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					ALM Assessment                                                                                                           Name of Insurer                                                                                                   Name of Assessor




 Sort Reg Item Element         Strong = 4                                 Acceptable = 3                                      Needs Improvement = 2                       Weak = 1 or 0                               Rating Explanation
 1.00 2.1   1 Existence of ALM Formal ALM program exists and              Formal ALM program exists and                       No formal ALM program. Some                 No formal ALM program, active
               program         covers all main elements described in      covers most main elements described                 elements of ALM exist, such as active       management of liquidity, or stress
                               the regulation.                            in the regulation. Necessary action is              management of liquidity. Stress testing     testing (other than DCAT).
                                                                          being taken to improve its scope and                is limited to DCAT.
                                                                          effectiveness.
 1.05 2.1     7 Level of           The sophistication of the strategies,  The sophistication of the strategies,               The sophistication of the strategies,       The strategies, processes, and models
                 sophistication of processes, and models used are fully processes, and models used are                        processes, and models used are too          used are inadequate in relation to the
                 the ALM program commensurate with the nature, scale, acceptable in relation to the nature,                   basic to fully capture the nature, scale,   nature, scale, and complexity of the
                                   and complexity of the risk exposures. scale, and complexity of the risk                    and complexity of the risk exposures.       risk exposures.
                                                                          exposures, but some strengthening is
                                                                          desirable.
 1.10 2.1     2 Objectives         Objectives appropriately balance risks Objectives appropriately balance risks              Objectives exist but are unclear,      No quantitative or qualitative
                                   and rewards and reflect the insurer’s and rewards, but do not appear to take               incomplete, or otherwise inadequate as objectives have been established for
                                   assessment of policyholders’           policyholders’ expectations into                    a basis for ALM.                       ALM.
                                   expectations.                          account.
 1.15 2.2     9 Economic basis of The ALM program is based on             The ALM program considers                           The ALM program is based on a               The ALM program is based on a very
                 ALM               economic value and considers the       economic value, but objectives are                  variety of short-term measures of           few short-term measures of financial
                                   change in economic value that will     largely focused on short-term                       financial performance, such as              performance, for example, focusing
                                   arise from a range of plausible        measures of financial performance.                  earnings, regulatory solvency               solely on the liquidity ratio.
                                   scenarios. Accounting and regulatory                                                       requirements, and liquidity ratios.
                                   requirements are reflected as
                                   constraints on the cash flows valued.
 1.20 2.3     13 Development of    Senior management is actively          Senior management reviews and                       Senior management reviews the ALM           Senior management reviews the ALM
                 ALM policy        involved in the development of ALM understands the ALM policy                              policy developed by others, but may         policy developed by others, and some
                                   policy and is supportive of it.        developed by staff, and is supportive               not fully understand or be actively         members of senior management have
                                                                          of it.                                              supportive of it.                           significant concerns with it.

 1.25 3.1     19 Content of ALM      The ALM policy includes clear and           The ALM policy includes appropriate          The ALM policy includes descriptions        The ALM policy lacks descriptions of
                 policy              appropriate descriptions of all of the      descriptions of all of the following:        of all of the following: objectives; risk   one or more of the following:
                                     following: objectives; risk tolerance;      objectives; risk tolerance; nature of the    tolerance; nature of the risks; metrics     objectives; risk tolerance; nature of the
                                     nature of the risks; metrics used to        risks; metrics used to measure the           used to measure the risks; strategy for     risks; metrics used to measure the
                                     measure the risks; strategy for             risks; strategy for managing the risks;      managing the risks; and                     risks; strategy for managing the risks;
                                     managing the risks; and                     and responsibilities of those involved       responsibilities of those involved in the   and responsibilities of those involved
                                     responsibilities of those involved in the   in the implementation of ALM. Some           implementation of ALM. Some of the          in the implementation of ALM. Some
                                     implementation of ALM.                      of the information is unclear.               information is inappropriate or unclear.    of the information might also be
                                                                                                                                                                          inappropriate or unclear.
 1.30 2.1     6   Formulation of     Processes exist to ensure the               The business and professional                Responsibility for the formulation of       No ALM strategies have been
                  ALM strategies     application of a wide range of business     judgement of functional specialists,         ALM strategies is left to functional        formulated.
                                     and professional judgement to the           such as the actuary and investment           specialists, such as the actuary and
                                     results of the risk analysis in the         officer, are applied to the results of the   investment officer. There is little
                                     formulation of ALM strategies.              risk analysis in the formulation of          discussion of the strategies with senior
                                                                                 ALM strategies. Senior management            management.
                                                                                 reviews and concurs with the
                                                                                 strategies.




657dc622-70ae-43bd-8827-c65205df604e.xls                                                                              4/19/2010 10:08 PM                                                                                                         Page 1 of 7
ALM Assessment                                                                                                            Name of Insurer                                                                                                 Name of Assessor




 Sort Reg Item Element                 Strong = 4                                  Acceptable = 3                               Needs Improvement = 2                       Weak = 1 or 0                            Rating Explanation
 1.35 3.3 23 Content of ALM            The ALM strategy includes clear and         The ALM strategy includes clear and          The ALM strategy is either unclear or       The ALM strategy might be seriously
               strategy                complete descriptions of the manner in      complete descriptions of the manner in       incomplete in describing the manner in      deficient in describing the manner in
                                       which each category of risk will be         which each category of risk will be          which each category of risk will be         which each category of risk will be
                                       measured and managed, taking                measured and managed, and specific           measured and managed. It might lack         measured and managed. It might be
                                       account of the interactions between         strategies in respect of blocks of           specific strategies in respect of blocks    inconsistent with the risk tolerance,
                                       various risks; and specific strategies in   business whose risk characteristics          of business whose risk characteristics      liquidity position, or solvency position
                                       respect of blocks of business whose         materially differ from one another.          materially differ from one another, or      of the insurer. It might also be
                                       risk characteristics materially differ      However, it might not take explicit          fail to take explicit account of the        inconsistent with one or more of the
                                       from one another, taking account of         account of the interactions between          interactions between various risks or       other risk management policies of the
                                       the interactions between various            various risks or blocks of business. It      blocks of business. It takes account of     insurer, or fail to adequately describe
                                       blocks of business. It takes account of     takes account of the risk tolerance,         the risk tolerance, liquidity position,     the processes used to implement and
                                       the risk tolerance, liquidity position,     liquidity position, and solvency             and solvency position of the insurer. It    monitor the results of the strategy.
                                       and solvency position of the insurer. It    position of the insurer. It is consistent    might be inconsistent with one or more
                                       is consistent with and describes            with the other risk management               of the other risk management policies
                                       linkages to the other risk management       policies of the insurer, but might not       of the insurer. It describes the
                                       policies of the insurer. It describes the   describe the linkages to those policies.     processes used to implement and
                                       processes used to implement and             It describes the processes used to           monitor the results of the strategy.
                                       monitor the results of the strategy.        implement and monitor the results of
                                                                                   the strategy.
 1.40 2.3     14 Approval of ALM The board of directors approved the               The board of directors approved the          The board of directors approved the         The board of directors has not
                 policy          ALM policy, after taking account of               ALM policy, after considering some of        ALM policy, based on a presentation         approved the ALM policy, or has
                                 the asset-liability relationships, risk           the following factors: the asset-liability   by senior management and with little        approved it without discussion.
                                 tolerance, long-term risk and return              relationships, risk tolerance, long-term     discussion.
                                 requirements, liquidity requirements,             risk and return requirements, liquidity
                                 and solvency position of the insurer.             requirements, and solvency position of
                                                                                   the insurer.
 1.45 2.3     15 Senior                Senior management is actively               Senior management passively supports   Senior management leaves the                      Senior management impedes the
                 management            involved in ensuring the successful         the implementation of the ALM policy.  implementation of the ALM policy to               implementation of the ALM policy, for
                 responsibility for    implementation of the ALM policy.                                                  functional specialists, such as the               example, by acting in a manner
                 implementation of                                                                                        actuary and investment officer, with              contrary to its objectives or by failing
                 ALM policy                                                                                               little ongoing involvement.                       to provide necessary resources.
 1.50 2.3     16 Integration of        The ALM program is an integral part         The ALM program operates as an         The ALM program operates as                       The ALM program operates primarily
                 ALM                   of the insurer’s governance and             adjunct to the insurer’s governance    financial-management activity of                  as reporting activity of the actuary.
                                       business activities. ALM is usually         and business activities. ALM is        functional specialists, such as the               ALM is rarely, if ever, considered in
                                       considered in the context of business       sometimes considered in the context of actuary and investment officer. ALM               the context of business activities.
                                       activities such as planning, product        business activities such as planning,  is seldom considered in the context of
                                       development, pricing, and                   product development, pricing, and      business activities such as planning,
                                       performance assessment.                     performance assessment.                product development, pricing, and
                                                                                                                          performance assessment.

 1.55 2.3     18 Assessment of        Senior management and the board of           Senior management and the board of           Senior management and the board of          Senior management and the board of
                 effectiveness        directors assess the effectiveness of        directors assess the effectiveness of        directors assess the effectiveness of       directors assess the effectiveness of
                                      the ALM program annually or more             the ALM program annually. The ALM            the ALM program annually. The ALM           the ALM program less frequently than
                                      frequently. The ALM policy and its           policy and its implementation are            policy and its implementation are           annually. The ALM policy and its
                                      implementation are promptly revised,         sometimes revised, as appropriate, to        rarely revised to ensure that the ALM       implementation are rarely revised to
                                      as appropriate, to ensure that the ALM       ensure that the ALM program is               program is effective and responds to        ensure that the ALM program is
                                      program is effective and responds to         effective and responds to changes in         changes in the business and the             effective and responds to changes in
                                      changes in the business and the              the business and the external                external environment.                       the business and the external
                                      external environment.                        environment.                                                                             environment.
 2.00 2.1     3   Risk identification Formal process for identifying all           Risks arising from the insurer’s assets      Identification of risks is limited to the   No formal process exists to identify
                                      material risks arising from the              and liabilities and their interaction are    review and discussion of DCAT               risks. If DCAT is performed, its
                                      insurer’s assets and liabilities and their   identified using quantitative analyses,      results.                                    results are not used in the context of
                                      interaction, using both interview            supplemented by board and senior                                                         ALM.
                                      techniques and quantitative analyses.        management discussion.




657dc622-70ae-43bd-8827-c65205df604e.xls                                                                                4/19/2010 10:08 PM                                                                                                      Page 2 of 7
ALM Assessment                                                                                                        Name of Insurer                                                                                               Name of Assessor




 Sort Reg Item Element                Strong = 4                                 Acceptable = 3                           Needs Improvement = 2                     Weak = 1 or 0                              Rating Explanation
 2.05 2.1   4 Risk analysis           Qualitative and quantitative analysis of   Qualitative analysis of the underlying   Qualitative analysis of the underlying    Little or no qualitative or quantitative
                                      the underlying causes of each risk, the    causes of each risk, the relationships   causes of each risk, but with             analysis of the underlying causes of
                                      relationships between various risks,       between various risks, and the           inadequate attention to the               risks.
                                      and the relationships between risks        relationships between risks and          relationships between various risks,
                                      and external factors.                      external factors.                        and the relationships between risks
                                                                                                                          and external factors.
 2.10 4.1     27 Embedded options The ALM tools and techniques                   The ALM tools and techniques             The ALM tools and techniques              The ALM tools and techniques
                                  employed by the insurer take into              regularly employed by the insurer do regularly employed by the insurer do          regularly employed by the insurer do
                                  account risks posed by options                 not take into account risks posed by     not take into account risks posed by      not take into account risks posed by
                                  embedded in both assets and insurance          options embedded in its assets and       options embedded in its assets and        options embedded in its assets and
                                  policies, and are used to assess the           insurance policies. However, separate insurance policies. However,                 insurance policies. The insurer has not
                                  effects such embedded options might            quantitative analyses have been          qualitative consideration has been        considered the effects such embedded
                                  have throughout the life of the                performed to assess the effects such     given to the effects such embedded        options might have throughout the life
                                  insurance policies.                            embedded options might have              options might have throughout the life    of the insurance policies.
                                                                                 throughout the life of the insurance     of the insurance policies.
                                                                                 policies.
 2.15 2.1     8   Risks covered by The ALM program covers all risks              The ALM program covers the most          Some significant risks requiring the      The ALM program is narrowly
                  the ALM program requiring the coordination of assets           significant risks requiring the          coordination of assets and liabilities    focused, covering only limited aspects
                                   and liabilities including (to the extent      coordination of assets and liabilities, are not covered by the ALM program.        of the risks requiring the coordination
                                   relevant) liquidity risk, market risk,        but some risks are not dealt with to as                                            of assets and liabilities.
                                   and underwriting risk.                        fully as would be commensurate with
                                                                                 the risk exposures.
 2.20 2.2     12 Risk metrics         The ALM program incorporates a             The ALM program incorporates a           The ALM program incorporates at           Risk metrics are limited to regulatory
                                      variety of appropriate risk metrics to     limited number of appropriate risk       least one appropriate risk metric to      compliance measures, such as liquidity
                                      measure the exposure of economic           metrics to measure the exposure of       measure the exposure of economic          and capital adequacy ratios.
                                      value to risks, providing a                economic value to risks, providing a     value to risks, but the risk metrics
                                      comprehensive view of risk.                reasonably complete view of risk.        provide an incomplete view of risk.
 2.25 4.1     26 Measurement of       The insurer uses appropriate metrics to    The insurer uses appropriate metrics to The insurer uses metrics to measure        The insurer does not measure its
                 market risk          measure exposure to market risk and        measure exposure to market risk and exposure to market risk and related            exposure to market risk and related
                                      related credit risk. The sophistication    related credit risk. The sophistication credit risk. However, the                  credit risk.
                                      of the models is fully commensurate        of the models is acceptable in relation sophistication of the models is
                                      with the complexity of its portfolios of   to complexity of its portfolios of       inadequate in relation to complexity of
                                      products and investments.                  products and investments.                its portfolios of products and
                                                                                                                          investments.
 2.30 2.1     5   Quantification of   The level of risk exposure is quantified   The level of risk exposure is quantified The level of risk exposure is             The level of risk exposure has not
                  risk exposure       using appropriate techniques, and the      using appropriate techniques, but the quantified, but the techniques used do       been quantified.
                                      expected rewards and costs associated      expected rewards and costs associated not capture all relevant and material
                                      with the risk exposure are assessed.       with the risk exposure are not           risks.
                                                                                 explicitly assessed.
 2.35 3.2     20 Risk tolerance       The risk tolerance statement sets out      The risk tolerance statement sets out The risk tolerance statement is              The risk tolerance statement is either
                 statement            quantitative and qualitative tolerance     quantitative and qualitative tolerance incomplete, for example, setting out        nonexistent or seriously deficient in
                                      levels overall, together with tolerance    levels overall, together with tolerance tolerance levels overall but not for       terms of completeness or the manner
                                      limits for each relevant and material      limits for each relevant and material    each relevant and material category of    in which risk tolerance is expressed.
                                      category of risk, taking into account      category of risk, but does not take into risk (or vice versa), or setting out
                                      the relationships between these risk       account the relationships between        qualitative but not quantitative
                                      categories. The manner in which risk       these risk categories. The manner in tolerance levels (or vice versa). It
                                      tolerance is expressed and reported is     which risk tolerance is expressed and might also fail to take into account the
                                      commensurate with the nature, scale,       reported is commensurate with the        relationships between risk categories.
                                      diversity, and complexity of the           nature, scale, diversity, and complexity
                                      business.                                  of the business.




657dc622-70ae-43bd-8827-c65205df604e.xls                                                                            4/19/2010 10:08 PM                                                                                                    Page 3 of 7
ALM Assessment                                                                                                          Name of Insurer                                                                                               Name of Assessor




 Sort Reg Item Element               Strong = 4                                   Acceptable = 3                              Needs Improvement = 2                      Weak = 1 or 0                           Rating Explanation
 2.40 3.2 21 Risk tolerance          The risk tolerance levels are fully          The risk tolerance levels are largely       The risk tolerance levels are              The risk tolerance levels are
               levels                consistent with the objectives,              consistent with the objectives and          inconsistent with the objectives and       inconsistent with the solvency position
                                     management philosophy, and solvency          management philosophy of the insurer,       management philosophy of the insurer,      of the insurer.
                                     position of the insurer.                     and fully consistent with its solvency      but fully consistent with its solvency
                                                                                  position.                                   position.
 3.00 4.1     24 Tools and           The insurer employs tools and                The insurer employs tools and               The insurer employs tools and              The insurer employs tools and
                 techniques          techniques for the measurement and           techniques for the measurement and          techniques for the measurement and         techniques for the measurement and
                                     management of risks fully                    management of risks acceptable in           management of risks that do not            management of risks that are seriously
                                     commensurate with the nature, scale,         relation to the nature, scale, diversity,   readily or appropriately deal with the     inadequate in relation to the nature,
                                     diversity, and complexity of its             and complexity of its business. They        nature, scale, diversity, and complexity   scale, diversity, and complexity of its
                                     business. They are capable of                are capable of producing a firm-wide        of its business. They are incapable of     business. They are incapable of
                                     producing a firm-wide measurement of         measurement of risks, but such              producing a firm-wide measurement of       producing a firm-wide measurement of
                                     risks, and such measurement is               measurement might not be regularly          risks.                                     risks.
                                     produced and used.                           produced and used.
 3.05 4.1     25 Data                The insurer has developed and                The insurer has developed and            The insurer has developed and                 The insurer has not developed, or does
                                     maintains sufficient, appropriate, and       maintains sufficient, appropriate, and   maintains data to enable the use of its       not regularly maintain, the data needed
                                     reliable data to enable the effective use    reliable data to enable the effective useALM tools and techniques. However,            to support the effective use of ALM
                                     of its ALM tools and techniques. The         of its ALM tools and techniques.         the data is not always sufficient,            tools and techniques.
                                     data is readily available when needed.       However, the data is not always          reliable, or readily available when
                                                                                  readily available when needed.           needed.
 3.10 2.3     17 Acting on           The information produced by ALM is           The information produced by ALM is       The information produced by ALM is            The information produced by ALM is
                 information         actionable, and timely and appropriate       actionable, and action is usually taken  difficult to act on, but action is            difficult to act on, and action is seldom
                                     action is taken in response to such          in response to such information.         sometimes taken in response to such           taken in response to such information.
                                     information.                                                                          information.
 3.15 3.2     22 Application of risk Risk tolerance is reflected in the ALM       Risk tolerance is reflected in the ALM Risk tolerance is reflected in the ALM          Risk tolerance is not reflected in the
                 tolerance           strategy and actively applied within         strategy, but is not as actively applied strategy, but is not applied within the       ALM strategy, nor is it applied within
                                     the ALM program. Defined risk                within the ALM program as it should ALM program.                                       the ALM program.
                                     tolerance limits are embedded in             be. Defined risk tolerance limits are
                                     ongoing operations through risk              not embedded in ongoing operations
                                     management policies and procedures.          through risk management policies and
                                                                                  procedures.
 3.20 4.2     28 Forecasts of cash   The insurer prepares forecasts of cash       The insurer prepares forecasts of cash The insurer prepares forecasts of cash          The insurer does not prepare forecasts
                 flows               flows from its assets and liabilities that   flows from its assets and liabilities.   flows from its assets and liabilities.        of cash flows from its assets and
                                     include assumptions on the likely            However, the forecasts do not            However, the forecasts might not              liabilities that would be useful in the
                                     behavioural responses of key                 explicitly reflect assumptions on the    explicitly reflect assumptions on the         management of liquidity risk.
                                     counterparties and policyholders to          likely behavioural responses of key      likely behavioural responses of key
                                     changes in conditions. The granularity       counterparties and policyholders to      counterparties and policyholders to
                                     and time horizon of such forecasts,          changes in conditions. The granularity changes in conditions. The granularity
                                     and the frequency with which they are        and time horizon of such forecasts,      and time horizon of such forecasts, or
                                     updated, are commensurate with the           and the frequency with which they are the frequency with which they are
                                     nature of the portfolios of assets and       updated, are commensurate with the       updated, are not commensurate with
                                     liabilities.                                 nature of the portfolios of assets and the nature of the portfolios of assets
                                                                                  liabilities.                             and liabilities.

 3.25 2.2     10 Derivation of cash To the extent possible, cash flows and        Models are used that recognise              Cash flow projections are based solely Either asset cash flows or liability cash
                 flow projections their values are derived by direct              changes in cash flows, and changes in       on best estimates of future experience, flows, or both, are not explicitly
                                    observation or by considering                 the economic value of those cash            rather than a range of plausible        projected.
                                    replicating portfolios. If not, then          flows, that will arise from a range of      scenarios.
                                    models are used that recognise                plausible scenarios. Limited or no use
                                    changes in cash flows, and changes in         is made of direct observation and the
                                    the economic value of those cash              consideration of replicating portfolios.
                                    flows, that will arise from a range of
                                    plausible scenarios.




657dc622-70ae-43bd-8827-c65205df604e.xls                                                                              4/19/2010 10:08 PM                                                                                                    Page 4 of 7
ALM Assessment                                                                                                         Name of Insurer                                                                                                Name of Assessor




 Sort Reg Item Element          Strong = 4                                     Acceptable = 3                            Needs Improvement = 2                        Weak = 1 or 0                              Rating Explanation
 3.30 2.2 11 Realism of the     Models are regularly calibrated to             Models are occasionally calibrated to     Models are seldom calibrated to              Models are not calibrated to
               cash flow models appropriate observable market prices           appropriate observable market prices.     appropriate observable market prices.        appropriate observable market prices.
                                and take into account the specific             Models do not fully account for the       Models do not fully account for the          Models do not fully account for the
                                variability in cash flows that is              specific variability in cash flows that isspecific variability in cash flows that is   specific variability in cash flows that is
                                inherent in some products, such as             inherent in some products, but the        inherent in some products, but the           inherent in some products, but the
                                exposure to catastrophe risk.                  users apply judgement to compensate       users apply judgement to compensate          users do not appear to compensate for
                                                                               for this.                                 for this.                                    this.
 3.35 4.2     29 Liquidity risk      The insurer actively monitors its         The insurer actively monitors its         The insurer infrequently monitors its        The insurer manages liquidity
                 management          liquidity position and structures its     liquidity position and structures its     liquidity position, but does take            reactively, responding to cash flows
                                     assets so that it has sufficient cash and assets so that it has sufficient cash and account of anticipated large cash            largely as the occur, with little or no
                                     diversified marketable securities to      diversified marketable securities to      outflows and structures its assets so        use of cash flow projections.
                                     meet its obligations as they fall due.    meet its obligations as they fall due.    that it has sufficient cash and
                                     The insurer maintains a cushion of        The insurer maintains a cushion of        diversified marketable securities to
                                     liquid assets sufficient to deal with     liquid assets sufficient to deal with     meet its obligations as they fall due.
                                     both routine fluctuations in the level    routine fluctuations in the level and     The insurer maintains a cushion of
                                     and timing of obligations and             timing of obligations, but not adverse    liquid assets sufficient to deal with
                                     reasonable adverse deviations in actual deviations in actual cash flows             routine fluctuations in the level and
                                     cash flows compared to its forecasts. compared to its forecasts.                    timing of obligations, but not adverse
                                                                                                                         deviations in actual cash flows
                                                                                                                         compared to its forecasts.
 3.40 4.2     30 Liquidity           The insurer has developed and              The insurer has developed and            The insurer has developed and                The insurer does not have a liquidity
                 contingency plan    maintains a contingency plan to deal       maintains a contingency plan to deal maintains a contingency plan to deal             contingency plan.
                                     with unexpected cash outflows or           with unexpected cash outflows or         with unexpected cash outflows or
                                     conditions that would impair its ability   conditions that would impair its ability conditions that would impair its ability
                                     to liquidate assets at a reasonable        to liquidate assets at a reasonable      to liquidate assets at a reasonable
                                     price. The plan does not rely solely on    price. The plan does not rely solely on price. However, the plan relies solely
                                     group resources. Commitments               group resources. Commitments             on group resources.
                                     necessary to execute the plan are in       necessary to execute the plan are not
                                     place.                                     in place.
 3.45 4.3     31 Longer-term         The insurer prepares analyses of           The insurer prepares analyses of         The insurer prepares analyses of             The insurer does not prepare analyses
                 analyses            relevant risks and the likely              relevant risks and the likely            relevant risks and the likely                of relevant risks and the likely
                                     effectiveness of its ALM strategies        effectiveness of its ALM strategies      effectiveness of its ALM strategies          effectiveness of its ALM strategies
                                     under a range of alternative scenarios.    under a range of alternative scenarios. under a range of alternative scenarios.       under a range of alternative scenarios
                                     Such analyses include forecasts of its     Such analyses include forecasts of its Such analyses include forecasts of its         that include forecasts of its future
                                     future financial condition over a period   future financial condition over a period future financial condition over a period     financial condition over a period of
                                     of several years. The sophistication       of several years. The sophistication     of several years. However, the               several years.
                                     and time horizon of such forecasts,        and time horizon of such forecasts are sophistication or time horizon of such
                                     and the frequency with which they are      commensurate with the nature of the forecasts, or the frequency with which
                                     updated, are commensurate with the         portfolios of assets and liabilities.    they are updated, not commensurate
                                     nature of the portfolios of assets and     However, the frequency with which        with the nature of the portfolios of
                                     liabilities.                               the analyses are updated is              assets and liabilities.
                                                                                insufficient.

 3.50 4.3     32 Using the results   The board of directors and senior          The board of directors and senior           The board of directors and senior         The board of directors and senior
                 of longer-term      management of the insurer consider         management of the insurer consider          management of the insurer consider        management of the insurer do not use
                 analyses            how they would respond under the           how they would respond under the            how they would respond under the          the results of the analyses.
                                     various scenarios, focusing on those       various scenarios, not necessarily          various scenarios, not necessarily        Alternatively, they review the results
                                     with the most damaging impact on the       focusing on those with the most             focusing on those with the most           but do not consider how they would
                                     future financial condition. The            damaging impact on the future               damaging impact on the future             respond under the various scenarios.
                                     business plans and ALM strategy are        financial condition. The business plans     financial condition. The business plans
                                     revised, as appropriate.                   and ALM strategy are revised, as            and ALM strategy are not revised.
                                                                                appropriate.




657dc622-70ae-43bd-8827-c65205df604e.xls                                                                            4/19/2010 10:08 PM                                                                                                      Page 5 of 7
ALM Assessment                                                                                                        Name of Insurer                                                                                          Name of Assessor




 Sort Reg Item Element               Strong = 4                                 Acceptable = 3                           Needs Improvement = 2                      Weak = 1 or 0                         Rating Explanation
 4.00 5.1 33 Organisation            The insurer is organised in a manner       The insurer is organised in a manner     The insurer is organised in a manner       The insurer is not organised in a
                                     that provides a close and continuing       that provides a close and continuing     that should provide a close and            manner that would provide a close and
                                     liaison between all areas that need to     liaison between all areas that are       continuing liaison between all areas       continuing liaison between all areas
                                     be involved to maintain effective          actually involved in ALM. The range      that are actually involved in ALM, but     that are or should be involved in
                                     ALM. A wide range of organisational        of organisational functions involved in  the organisation is not functioning        ALM.
                                     functions are involved in ALM.             ALM is not as wide as it should be to    well. The range of organisational
                                                                                maximise the effectiveness of ALM.       functions involved in ALM is not as
                                                                                                                         wide as it should be to maximise the
                                                                                                                         effectiveness of ALM.
 4.05 5.1     34 Separation of       To the extent practicable, the             The monitoring of risk and processes The monitoring of risk and processes           The monitoring of risk and processes
                 duties              monitoring of risk and processes has       has not been organisationally            has not been organisationally              has not been organisationally
                                     been organisationally separated from       separated from the functions             separated from the functions               separated from the functions
                                     the functions overseeing investments,      overseeing investments, pricing and      overseeing investments, pricing and        overseeing investments, pricing and
                                     pricing and management of in-force         management of in-force business.         management of in-force business.           management of in-force business. No
                                     business.                                  However, compensating controls, such Routine review of results by senior            mechanisms are in place to identify
                                                                                as frequent and detailed review by a     management or a board committee is         problems.
                                                                                board committee or regular review by relied on to identify problems.
                                                                                internal audit, are in place.
 4.10 5.1     35 Documentation of    The mandates, roles, and                   The mandates, roles, and                 The mandates, roles, and                   The mandates, roles, and
                 mandates, roles,    responsibilities of the positions and      responsibilities of the positions and    responsibilities of the positions and      responsibilities of the positions and
                 and                 committees involved in the ALM             committees involved in the ALM           committees involved in the ALM             committees involved in the ALM
                 responsibilities    program are clear, appropriate, and        program are appropriate and              program are appropriate, but might not     program are poorly defined or
                                     documented in writing.                     documented in writing, but not as        be as clearly defined as they should       inappropriate. They might not be
                                                                                clearly defined or described as they     be. They are not documented in             documented in writing.
                                                                                should be.                               writing.
 4.15 5.2     36 Policies and        The insurer has developed and              The insurer has developed and            The insurer has developed and              The insurer has not developed or does
                 procedures          maintains written policies and             maintains written policies and           maintains written policies and             not adequately maintain written
                                     procedures for its ALM program. The        procedures for its ALM program.          procedures for its ALM program.            policies and procedures for its ALM
                                     scope and level of detail of such          However, the scope or level of detail However, the scope and level of detail        program.
                                     documentation is commensurate with         of such documentation is not             of such documentation are not
                                     the nature, size, and complexity of the    commensurate with the nature, size,      commensurate with the nature, size,
                                     insurer and the nature of its ALM          and complexity of the insurer and the and complexity of the insurer and the
                                     program.                                   nature of its ALM program.               nature of its ALM program.
 4.20 5.3     37 Controls            The insurer has developed and              The insurer has developed and            The insurer has developed and              The insurer has not developed and
                                     implemented controls and reporting         implemented controls and reporting       implemented controls and reporting         implemented controls and reporting
                                     procedures for its ALM program that        procedures for its ALM program that procedures for its ALM program that             procedures for its ALM program that
                                     are appropriate for its business and the   are appropriate for its business and the are appropriate for its business and the   are appropriate for its business and the
                                     risks to which it is exposed. It           risks to which it is exposed. It         risks to which it is exposed. However,     risks to which it is exposed.
                                     monitors the observance of its controls    monitors the observance of its controls it does not monitor the observance of
                                     closely and reviews their effectiveness    closely. The effectiveness of controls its controls closely. The effectiveness
                                     regularly. Such monitoring includes        is reviewed occasionally by the          of controls is review rarely, if ever.
                                     periodic review by the internal audit      internal audit function.
                                     function.
 4.25 5.3     38 Reports prepared    Reports are sufficiently detailed and      Reports are generally adequate to         Reports are inadequate in either detail   Reports are seriously deficient in both
                 for operational     frequent enough to enable operational      enable operational management to          or frequency, impairing the ability of    detail and frequency, making it
                 management          management to effectively manage the       manage the risks on a day-to-day          operational management to manage the      impossible for operational
                                     risks on a day-to-day basis.               basis. However, the effectiveness of      risks on a day-to-day basis.              management to manage the risks on a
                                                                                risk management could be improved if                                                day-to-day basis.
                                                                                the reports were more detailed or more
                                                                                frequent.




657dc622-70ae-43bd-8827-c65205df604e.xls                                                                           4/19/2010 10:08 PM                                                                                                Page 6 of 7
ALM Assessment                                                                                                      Name of Insurer                                                                                          Name of Assessor




 Sort Reg Item Element               Strong = 4                                 Acceptable = 3                           Needs Improvement = 2                    Weak = 1 or 0                         Rating Explanation
 4.30 5.3 39 Reports prepared        Reports contain sufficient information     Reports contain sufficient information   Reports do not contain sufficient        Reports do not contain sufficient
               for senior            to allow senior management to monitor      to allow senior management to monitor    information to allow senior              information to allow senior
               management and        adherence to the approved ALM              adherence to the approved ALM            management to monitor adherence to       management to monitor adherence to
               the board of          policy on a regular basis, such as         policy on a regular basis, such as       the approved ALM policy on a regular     the approved ALM policy on a regular
               directors             monthly or quarterly. Reports are also     monthly or quarterly. Reports are also   basis. Reports are prepared for senior   basis. Reports prepared for senior
                                     prepared for senior management and         prepared for senior management and       management and the board of directors    management and the board of directors
                                     the board of directors that are            the board of directors that provide      that provide information about various   do not provide sufficient information
                                     analytical in nature, allowing the users   information about various aspects of     aspects of the ALM program and its       about the ALM program to enable
                                     to draw independent conclusions about      the ALM program and its results.         results.                                 them to assess its results.
                                     various aspects of the ALM program
                                     and about its effectiveness.
 4.35 5.3     40 Assessment of       The usefulness and timeliness of           The usefulness and timeliness of         The usefulness and timeliness of         The usefulness and timeliness of
                 reporting           reporting, and the accuracy and            reporting are considered in an ad hoc    reporting are considered in an ad hoc    reporting are considered in an ad hoc
                                     integrity of reporting systems are         manner. The accuracy and integrity of    manner. The accuracy and integrity of    manner. The accuracy and integrity of
                                     periodically verified in a formal          reporting systems are periodically       reporting systems are seldom verified    reporting systems are never verified in
                                     manner.                                    verified in a formal manner.             in a formal manner.                      a formal manner.




657dc622-70ae-43bd-8827-c65205df604e.xls                                                                         4/19/2010 10:08 PM                                                                                                Page 7 of 7

				
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