Poland: Mass lapse potential

Poland is exploring the use of new techniques for its life insurance markets. But the make-up of the country’s life products means it will not be pushing into reinsurance anytime soon, the financial regulator, the KNF, says.

What is the current status of life reinsurance in Poland?

In Poland, reinsurance in life insurance is generally very low compared to reinsurance in non-life insurance. In particular, we practically do not record any asset intensive reinsurance or longevity reinsurance. In contrast to the portfolios of countries such as France or UK, our insurance companies have few pension insurance with the so-called long-term guarantees, and it is mainly for such a portfolio that asset intensive reinsurance contracts are dedicated.

If such inquiries will appear, the KNF will verify such solutions individually and assess whether these proposed solutions offer real risk transfer and do not generate basis risk.

What kinds of concerns might you have with life reinsurance or are there any other types of risk transfer in Poland currently being considered by life insurers?

First of all, the reinsurance agreement must offer a real risk transfer. As a supervisor, we always pay attention to this. Recently, companies have been contacting us with questions about the possibility of using mass lapse reinsurance. According to the EIOPA Opinion on the use of risk mitigation techniques by insurance undertakings, in such a case, companies should demonstrate to us that these agreements provide a real and effective transfer of risk and do not generate a basis risk. We do not agree to empty reinsurance treaty, the sole purpose of which is to reduce capital requirements and there is no real transfer of risk. Another risk that we see in this type of agreements is proper inclusion of them in the calculation of capital requirements, in accordance with Solvency II regulations. In our process of assessing insurance companies (Risk Assessment Framework), one of the criteria that significantly affects the final score of the assessment is the adjustment that is applied if the insurance companies use a reinsurance contract as part of the SCR calculation, the subject of which is the risk of loss of basic own funds caused by the realization of a negative scenario/event.

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