How (and why) to read a NAIC U.S. Statement of Actuarial Opinion (Property/Casualty)
Loss Reserves are generally the largest liability listed on an insurance company’s balance sheet. Loss Reserves are the amounts set aside to pay for claims that have already occurred for which the company is obligated to pay, whether they have been reported to the company or not.
In the past, a high percentage of property/casualty insurance company insolvencies have been due to the inadequacy of these reserves. In order to verify the reasonableness of these reserves, each state now requires that there be an attestation, formally called the “Statement of Actuarial Opinion,” (SAO) and frequently referred to as an “opinion,” by a qualified professional actuary.
Is it a clean opinion?
One of the first questions asked of the opining actuary is whether or not the opinion is “unqualified” or “clean.” A clean opinion states that the loss reserves:
- Meet the requirements of the domiciliary state,
- Are consistent with reserves computed with accepted loss reserving standards and principles, and,
- Makes a reasonable provision in the aggregate for all unpaid loss and loss adjustment expense obligations of the Company under the terms of its contracts and agreements.
The first two items are rarely an issue; it is the third point that usually prompts the question. In a sense, a “clean” opinion is saying that in the actuary’s opinion, the booked loss and loss expense reserves are reasonably sufficient.
The alternatives to a “clean” opinion are generally not good, and are outlined below:
A qualified opinion happens when the reserves for a certain item or items are in question; either they cannot be reasonably estimated, or the actuary is unable to render an opinion on those specific items. Note: if there is a loss for which the actuary has no means of determining the ultimate value, but the perceived value is not material, the opinion can still be “clean.”
A Deficient or Inadequate Provision. This is the one you do not want to see. When the carried reserve amount is less than the minimum amount believed to be reasonable, the actuary will issue a Statement of Actuarial Opinion specifying that the carried reserve amount does not make a reasonable provision for the liabilities associated with the specified reserves.
A Redundant or Excessive Provision is very rare and occurs when the carried reserve amount is greater than the maximum amount believed by the actuary to be reasonable. In this situation, the actuary issues a redundant opinion.
A No Opinion is another rare rendering. The actuary’s ability to give an opinion is dependent upon data, analyses, assumptions, and related information deemed sufficient to support a conclusion. If the actuary cannot reach a conclusion due to deficiencies or limitations with this information, he/she may issue a statement of “no opinion” which should include a statement as to why no opinion could be given.
Several other sections of the SAO are also of importance:
The “Relevant Comments” section starts with “Risk of Material Adverse Deviation” and answers three important questions:
- Is there a risk of a material deviation (i.e. change) from the loss and loss expense reserves booked?
- How large does a possible deviation need to be to be considered “material?”
- What is the source of such a deviation(s)?
An indication that there are one or more items that are a potential source of risk of material deviation may or may not be a cause for concern. The absence of a risk of material adverse deviation does not imply that additional factors will not be identified in the future as having a significant influence on the company’s reserves; it is a statement concerning a point in time.
While the interest in Asbestos Exposures and Environmental Exposures has waned in recent years, these can still represent a significant exposure to the company. These are addressed in the section bearing that as a title.
Most companies do not write policies with durations over thirteen months, but the section titled Disclosure of Unearned Premium Reserves for Long Duration Contracts will provide information to that effect.
The Reinsurance Collectability section provides information pertaining to the likelihood of the company’s ability to collect on its reinsurance. While the actuary’s comments do not imply an opinion as to the financial stability of any of the reinsurers, it should include information from management regarding any collectability problems the company has encountered with its reinsurers. Publicly available information, as well as the reinsurers’ ratings provided by a rating agency, are used by the actuary to reach his/her conclusion.
The National Association of Insurance Commissioners (NAIC) has a series of mathematical formulae, or “NAIC IRIS Tests,” that are applied to various Annual Statement entries. Of the thirteen formulae, the last three, Tests 11, 12 and 13, concern the booked loss and loss expense reserves. The actuary is required to look at these tests and comment on any that fall outside the range of acceptance: i.e. they “fail” the test.
If the company fails any of these tests, the actuary will provide a narrative as the level of importance of this failure. More detailed information is available at
https://www.naic.org/prod_serv/UIR-ZB-17_UIR_2017.pdf
The final pages of the “opinion” include the signature page and any supporting exhibits providing selected values.
In summary, the SAO should answer the following:
- Is the opinion qualified or unqualified (i.e. “Clean”)
- How financially large does a deviation need to be in order to be a material risk to the finances of the company, and are there any such risks?
- Did the company fail any IRIS Tests? And if so, why?
If you have any further questions on this topic, please feel free to contact your Huggins Actuarial Services consulting actuary.
Authored by:
Grover M. Edie, MBA, FCAS, MAAA, CPCU, ARP, CERA, ARM
Consulting Actuary
Huggins Actuarial Services, Inc.
