This consultation paper (CP) sets out further proposed detail on the Prudential Regulation Authority’s (PRA) expectations in respect of firms investing in equity release mortgage (ERMs) portfolios, as set out in Chapter 3 of Supervisory Statement (SS) 3/17.
The purpose of the proposals is to ensure that, where firms have invested in ERMs and have approval to use the MA or TMTP, their TPs are not understated and that their Solvency II and ICAS balance sheets include appropriate allowance for the risks to which they are (directly or indirectly) exposed.
This CP is relevant to insurance and reinsurance companies holding ERMs.
Summary of proposals
The PRA therefore proposes to provide firms with greater clarity on how they should address these aspects of NNEG risks under SS3/17 by setting out an option valuation approach and minimum deferment rate calibration that it considers to be consistent with principles (ii) to (iv). The PRA does not necessarily consider this to be the only approach that could address the issues identified above but firms using this approach will be meeting the PRA’s expectations for the purposes of applying the EVT.
The proposals included in this CP are:
(i) Firms using the approach and minimum calibration proposed would meet the PRA’s expectations for assessing the allowance for NNEG risk for the purposes of the EVT;
(ii) Firms holding ERMs should include an explicit allowance for ‘other risks’ within the EVT;
(iii) Where firms holding restructured ERMs in their MA portfolio cannot meet the EVT then this suggests that they may be taking an inappropriately large MA benefit. Accordingly, they will need to review their current approach and consider making changes to the structure, valuation or rating of restructured ERMs to ensure that they are able to calculate their MA benefit consistently with Solvency II requirements;
(iv) Firms holding ERMs that benefit from the TMTP should adopt the same approach to an assessment of NNEG and other risks for their ICAS TP calculations as they do for Solvency II TP calculations for the purposes of calculating TMTP to ensure consistency between the calculation bases; and
(v) Firms should consider whether they need to revise their internal models in response to any changes as above.
Responses and next steps
This consultation closes on Sunday 30 September 2018. The PRA invites feedback on the proposals set out in this consultation. Please address any comments or enquiries to CP13_18@bankofengland.co.uk.
The proposed implementation date for the proposals in this CP is Monday 31 December 2018.
The PRA recognises that the consequences of applying the new calibrations in the proposed updates to SS3/17 may be significant for some firms. In such cases, the PRA would consider making a proportionate allowance for that impact (ie as a result of these new proposals) on the firm. The PRA would expect this to be a short phase-in period, dependent on the circumstances of the firm, unlikely to exceed 3 years in any event. The PRA would not expect firms to require any phase in period in relation to the expectations in SS3/17 published in July 2017.