IAA Committee on Insurance Accounting and Subcommittee on Actuarial Standards Minutes from Meeting in Paris on 25-27 May 2006
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IAA Committee on Insurance Accounting and Subcommittee on Actuarial Standards Minutes from Meeting in Paris on 25-27 May 2006 1) Attendees. Félix Arias Bergadà (Spain), Victor Bagnati (Belgium), Maria Barroso (Portugal), Tom Behar (France), Ralph Blanchard (U.S.), Amy Bouska (U.S.), Guy Castagnoli (Switzerland), Mo Chambers (Canada), Peter Clark (IASB), Kevin Cronin (U.S.), Peter Diethelm (Switzerland), Rianto Djojosugito (Indonesia), Stefan Engeländer (Germany), Rob Esson (U.S. – IAIS), Jiri Fialka (Czech Republic), Dave Finnis (Australia), Gaida Pettere (Latvia), Alexandre Guchet (France), Marika Guralnik (Estonia), Sam Gutterman (U.S. – chair), Morten Harbitz (Norway), William Hines (U.S.), Harold Hugel (Canada), Stephen Humphreys (Canada), Hiroyuki Iijima (Japan), Burt Jay (U.S.), R Kannan (India), Steve Kellison (U.S.), Kurt Lambrechts (Belgium), Barbara Lautzenheiser (U.S.), Mustapha Lebbar (Morocco), Steve Lehmann (U.S.), Chris Lewis (Australia), Mike Lombardi (Canada), Paul McCrossan (Canada – vice-chair; co- chair of Subcommittee), Bob Miccolis (U.S.), Jim Milholland (U.S.), Kesh Mittal (U.K.), Markku Paakkanen (Finland), Alexander Omanadze (Georgia), John Poole (India), Tatjana Racic-Zlibar (Croatia), Anna Maria Ramirez (Mexico), Fred Rowley (Australia), Stewart Ritchie (U.K.), Richard Roth (U.S.), Francis Ruygt (The Netherlands – vice- chair; co-chair of Subcommittee), Junichi Sakamoto (Japan), Kenneth Shih (Taipei), Masaaki Shigehara (Japan), Krzysztof Stroinski (Poland), Shigeru Taguchi (Japan), Tuomo Virolainen (Sweden), Peter Withey (South Africa), Derek Wright (U.K.), Eng Kim Yeoh (Canada), Masaaki Yoshimura (Japan). 2) Minutes of the last meeting were not prepared. As a result, no minutes were approved. 3) Paul McCrossan. a) Paul McCrossan, who will be retiring from the Committee and the Subcommittee at the end of the Paris Council meeting, was thanked with much appreciation for his long service, not only to the Committee and Subcommittee, but also for the international profession as a whole. A gift was given. b) Paul provided background and history of the entire IASB and IAA standards setting process, including the role of the IAIS. It began with the IAA involvement with the proposed IASC amendment of IAS 19 (Pensions) in 1996 and is expected to continue for some time into the future. 4) International Actuarial Standards of Practice (IASPs). The first morning of the meeting addressed IASP practice. a) Professional Committee’s recommended due process paper i) It was generally agreed that there should be a distinction between International Actuarial Standards of Practice and educational material. The Subcommittee far preferred the term “International Actuarial Educational Notes” rather than the proposed “International Actuarial Practice Notes” ii) Sam suggested that there should be one class of IASP rather than a two class system that had been proposed. He saw no need for a “mandatory” class of IASP, although if a local association decided that their members should be required to comply, they could do so. IAA Committee on Insurance Accounting and Subcommittee on Actuarial Standards Minutes from Meeting in Paris on 25-27 May 2006 (1) Paul suggested as an alternative that we have a mandatory class just in case it is needed in the future iii) Some expressed the feeling that the draft revised due process for IASP developed from an IAEN (IAPN) needs to be clarified. iv) A brief discussion was held regarding the use of the first seven IASPs. Kesh indicated that he wasn’t aware of anyone in the U.K. or Germany who has declared that they had followed the IASPs, but that isn’t surprising since they were intended for educational purposes. v) There has been some confusion in certain IAA member associations regarding the options that are available to them regarding the IASPs: adopt/adapt/ endorse. (1) Sam indicated that these options are more relevant to class 3 IASPs, rather than class 4 IASPs (2) Stefan indicated that language (local) was not considered in these options (3) A suggestion made was that “recognize” might be a more appropriate term than “endorse” vi) A discussion of the applicability of subsidiarity was held. A possible distinction between the applicability of this principle to practice and technical type standards may exist (1) IASPs that are technical or educational in nature and applicable to international practice should not vary in applicability and should not be affected by subsidiarity (2) Those IASPs that relate to actuarial practice may be affected (3) Educational / Practice Notes should not have to be approved by member associations, as long as they are for education purposes (4) There appeared to be a consensus that consistent practice relative to the same accounting standards was desirable. vii) A possible alternative organizational structure of the contents of future IASPs that should be considered: (1) A summary / synthesis of applicable accounting standards / guidance (2) Clarification of areas that are not clear (3) Summary of current practice with regarding the accounting standards / guidance. Discussion regarding the use of best practice rather than current practice was held, but since best practice can change over time, vary from one jurisdiction to another, and judgment can vary regarding what constitutes best practice, this might prove difficult. viii) The Professionalism Committee expects to conduct a survey of member associations regarding practice with respect to the IASPs. The consensus was that this is a good idea. Comments regarding practice included: (1) Australia – the IASPs don’t apply if practice involves Australian practice; they do apply if the actuary’s client applies IFRS outside Australia (2) South Africa – has endorsed the IASPs and communicated that fact to its members. 2 IAA Committee on Insurance Accounting and Subcommittee on Actuarial Standards Minutes from Meeting in Paris on 25-27 May 2006 b) Current draft IASPs i) Given the short time between comments being provided and the Paris meeting, the Subcommittee was unable to complete its review in a timely manner. As a result, the four outstanding IASPs were not being presented for approval of IAA Council at this meeting. ii) The IAA received several quite valuable sets of comments regarding them from both actuarial and other organizations. Katy Martin had compiled those comments in a single document, attached to the agenda of this meeting. iii) The general reaction on each preliminary IASP was mixed, with some respondents indicating that they were acceptable as is, while others suggested a number of changes and areas that needed elaboration, refinements or correction. iv) The only suggested changes to the preliminary IASPs had been prepared by Stefan regarding the Embedded Derivative IASP. These suggestions had not been distributed to the Subcommittee as it was felt that it was premature to discuss the detailed suggested changes at this meeting v) Some of the more significant concerns raised included: (1) The preliminary Embedded Derivative IASP was too complicated and may not be worthwhile given its limited application under IFRS 4. (a) However, most felt that its complexity was a direct result of the complexity of the topic, that it was quite appropriate, and educational material on this topic was needed in any case. In addition, actuaries needed to recognize situations in which embedded derivatives need not be bifurcated, as well as those few cases in which they may or have to be recognized in this manner. (2) The preliminary Disclosure IASP was somewhat unwieldy and hard to get through, particularly because it attempted to address multiple practice areas together. In part it was felt that where appropriate, the areas that concerned only life insurance or only property and casualty insurance be discussed in separate sections. This thought applied to all IASPs. (3) One view was that it focused too much on accounting policy rather actuarial practice. (a) However, several actuaries working for accounting firms disagreed with this view, in that if actuaries are to work in the area of financial reporting, they have to understand the financial reporting context in order to provide valuable actuarial services. (b) In addition, in many instances, those charged with the application of accounting practice do not understand the business of insurance and therefore need the assistance of actuaries in developing, managing and applying this practice in developing and managing their accounting policy. (c) In fact, the intention of the preliminary IASP is not to tell actuaries what to do, but rather provide the context and educational practice guidance in which to apply the accounting standards and guidance. (d) The CIA had suggested that much of this material would be better if it came from IFRIC. Sam indicated that he disagreed with this suggestion, 3 IAA Committee on Insurance Accounting and Subcommittee on Actuarial Standards Minutes from Meeting in Paris on 25-27 May 2006 as IFRIC only deals with interpretations of IFRSs, which the IASPs are specifically designed to avoid. (e) Kim indicated that they were useful as a reference document, but would not in most cases be read altogether at one time. There was general agreement with this, although this would not always apply if someone just entered this area of practice. (f) Although in some cases actuaries are not involved in the development of an entity’s accounting policy, in some cases they have been key contributors to this policy. After discussion, it was felt that this