Plaxy Dissertation Final
Plaxy Dissertation Final
Plaxy Dissertation Final
BY
PLACXEDES MUKONZO
R125253N
MAY 2016
1
FACULTY OF COMMERCE
RELEASE FORM
Permission is hereby granted to the Midlands State University library to produce single copies of
this dissertation and to lend or to sell such copies for private, scholarly, or scientific research
only. The author reserves other publication rights; neither the dissertation nor extensive extracts
from it may be printed or otherwise reproduced without the author’s written permission.
SIGNED:……………………… DATE:……………………………
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FACULTY OF COMMERCE
APPROVAL FORM
This serves to confirm that the undersigned has read and recommended to the Midlands State
University for acceptance of a dissertation entitled,
SUPERVISOR:………………………… DATE:……………..…………………………
(Signature)
CHAIRPERSON:…………………… DATE:…………………………………………
(Signature)
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ACKNOWLEDGEMENTS
I would like to thank the Almighty God for guiding me through my academic progression up to this stage.
I extend my appreciation to Mr F. Makaza for the supervision and advice provided during the study. My
profound gratitude goes to the Zimbabwean short term industry for providing me with information I
required. Lastly I wish to express my sincere gratitude to my friends Munyaradzi Karumbidza and
Paidamoyo Saungweme for their encouragements and help.
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DEDICATIONS
“I dedicate this project to my mother Mrs. W. Mukonzo and my brothers Simbarashe Mukonzo
and Batanayi Mukonzo for their love, inspiration and support.
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ABSTRACT
The study sought to explore the adoption of a risk based approach to solvency management in
the Zimbabwean short term insurance industry. The review of literature was carried out in order
to establish what other authors had to say on the subject. To come up with a sample of 17 short
term insurers and reinsurers out of a target population of 33 operational insurance and
reinsurance companies, the researcher used stratified sampling technique since the study
population comprised of different characteristics. The researcher used questionnaires and
structured interviews to collect information. Tables, bar graphs and pie charts were used to
present responses from the survey. The results indicated that the insurers and reinsurers are
facing challenges in meeting the minimum capital requirement and appreciates the benefits of
adopting solvency II. However, the challenges and costs associated with the adoption of
solvency II makes its adoption in the Zimbabwean short term industry difficult. The study
recommends the modification of the current solvency management system so as to encourage
insurers and reinsurers to hold risk based capital and the protect policyholders through reporting
rules and the establishment of a policyholder protection fund. It also recommends short term
insurers and reinsurers to use effective capital management and risk management systems.
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TABLE OF CONTENTS
RELEASE FORM ....................................................................................................................... i
ACKNOWLEDGEMENTS....................................................................................................... iii
DEDICATIONS ........................................................................................................................ iv
ABSTRACT ...............................................................................................................................v
CHAPTER 1 ..............................................................................................................................1
INTRODUCTION .....................................................................................................................1
CHAPTER 2 ..............................................................................................................................5
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2.0 Introduction ...........................................................................................................................5
2.5 Why insurers and reinsurers should implement solvency II? ................................................ 20
2.8 The applicability of the risk based approach to solvency management. ................................ 24
CHAPTER 3 ............................................................................................................................ 27
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3.2 Target Population ........................................................................................................... 27
CHAPTER 4 ............................................................................................................................ 34
4.2.1 Short term insurers and reinsurers faced with challenges of complying with the capital
based regulation. ....................................................................................................................... 35
4.2.2 Challenges faced by short term insurers and reinsurers in complying with the capital based
regulation. ................................................................................................................................. 36
4.2.4 The weaknesses of the capital based approach in solvency management. .......................... 38
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4.2.8 Costs of adopting solvency II............................................................................................ 40
4.2.10. The adoption of solvency II in the Zimbabwean short term industry. ............................. 42
4.3.1 The reasons of failure to meet minimum capital requirements by short term insurers and
reinsurers. ................................................................................................................................. 43
4.3.2 Methods used for coming up with minimum capital requirements. .................................... 44
4.3.4 Preparedness of the short term insurers and reinsurers to adopt solvency II ....................... 44
CHAPTER 5 ............................................................................................................................ 45
References ................................................................................................................................ 49
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LIST OF FIGURES
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LIST OF APPENDICES
Appendix A: Request for information needed for research……………………………………...55
Appendix B: Short term insurers and reinsurers-questionnaire………………………………….56
Appendix C: Interview Guide for Short tern insurers and reinsurers……………………………59
Appendix d: Interview guide for the regulator…………………………………………………..60
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LIST OF ACRONYMS AND ABBREVIATIONS
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CHAPTER 1
INTRODUCTION
1.0 Introduction
This chapter introduces the research being undertaken. The background of the study, statement
of the problem, research objectives and research question are also looked at. The importance of
study, assumptions, and limitations, definition of terms and delimitation of the research are
outlined in this chapter. Generally, it is the laying ground of the project and a map which will
direct the researcher in carrying out the project.
The insurance commissioner deregistered 61 insurance players in 2010 because of failure to meet
set minimum capital requirements. According to the IPEC non-life insurance report for the fourth
quarter 31 December 2014, five insurers reported capital positions below the set minimum
capital requirement of USD 1.5 million dollars. This resulted to the deregistering of Altfin and
the suspension of Global Insurance Company, KMFS Insurance Company and New Reinsurance
Company. Excellence Insurance Company, Quality Insurance Company, Tristar Insurance
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Company and Cell Insurance Company were also warned by IPEC in 2015 to meet the minimum
capital requirement of USD 1.5 million dollars so as to avoid being shut down. Although
insurance players are struggling to meet the set minimum capital requirement of USD 1.5 million
dollars, IPEC also highlighted on a soon to be announced 233% increase in capital requirement
to $5 million dollars (Daily News ,18 August 2015).
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(e)To investigate the adoption of the risk based approach to solvency management in the
Zimbabwe insurance industry.
1.6 Assumptions
The research was carried under the following assumptions:
(a) Honest, reliable and relevant information shall be provided by respondents to the research.
(b) The selected sample was a true representation of the population.
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1.7 Limitations
(a) The research had limited financial resources for travelling expenses from Gweru to the oasis
of information which was Harare.
(b) There was limited time since the research ran simultaneously with her final semester.
(c) Respondents could not provide all the required information due to company privacy policies.
1.10 Summary
This chapter introduced the study and outlined the factors that prompted this research. The
background of the study, the importance of the study, assumptions and limitations were also
outlined in this chapter.
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CHAPTER 2
LITERATURE REVIEW
2.0 Introduction
According to the Leedy (1997) literature review is an account of what has been published on a ce
rtain topic or concept by accredited authors and writers. In presenting literature review, the purpo
se is to convey to the reader the knowledge and ideas that have been established on a topic and w
hat requires further research.
The chapter tries to critically analyze what has been studied so far in the subject of the risk based
approach to solvency management. This analysis will pay attention to some overlooked but criti
cal aspects of the subject area.
The consumers considers insurance to be a key risk management strategy, therefore the
minimization of the disruption of insurance companies is of paramount importance (Leadbetter
and Dibra 2008).This makes the subject of solvency of great essentiality in the field of insurance
since the whole functionality of insurance is based on insurance players meeting their
obligations. When assets become insufficient for an insurance company to meet its contractual
and other financial obligations it is called insolvency (Leadbetter and Dibra 2008).
Solvency is described by other scholars in liquidity terms as the ability to meet current payment
obligations as they fall due. Cummins and Derrig (2008) however argues that when solvency is
measured in liquidity terms, companies may appear liquid (able to meet its current obligations by
using its current cash flows) while being ruined in the long term sense (liabilities exceeding
assets).
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There is the accounting, legal, economist and financial expert’s ways to measure solvency.
However, the accounting way in terms of solvency ratios is widely applied in measuring
solvency.
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2.1.2 Main reasons for insurance companies’ insolvency
According to Leadbetter and Dibra (2008) by understanding the causes of insolvency, a
reduction in the winding up of companies and improvements in solvency supervision can be
achieved.
Several scholars have looked into the causes of insolvency in insurance companies. Cummins
and Phillips (2005) research concluded that the leading cause of involuntary exit is inadequate
pricing and deficient loss reserves in which in their research accounted for 31% of the
impairments. The American Academy of Actuaries Property (2010) agrees that deficient loss
reserves and inadequate pricing are causes of insolvency but cited rapid growth, fraud and
mismanagement as the major causes of insolvency.
Most of the scholar’s findings converge on the financial aspects which results in the failure of
insurance companies but in the studies of Hall (1992) size of companies was considered as a key
factor in insolvency of firms. This was supported by Cummins and Phillips (2005) as they
mentioned that larger insurers are less sensitive to financial distress than small insurers .Costello
(2003) identifies catastrophes, reinsurance (either not enough not ceded or failure of reinsurance)
, false reporting and investment failure as causes of insurance companies failures.
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2.2.1 Solvency management and the regulators.
Stewart et al (1988) states that, the major purpose of insurance regulation is to prevent
insolvency. It further recognizes insolvency as a regulatory failure. According to Monayery
(2013), the objective of insurance regulation is:
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Nini (2002) define a risk based approach as a regime that is oriented towards the insurer risk
structure. It ensures a better understanding of risks thereby necessitating a proactive approach to
solving or preventing problems. However, the risk based approach is also defined in term of the
European Union solvency II as it covers all the aspects and principles of the risk based approach.
Solvency I is defined by Swain and Swallow (2015) as a rules based regulatory frame work in
which there is a uniform capital requirement for insurance players. According to the Financial
Conduct Authority (2015) it consists of a set of rules and amendments made up of the core which
is the non life directive of 1973 and life directive of 1979. In 2002 amendments as to improve the
calculation of solvency margin were made. Solvency margin required for non life insurers under
solvency I is based on a percentage of gross written premium, a percentage of average claims
over a time period, or the carried forward amount of preceding year (European Commission
Directive 2009/138/EC). In respect of the life business, the solvency margin is based on a
percentage of mathematical provisions and adds a percentage of the remaining positive capital at
risk.
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(a) Inadequate and inconsistent policyholder protection
In 2009, the solvency II directive was approved over the solvency I directive and Swain and
Swallow (2015) argues that it was as a result of the inadequacy and weaknesses of the solvency I
that drove the proposition and approval of the solvency II directive. Capgemini (2006)
recognizes the weakness of the solvency II in the calculation of the non life solvency margins in
which they are focused on the volume of the contracts instead of the actual risks inherent to
specific contracts. This poses questions of protection to the policyholders hence another shortfall
of solvency I, it provides inadequate and inconsistent policyholder protection.
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technical risks than general risks making it essential for regulatory intervention so as to tackle
other risks. The complexity in risks has been countered by technical developments which have
provided advanced risk management strategies which the insurers are trying to implement.
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2.4.2 Pillar I
According to Eling et al (2007) pillar 1 outlines the financial requirements such as market
consistent valuation of the balance sheet including insurance liabilities and assets. Piotrowska
(2008) argues that pillar I primarily concerns itself with capital requirements in form of the
minimum capital requirement and solvency capital requirement. Pillar I generally focuses on the
quantitative requirements and it ensures adequate capitalization of firms with risk based capital.
The trading of assets is done in liquid markets where prices which are taken to be market values
which is not the case for liabilities. According Piotrowska (2008) the market value of insurance
liabilities is the forecast of future liability cash flows discounted using a risk free interest rate.
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(c)Solvency capital requirement (SCR)
KPMG (2011) defines SCR as an approach to solvency calculation which is sophisticated,
dynamic and more risk sensitive. It is designed to focus on key risks affecting all balance sheet
components and will be fully centered on any risk mitigation that can be demonstrated. The SCR
is according to Eling et al (2012) there to absorb unforeseen losses therefore assuring desired
policyholders protection. The SCR is designed to be a target level of capital which will cover all
risks an insurer faces, the confidence level is proposed to be 99, 5% over one year period (White
et al 2011).SCR covers market risks, operational risks, credit risks and insurance risks.
When calculating SCR, companies have the option to use the standard formula which is set by
the directive or the internal model which is preapproved by the regulator. Solvency II however
encourages the use of an internal model as costly as it is because it deals with risks that are
specific to a company (White et al 2011).This is because although it is simple and less costly, the
standard formula is a one size fits all approach to the measurement of risk exposure.
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Companies could apply for approval of including some off balance sheet finance to own funds
and so called is Ancillary Own Funds (AOF). Ancillary Own funds include unpaid share capital
and letters of credit and guarantees. This is to classify and restrict the extent at which various
components of own funds can be used to meet capital requirement and both SCR and MCR have
rules in regard to extent in which these could be used. Both BOF and AOF are classified into
three tiers which according to McHugh (2014) are:
(a)Tier 1 capital comprises of common equity, retained earnings and surplus funds. It is the
highest capital quality capable of absorbing losses on a day to day basis. The proportion of this
tier should at least be higher than a third of the total amount of the eligible own funds (European
Commission Directive 2009/138/EC).
(b)Tier 2 capital is subordinated debt and is of low quality and only absorbs losses on
insolvency. This takes the form of mutual type associations.
(c)Tier 3 is said to be the lowest of capital and has only limited loss. The eligible amount of this
tier should at least be less than a third of the eligible own funds (European Commission Directive
2009/138/EC).
The classification of own funds into tiers depends on whether they are basic own funds or
ancillary own funds. Additionally, the level of subordination, servicing costs involved and the
availability of the funds in terms of permanence and demand is considered.
(f) Investment
Insurance and reinsurance companies under the solvency II regime are not restricted on the
classes of assets that they can investment provided that in all those assets they can prove that
they are complying with the prudent person investment (PPIP).PPIP provides for full
understanding of risks involved with the assets invested in and provide for them accordingly
through the SCR and that the investments decisions that were made were in the best interest of
policyholders. Pillar 1 also focuses on investment management rules of insurance companies and
stipulates that insurance companies can make investments they deem appropriate but risks
associated thereto should be catered for within the SCR of the company (European Commission
Directive 2009/138/EC).
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Investment of assets covering the MCR and SCR should however be invested in such a manner
that ensures security, quality, liquidity, profitability and availability through localization (White
et al 2011). Assets covering technical provisions on the other hand shall be invested in a manner
appropriate to the nature and duration of the insurance and reinsurance liabilities and these are
invested in the best interest of the policyholders. The assets should also be properly diversified to
avoid excessive reliance on a particular asset (European Commission Directive 2009/138/EC).
2.4.4 Pillar II
It pertains to corporate governance within insurance firms, supervisory review process and the
enforcement of high standards of risk management. The key issue on pillar II is to establish
processes and functions that support a sound risk management system and the seen compasses
internal audit functions, actuarial, risk management and finance with the board being ultimately
responsible for all three pillars compliance (European Commission Directive 2009/138/EC).
Clarke et al (2014) argues that under pillar II of the solvency II regime, supervisors are required
to challenge the internal control systems and qualitative aspects of a company's risk
management. These qualitative issues involves a leadership overall responsible for risk
management, risk strategies that are clearly defined and links to the business strategy and a
continuous and ongoing control and management of a company's risk also considering its
capacity.
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If deficiencies or weaknesses are identified, the authorities have the power to require remedies.
According to Capgemini (2006) an important feature of pillar II is the power the supervisor has
to require additional capital resulting in a so called adjusting SCR, and to take measures to
reduce risks. Capital add on could be required in situations where the system of governance has
failed to identify, measure, monitor, manage and report risks or if the review concludes a
significant deviation of the insurance or reinsurance company's risk profile from the SCR
assumptions.
(b)System of governance
Insurance and reinsurance companies are required to put in place effective governance systems
and this includes transparency in terms of allocation and segregation of responsibilities (KMPG
2011). The system is determined by the complexity and nature of an organization’s operations
and it also outlines the policies that deal with internal control, internal audit and risk
management. Clarke et al (2014) states that a qualified, knowledgeable and experienced
personnel who adequately enables sound and prudent management completes the requirements
of the governance system.
(c)Risk Management
Risk management is also key as in this pillar it has a potential to take a thorough view of risk
than on pillar I and this results in more extensive categories of risks being catered for. KPMG US
(2011) argues that in pillar II a company does not only manage its retained risks but all risks
relating to the management of the business environment and has to be communicated to the
supervisory authority. Risk management comprises of necessary procedures to identify, measure,
monitor, manage and report on risks continuously at both individual and aggregate level (White
et al 2011). The effectiveness of these risk management systems requires the full integration of
the whole organization.
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ensure the conduction of own assessment of solvency and financial position as well as own
review of exposed risks by senior management (European Commission Directive 2009/138/EC).
(a)A detail of the business how it is performing .That is the company describes its activities,
group structure, external environment, objectives, and strategy of financial results.
(b)Governance structures and an evaluation of how the governance structures are adequate for
the insurance or reinsurance company's risk profile. A compliance code including competence
and integrity rules is also drawn.
(c)Valuation method that is used to calculate technical provisions, assets held to cover technical
provisions and capital requirements, as well as other assets and liabilities.
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(d)Risk management strategies used to identify, measure, control and hedge risks. This includes
the SCR and MCR as well as any breach if any and the explanations and then corrective
measures taken.
The regulators also ensure that there is onsite verification of information. However, there are
circumstances in which the regulators may approve nondisclosure of certain information
(European Commission Directive 2009/138/EC). This is information which when disclosed may
give the insurer's or reinsurer's competitors a significant undue advantage. There are also
circumstances in which a company has a binding obligation to policyholders of nondisclosure,
the regulator may approve it. If the regulators approve nondisclosure, the company shall make a
statement in its report to the effect clearly stating the reasons.
(b)Under solvency II there is much emphasis on the identification and mitigation of risks as well
as aligning risks to capital which will eventually result to more efficient, accurate and transparent
risk measurement and management. Coates et al (2011) mentioned that it aims to instill a greater
understanding of measuring risks as well is the monitoring and management of the risks.
(c)The MCR and SCR provide an early warning system for deterioration in solvency by active
capital management.
(d) It is also meant to create incentives to implement effective risk management strategies.
(e) According to Coates et al (2011) the emphasis on transparency help policyholders to compare
insurers and products therefore the solvency II framework aims to improve policyholders’
choice.
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2.4.7 Principles of the solvency II directive.
The solvency II regime is based on principles in comparison to solvency I which is rules based.
These principles are stated by (European Commission Directive 2009/138/EC) as:
(a) Principle 1
Technical provisions should be objective, reliable and adequate.
(b) Principle 2
Liabilities should be adequate.
(c) Principle 3
Appropriate assets should be objectively valued and they should be reliable.
(d) Principle 4
Assets and liabilities should be matched in terms of currency and amount of cashflow.
(e) Principle 5
Capital Requirements should be adequate to absorb losses and risks.
(f) Principle 6
Capital adequacy has to be sensitive to risking the form of the requirements of assets, clearly
defined appropriate capital, solvency margin etc.
(g) Principle 7
There should be control levels created and be enabled to intervene when necessary.
(h) Principle 8
Minimum capital requirement should be specified.
(I) Principle 9
Forms of capital should be clearly defined.
(j)Principle 10
There should be effective risk management systems.
(k)Principle 11
There should be allowance for different forms of risk transfer not only reinsurance for insurance
companies.
(l)Principle 12
Market disclosure is of paramount importance.
(m)Principle 13
Solvency assessment should be undertaken by solvency authorities.
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2.5 Why insurers and reinsurers should implement solvency II?
(a)Competitive advantage in capital requirements
Coates et al (2011) states that solvency II acknowledges that insurance companies have different
risk profiles hence their capital requirements should differ. This will result into some companies
benefiting from lower capital requirements than their competitors. Niche players will also benefit
from their low risk profiles as well as calculation of the SCR using the standard model which is
relatively cheaper Capgemini (2006).
(c)Performance management
Through the solvency II risk based principles, insurance companies can proactively and
continuously identifying profitable lines of business and pursue them and they also have the
choice to abandon the less profitable ones.
(d)Investment strategy
Solvency I state the rules for investment of assets and that’s how it deals with the investment risk
(The Institute and Faculty of Actuaries, 2015).Under solvency II insurance and reinsurance
companies are not prohibited to invest in any assets provided they can prove that the investment
risk is carted for in the SCR. The capital charges for investment risks may encourage insurers to
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take less investment risks and their investment decisions will be solely based on the best interest
of the policyholders.
(f) Reserving
According to White et al (2011) technical provisions are the largest item on an insurer's balance
sheet. The reserving risk is the risk of insufficient technical provisions and under solvency II
these are backed up by a capital charge. The market consistent valuation of reserves also
enhances transparency of reserves as well as a better understanding of risks associated with
reserves. This may encourage insurers and reinsurers to adequately reserve for technical
provisions.
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Young (2008).Solvency II therefore gives insurers and reinsurers a wider spectrum of risk
hedging and risk transfer instruments. New options will give insurers an incentive to optimize
their risk transfer solutions and may consequently intensify competition among providers of
various solutions (KPMG 2011).
(b) Complexity
According to Capgemini (2006) insurers may be familiar with risk management strategies like
scenario analysis as well as actuarial approaches but not with specific risk dimensions such as
probability of economic ruin and value at risk which is integral to the solvency II approach. Also
the implementation of the risk management strategies requires experienced personnel for
instance actuaries as well as models that are costly to the organizations. Coates et al (2011) also
argues that the proposed approach is too complex and some terms of the requirements are
difficult to interpret even after clarifying making it difficult to apply them.
(c) Disclosure
Coates et al (2011) expresses concern of the disclosure requirements under solvency II in that
there is some confidential information which is said to sensitive and misinterpretation of that
information may highly cost the organization. This was also supported by Ducoffe and Chanson
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(2013) as they mentioned that too much information to consumers may be as helpless as too little
information.
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(c)Skilled resources and models
Bernardino (2011) mentions that solvency II is mainly focused on the valuation of the balance
sheet and the calculation of the capital requirements which. Sherwood et al (2011) argues that the
effectiveness of solvency II is also dependent on enterprise risk management .The quantitative
aspects of solvency II as well as enterprise risk management requires the use of models. This
implies that there is need for an actuarial function and other industry professionals which could
be costly for organizations.
The Dodd-Frank Wall Street Reform and Consumer Protection Act were created among other
things and it was meant to reduce excessive risk taking by financial institutions that led to the
financial crisis. According to The United States Insurance Financial Solvency Framework (2010)
in 2008 through the NAIC, the state insurance regulators in the US embarked on the Solvency
Modernization Initiative (SMI) to perform a critical self evaluation development in insurance
supervision and international accounting standards to determine their potential use in US
insurance supervision. The SMI focuses on 5 key solvency issues which are capital requirements,
international accounting, insurance valuation, reinsurance and group regulatory issues (Deloitte
2012).According to the National Association of Insurance Commissioner, the adoption of a risk
based regime was as a result of large company insolvencies. Its main aim is to match capital
levels of companies to the related risks which raises a safety net for insurers and also provides
for regulatory authority's timely action.
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As in the case in many other countries in the world, the present supervisory regime in China is
based on Solvency I and the lack of risk sensitivity and the absence of an incentive for insurance
undertaking to improve the risk management were important reasons for the China Insurance
Regulatory Commission (CIRC) to plan are form to its existing regulatory scheme introduced in
2003 (Van Hulle 2014). Prior to 2012 according to the CARe Conference (2015) there were
minimum capital requirement set and CIRC officially launched the China Risk Oriented
Solvency System(C-ROSS) in March 2012 and testing started in 2014 with the aim to evaluate
the reasonableness and practicability of the C-ROSS formula and full implementation is targeted
in 2016 with a transition period with respect to meeting the capital requirements.
C-ROSS also borrows the solvency II three pillar approach with pillar 1 additionally to the
solvency II pillar 1 consisting of quantitative requirements for insurance risk, credit risk and
market risk. Pillar 2 focuses on risk management as well as dealing with risks that are difficult to
quantify. These are operational risks, strategic risks, reputational risks as well as liquidity risks.
Pillar 3 looks at the market discipline through public disclosure or transparency of insurance
companies operations and dealings.
The Kenya Insurance Act was put in place 1984. The collapse of many insurance companies in
Kenya during the 1990s coupled with numerous problems that bedeviled the sector necessitated
amendments to the relevant laws governing insurance. The first set of significant amendments to
the act was made in 2003 and these mainly dealt with mismanagement and transparency. In 2006
there were amendments with the effort to enhance the ability of payment of claims and 2010 one
core function set out in the amendment was to monitor the risk profile on insurers Gadaffi
(2014). In 2013 the supervision frame work for the Kenya insurance industry shifted from
compliance based supervision to risk based supervision (IAIS 2015).
Due to the 2008 global financial crisis, South Africa reviewed its regulatory frame work on its
financial sector. With the adoption of the solvency II in Europe, South Africa have adopted an
equivalent frame work for insurers called the Solvency Association and Management Framework
(SAM) which replaced certain sections of the Long Term Insurance Act 52 of 1998 and the short
term Insurance Act 53 of 1998 (International Reinsurance Letter 2015). The risk based frame
25
work mainly seeks to address the short coming so for the global financial crisis that is the lack of
sufficient mechanisms to provide supervisors with early warning of potential solvency concerns
as well as risk management (Khoza, 2015).
2.9 Conclusion
The chapter gave us an overview of the risk based approach in the insurance sector. Despite the
fact that risk based approach will not end all the insurance industry predicaments it has proven to
be of significant changes in the industry. To critically analyze the relevancy and applicability of
the intended objectives in the Zimbabwean insurance industry, we have to employ the research
methods detected in the following.
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CHAPTER 3
RESEARCH METHODOLOGY
3.0 Introduction
This chapter focuses on the research design and methodologies the researcher employed to
collect data and a detailed description of the procedure applied in conducting the research, the
research instruments, sampling techniques and sources of data.
Collins and Hussey (2009), notes that the determination of a research design gives a detailed plan
which one will use to guide and focus his research. A descriptive research design was used for
the purpose of this study because it allows for the fusion of both qualitative and quantitative data.
In this survey, questionnaires and interviews were used to obtain information from respondents
on their views regarding the adoption of a risk based approach to solvency management in
Zimbabwe. Questionnaires enabled the researcher to get honest opinions of respondents on the
subject as there is an element of anonymity associated with questionnaires whereas interviews
gave the researcher an opportunity to further probe as well as observe and gather information
through nonverbal cues.
The targeted population for this research consists of the Insurance and Pension Commission
(IPEC), 24 operational short term insurance companies and 9 short term reinsurance companies.
27
General Managers (operations) of short term insurance and reinsurance companies were targeted
respondents. This is because they have the knowledge regarding the capital positions and
systems of their organizations and are also involved in the decision making of the overall
operations of the organization. However, the researcher could not collect data from the whole
population due to financial constraints and limited time so a sample representative of the
population was selected.
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(b) Systematic sampling
Systematic sampling involves the selection of elements using a fixed or sytematic interval until
the desired sample is reached (Allison et al; 2001).
(c)Stratified sampling
Stratified sampling involves dividing the population into subgroups, with each subgroup having
relatively uniform elements. Once the strata have been identified a simple random sample is
selected from each stratum separately, the sample corresponding to the proportion of elements in
each stratum. Stratified sampling is used when the population is assumed to consist of a number
of smaller subgroups or sub populations such as male or female which are thought to have an
effect on the data to be collected (Wagner 1993).
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3.5 Research instruments and Data collection
Data collection steps comprises of the boundaries for the study, collecting information through
unstructured or semi structured observations and interviews, documents and visual materials as
well as establishing the protocol for recording information (Creswell (2009).The researcher used
the survey design in which questionnaires and interviews data collection instruments were used.
The data sources can be categorized into primary and secondary data.
3.6.1 Questionnaires
A questionnaire is a tool for collecting and recording information about a particular issue of
interest (Corporate Research and Consultation Team 2008).It comprises of list of questions
which include clear instructions as well as options and space for answers. The questionnaires
were delivered by the researcher in person to the selected short term insurers and agreed on the
date of collection with the respondents.
Advantages
(a) Questionnaires allows for a quick and easy contact of large numbers of people. They can be
distributed to different people at the same time and collected within a short period.
(a) They are easy and quick to interpret and provide anonymity of respondents which encourages
them to give honest opinions.
(b) A questionnaire is standardized in that it asks the same questions in the same manner.
(c) They avoid interview bias. Personal questions are often more willingly answered as the
respondent is not face-to-face with the interviewer.
Disadvantages
(a) The respondent may not clearly understand the question and it’s difficult to know especially
when the researcher is not present.
30
(b) The respondents have a tendency of discussing the questions with others so as to complete
the questionnaire and this may result to biased answers.
(c) Questionnaires do not permit the observation of facial expressions and gestures yet they are
essential for evaluation of responses and does not also allow for further probing so as to
achieve clarity and understanding.
(d) The targeted respondents may not complete the questionnaire. For instance, a busy manager
may ask a personal assistant to complete it on their behalf.
Advantages
(a) The researcher benefits from face-to-face communication with the interviewee and thus any
misunderstandings are cleared immediately and the researcher can ask probing questions.
(b) The respondents through interviews can freely express themselves and can benefit from non-
verbal communication.
(c) Interviews are less time consuming.
Disadvantages
(a) The presence of the interviewer may influence the interviewees such that they may end up
giving biased responds so as to please the interviewer.
(b) Interviews require good interpersonal skills to build the trust of respondents as well as to get
unbiased responses.
(c) Interviews are costly in terms of transportation.
31
3.7 Secondary Data
This involves the collection of data from sources that are already available. Lancaster (2005)
notes that the sources can be categorized into raw secondary and compiled secondary data.
Compiled secondary data is data that would have been selected and summarized whereas raw
secondary data is that which diminutive has been done. Secondary information contributed
immensely to the research effort as the researcher consulted several sources of data available on
the topic area of the study.
Advantages
(a) The internet provides recently researched data that is not found in the library.
(b) It is easy to access and it helps the researcher to screen out unnecessary data.
Disadvantages
(a) It can be difficult to retrieve information from the internet since its efficiency is dependent on
network servers which can be highly congested sometimes.
(b) It is time consuming as the researcher has to screen the data provided on internet.
3.8 Summary
This chapter focused on the summarizing of the methods and techniques used to gather data for
the research. The data range from primary to secondary and secondary data was mainly used on
32
the literature review whereas primary data forms the next chapter in which data analysis is
focused on.
33
CHAPTER 4
4.0 Introduction
This chapter presents a description and analysis of data gathered through the use of
questionnaires and interviews. Tables and graphs were used for quantitative data presentation
whereas qualitative data was used for analysis.
12%
88%
34
4.2 Data Analysis and Presentation
4.2.1 Short term insurers and reinsurers faced with challenges of complying with the
capital based regulation.
The researcher mentioned the above question in order to find out the number of short term
insurers and reinsurers that have faced challenges in complying with the capital based regulation.
Challenges of compliance with the capital based regulation were indicated by 65% of the
respondents. Some operated for a quarter or two with capital below the set minimum whereas
some had to run around and raise the required capital at a very costly rate. However, 35% of the
respondents did not face any capital based regulation compliance challenges. The findings are
illustrated in figure 4.2
35
4.2.2 Challenges faced by short term insurers and reinsurers in complying with the capital
based regulation.
This question was designed to assess the challenges that the short term insurers and reinsurers
faced. The liquidity crunch and ever increasing regulatory capital was stated by 70% of the
respondents as they constitute the greater percentage of the challenges they faced in complying
with the capital based regulation. The regulators are ever increasing the minimum capital
requirement as a way of hedging against risk but are not considering the low market penetration
rate the insurance industry is currently facing. The premiums written and the capital requirement
are not corresponding. However, 20% of the respondents mentioned the depletion of their capital
and investments during the dollarization era as a challenge they faced in meeting capital
requirements. The remaining 10% indicated that they faced challenges of capital based
regulation compliance because there is no or little activity on the stock market. The findings are
illustrated in figure 4.3 below
36
4.2.3 Effects of compliance challenges.
The question sought to find out the effects the short term insurance industry faced due to failure
to comply with the capital based regulation. The high costs of accessing external funds as stated
by 35% of the respondents resulted in the reduction of profits. The perceived instability of
companies as cited by 30% of the respondents brought about by warnings from the regulator
resulted in companies losing their key workers. A number of policyholders withdrew their
policies after challenges’ of compliance were publicized; this according to 20% of the
respondents was an effect of bad reputation. Compliance challenges’ as indicated by 15% of the
respondents resulted in suspension which affected their relationships with service providers. The
findings are presented in figure 4.4 below
Withdrawal of policies
30%
Relationships with service
providers
37
4.2.4 The weaknesses of the capital based approach in solvency management.
Respondents indicated that insurance players face different risks which require a different
capital back up. The capital based approach on the other hand uses uniform factors when setting
the minimum capital requirement. The other weakness of the capital based approach is that it
perpetually changes therefore presenting a level of uncertainty to insurance players.
102
100
98
96
94
Awareness
92 Knowledge
90
88
86
84
Awareness Knowledge
38
the respondents and this comprises of insurance giants that are currently heavily capitalized. 60%
of the respondents mainly constituting of small insurance players stated that they are not able to
adopt solvency II. The results are illustrated on figure 4.6 below
40%
Inability to adopt solvency
II
60%
Ability to adopt solvency
II
39
Figure 4.7 Challenges of adopting solvency II.
80
70
60
50
Integration of the whole
40 organisation
Disclosure requirements
30
Cost of insurance
20
10
0
Integration of Disclosure Cost of
the whole Requirements Insurance
organisation
40
Figure 4.8 Costs of adopting solvency II
20%
41
Figure 4.9 Benefits of adopting solvency II.
70
60
50
40
Adequate reserving
30
Product design and pricing
20
10 Improvement in overall
performance of organisations
0
Adequate Product design Improvement
reserving and pricing in overall
performance
of
organisations
42
Figure 4.10 Preparedness of the adoption of solvency II
4.3.1 The reasons of failure to meet minimum capital requirements by short term insurers
and reinsurers.
The regulator highlighted that there are poor returns on most insurer’s investments and also most
of the insurer’s funds are tied up in premium debtors which makes it difficult for them to meet
required capital. Respondents also mentioned that some of the insurance players are greatly
affected by rate undercutting and lack of product innovation which in turn reduces their retained
profits.
43
4.3.2 Methods used for coming up with minimum capital requirements.
This question was probed so as to find out what uniform factors are used to determine the
minimum capital requirement. The respondents stated that the balance sheets of insurance and
reinsurance companies are considered and an average capital requirement is extracted from this.
4.3.4 Preparedness of the short term insurers and reinsurers to adopt solvency II
The respondents cited poor data collection skills and inexperience as a major hindrance of
insurance companies and reinsurers to the adoption of solvency II. The difficulties of the
implementation of pillar 1 as compared to pillar II and III were however mentioned as it was
explained that pillar II and pillar III can be adopted in Zimbabwe with minimal difficult. As far
as the preparedness of insurers and reinsurers is concerned, the respondents argues that the
implementation of solvency II would take time and high cost hence their ability to implement
solvency II is limited.
4.4 Summary
This chapter focused on the findings, data interpretation and analysis. The data gathered was
presented in the form of pie charts, bar graphs and tables.
44
CHAPTER 5
5.0 Introduction
This chapter summarizes the entire research project, conclusions and recommendations based on
the research were drawn. The research intended to explore the adoption of a risk based approach
to solvency management of short term insurers and reinsurers in Zimbabwe.
45
(g) There are a number of costs that are associated with the implementation of solvency II in
Zimbabwe and these are the costs of compilation of data and set up of internal models, the
need for actuaries and industry professionals and regulators risk management systems.
(h) A substantial proportion of short term insurers and reinsurers are not able to implement
solvency II and do not support its adoption in the Zimbabwean insurance industry.
5.2 Conclusion
Capital based approach is not a very effective tool to solvency management in the Zimbabwean
insurance sector. Window dressing of accounts, failure to meet the set minimum capital
requirement, suspension and deregistering of companies are some of the effects of using the
`capital based approach to solvency management. Capital based approach encourages insurers to
focus on achieving compliance yet neglecting the management of their specific risks in relation
to their own funds. The regulators on the other hand are also mainly concerned with the
compliance of the (re) insurance players with capital requirements than their prudent actions in
business operations and risk management strategies. The use of capital based approach as a
standalone tool has proved to be less effective since there are a number of loop holes and other
strategies need to be adopted to curb problems caused by capital based approach.
5.3 Recommendations
The capital based approach is currently being used as solvency management tools in the
Zimbabwean insurance sector were a minimum capital requirement is set. This is meant to
safeguard policyholders from the insolvency of insurance companies. The study has revealed a
number of weaknesses of the solvency management tool currently in use. The regulator is also to
blame as they put much emphasis on the minimum capital requirement compliance. This puts
much strain on the insurance players as they end up employing unethical strategies such as
window dressing of accounts in order to satisfy the regulator. Critical risk elements such as
investment of premium in prescribed assets instruments are forgone, risk management
departments are closed as a cost cutting measure and a way of increasing retained profit so as to
meet the set capital requirement. The following recommendations were made in an effort to
improve solvency management in the Zimbabwean short term insurance industry:
46
5.3.1. To the regulator
(a) Modification of the current regulation for short term insurance and reinsurance
companies.
The merging of the Own Risk and Solvency Assessment (ORSA) model and current regulation
can help (re)insurance companies better manage their risks .This would take the form of a capital
requirement being set and companies have the option to take on the ORSA model in which they
will be required to report on the assessment of their risks and risk management strategies in sync
with sufficient own funds. If the company can prove that the capital set is too high for their level
of business and risks, it therefore can be reduced accordingly. The use of ORSA limits insurance
companies from accepting risks which are above their capacity. Cases were a company's pool is
wiped out by a single risk are minimized, issues of suspension and deregistering of insurance
companies are reduced and this has the effect of improving the image of the whole insurance
sector.
47
(d) Further research on risk based approaches
A further research on the risk based approach could be conducted. Delays in other countries as
well as weaknesses of the frameworks could be better understood. This will assist in tailor
making a risk based framework for the Zimbabwean insurance industry.
5.4 Summary
The conclusions from the research findings were drawn in this chapter. It was concluded that the
capital based approach as a standalone tool is less effective in solvency management. However,
it was revealed that the adoption of a risk based approach in the Zimbabwean insurance industry
is difficult .A recommendation of current regulation modification was made by the researcher as
one of the strategies to manage solvency in the insurance industry.
48
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54
APPENDIX A
FACULTY OF COMMERCE
Dear Sir/Madam
All the information and expressions to be expressed by the respondents will be confidentially and
strictly handled. The findings of this research are for academic use only. If you wish to get more
information about this study, you are free to contact the chairperson of the Department of
Insurance and Risk Management, Mr. F. Makaza on his email [email protected] or mobile
number 0774 620 669
Yours sincerely
Placxedes Mukonzo
077641901
55
APPENDIX B
SHORT TERM INSURERS AND REINSURERS-QUESTIONNAIRE
(a) Have your organization ever faced challenges in complying with the capital based
regulation?
Yes No
(b) If Yes, briefly explain the challenges that the organization have faced in complying with
the capital based regulation?
................................................................................................................................................
................................................................................................................................................
................................................................................................................................................
................................................................................................................................................
(c) To what extent was your organization affected by failure to comply with capital based
regulation?
................................................................................................................................................
................................................................................................................................................
................................................................................................................................................
.................................................................................................................................................
(d) What do you think are the weaknesses of the capital based approach to managing
solvency?
................................................................................................................................................
................................................................................................................................................
................................................................................................................................................
................................................................................................................................................
56
................................................................................................................................................
(e) The insurance sector worldwide is moving towards the implementation of solvency II, do
you think Zimbabwe should do the same?
Yes No
(g) Do you think your organization is able to adopt the solvency II framework?
Yes No
(h) What do you think are the challenges your organization may face in implementing
Solvency II?
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………….......
57
(i) What do you think are the costs of adopting solvency II to your organization?
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………………
………………………………………………………………………………………………
…………………………………………………………………………...............................
(j) What do you think are the benefits of adopting solvency II to your organization?
.......................................................................................................................................
.......................................................................................................................................
.......................................................................................................................................
.......................................................................................................................................
(k) Do you think Solvency II could be adopted in the Zimbabwean insurance industry?
Yes No
………………………………………………………………………………………..
.......................................................................................................................................
.......................................................................................................................................
.......................................................................................................................................
58
APPENDIX C
(a) Have your organization ever faced challenges in complying with the capital based
regulation?
(b) What are the challenges that the organization have faced in complying with the
capital based regulation?
(c) To what extent was your organization affected by failure to comply with capital based
regulation?
(d) What do you think are the weaknesses of the capital based approach to managing
solvency?
(e) The insurance sector worldwide is moving towards the implementation of solvency II,
do you think Zimbabwe should do the same?
(f) Do you think your organization is able to adopt the solvency II framework?
(g) What do you think are the challenges your organization may face in implementing
Solvency II?
(h) What do you think are the costs of adopting solvency II to your organization?
(i) What do you think are the benefits of adopting solvency II to your organization?
(j) Do you think Solvency II could be adopted in the Zimbabwean insurance industry?
59
APPENDIX D
60