PS 10/24 Policy Statement on Matching Adjustment

Key piece of Solvency UK puzzle now in place

Spiral abstract building

June 2024 

The Policy Statement (PS) on the Matching Adjustment (MA) has been published, and insurers will be relieved that it has been issued despite the regulatory quiet period that typically precedes a general election. 

While the PRA has listened to some industry comments, the final rules remain largely as consulted. The certainty offered by PS 10/24 is welcome, but the MA reform as a whole may be a missed opportunity to rethink fundamentally how insurers can invest to deliver on the review's objectives of unleashing investment into the UK economy and transition to net zero.   

The MA reform (as consulted on and now finalised) provides insurers with greater flexibility to invest in long-term assets, though there are also more complex rules to police the MA mechanism. From the PRA's perspective, the final policy improves the way the MA supports investment and maintains a high level of prudential standards in the life insurance sector. PS10/24 contains some welcome changes, such as the inclusion of in-payment group policies and a more streamlined approach to the MA application process. 

The PRA has been given significant new powers to supervise how insurers use the MA. The extent to which it uses all the tools at its disposal will partly determine whether the reforms achieve the Government's objective of having a more flexible and internationally competitive regime.

The PRA is also running Subject Expert Groups (SEG) to explore the feasibility of implementing an industry proposal to have `sandboxes' for a quicker route for new types of assets towards Matching Adjustment eligibility.

Timelines


From 30 June 2024:

  • Insurers can apply for permission to include a wider range of assets and liabilities in their MA portfolios;
  • PRA expectations on internal credit assessments and MA permissions come into effect; 
  • Insurers can choose to implement notching, though this does not become mandatory until 31 December 2024; and
  • Firms may choose to apply voluntary fundamental spread (FS) additions, but the PRA recognises that insurers are unlikely to apply these to their 30 June balance sheets.

MA attestations will be required with a first reference date of 31 December 2024. 

Six key takeaways for life and protection insurers:

  1. Providers of protection policies will welcome that all in-flight income protection business and in payment group-dependent annuities (GDA) will be eligible for inclusion in Matching Adjustment Portfolios (MAPs).
  2. The rules on assets with highly predictable (HP) cash flows within MA portfolios are broadly unchanged, and insurers will continue to find the requirements onerous. The PRA has re-confirmed that assets currently classified as `fixed' do not risk being re-classified as HP — a primary concern for those with existing MAPs. It has also been re-emphasised that the maximum contribution to the overall MA benefit from HP assets is capped at 10%, and there is a slight softening to the matching tests for portfolios containing HP assets.
  3. There is streamlining of the MA attestation process, for example by allowing an initial analysis of assets by homogenous risk groups, but overall this remains an extensive process. The PRA has been given considerable tools to oversee firms' use of the MA. How the PRA applies these in practice will make a tangible difference.
  4. There are some improvements to the MALIR form (Matching Adjustment Asset and Liability Information Return), e.g. removing the need to submit detailed cashflows beyond 50 years. The PRA notes it is halving the number of cashflow fields, compared to the CP proposals, but in practice the benefit to firms will be relatively negligible.
  5. The PRA has provided important clarification regarding the audit requirement on Fundamental Spread (FS) additions, with audit only required for mandatory additions.
  6. There are several other marginal — but useful — improvements compared to the CP:
    • The calibration of sub-investment grade (SIG) assets in the SCR does not need to apply the SIG cap although the appropriateness of the calibration will need to be revisited (and has become more important given the SIG cap has been removed).
    • Including SIG assets in voluntary FS additions has been simplified.
    • The notching implementation date has been pushed back to 31 December 2024.
    • Finally, the PRA has also committed to transparency on publishing how many MA applications they have considered and how quickly.

How KPMG in the UK can help

With the Solvency UK implementation deadlines now imminent, key areas of focus for insurers include:

  • MA calculation and analysis:  Many firms have reasonably clunky processes around determining their MA, including significant spreadsheet work and / or data collection from multiple systems. This includes assets data, cashflow production, stressing, the MA calculation and pulling the MALIR data together. We can support making these processes efficient. This includes aligning with IFRS discount rate, making hypothecations automated to help achieve a firm’s objectives and producing an automated Analysis of Change (AoC) in MA to better understand the drivers of its changes.
  • Optimisation of reporting processes:  Given the MALIR reporting requirements are at an individual asset level, some firms may look to roll the MALIR reporting and attestation review into a wider technology transformation project, to both tidy up their MA process and harmonise the discount rate setting across all metrics e.g., Solvency II, IFRS 17 and economic capital.  KPMG has supported many firms through such transformation projects (most recently around the introduction of IFRS17) as well as advising on the streamlining of Solvency II processes.
  • Valuation of illiquid assets:  this continues to be a key area of supervisory focus. KPMG can provide independent validation for the internal valuation of illiquid assets, validate the internal ratings process for no-bias and advise on governance, process and methodology for determining FS add-ons.
  • Assurance: KPMG can provide assurance services on aspects of the incoming requirements, including attestation, reporting and MALIR.

Please get in touch for more information on how firms can turn what could be viewed as a large compliance exercise into an opportunity to create a more efficient process for calculating the MA and other discount rates used across their business.

PS 10/24 - Detailed Summary