Solvency 2 and the magic behind the 99,5% limit

Choosing a limit for the probability of ruin is not an obvious task and we have no ambition to change here the theoretical and practical choices made by the regulators for Solvency 2.

As you know some pretend that the figure appeared all of a sudden, with no real discussion within the industry. Anyway, the famous 99,5% over a one-year horizon is now heavily embedded in regulation in article 101 of the directive.

But how does the 99,5% reacts when applied to real world or how compatible is this « magic » with reality?

1 the 99,5 %, an economic perspective

The issues in our view don’t lie into the figure itself but what it reveals regarding the conception of the industry in regulators’ eyes: for regulators the disappearance of an insurance company should be as remote as possible, and only under highly stressed situations. This is no wonder, for the main mission of the regulator is to guarantee as safe an industry as possible. Regulators are here to prevent bankruptcy and to guarantee that companies will exist to pay when needed.

Adopting a 99.5% limit is, in the real world, trying to get rid of most potential scenarios of disappearance of companies.

But it is commonly accepted that renewal of companies and destruction of capital is a natural tendency of capitalism. Even if you are not an adept of Schumpeter and of his creative destruction, you may accept that capital renewal is playing a role in the efficiency of capitalism. As stated by Jacques Banville: « Everybody knows that a cent invested in year one of our era would be today a mass of gold covering the entire globe. The assumption is however stupid. What balances it is that a capital is bound to be destroyed several times during 19 centuries »[1].

This is why people with fortunes dating hundreds of years back are so rare. There is a constant renewal of capital through renewal of companies in capitalism. Anti-capitalists even see it as a major source of evils, especially in the social and human field. The critics are always about the human cost involved in this « arbitrage », not really in its association to capitalism.

This cycle of disappearance is a way of getting rid of non-performing assets, permitting a constant and good allocation of capital. This case was illustrated by the destruction of carriages in favour of cars manufacturers.

And we, insurers, are professionals of capital allocation. Oddly enough it is the part of the system that is in charge of the regulation of capital allocation, the financial system, that is prevented from efficient internal capital allocation. And the protection lies in this 99,5% limit.

I think this protection is incredibly costly and in fact impossible to sustain in the longer term.

For those who have any doubt, just take a view at the 2008 crisis and the cost involved to prevent bankruptcies of banks. Billions pumped into the economy with limited success, reduction in the number of banks, reduced competition and last but not least bankruptcies of Nation States.

2 In insurance the attempts to implement solvency 2 are revealing the problems related to the choice of this limit. Let’s explore some:

the regulator itself had to cheat and to invent exceptions so that the scheme fits into reality. The case for OECD sovereign bonds considered as « default risk free » assets is a stunning example! Under solvency 2 Greece bonds are low risk assets…

The quiet acceptance of this incredible idea that government bonds were risk free assets and required no capital charge is in contradiction to any ERM system. However it was a nice way to get rid of a potential problem: by stating that OECD sovereigns were risk free the governments were making it easier to finance their deficit.

The combination of 99,5% and one year horizon has important consequences on the capital charge of equities. The critics made by the industry are in fact the critics of the impossibility to risk significant amount of assets when your balance sheet is supposed to be « as safe as the Bank of England » (if by any chance you think Bank of England is safe). Once you have adopted 99,5% and one year, the capital charge is a mere consequence of calculations based on volatility.

The number of tricks invented to try and make compatible 99,5% and real economy are many and sometimes weird. Liquidity premiums, contra cyclic premiums, and now volatility balancers belong to these.

I suspect, without any proof, that it is the growing conscience of the impossibility to make compatible the 99,5% and the real world that the ORSA is taking such an importance in the current discussions; It is the place where reality meets regulations, as Kafka meet Alice in Wonderland.

[1] « Tout le monde sait qu’un sou placé à intérêts composés depuis l’an premier de notre ère formerait une masse d’or plus grosse que notre globe lui-même. Sur le papier, cette progression arithmétique n’est pas contestable. L’hypothèse est pourtant absurde. Ce qui la corrige, c’est qu’un capital est condamné à être détruit un grand nombre de fois dans le cours de dix-neuf siècles. » J Bainville.

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