Financial Sector (Collection of Data) (reporting standard) determination No. 4 of 2009
Reporting standard LRS 110.0 Capital Adequacy
Financial Sector (Collection of Data) Act 2001
I, John Roy Trowbridge, a delegate of APRA, under paragraph 13(1)(a) of the Financial Sector (Collection of Data) Act 2001 (the Act) and subsection 33(3) of the Acts Interpretation Act 1901:
· REVOKE Reporting Standard LRS 110.0 Capital Adequacy made by Financial Sector (Collection of Data) (reporting standard) determination No. 19 of 2007 (the old standard); and
· DETERMINE Reporting Standard LRS 110.0 Capital Adequacy in the form set out in the Schedule (the new standard), which applies to the financial sector entities to the extent provided in paragraph 2 of the reporting standard.
Under section 15 of the Act, I DECLARE that the new standard shall begin to apply to those financial sector entities, and the old standard shall cease to apply, on the later of 1 October 2009 and the date of registration of this instrument on the Federal Register of Legislative Instruments.
Dated 17 July 2009
[Signed]
John Trowbridge
Member
Interpretation
In this Determination
APRA means the Australian Prudential Regulation Authority.
Federal Register of Legislative Instruments means the register established under section 20 of the Legislative Instruments Act 2003.
Schedule
Reporting Standard LRS 110.0 Capital Adequacy comprises 18 pages commencing on the following page.
Reporting Standard LRS 110.0
Capital Adequacy
Objective of this reporting standard
This reporting standard is made under section 13 of the Financial Sector (Collection of Data) Act 2001. It requires all registered life insurance companies to report to APRA, in general, on a quarterly and an annual basis in relation to capital adequacy.
This reporting standard outlines the overall requirements for the provision of relevant information to APRA. It should be read in conjunction with Form LRF 110.0 Capital Adequacy, and the associated instructions (both of which are attached and form part of this reporting standard).
Purpose
1. Information collected in Form LRF 110.0 Capital Adequacy (LRF 110.0) is used by APRA for the purpose of prudential supervision, including assessing compliance with prudential standards where appropriate. It may also be used by the Reserve Bank of Australia, the Australian Bureau of Statistics and the Australian Securities and Investments Commission.
Application and commencement
2. This reporting standard applies to all life insurance companies including friendly societies (together referred to as life companies) registered under the Life Insurance Act 1995 (Life Insurance Act) for reporting periods commencing on or after 1 October 2009.
Information required
3. A life company must provide APRA with the information required by Form LRF 110.0 for each reporting period.
Note: The instructions for Form LRF 110.0 explain in more detail the information that is required.
4. The information required to be provided to APRA under this reporting standard is not intended to form part of the financial statements or the annual returns, within the meaning of section 124 of the Life Insurance Act, given by the life company to APRA.
Method of submission
5. The information required by this reporting standard must be given to APRA either:
(a) in electronic form using the ‘Direct to APRA’ application, applying one of the electronic submission mechanisms under that application; or
(b) by completing Form LRF 110.0 on paper and mailing the completed form to APRA
Note: The ‘Direct to APRA’ application software and paper forms may be obtained from APRA.
Reporting periods and due dates
6. Subject to paragraph 7, a life company must provide the information required by this reporting standard:
(a) in unaudited form - in respect of each quarter based on the financial year
of the life company; and
(b) in audited form - in respect of each financial year of the life company.
Note 1: This means that this form will be submitted five times for a full financial year.
Note 2: The annual audited form must be submitted in conjunction with the annual auditor’s report, as required under Prudential Standard LPS 310 Audit and Actuarial Requirements.
7. APRA may, by notice in writing, change the reporting periods, or specified reporting periods, for a particular life company, to require it to provide the information required by this reporting standard more frequently, or less frequently, having regard to:
(a) the particular circumstances of the life company;
(b) the extent to which the information is required for the purposes of the prudential supervision of the life company; and
(c) the requirements of the Reserve Bank of Australia or the Australian Bureau of Statistics or the Australian Securities and Investments Commission.
8. The quarterly information required by this reporting standard in unaudited form must be provided to APRA within 20 business days after the end of the reporting period to which the information relates. The annual information required by this reporting standard in audited form must be provided to APRA within four months after the end of the reporting period to which the information relates.
9. APRA may grant a life company an extension of a due date in writing, in which case the new due date for the provision of the information will be the date on the notice of extension.
Quality control
10. The information provided by a life company under this reporting standard must be the product of processes and controls that have been reviewed and tested by the auditor of the life company.
11. All information provided by a life company under this reporting standard must be subject to processes and controls developed by the life company for the internal review and authorisation of that information. It is the responsibility of the board and senior management of the life company to ensure that an appropriate set of policies and procedures for the authorisation of data submitted to APRA is in place.
12. Actuarial valuations and calculations included in, or used in the preparation of, the information provided to APRA must be in accordance with the prudential standards in force for the reporting period. However, life companies may use reasonable estimates when preparing information that will not be audited (i.e. for the first four submissions of information for a full financial year). The instructions to Form LRF 110.0 include general principles on the use of estimates.
Authorisation
13. If the officer of a life company provides the information required by this reporting standard:
(a) using Direct to APRA (D2A), the officer must digitally authorise, submit the data to APRA and receive a D2A receipt number for the information to be considered given to APRA. APRA will issue ‘digital certificates’ to officers of the life company who have authority to transmit the data to APRA; or
(b) on paper, the relevant completed form must be signed on the front page by the principal executive officer or chief financial officer of the life company.
Note: Information in draft returns saved at APRA using D2A will not be considered to be provided to APRA for the purposes of the life company's obligations under this reporting standard.
Transitional
14. A life company must report in relation to a reporting period ending prior to 1 October 2009 in accordance with the reporting standard that this reporting standard replaces rather than under this reporting standard.
Interpretation
15. In this reporting standard:
business days means ordinary business days, exclusive of Saturdays, Sundays or public holidays;
principal executive officer means the principal executive officer of the life company for the time being, by whatever name called, and whether or not he or she is a member of the governing board of the entity;
reporting period means a reporting period under paragraph 6 or, if applicable, paragraph 7.
16. A reference to a prudential standard means the prudential standard made under section 230A of the Life Insurance Act mentioned in the reference, as amended from time to time. If the prudential standard has been revoked and replaced, the reference shall be taken to be to the prudential standard that has replaced it.
Reporting Form LRF 110.0
Capital Adequacy
Instruction Guide
Introduction
Form LRF 110.0 Capital Adequacy (LRF 110.0) provides APRA with the necessary information on the capital adequacy requirement of each statutory fund, the capital adequacy position, reserve, ratio & coverage, and component details, to undertake an assessment of the adequacy of a life insurance company’s capital position. It also assists APRA in its supervision of compliance with the requirements of the Life Insurance Act 1995.
This Instruction Guide is designed to assist reporting entities in the completion of LRF 110.0. The Instruction Guide provides:
· general directions and notes regarding preparation and lodgement; and
· instructions relating to specific items.
General directions and notes
Reporting levels
LRF 110.0 must be completed by all life insurance companies, including friendly societies.
The form is to be completed separately for each statutory fund (approved benefit fund).
LRF 110.0 contains four sections:
1. Capital Adequacy Requirement;
2. Capital Adequacy Assessment (Capital Adequacy Position/Reserve/Ratio/ Coverage);
3. Capital Adequacy Inadmissible Assets; and
4. Capital Adequacy Resilience Requirements.
Within each section, reporting items are to be completed at total fund level.
For the purposes of reporting under this form, contracts are to be classified in accordance with Prudential Standard LPS 350 Contract Classification for the Purpose of Regulatory Reporting to APRA (LPS 350).
Unit of measurement
LRF 110.0 is to be prepared in thousands of Australian dollars (AUD). Amounts denominated in foreign currency are to be converted to AUD in accordance with AASB 121 The Effects of Changes in Foreign Exchange Rates.
Definitions
Definitions for data reporting items required by this form have been provided where appropriate in the instructions under the section headed ‘Instructions for specific items’.
Definitions, unless specified, apply to all life insurance companies, including friendly societies as if each reference to a statutory fund, or shareholders’ fund, were a reference to an approved benefit fund, or management fund, respectively. Likewise, reference to shareholders should be taken to embrace ‘members’ of a mutual association and/or a society. The term ‘life companies’ or ‘life insurance companies’ includes friendly societies unless stated otherwise. This is in line with the usage of terms in the Life Insurance Act 1995.
Reporting period
Life companies are required to report the information in the reporting form on a quarterly and annual basis.
· The quarterly information is to be completed as at the end of each quarter based on the financial year of the life company, not the calendar year.
· The annual information is to be completed as at the end of the financial year of the life company.
· The financial information requested in this form is to be reported as at the close of business for the last day of the reporting period.
Basis of preparation
In completing this form, unless specifically stated otherwise, institutions are to follow the basis that is used for the preparation of the annual financial statements in accordance with the Australian accounting standards.
Asset values are to include interest or dividend income accrued but not received. All assets of a statutory fund are to be reported in this form at Fair Value, with movements in Fair Values recognised in Profit or Loss. NB this treatment differs from Australian accounting standards, which do not allow assets to be valued at Fair Value in all circumstances eg owner occupied property.
Actuarial valuations and calculations included in, or used in the preparation of, the form must be in accordance with prudential standards.
Whilst maintaining that the requirements of Prudential Standard LPS 3.04 Capital Adequacy Standard (LPS 3.04) apply on a continuous basis, APRA recognises that for some periods life insurance companies (including friendly societies) may not carry out full accounting, actuarial valuation, and audit procedures or do so in sufficient time to report on the return (for quarterly returns). Where this applies, some estimation could be applied reasonably at the current quarter to determine an approximation to the results that would be obtained if full detailed valuations had been carried out.
APRA expects that all life insurance companies (including friendly societies) will utilise their best endeavours to ensure that any estimations adopted are a good and reasonable basis of approximation, and are consistent with the requirements set out in LPS 3.04. The estimation process needs to be sufficiently rigorous in order to be acceptable and at a minimum should be of a standard that would be considered appropriate for use in reporting to management and the Board of directors. APRA generally expects that any approximation methodology used will be approved by the Appointed Actuary; this provides an assurance that he or she is satisfied that the methods should be reasonably acceptable and consistent with the requirements in LPS 3.04.
If additional clarification is required for specific items in this form, reference should be made to the section ‘Instructions for specific items’, which is provided as a guide.
Capital Adequacy Requirement to be calculated on a gross of reinsurance basis
APRA would like to remind reporting entities that LPS 3.04 applies on a gross of reinsurance basis. This includes CTV and Capital Adequacy Liability as elements of the Capital Adequacy Requirement. In effect, the gross policy liabilities ceded under reinsurance are no longer to be set off against the liabilities side (i.e. netting against gross policy liabilities assumed, either directly and/or as reinsurance inwards), but are to be added to the assets side.
For further background, refer to subsection 3.5 (‘Reinsurance’) in LPS 3.04; and in particular, paragraph 7.4 of LPS 3.04 (under Part B – Methodologies).
Instructions for specific items
This form is designed to report items defined by LPS 3.04. Therefore the following instructions are largely intended to deal with matters not already defined or discussed in LPS 3.04 or to highlight particular aspects of the reporting requirements.
While these instructions apply to all life insurance companies, including friendly societies, not all items may be applicable to both: some items may not be applicable to friendly societies while others may not be applicable to life insurers.
1. Capital Adequacy Requirement
This part of the form consists of Items 1.1 to 1.11 inclusive. This section of the form aligns directly with the methodology of LPS 3.04 as set out in Section 7 of that Prudential Standard.
1.1. Greater of Capital Adequacy Liability and Current Termination Value (CTV)
Each of Items 1.1.1 to 1.1.3 inclusive are to be reported under three columns, relating to the amounts for each item –
· Gross of outwards reinsurance (Column 1);
· Reinsurance ceded under outwards reinsurance (Column 2); and
· Net of outwards reinsurance (Column 3).
In paragraphs 7.2 and 7.3 of LPS 3.04, the actuary is relieved of calculating the total Capital Adequacy Liability (CAL) and the total CTV (respectively) for a related product group (RPG) under certain conditions. For aggregating and reporting purposes, the single amount calculated for an RPG should be included in both the CAL and the CTV, rather than not including any value for the inapplicable item.
Amounts under Columns 1 and 2 for Item 1.1.3 are reported amounts, not derived amounts, as effectively the maximum in each case is taken at the RPG level and then aggregated across the statutory fund. Therefore each of these amounts will not necessarily match the greater of the corresponding amounts entered under Items 1.1.1 and 1.1.2.
Note that amounts under Column 2 are expected to be entered with the opposite arithmetical sign to amounts under Column 1. Therefore Column 3 is derived for each item as the sum of Columns 1 and 2.
1.1.4. Amount of reinsurance/risk mitigation difference applicable to Item 1.1.3
While the above items (CAL, CTV and ‘Greater of’ amount) are to be included in the calculation of Capital Adequacy Requirement on a Gross of reinsurance basis, paragraph 7.4 of LPS 3.04 allows an item of difference to be included as an offset or addition to each of these items. Report the effective amount of difference that is applicable to Item 1.1.3.
1.2. Other Liabilities
Other Liabilities are required to be entered as the value of Other Liabilities in accordance with subsection 3.3 of LPS 3.04 under the relevant Capital Adequacy scenario. To the extent that the value of Other Liabilities would further vary under the Resilience scenario, such impact is to be reflected in the Resilience Reserve for the relevant scenario.
1.2.2. Eligible Amount of Approved Subordinated Debt
The eligible amount is the quantum of the approved subordinated debt (as determined in accordance with the approval letter received from APRA) that can be used in meeting the solvency/capital adequacy requirements of the statutory fund. Any amounts of approved subordinated debt should be entered as positive values.
Refer to the instruction guide to Forms LRF 300.1 Statement of Financial Position (SF and SF Eliminations) (LRF 300.1) and LRF 300.2 Statement of Financial Position (SF Total, SHF, SH Elim, Entity) (LRF 300.2), Item 20 ‘Approved Subordinated Debt’ for more information. This is Item 20.1 on those forms.
1.2.3. Seed Capital
This is Item 13.3 on LRF 300.1.
1.2.4. Other Liabilities (adjusted for Subordinated Debt and Seed Capital) [derived item]
This item is calculated automatically by the form, as the difference between Item 1.2.1 and the sum of Items 1.2.2 and 1.2.3.
1.3. Total Amount of Liabilities for Capital Adequacy purposes ( = L ) [derived item]
No value needs to be entered under this item as it is calculated automatically by the form, as the sum of Items 1.1.5 and 1.2.4.
1.4. Capital Adequacy Inadmissible Assets Reserve [derived item]
No value needs to be entered under this item as it is calculated automatically by the form.
1.5. Capital Adequacy Resilience Reserve
Details used in calculation of the Resilience Reserve are included under Section 4 of the form, Resilience Requirements. The results of those calculations are to be reported in Item 1.5 and should follow the requirements set out under LPS 3.04, Section 11.
1.5.1. Credit Risk component of Resilience Reserve
This item is expected to be calculated as:
RRCR = (L’ / A”) x (ΔACRY + ΔACRD)
Where:
RRCR = Credit Risk component of the Resilience Reserve;
L’ = Liabilities after prescribed change (per Section 4);
A” = Adjusted value of admissible assets (per Section 4);
ΔACRY = Credit Risk Yield Adjustment, per Column 2 of Section 4.1; and
ΔACRD = Credit Risk Default Adjustment, per Column 6 of Section 4.1.
1.5.2. Balance of Resilience Reserve
This item is expected to be calculated as:
RRB = RR - RRCR
Where:
RRB = Balance of the Resilience Reserve;
RR = Resilience Reserve = L’ x [A / A”] – L;
A = Assets prior to prescribed change (per Section 4);
L = Liabilities prior to prescribed change (per Section 4).
1.6. Sub-total of above items [derived item]
This item is calculated automatically by the form, as the sum of Items 1.3, 1.4 and 1.5.5.
1.7. Solvency Requirement for this fund
This should equal Item 1.11 on LRF 100.0 Solvency (LRF 100.0) for this fund.
1.9. New Business Reserve
In completing this item, life companies should refer to LPS 3.04 Section 12.
1.10. Other Significant Item - Capital Adequacy
This item is for any reserves established by the Actuary in relation to additional risks or costs that are not otherwise reflected in the prescribed requirements of LPS 3.04. Include any transitional adjustment required to the Capital Adequacy Requirement.
2. Capital Adequacy Assessment (Capital Adequacy Position/Reserve/ Ratio/Coverage)
2.1. Capital Adequacy Position
This part of the form requires the input of Total Assets from LRF 300.1 and uses it to derive the excess (or shortfall, if applicable) of Total Assets over the Total Capital Adequacy Requirement for the fund.
2.1.1. Life Insurance Act Total Assets
This is Item 12 on LRF 300.1, and should agree with Item 2.1.1 of LRF 100.0.
Item 2.1.2 [a derived item] is then calculated automatically by the form, as the difference between Item 2.1.1 and Item 1.11.
2.2. Capital Adequacy Reserve
Capital Adequacy Reserve (at Item 2.2.5, which is a derived item) represents the excess of Total Capital Adequacy Requirement over the total minimum liabilities for the fund. Note that while other sections of this form are on a gross of reinsurance basis, the Capital Adequacy Reserve and related metrics are effectively net of reinsurance. Note also that the reference point for minimum liabilities is the same in this form as for Solvency in Item 2.2 of LRF 100.0. This achieves comparability between reserves under the two forms.
2.2.2. Less: Total Gross Policy Liabilities Ceded under Reinsurance
This is to be entered as a subtracted item, where the amount to be subtracted is the sum of Items 11.2 and 11.5 on LRF 300.1. The amount entered should agree with Item 2.2.2 of LRF 100.0.
2.2.3. Less: Net Minimum Termination Value (MTV) excluding IL risk margin
This is to be entered as a subtracted item, where the amount to be subtracted is the difference between Item 1.1.2 [Net Amount, per Column 3] on LRF 100.0 and Item 1.1.6 on that form. The amount entered should agree with Item 2.2.3 of LRF 100.0 (which is a derived item on that form).
2.2.4. Less: Other Liabilities adjusted for Subordinated Debt and Seed Capital
This is to be entered as a subtracted item, where the amount to be subtracted is one that corresponds with Item 1.2.4 above, except that for Item 2.2.4 it is to be calculated on the basis used for preparation of LRF 300.1. Therefore this amount may differ from the result at Item 1.2.4.
2.3. Capital Adequacy Reserve Ratio (%) [derived item]
This is calculated automatically by the form, as:
Capital Adequacy Reserve (Item 2.2.5)
divided by
[ The sum of Total Capital Adequacy Requirement (Item 1.11) and
Less: Total Gross Policy Liabilities Ceded under Reinsurance (Item 2.2.2),
minus
Capital Adequacy Reserve (Item 2.2.5) ]
{This denominator equates to Net MTV (LRF 100.0 Item 1.1.2) + Other liabilities (Item 2.2.4).}
2.4. Amounts Available for Capital Adequacy Reserve
This is the amount that will be compared with the Capital Adequacy Reserve at Item 2.2.5 to establish ‘Capital Adequacy Coverage’. The following components reconcile with items in LRF 300.1 and are summed to obtain Item 2.4.6 (as a derived item):
2.4.1. Life Insurance Act Net Assets
This is Item 28 (or, equally, Item 23) on LRF 300.1. Note that it includes the amount of Unallocated Benefit Fund reserves (Item 25.1 on LRF 300.1). The amount entered should agree with Item 2.4.1 of LRF 100.0.
2.4.2. Policy Owner Retained Profits at end of period
This is Item 18 on LRF 300.1, and should agree with Item 2.4.2 of LRF 100.0.
2.4.3. Eligible Amount of Approved Subordinated Debt [derived item]
This is Item 1.2.2 and should agree with Item 2.4.3 of LRF 100.0.
2.4.4. Seed Capital [derived item]
This is Item 1.2.3 and should agree with Item 2.4.4 of LRF 100.0.
2.4.5. Surplus or Deficit (if any) of Net Policy Liability relative to Net MTV
This item is to be calculated Net of outwards reinsurance (for both parts of the calculation: Policy Liability, and MTV). The amount entered should agree with Item 2.4.5 of LRF 100.0.
2.5. Capital Adequacy Coverage [derived item]
This is calculated automatically by the form, as:
Total Amounts Available for Capital Adequacy Reserve (Item 2.4.6)
divided by
Capital Adequacy Reserve (Item 2.2.5)
3. Inadmissible Assets
In completing this section, life companies should refer to LPS 3.04 Section 10.
Amounts entered in the Value column are the full value of any asset which is wholly or partly inadmissible, and should be consistent with what is reported in LRF 300.1. A Value entry is not required for Item 3.6.
Amounts entered in the Inadmissible Amounts column represent the inadmissible portion of the assets reported in the Value column. These amounts add up to the Inadmissible Assets Reserve.
4. Resilience Requirements
In completing this section, life companies should refer to LPS 3.04 Section 11.
While the first ‘Adjustment’ column relates solely to the Yield change element of Credit Risk, the second ‘Adjustment’ column reflects the prescribed yield change and the application of the Diversification benefit. The insertion of one further column assists in making the logical flow of this part of the form align more closely with the methodology in LPS 3.04.
4.1. Assets with Resilience Requirement
4.1.12. Assets with non-standard resilience factors
This asset class should only be used in rare cases. It is intended to cover situations where assets are disaggregated into (1) an identifiable sub-asset and (2) a residual that does not fit into any of the asset sectors specified by LPS 3.04 for resilience purposes, or where a non-standard resilience risk has been modelled in accordance with paragraph 11.11 of LPS 3.04.
4.2. Assets with no Resilience Requirement
This is for assets that are admissible but do not have resilience requirements, as specified in LPS 3.04 section 11.3.
Where the policy owner liabilities of the statutory fund move in harmony with the assets supporting them, the Resilience Reserve in respect of those liabilities can be zero. A Resilience Reserve may be required, however, in respect of the Other Liabilities of the fund. For statutory funds where this applies, the assets supporting policy liabilities should be entered at Item 4.2 Assets with no resilience requirement, while the assets other than those supporting policy liabilities should be entered in Section 4.1, across Items 4.1.1 to 4.1.13 as appropriate.
4.3. Total Admissible Assets
The sum of Total Admissible Assets and Total Inadmissible Amounts (from Item 3.7) should be equal to Total Assets in LRF 300.1.
4.4. Liabilities for Resilience
4.4.1. Capital Adequacy liabilities, excluding other liabilities
While the amount at Item 4.4.1 Capital Adequacy liabilities, excluding other liabilities for the amount ‘Prior to Prescribed Change’ (L) is derived within the form, this amount may not be the amount that has been used for resilience purposes, e.g.in the situation of an investment linked fund, where policy owner liabilities move in harmony with the assets supporting them. The amount to be entered at this item for the amount ‘After Prescribed Change’ (L’) may be equal to (or very similar to) L. For an investment linked fund, the difference that is implied in the amount reported at this item may be limited to the impact of the prescribed change on the risk margin for investment linked policies, as described in Paragraph 4.5.2 of LPS 3.04.
4.4.2. Effective borrowings
These are to be calculated on a look through basis.
4.4.4. Other liabilities, apart from borrowings and tax liabilities
Only exclude the items specified in the title. Therefore this item includes approved subordinated debt.
