RBNZ Consults on Aspects of Insurance Act, Solvency Standards & IFRS17

Consultation on Insurance Prudential Supervision Act 

In 2017, RBNZ had commenced a review of IPSA. The first stage of the review, which comprised identification of issues at a high level and an initial public consultation process, was completed in 2017. This consultation paper marks the beginning of a second stage of the review of IPSA. In this stage, RBNZ will work through each of the 11 modules set out in the 2017 consultation paper, seeking feedback on specific options for reforming the existing legislation. This paper, however, deals with two modules; one module is on the scope of legislation and it discusses whether the legislation applies to the appropriate range of entities; the other module concerns overseas insurers and it details treatment of branches and overseas insurers. The remaining modules will be grouped together pragmatically in ways that ensure, where possible, related and interacting issues are dealt with in the same consultation. RBNZ expects these subsequent papers to be issued during 2021 and 2022.

This consultation paper on IPSA discusses whether the definition of insurance contracts remains sufficiently broad to cover new forms of business and whether it is clear enough to give industry the guidance it needs. It also invites stakeholders to identify any places in which they think the boundary of "insurance business" is incorrectly drawn by the current framework. The paper also discusses whether IPSA should regulate New Zealand-based insurers and reinsurers that issue all their policies overseas. Additionally, the paper explores how the balance of risks is struck in the current legislation and invites stakeholders to consider whether that balance remains appropriate. The paper goes on to ask whether IPSA needs tighter coverage of reinsurance or whether insurers should be under increased obligations to monitor and report on their risk assessment of reinsurance arrangements. Finally, the paper moves on from the entities captured by IPSA to discuss issues about how entities’ corporate and legal form affects regulations. 

Consultation on Insurance Solvency Standards 

The consultation on Insurance Solvency Standards looks at a series of technical issues concerning how insurance companies calculate their solvency capital requirements. In this document RBNZ explores the possibility of having a single framework apply to both life and non-life business. In October 2020, RBNZ announced the start of the Solvency Standards Review alongside the IPSA Review. It is timely to review the standards to ensure that they are robust and fit for purpose. The review will be divided into two stages. The first stage (now underway) will address structural changes and other issues that require immediate attention (including IFRS 17). The second stage will address the determination of individual components of the solvency requirements (asset risks, liability risks, other components). RBNZ will introduce interim standards at the end of the first stage and final standards at the end of the second stage. In conducting the review, RBNZ will take into account efficiency considerations from the industry.

This consultation paper on Insurance Solvency Standards relates to the first stage of the review. It is concerned with the issues that shape the standard’s fundamental structure and nature. While IPSA provides general purposes and principles to govern regulation and supervisory activity and empowers the solvency standards, it provides no specific purpose for holding regulatory capital. RBNZ proposes that the purpose of holding regulatory capital is to ensure that, in adversity, an insurer’s obligations to policyholders will continue to be met in full as they fall due. This consultation also seeks views on whether:

• A total balance sheet approach should be adopted to capture second-order effects and balance sheet interactions
• Certain “sectorally important” insurers are critical to the functioning of financial system of New Zealand and  should be treated differently for capital purposes compared to the “non-sectorally important” insurers

The consultation paper highlights that RBNX is exploring the possibility of using a “standardized balance sheet” structure as part of its response to IFRS 17. This new accounting standard is expected to have a material impact on an insurer’s balance sheet. In particular, from a New Zealand perspective there is likely to be a number of areas requiring judgment to be exercised, leading to inconsistent results across the industry. As the solvency requirements are based on the accounting balance sheet, it follows that they may be similarly affected. To minimize any unintended consequences,  it is necessary to fully consider and understand the extent to which IFRS 17 will impact the solvency position and the potential avenues available to respond to IFRS 17.

Related Links

• Press Release
• Consultation on IPSA (PDF)
• Consultation on Insurance Solvency Standards (PDF)

Comment Due Date: February 18, 2021

Keywords: Asia Pacific, New Zealand, Insurance, IPSA, IFRS 17, Insurance Contracts, Solvency Capital Requirement, Insurance Prudential Supervision, RBNZ