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报告摘要

FSI Briefs No 4: Insurance Regulatory Measures in Response to Covid-19

Core Content

This FSI Brief provides an overview of insurance regulatory measures implemented in response to the financial and operational challenges posed by the Covid-19 pandemic. The focus is on preserving insurer solvency, mitigating procyclical investment behavior, providing operational relief, and maintaining the continuity of insurance services.

Main Objectives

Insurance authorities have taken measures to achieve the following four objectives:

Preserve capital adequacy of insurers
Mitigate excessive procyclical investment behavior
Provide temporary relief from non-essential regulatory and supervisory requirements
Preserve the continuity of insurance coverage

Key Regulatory Measures

1. Capital Conservation Measures

Dividend and remuneration policies are being adjusted to conserve capital:
- Delaying, reducing, or cancelling dividend distributions and share buybacks in multiple jurisdictions (Australia, Croatia, Czech Republic, EIOPA, Finland, France, etc.)
- Reviewing variable remuneration policies and postponing disbursements
Regulatory guidance encourages a forward-looking approach to capital conservation, based on stress-testing results and prudent risk management.
Capital requirement adjustments include:
- Lowering requirements for certain risks (e.g., credit, suretyship)
- Relaxing interest rate risk capital requirements
- Favorable treatment of transitional measures on technical provisions under Solvency II

2. Countercyclical Capital Measures

Volatility Adjustment (VA) under Solvency II is used to dampen procyclical behavior:
- Currency VA is 65% of the risk-corrected currency spread
- Country VA is triggered when the risk-corrected country spread exceeds thresholds (100 bps initially, later reduced to 85 bps in Italy)
- This measure helps improve solvency ratios and reduce the impact of market volatility
Other countercyclical tools include:
- Symmetric adjustment mechanism for equity risk
- Matching adjustment to increase discount rates
- Temporary relaxation of investment limits and accounting rules in Peru

3. Regulatory and Supervisory Relief Measures

Extended reporting deadlines and flexible submission of unaudited financial reports have been introduced
Postponement of public consultations on new regulations
Relaxed penalty payment deadlines and exemption from sanctions for minor misconduct
Reduced licensing fees in some jurisdictions (e.g., Dubai, Thailand)
Operational adjustments include:
- Postponement of on-site inspections
- Relaxation of board meeting frequency and allowing virtual meetings
- Extension of licensing deadlines and acceptance of incomplete applications
- Relaxation of continuing professional development and examination requirements
Electronic filings and signatures are now accepted in several jurisdictions

4. Measures to Preserve the Provision of Insurance Services

Product design and coverage have been adjusted:
- Review of products impacted by the pandemic
- Relaxation of pricing requirements
- Extension of coverage periods for certain insurance types (e.g., travel, marine, aviation)
- Expansion of coverage for pandemic-related risks (e.g., business interruption, health, medical)
Policy servicing has seen:
- Deferral of premium payments without policy lapse
- Avoidance of policy cancellation or denial of claims due to movement restrictions
- Clarification of policy exclusions related to pandemic events
- Extension of complaint response periods
Claims processing has been streamlined:
- Simplification or exemption of paper-based claims submission
- Expedited processing of valid claims
- Extension of claims notification periods

Key Considerations

Solvency concerns are primarily driven by financial market volatility rather than increased insurance claims
Procyclical investment behavior is a major risk, and countercyclical measures are essential to mitigate it
Operational resilience is crucial for insurers to continue serving policyholders during the crisis
Balanced approach is needed between ensuring solvency and maintaining fair treatment of customers
Exit strategies will be necessary post-pandemic to unwind extraordinary measures without compromising risk management or customer trust

Conclusion

Insurance regulators have implemented a range of measures to address the challenges posed by the pandemic. These include capital conservation, countercyclical adjustments, operational relief, and support for continued service delivery. While these measures are essential for maintaining stability, they must be carefully unwound in the post-pandemic phase to ensure long-term solvency and market integrity. The importance of a well-designed solvency framework that withstands extreme events cannot be overstated.