With the January 1 deadline for IFRS 17 implementation rapidly approaching, there may be some last-minute items that actuaries in the P&C practice area need to consider. In the first episode of a two-part series, FCIAs Sati MacLean and Houston Cheng discuss the Transition Readiness Test and the role of the Appointed Actuary in the move to IFRS 17.
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Fievoli: Welcome to Seeing Beyond Risk, a podcast series from the Canadian Institute of actuaries. I’m Chris Fievoli, Staff Actuary, Communications and Public Affairs, at the CIA.
The adoption date for IFRS 17 is now only a couple of months away. If you’re a P&C actuary that still has outstanding implementation issues, should you be panicking? The answer: absolutely yes.
But don’t worry! We have you covered. This is the first of two episodes where we’ll be providing some last-minute discussion points as we move towards January 1, so joining us to walk through these issues are CIA members Sati MacLean and Houston Cheng.
Thank you both for coming on the podcast today.
Cheng: Thanks, Chris – glad to be here.
MacLean: Thank you, Chris.
Fievoli: So, before we get into some of the more specific details, I’d just like to get some of your reflections on IFRS 17 through this process.
How were you involved in this? What were some of the things you liked, the things you didn’t like, and how are you managing into the final weeks before implementation? What are some of the key learnings you would like to share?
MacLean: Because it feels like IFRS 17 has been quite a consistent part of my career, from IFRS 4 Phase 2 to what it is now. In terms of my involvement in IFRS 17, I’ve been leading the actual work stream in IFRS 17 at Munich Re on the P&C side for local implementation, and I’m also the Co-Chair of the CIA’s IFRS 17 Steering Committee.
In terms of what I like about IFRS 17, well, my kids would tell you that I love IFRS 17. [Chuckle] I spent too much time over the pandemic mixing virtual schooling with IFRS 17 conference calls with Germany. But one of the things I’ve really enjoyed about it, and am enjoying about it, is the intellectual challenge. There’s a lot of new stuff that’s being thrown at us where we have to really, as actuaries, work through understanding how to implement the standard and then what the implications are.
But it has been quite challenging in some ways. One thing I would comment on is that common sense doesn’t necessarily seem to have prevailed. It still does mystify me that we managed to get so far in terms of implementing a massive accounting standard change, yet the business benefits are still slightly unclear. And we should expect that there will be some confusion as we wrap our arms around the results when we start to see them. But the decision was made and there’s no going back, kind of like Brexit. Hopefully we will end up in a place where there is more clarity and consistency in terms of accounting standards applied to insurance and accounting. But overall, it’s been an interesting journey. I feel like we’re probably at mile 20, even, of a marathon and we’ve got that last push to go before we implement, so we just need to get on with it, really.
Houston? What about you?
Cheng: [Chuckle] You hit on so much stuff in there, Sati.
For me, I’ve really started getting involved back when the standard was near final and finalized from various perspectives. In the early days as Chair of the PCFRC, drafting guidance or at least leading and helping draft some of the guidance that many of the many of the actors in Canada are using and quite frankly around the world are using.
And moving on to working with companies that I currently work with, both from my capacity as Appointed Actuary as well as from the audit or from the implementation side of things. So, seeing a relatively wide gamut of the journey into IFRS 17.
I like how Sati brought up something that you liked pretty easily, and you reference a big part of 17, where it was done during the COVID pandemic. I think, for me, if there’s anything I liked about it, it was the newness of it, right? So, a lot of modeling, dealing with new challenges, working with new people, working very closely with the accountants, with finance, with IT, and building something from scratch in many instances.
This reference was used a lot, where you’re building an airplane while it’s in the air kind of thing. So that was quite neat in terms of being able to participate in that. But in terms of hate – a strong word – I don’t know if I hate anything within 17, but there’s a lot of dislikes where there are things, like you say, Sati, where it seems reasonable from an actuarial perspective, but when you talk to accountants, we’re not thinking the same way, right?
And at the end of the day, it’s an accounting standard and there’s only so much that, as an actuary, you might be able to push on certain issues. So that’s also part of the learning – learning where you need to compromise and where you need to stand firm.
In terms of managing the final weeks, I think that “running the marathon” reference certainly has come up quite a bit. But for me, I just feel like the finish line might be 1/1/2023, but there’s still a long victory lap or some sort of cool-down lap or a frantic run to the year end of December 31, 2023, to come. So that’s kind of where I think my feeling is if we wanted a reference.
Fievoli: Great. Let’s talk a little bit about the OSFI Transition Readiness Test, and as the name suggests, the goal of this exercise was to test the readiness of companies as they transitioned to IFRS 17. Do you think this goal was achieved?
Cheng: I think, overall, the goal was achieved. You know, there was a lot of grumbling from the industry when this came up back in March and April, and it was another thing that companies must do and that teams have to deal with. But if we measure the fact that the goal of the TRT was to test the industry’s actual readiness, whether they’re ready or not, I think it achieved the goal with that.
This got the industry moving forward in the reporting process and understanding that perfection may not be achieved from the company’s perspective in their filing with OSFI on September 30. But it moved the dial forward, and it gave everyone a common goal that they really had to put everything to the test. So, in terms of just testing the readiness, yes, I think it was achieved.
Sati, is that the sense that you get from your perspective?
MacLean: Yeah, I’d agree with that, Houston.
I think it was almost a necessary evil that we had to go through this, and IFRS 17 has been such a long-running project that having these deadlines in between, and in terms of ensuring that we’re meeting deliveries, is essential. And that’s sort of how we viewed it, that this is now the next stage. We had done the QIS where we were testing impact analyses, and now this was really a dry run.
Can we produce the returns, and have we got the system set up to enable that? The timing of reporting under IFRS 17 is going to be extremely tight, and a lot of companies must be able to streamline how they produce the returns and ensure that they are a quality product.
So it was something that was worthwhile. And I think it has laid the roadmap for some work that needs to be undertaken to be able to actually produce the returns when we’re in a live environment.
Fievoli: So were there any specific positive results that came out of this exercise, and were there some challenges that you identified along the way?
MacLean: The positives I’d say were, as I said, having a roadmap to what that 31st of March return is going to look like and having a plan for addressing the critical areas that need to be addressed.
One thing with IFRS 17 is that the devil really is in the details. When you then look at the regulatory requirements and the interpretation that the regulator has, there are some areas where OSFI’s interpretation of requirements for the regulatory return can be different to IFRS 17.
So this really allowed companies, the accountants and the actuaries to look at what’s going on and what OSFI is requiring and requesting and making sure that they could then take the IFRS 17 balance sheet and adapt it for OSFI reporting.
Cheng: And then I think from my perspective on that question, Chris, in terms of positive results, I certainly agree with the many things that Sati has mentioned already, but I think the positive, again, is that companies were forced to expand even if the resources and systems may not be 100% ready.
They were forced to accelerate their process to achieve the completion of the regulatory filings in whatever state that they submitted it or they were able to generate for September 30. So even if the pictures or numbers weren’t all rosy, at least this served as a real dry run with an external deadline and a wake-up call on key individuals and systems that that need to be added, shored up or worked on to hit that Q1 reporting.
And like Sati said, with the roadmap, if things can’t be completed for Q1, there are still a few quarters next year to smooth things out or have ideas on how to improve the process where the improvements can be had.
MacLean: And I’ll say, one other area that I think this will pay dividends is increasing the number of people who’ve been involved.
Certainly, when we were looking at the quantitative impact studies, there’s a lot of actuarial involvement, and I don’t know if it’s fair to say if this is true for all companies, but I think the actuaries carried the burden, whereas now we’re really transitioning into, how do we take those numbers and how do we report them to our regulator and elsewhere?
And this is really involving the accountants and others in the organization, which is actually a really positive thing for IFRS 17 because come next year, we’re all going to have to be reading financials with an IFRS 17 lens.
And a challenge that’s going to come with that is that if you haven’t been involved in the journey, it’s not necessarily the easiest thing to pick up and understand. So I think that that sort of educational piece is also a benefit of having gone through the through the TRT.
Fievoli: Let’s talk a bit about the role of the Appointed Actuary in this whole process. As we get into the final few weeks of this year, what are some of the key activities that Appointed Actuaries are performing, or should be performing at this point?
Cheng: I think there are many things that depend on where the companies are at, obviously, but I think there are many things, as the Appointed Actuary, that we still need to do, and certain activities that will likely take place post actual transition at 1/1/2023.
I think Sati had mentioned that a lot of actuaries and Appointed Actuaries would have been involved in the actual TRT process and generating a lot of the numbers on the face of the financials and helping others within the company understand the numbers.
But then moving forward is continuing working with implementation if it’s not completed or testing of the systems if they’re not completed. So validating some of the generated results either from systems or from internal software, so looking at the outputs from both the balance sheet and income statement and then maybe some of the more detailed schedules in the footnotes or in the notes to the financials.
And then in terms of the regulatory returns, there likely will be areas that were identified in the TRT process that can be approved on and additional schedules that actuaries may be asked or required to produce from that perspective. Other companies might be fine-tuning the assumptions, so fine-tuning discounting investments and kind of preparing them for reporting under the AA within the IFRS 17 framework.
So we can probably separate work for the AA in the form of work that needs to be done in the last few weeks of 2022, and there’s likely a fairly long list for next year as well.
MacLean: Yes, that list for next year does seem to be growing, Houston. That’s for sure.
I think the actuaries have got a key role to play in terms of the audit prep of whatever balances the auditors are going to be looking at for IFRS 17. And suddenly, some of the key policy decisions that were made earlier on, there may be some testing that needs to be supported to supplement that to demonstrate that whatever approach is being taken is reasonable.
You know, and Houston, as you said, the fine-tuning is going to be important. Does anything need to change? IFRS 17 implementation is certainly not going to be perfect, and the question is, what needs to be fine-tuned before implementation?
And I think the actuaries are going to have a role to play there, not just in terms of the risk adjustment and the discounting, but also as the role of the Appointed Actuary will be evolving, are there other areas of the financial statement that the actuaries are going to need to be able to opine on, or have a view on, that they need to get comfortable with or challenge before the transition and the comparatives are finalized?
And I think the actuaries will also have a role to play in terms of educating not just others in the organization, but your board, and do they know what to expect? Is this going to be a really big surprise? How will the results be interpreted externally when comparatives or reporting are finally publicly available across the industry and across the globe – apart from the US, obviously? So the actuaries are going to have a key role to play, because they’ve been there from the beginning interpreting the standard and implementing it.
And lastly, I think I’d add, in terms of the last few weeks, the CIA has finalized its educational notes, and just like anything, IFRS 17 has a lot of material to get through. So certainly, one of the things that we’re looking at is, based on the finalized notes, are there any areas where we continue to fine-tune so that we are consistent and compliant with Canadian actuarial practice?
Fievoli: Let’s continue on about the comparatives, because obviously, your end results for 2022 will be prepared on both IFRS 4 and IFRS 17. What are some of the issues you’re seeing in preparing that documentation on both bases? And I’m also curious what impacts you’re seeing potentially on the Appointed Actuary’s opinion.
Cheng: I think this is something that, on my end, we work with various companies in different capacities, so as an actuary as well as from the audit perspective. And if I just leave the implementations alone just because implementations typically have a good set of people involved already – from the audit and the Appointed Actuary’s perspective, there’s quite a bit of work that had to be done or still needs to be done for the comparatives from 2022.
We have the opening balance of 1/1/2022 that will be under IFRS 17, and we certainly have the opening balance for 1/1/2023 under IFRS 17. The thinking may have changed in between the preparation of the opening balance of 2022 versus 2023, so how do you deal with that? So that’s one of the areas that I think companies may need to consider.
Other areas could be that there’s actual work that would need to be performed from the actuarial perspective to get those IFRS 17 balances.While it’s not necessarily that the Appoint Actuary is signing off on opining on the validity of these particular year-ends and those numbers that are making their way into the balance sheet, they have to be quite reasonable. Otherwise, we really aren’t comparable from the actual December 31, 2023, numbers.
So we’re spending a lot of time from that perspective, as AAs, and then moving forward from the audit perspective, how do you audit this? And we’re working closely with the auditors here within our firm just to get a sense of what we are really opining on as auditors, and the timeframe of sign-off and things like that. So those are things to consider for both of those balances.
And then in terms of our role, it’s shifting under IFRS 17. I think it in some respects you could interpret it as that our role is broader in terms of what we’re signing off on the opinion, where in the past, the numbers that appeared on the opinion are more strictly the claim and premium liabilities.
Whereas now, it’s anything that is on the balance sheet or income statement. It’s really the final statements that we should be opining on. My interpretation is we wouldn’t encompass anything on the balance sheet, so what we were used to opining on in terms of the LIC and portions of the LRC.
But then we have findings expense within the Engram statement as well as the notes to the financials, so that’s certainly some things that will still need to be ironed out as to what it really means, and that, to me, is part of that list of things that we must do for next year.
MacLean: And I’ll just add that as we are all preparing to report under both IFRS 4 and IFRS 17, a very practical challenge in terms of documenting results and approaches is the sheer amount of detail that we must deal with.
And obviously, I think everyone’s facing restricted resources or availability of resources to do that. And certainly, as we’re documenting our approaches and our assumptions, we’re also trying to do this in a sustainable way so that we’re building processes to support the provision of assumptions and the review of results.
And some of this sort of takes us forward in terms of what we’re going to have to be reporting in our Appointed Actuaries Report. So, a lot of the documentation that we’re pulling together, we’re looking at what that final AAR looks like. And as you said, Houston, in some ways, there is a question mark as to if the opinion of the AA is going to change, but in some ways, it’s going to be a lot broader than what it is now. And that Appointed Actuaries Report is going to have to change quite significantly. And while we’re not necessarily writing it now, we’re getting the pieces together so that we’re prepared to be able to support our assumptions and our results and do so in in the Appointed Actuaries Report.
Fievoli: A very quick question to wrap up: What are some of the other issues that you think we need to talk about on this?
Cheng: We certainly talked a lot about some of the things that will be on the AA’s list for next year from the reporting perspective, but there’s much more to do in other areas. If we just stay within the realm of the AA, the FCT (Financial Condition Testing), that’s actually a pretty big question mark in terms of readiness – how much companies have been preparing for this, either the use of internal or external models for this. It’s something that will need to take place very soon, if not already. So that that’s one of them.
And the other one for me, I think, is the KPIs and the planning process. I’m certainly seeing a lot of companies have question marks as to, does IFRS 17 change the planning process? And that might look different for different companies. How granular do you go? So I think that’s something that we might need to explore in a subsequent discussion.
MacLean: Yeah, I totally agree, Houston. Planning and FCT are definitely high on the agenda. Obviously, we need to get through the December 31 under both IFRS 4 and IFRS 17. But as you said at the beginning of the podcast, there will need to be a victory lap once we reach that finish line – that’s not it.
And whilst our victory lap may be more of a limp, we do need to lift our sights beyond December 31, 2022, and be prepared for the reporting that’s going to come, the interpretation of the results and the implications for FCT, and then, as I mentioned as well, we’ll have to get that AAR done as well. So, I think 2023 has the potential to be busier than 2022.
Fievoli: OK, great. Well, let’s tackle these topics in the next episode that we will do together. But in the meantime, thank you both very much for joining us today.
MacLean: Thank you.
Cheng: Thank you, Chris.
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This transcript has been edited for clarity.