."
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17 "Initial case reserves are not established or From JL: One of the possible controls for this risk is that "qualified Remove references to actuaries in this risk's controls and control tests:
reviewed in accordance with the insurer’s actuaries are involved in establishing and reviewing the reserving policy," 1) Change the control that begins "The insurer has a case reserving philosophy…" to something
standards." and one of the possible control tests is to "Review the reserving like "The insurer has a case reserving philosophy, and personnel with experience in claims
philosophy for actuarial review and policy adequacy." Actuaries usually handling are involved in establishing and reviewing the reserving policy."
aren't involved in establishing or reviewing case reserving policies, 2) In the control test that begins "Obtain documentation supporting..." delete the sentence that
though they do consider any changes in case reserving policies when begins "Review the reserving philosophy for actuarial review..."
performing their analyses; the need for the actuary to consider case
reserving changes is covered under the risk "The assumptions and
methodologies..."
18 "Initial case reserves are not established or From Missouri EIC: There is no corresponding test of controls for the "The
Missouri EIC suggests adding a possible test of controls like: "Obtain/review audit reports and/or
reviewed in accordance with the insurer’s insurer verifies that the TPAs that process claims follow the insurer’s other documentation to determine whether the insurer is reviewing the TPA/MGA’s compliance
standards." guidelines for setting case reserves on reported claims" control. with the insurer’s guidelines for setting case reserves on reported claims."
19 "The insurer is not properly recording case From Missouri EIC: "A couple of the risks relating to reinsurance seem Eliminate this risk. This risk is covered in the "Case reserves are not established, updated, or
reserves (assumed or ceded) for contracts duplicative." reviewed in accordance with the insurer's standards" risk (which is, itself, a combination of two
subject to reinsurance." risks, as recommended in a comment above).
19 "The assumptions and methodologies used JL comment: The wording of the risk and certain controls assumes that 1) Change the wording of the risk to "The assumptions and methodologies used by the insurer or
by the insurer are not accurate or the insurer has an internal actuarial function, on whose work the its appointed actuary..."
appropriate." insurer's management bases its carried reserves. Some insurers, 2) Change the wording of the control that begins "The insurer uses…" to "The insurer or its
especially small ones, base their carried reserves entirely on their appointed actuary uses..."
external appointed actuary's independent reserve analysis. The language 3) Change the wording of the control test that begins "Gain an understanding of the insurer's..."
in the repository could be made more general with a few minor wording to "Gain an understanding of the insurer's or its appointed actuary's..."
adjustments. 4) See comment 25 below for more suggested changes to the wording of the risk.
RB comment: "Can a word other than 'accurate' be found? Reserving is
not a precise science, and differences between actual and expected are
rarely zero. Perhaps replace 'accurate' with 'reasonable'?"
That said, it would be perfectly reasonable to add controls and control
tests that are designed to ensure that the insurer's actuarial team, or the
external appointed actuary's team, has a process whereby significant
assumptions and methodologies are reviewed by senior leaders of the
actuarial team who have the appropriate knowledge and experience .
21 "The assumptions and methodologies used JL comment: In the detail test "Compare the opining actuary's Either delete this detail test or, if the intent is to compare the opining actuary's assumptions and
by the insurer are not accurate or assumptions and estimates with those in other available actuarial methods with those of the internal actuarial function, then reword the detail test as "Compare
appropriate." analyses," it's not clear what the "other available actuarial analyses" refer the opining actuary's assumptions and methods with those used by the internal actuarial
to. function."
22 "The assumptions and methodologies used JL comment regarding the control test that begins "The insurer's 1) Change the control that begins "The insurer's organizational structure…" to "The insurer's
by the insurer are not accurate or organizational structure…" and the associated control test: The topic of management does not inappropriately influence the methods, assumptions, or conclusions of
appropriate." management's influence on the appointed actuary is an important one, the appointed actuary."
but I believe the wording of this control and test could be adjusted. It's 2) Change the control test that begins "Interview the appointed actuary..." to "Interview the
not clear that this risk could be adequately controlled through the appointed actuary during the planning phase of the examination to ascertain the degree of
"insurer's organizational structure." influence the insurer's management has on the appointed actuary's work."
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23 "Catastrophe‐type (CAT) claims or large or From Missouri EIC: "It does not appear that this would ever be a material
1) Eliminate this risk. Consider adding a control like "Catastrophe claims and large claims are
significant exposure type claims data are not risk. Consider deleting this one. Even on exams of insurers with analyzed separately in the actuarial reserve analysis" to the "The assumptions and
separately identified and evaluated from significant catastrophe exposure (eg, homeowners), I don’t recall any methodologies..." risk. The associated control test could be "Review the actuarial reserve
other claims." situation in past exams where this type of risk has been communicated analysis to ensure that catastrophe claims and large claims are analyzed separately."
from our consulting actuary or has been a risk for the exam staff." 2) For companies with high CAT exposure that rely on independent adjusters to handle high‐
volume events, consider adding a claims‐handling risk like "The insurer does not have sufficient
processes in place to monitor the activities of independent claims adjusters."
24 "Changes in the legal environment or From Missouri EIC: "The risk relating to 'Changes in the legal Eliminate the "Changes in the legal environment or changes in the insurer’s underwriting…" risk.
changes in the insurer’s underwriting, case environment…' could be eliminated since this would be considered in the Consider moving the controls, control tests, and detail tests from this risk to the "The
reserving or claims‐handling processes are risk that assumptions and methodologies are not appropriate." assumptions and methodologies..." risk.
not appropriately considered within the
insurer’s reserving assumptions and
methodologies."
25 "The loss and loss adjustment expense (LAE) JL comment: The controls, control tests, and detail tests for this risk are Eliminate this risk. Consider changing the wording of the "The assumptions and
reserve computations are not performed very similar to those for the "The assumptions and methodologies…" risk. methodologies…" risk to "The assumptions and methodologies used by the insurer are not
correctly or the selected estimates are appropriate, the calculations in the reserve analysis are incorrect, or the estimates selected are
unreasonable." not appropriate in comparison to the method results."
26 "The computation of reinsurance credits JL comments: Eliminate this risk.
within loss reserves are not performed 1) This risk seems to be included in other risks. The risk that the data is
correctly." incorrect is covered in the risk that the claims data used by the actuary is
incorrect and the risk that the case reserves are incorrect. The risk that
the methods are applied incorrectly or the assumptions are inappropriate
is covered in the "The assumptions and methods..." risk.
2) The two controls do not seem like they would mitigate the risk. The
two controls just describe ways in which the net‐of‐reinsurance reserves
can be derived.
From Missouri EIC: "A couple of the risks relating to reinsurance seem
duplicative."
RB comment: "I'm also concerned with placing too much emphasis on a
single point estimate vs. a range of reasonable estimates. The concern I
have is with regard to the perspective of changing a previous estimate.
For a public company there needs to be a reason why management
changed their previous estimate. Hence management is not supposed to
react to noise in their estimates. But in my experience the same is not as
true for actuarial estimates. Keeping the same method would result in
the point estimate changing from period to period due to normal
variability (noise) in the process. Would suitable documentation (for the
difference between management's estimate and the actuary's point
estimate) be that management does not believe there is sufficient
reliable new information to deviate from management's prior estimate,
and that the change in the actuary's point estimate cannot be reliably
distinguished from 'noise' at this time? (I am aware that this might be
abused by some, but an SEC filer isn't supposed to change a prior
estimate unless there is new, credible information to support the
change.)"