Insurers and regulators need to adopt the idea of characterizing stress tests scenario frequency as:
Or something equivalent.
With the idea that it is reasonable for an insurer to prepare for a Realistic Disaster Scenario, but not practical to be prepared for all Worst Case scenarios. Not practical because the insurance would cost too much and less insurance would be sold.
With such a common language about frequency relating to stress tests, the results of the stress testing and the response to those results can make much more sense.
The outcomes of stress testing then fall into a pattern as well.
- An insurer should be able to withstand normal volatility without any lasting reduction to capital.
- An insurer should be able to withstand a Realistic Disaster for most of their risks without a game changing impairment of capital, i.e. it would be realistic for them to plan to earn their way back to their desired level of capital. For the most significant one or two risks, a Realistic Disaster may result in Capital impairment that requires special actions to repair. Special actions may include a major change to company strategy.
- An insurer can usually withstand a Worst Case scenario for most of their risks with the likelihood that for some, there will be an impairment to capital that requires special actions to repair. For the largest one or two risks, the insurer is unlikely to be able to withstand the Worst Case scenario.
Those three statements are in fact a requirement for an insurer to be said to be effectively managing their risks.
So the ORSA and any other stress testing process should result in the development of the story of what sorts of stresses require special management actions and what types result in failure of the insurer. And for an insurer with a risk management program that is working well, those answers should be known for all but one or two of their risks. Those would the second and third largest risks. An insurer with a perfect risk management program will not have very much daylight between their first, second and third largest risks and therefore may well be able to survive some worst case scenarios for even their largest risks.