Tug of War Between Intertwined Roles
A question posed to RISKVIEWS:
Do you have a clear distinction between “What’s Risk vs What’s Actuarial?” It seems that the roles of Risk Management and Actuarial are utterly intertwined and overlapping, thus causing utter confusion, within the company of my employ. While we have internally agreed to a segregation of duties over two years ago, the organization has barely moved forward to align itself accordingly.
Any attempt I have made to seek external guidance has not resulted in any definitive clarity. In response to the question “What’s Risk vs What’s Actuarial?”, most consultants offer “it depends on the company”. Solvency II guidance seems to indiscriminately interchange, say, risk management function (risk management is everyone’s job) with Risk Management Department.
I should clarify – when I refer to Actuarial, I am referring to “all four legs of the actuarial stool” – namely, Pricing, Modeling/Projections, Valuation, and Experience Studies.
In fact, it really does depend upon the company. That is because actuarial roles are extremely broad in some companies and very narrow in others.
The four legs of the actuarial stool referenced, “Pricing, Modeling/Projections, Valuation, and Experience Studies” are in fact a moderately broad definition. In the most narrowly drawn situations, the actuarial role is limited solely to situations where an actuarial opinion is required by law or regulation. In companies that define the actuarial role in that manner, there is almost no overlap with the Risk function.
But Risk can be defined differently in different companies as well. In some companies, the definition of the Risk function takes in only what is needed to get capital relief from regulators or rating agencies. Or to satisfy other requirements of the same audiences.
In companies where both the Actuarial and Risk roles are broadly defined, there is great potential for overlap.
- The Actuarial Function in these firms will include not only “Pricing, Modeling/Projections, Valuation, and Experience Studies” but may also have a role in broad financial oversight and or broad risk oversight. In fact, RISKVIEWS worked for two insurers with such a broad definition of the actuarial function.
- A broadly defined Risk function in these firms will overlap most clearly with those last two roles. With the installation of a separate Risk function, it seems clear that the broad risk oversight once performed by the Actuarial function needs to be surrendered. But there are Risk aspects of all five of the other functions listed.
- Pricing – A strong Risk function will want to make sure that pricing is appropriate for the risks of the activities
- Modeling/Projections – A strong Risk function will want to perform stress tests that are in fact simple projections.
- Valuation – Since the definition of the capital of the firm is totally dependent upon the valuation of the liabilities of the firm and the Risk function usually has a major role regarding capital adequacy, a strong Risk function will have a high interest in Valuation of Liabilities.
- Experience Analysis – The process that has been developed by actuaries to update Liabilities from year to year includes the collection and analysis of quite a large amount of information about the emerging experience of the firm. This information is also used in Pricing. And should be a main part of the information needed to evaluate the risks of the firm. Which makes this area of high importance to Risk.
- Broad Financial Oversight – Actuaries in many insurers have already lost this role to CFOs years ago. But in the cases where they have not, the CRO becomes a new challenger with the idea that Risk should oversee the strategic risk and capital budgeting processes.
Some of the conflict is a matter of competition between the leader of a “new” function within the firm and the leader of an “old” function. The firms where this conflict is the worst would be the firms where there is a broadly defined Actuarial and Risk function. The development of a new Risk function in these firms can be interpreted as Actuarial losing influence. This perception would add to the conflict and to the confusion. Risk will want to control its own destiny, so would naturally want to control much of what had “always” been Actuarial. Actuarial would not want to lose any responsibility and may therefore seek to maintain parallel activities even where Risk is now performing a former Actuarial function.
At the other extreme, a number of companies see the very high degree of overlap between the Actuarial function and the Risk function and have named their Chief Actuary to be their Chief Risk Officer. The success of that approach will depend upon the degree to which the Chief Actuary is willing to appropriately prioritize the activities needed to support the new responsibilities. In these cases, the conflict described above between Risk and Actuarial will take place, but a large part of it will be inside the Chief Actuary / CRO’s head.