Office of the Superintendent of Financial Institutions
This chapter provides an overview of the Life Insurance Capital Adequacy Test (LICAT) guideline and sets out general requirements. Details on specific components of the LICAT are contained in subsequent chapters.
The LICAT measures the capital adequacy of an insurer and is one of several indicators used by OSFI to assess an insurer's financial condition. The ratios should not be used in isolation for ranking and rating insurers.
Capital considerations include elements that contribute to financial strength through periods when an insurer is under stress as well as elements that contribute to policyholder and creditor protection during wind-up.
The Total Ratio focuses on policyholder and creditor protection. The formula used to calculate the Total Ratio is:
The Core Ratio focuses on financial strength. The formula used to calculate the Core Ratio is:
Available Capital comprises Tier 1 and Tier 2 capital, and involves certain deductions, limits and restrictions. The definition encompasses Available Capital within all subsidiaries that are consolidated for the purpose of calculating the Base Solvency Buffer, which is described below. Available Capital is defined in Chapter 2.
The amount of the Surplus Allowance included in the numerator of the Total and Core Ratios is based on provisions for adverse deviations (PfADs) calculated under the Canadian Asset Liability Method (CALM), or any other method prescribed under the
Standards of Practice of the Canadian Institute of Actuaries, that is used to determine insurance contract liabilities reported on the insurer's financial statements.Footnote 1 Any PfAD included in the Surplus Allowance to account for a specific risk must correspond to a PfAD included in the total liability reported in financial statements. The specific PfADs included in the Surplus Allowance used to calculate the LICAT ratios are:
All other PfADs, including PfADs for economic assumptions other than those for risk-free interest rates (e.g. credit spreads , foreign currencies, and investment expenses), PfADs for non-economic assumptions other than those listed above (e.g. operational risk), and PfADs associated with segregated fund contracts, are excluded from the Surplus Allowance.
Subject to limits, excess deposits placed by unregistered reinsurers (qq.v. sections 6.8.1 and 10.5.4) and claims fluctuation reserves (q.v. section 6.8.4) may be recognized as Eligible Deposits in the calculation of the Total Ratio and Core Ratio. Recognition of these amounts is subject to the criteria for risk transfer described in section 10.5.
Insurers' capital requirements are set at a supervisory target level that, based on expert judgment, aims to align with a conditional tail expectation (CTE) of 99% over a one-year time horizon including a terminal provision. The risk capital requirements in this guideline are used to compute capital requirements at the target level.
An insurer's Base Solvency Buffer (q.v. section 11.3) is equal to the sum of the aggregate capital requirement net of credits, for each of six geographic regions, multiplied by a scalar of 1.05. An aggregate capital requirement is calculated for:
Liabilities and their associated risks are allocated to geographic regions based on where the original policy underlying the liability was written directly. Assets backing liabilities are allocated to the same region as the liabilities that they back. Assets backing surplus, if held in a branch, are allocated to the region in which the branch is registered, otherwise they are allocated to the region in which the legal entity holding the assets is incorporated.
The aggregate capital requirement within a geographic region comprises requirements for each of the following five risk components:
Aggregate requirements are reduced by credits for qualifying in-force participating and adjustable products (Chapter 9), and risk diversification (Chapter 11). Additionally, it is possible to obtain credit (via a reduction of specific risk components or an amount recognized in Eligible Deposits) for the following risk mitigation arrangements:
Any arrangement (including securitization) under which a third party assumes, or agrees to indemnify an insurer for losses arising from insurance risk is treated as reinsurance for capital purposes, and is subject to the requirements in Chapter 10.
Collateral, guarantees and credit derivatives may be used to reduce the credit risk requirements for fixed-income financial assets and registered reinsurance assets. The conditions for their use and the capital treatment are described in sections 3.2, 3.3 and 10.5.3. Collateral and letters of credit may be used to reduce the deductions from available capital for unregistered reinsurance as described in section 10.3, subject to the conditions in section 10.4. Derivatives serving as equity hedges may be applied to reduce the market risk requirements for equities, as described in section 5.2.4, and derivatives serving as foreign exchange risk hedges may be applied to reduce the requirement as described in sections 5.6.2 and 5.6.4. Asset securitization may be used to reduce credit risk requirements as provided for in Guideline B-5: Asset Securitization; guarantees providing tranched protection are treated as synthetic securitizations, and fall within the scope of the securitization guideline.
Reinsurance that is intended to mitigate credit or market risks associated with a ceding insurer's on-balance sheet assets (e.g. equity risk, real estate risk), irrespective of whether it mitigates other risks simultaneously, must meet the conditions and follow the capital treatment specified in sections 10.5.3 and 10.5.4 in order for an insurer to reduce the requirements for these risks.
The Life Insurance Margin Adequacy Test (LIMAT) Ratios are designed to measure the adequacy of assets in Canada of foreign insurers. These ratios and their components (Available Margin, Surplus Allowance and Required Margin) are described in Chapter 12, "Life insurers Operating in Canada on a Branch Basis".
The LIMAT is only one element in the determination of the required assets that foreign insurers must maintain in Canada. Foreign insurers must also vest assets in Canada pursuant to section 610 of the
Insurance Companies Act.
OSFI has established a Supervisory Target Total Ratio of 100% and a Supervisory Target Core Ratio of 70%. The Supervisory Targets provide cushions above the minimum requirements, provide a margin for other risks, and facilitate OSFI's early intervention processFootnote 4. The Superintendent may, on a case by case basis, establish alternative targets in consultation with an insurer based on that insurer's individual risk profile.
Insurers are required, at minimum, to maintain a Total Ratio of 90% and a Core Ratio of 55%Footnote 5. Insurers should refer to Guideline A4 - Regulatory Capital and Internal Capital Targets for OSFI's definitions and expectations around the Minimum and Supervisory Target ratios and expectations regarding internal capital targets and capital management policies.
Unless indicated otherwise, the starting basis for the amounts used in calculating Available Capital, Available Margin, Surplus Allowance, Base Solvency Buffer, Required Margin and any of their components are those reported in, or used to calculate the amounts reported in, the insurer's financial statements and other financial information contained in the
Life Quarterly Return and
Life Annual Supplement, all of which have been prepared in accordance with Canadian GAAPFootnote 6 in conjunction with OSFI instructions and accounting guidelines.
These financial statements and information are required to be adjusted as specified below to determine the carrying amounts that are subject to capital charges or are otherwise used in LICAT calculations. The Canadian GAAP financial statements and information should be restated for LICAT purposes and reported in accordance with the following specifications:
The Appointed Actuary is required to sign, on the front page of the
LICAT Quarterly ReturnFootnote 9, an opinion in accordance with the
Standards of Practice of the Canadian Institute of Actuaries.
The text of the required opinion is:
"I have reviewed the calculation of the LICAT Ratios of [Company name] as at [Date]. In my opinion, the calculations of the components of Available Capital, Surplus Allowance, Eligible Deposits and Base Solvency Buffer have been determined in accordance with the
Life Insurance Capital Adequacy Test guideline and the components of the calculation requiring discretion were determined using methodologies and judgment appropriate to the circumstances of the company."
[Note: For a foreign insurer "LICAT Ratios", "Available Capital" and "Base Solvency Buffer" are replaced by "LIMAT Ratios", "Available Margin" and "Required Margin".]
The memorandum that the Appointed Actuary is required to prepare under the
Standards of Practice (LICAT Memorandum) to support this certification must be available to OSFI upon request.
Each life insurer is required to have an authorized Officer endorse the following statement on the
LICAT Quarterly Return:
"I confirm that I have read the
Life Insurance Capital Adequacy Test guideline and related instructions issued by the Office of the Superintendent of Financial Institutions and that this form is completed in accordance with them."
The Officer attesting to the validity of this statement on the
LICAT Quarterly Return at year end must be different from the insurer's Appointed Actuary.
Life insurers are required to retain an Auditor appointed pursuant to section 337 or 633 of the ICA to report on the year-end
LICAT Quarterly Return in accordance with the relevant standards for such assurance engagements, as promulgated by the Canadian Auditing and Assurance Standards Board (AASB).
Best Estimate Assumptions used to calculate the capital requirements for insurance and market risks are the assumptions used in the CALM base scenario, and consist of:
Insurers should adhere to the
Standards of Practice of the Canadian Institute of Actuaries on materiality and approximations with respect to approximations permitted within the LICAT. All approximations used, along with the vetting completed to measure the effectiveness of approximations, and the steps taken to refine and correct ineffective approximations, should be reported in the LICAT Memorandum.
In addition, insurers should adhere to the following specifications:
Approximations of LICAT calculations are not permitted if most of the data or information is available from other internal processes and this data or information is used to calculate liabilities for financial statement purposes. For example, if an insurer performs its CALM testing in real time, it should not use in-arrears asset and liability cash flows for LICAT purposes. In this case, approximations for LICAT should only be used if the actual calculation cannot be performed in real time (i.e. it is done in-arrears for valuation).
Insurers should use approximations consistently from quarter to quarter, unless reviews of their effectiveness require a modification to improve accuracy, or an improvement in the insurer's processes renders the approximation unnecessary.
The following approximations may be used in the calculation of the relevant LICAT components:Footnote 10
Sections 184.108.40.206, 220.127.116.11 and 18.104.22.168: Insurers may approximate marginal capital requirements by using quarter-in-arrears data to determine the ratio of the marginal solvency buffer to the standalone solvency buffer, and then multiplying this ratio by the current standalone solvency buffer. Additionally, the marginal requirements in sections 22.214.171.124 and 126.96.36.199 may be approximated using quarter-in-arrears data if the amount of capital held by third-party investors or attributable to non-controlling interests remains well below the applicable limit.
Section 188.8.131.52.2: An insurer may use quarter-in-arrears data to determine the individual and total policy requirements
Section 3.1.2: Quarter-in-arrears cash flows may be used to approximate the effective maturities of credit exposures subject to this section. If this approximation is used, an insurer should make appropriate adjustments for significant changes in asset inventory, disposals, maturities, etc. that have occurred since the last quarter-end.
In low-interest rate environments where an insurer is using the weighted average approach to calculate the effective maturity of exposures to a connected group, an insurer may apply weights based on market value instead of undiscounted cash flows to the individual exposures.
Sections 3.1.7 and 3.1.8: An insurer may estimate the proportions of reinsurance receivables and premium receivables that have been outstanding less than 60 days and more than 60 days using quarter-in-arrears data.
Section 3.1.7: An insurer may approximate reinsurance assets by reinsurer for the purpose of applying the zero floor by using quarter-in-arrears data to determine the percentage of reserves ceded to each reinsurer, and multiplying these percentages by total current ceded liabilities.
Sections 5.1.2 and 5.1.3: Quarter-in-arrears cash flows, in combination with roll-forwards and true-ups that an insurer uses for its in-arrears CALM cash flow testing, may be used to determine the most adverse scenario and project all cash flows.
Section 184.108.40.206: Second-order impacts of restating dividends on paid-up additions may be ignored.
Sections 220.127.116.11 and 6.1: Investment income taxes and tax timing differences may be projected under the CALM worst interest rate scenario instead of the base scenario.
Section 5.6.1: The maximum amount of the offsetting short position for a currency within a geographic region may be approximated as:
The basic capital requirement
BCRcurrency is the sum of the following amounts that are denominated in the currency under consideration:
Insurance liabilities, net amounts at risk, and segregated fund guarantee values in the above sum should be based on Best Estimate Assumptions, and should be measured net of all reinsurance. The guaranteed value of segregated funds is defined to be the actuarial present value of all benefits due to policyholders assuming that all account values are zero, and remain at zero for the life of the policies.
Up to and including year-end 2020, the maximum amount of the offsetting short position for a currency within a geography may also be approximated as:
Lcurrency is the amount of liabilities in the currency under consideration, and ∑L is the total amount of liabilities in all currencies in the geography.
Sections 6.2.1 and 6.5.1: Insurers may use cash flows with a lag of up to one year when conducting the tests used to determine which products are life supported and death supported, or lapse supported and lapse sensitive.
Sections 18.104.22.168: Insurers may use a lag of up to one year when calculating the ratio of the individual life volatility risk component to the following year's expected claims.
Sections 6.4.3, 6.4.4, 6.5.3, 6.5.4, 6.6.1: For the volatility and catastrophe components of morbidity and lapse risks, the shocks applied to best estimate assumptions are for the first year only, and zero thereafter. If an insurer, for example due to software limitations, is unable to apply shocks for partial calendar years, it may instead apply the LICAT insurance risk shock for the remaining portion of the calendar year, and a different shock for the entirety of the following calendar year. The second shock should be equal to the LICAT shock multiplied by the proportion of the current calendar year that has elapsed. For example, if the insurer is preparing a LICAT filing for the end of Q1 20x1, and LICAT specifies an insurance risk shock of 30%, then the insurer may use a shock of 30% for the remainder of 20x1, and a 7.5% shock for all of 20x2.
If this approximation is used for expense risk, the second shock representing the carryover from the first year should be added to the 10% shock in the second year.
Section 6.5.3: An insurer may approximate the requirement for lapse volatility by determining the present value of cash flows for a shock of +/- 30% in the first year, and subtracting the present value of best estimate cash flows.
Sections 6.8.1, 6.8.4, and 9.2: In order to determine a marginal insurance risk solvency buffer, insurers may use quarter-in-arrears data to determine the ratio of the marginal insurance risk solvency buffer to the standalone insurance risk solvency buffer, and then apply this ratio to the current standalone insurance risk solvency buffer. An insurer may use this approximation if changes from the previous quarter (e.g. diversification credit or the relative weights of different risks) do not have a material impact on the results.
Notwithstanding the minimum and target Total and Core Ratios described in the Guideline, Canadian life insurance companies are required to maintain a minimum amount of Available Capital, as calculated in this Guideline, of $5 million or such amount as specified by the Superintendent.
If approximations are permitted by the CIA Standards of Practice and used to calculate the PfADs those approximations should continue to be used for LICAT purposes.
Return to footnote 1
The PfADs in the Surplus Allowance include insurance risk PfADs for all business that an insurer has assumed under modified coinsurance arrangements, and exclude insurance risk PfADs for business that the insurer has ceded under registered modified coinsurance arrangements.
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Within this guideline, the term "foreign life insurer" has the same meaning as life insurance "foreign company" in section 2 of the
Insurance Companies Act.
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Industry-wide Supervisory Targets are not applicable to regulated insurance holding companies and non-operating insurance companies.
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Regulated insurance holding companies and non-operating insurance companies are required to maintain a minimum Core Ratio of 50%.
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The Canadian Accounting Standards Board has adopted International Financial Reporting Standards (IFRS) as Canadian GAAP for publicly accountable enterprises, including insurers. The primary source of Canadian GAAP is the Chartered Professional Accountants of Canada Handbook.
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Composite insurance subsidiaries that write both life insurance and property and casualty insurance are included within the scope of consolidation.
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Non-life solvency regulated financial corporations include entities engaged in the business of banking, trust and loan business, property and casualty insurance business, the business of cooperative credit societies or that are primarily engaged in the business of dealing in securities, including portfolio management and investment counselling.
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The Appointed Actuary is only required to sign the front page of the LICAT Quarterly Return for submissions made at year end.
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Only the approximations listed below may be used for LICAT components that affect the LICAT ratios materially. Other immaterial approximations may be used in the determination of the LICAT ratios.
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