A new methodology for calculating policy reserves for life insurance policies has taken effect. The new methodology grew out of the 2009 National Association of Insurance Commissioners (NAIC) revisions to the Model Standard Valuation Law. Dubbed Principle-Based Reserving (PBR), the law was to take effect on the first day of the next calendar year if 42 states enacted the revisions by July 1st. The threshold was passed in 2016 and as of today, 46 states have adopted the revised laws.
Insurance companies are required to set aside reserves to pay future claims, and the reserve requirements are specified by state regulation and laws. The current method of reserving will remain unchanged for in force business, as PBR only affects policies issued on or after January 1, 2017. However, life insurers will have three years to implement the new methodology. Currently, the requirements will be altered for life insurance policies only, but over time they are expected to apply to other products as well.
According to information provided by the NAIC (1), the new approach will lessen the need for changes to regulations and laws as new products are introduced. Under the new methodology, states would “establish principles upon which reserves are to be based rather than specific formulas.” Under the current formula, the risks, liabilities and obligations are not always correctly “reflected,” and “for some products this leads to excessive conservatism in reserve calculations, for others it results in inadequate reserves.” A study by the NAIC disclosed the new method will lower reserves for competitive level premium term insurance. Universal life policies with secondary guarantees will see both “higher and lower reserve requirements,” which was not unexpected, “given the variations in company interpretations of the reserve requirements for this product type that were in effect when this study was done.” Per the study, reserves for most other products, including current assumption universal life and whole life, will remain relatively unchanged.
Reserve requirements are only one of the many factors affecting the pricing of life insurance. Others factors include mortality expenses and investment returns, along with overhead expenses, other than reserving.
While it remains to be seen exactly how pricing will be affected, the NAIC believes the “right sizing” of reserves will benefit consumers since holding higher reserves tends to increase costs, and holding reserves that are too low puts the consumer at risk. The new regulations will also allow for the introduction of new products that could offer multi-benefits and more flexibility for consumers.
For those of us managing in force life insurance, the new methodology will change little, though new and replacement products going forward may be more or less attractive because of pricing changes.
1.) PBR Educational Brief, June 21,2013, The National Association of Insurance Commissioners, and The Center for Insurance Policy and Research