ASC 944-60-25-7
Original policy benefit assumptions for certain long-duration contracts ordinarily continue to be used during the periods in which the liability for future policy benefits is accrued under Subtopic 944-40. However, actual experience with respect to investment yields, mortality, morbidity, terminations, or expenses may indicate that existing contract liabilities, together with the present value of future gross premiums, will not be sufficient to do both of the following:
- Cover the present value of future benefits to be paid to or on behalf of policyholders and settlement costs relating to a block of long-duration contracts
- Recover unamortized present value of future profits.
ASC 944-60-25-8
The premium deficiency shall be recognized by a charge to income and either of the following:
- A reduction of unamortized present value of future profits
- An increase in the liability for future policy benefits
ASC 944-60-30-1
If the conditions in paragraph 944-60-25-7 exist, an entity shall determine the liability for future policy benefits using revised assumptions as the remainder of the present value of future payments for benefits and related settlement costs (determined using revised assumptions based on actual and anticipated experience) minus the present value of future gross premiums (also determined using revised assumptions based on actual and anticipated experience).
ASC 944-60-30-2
A premium deficiency shall then be determined as the liability measured in paragraph 944-60-30-1 minus the liability for future policy benefits at the valuation date, reduced by the unamortized present value of future profits.
For universal life-type contracts, we believe the premium deficiency analysis includes both the “liability for future policy benefits” described in
ASC 944-40-30-16, unamortized deferred sales inducement assets, and any additional accrued liabilities for death, other insurance, and annuitization benefits. That is, the amount subject to premium deficiency testing should include the sum of the following components:
- the accrued policyholder account balance (ASC 944-40-25-14),
- additional liabilities for death or other insurance benefits (as described in ASC 944-40-25-27A) and annuitization benefits (as described in ASC 944-40-25-26 and ASC 944-40-25-27),
- unamortized deferred sales inducement assets
- amounts assessed against policyholders for services to be performed in the future (e.g., unearned revenue),
- amounts previously assessed against policyholders that are refundable on contract termination, and,
- any amounts previously recorded for premium deficiencies.
The premium sufficiency/deficiency calculation is usually performed when current and anticipated experience varies significantly from the original assumptions. One indication that current and anticipated experience may be varying from original assumptions is when the insurance company significantly changes assumptions used for new business from those used in the prior period.
The significant assumptions are:
- investment yields
- mortality and morbidity rates
- terminations
- expenses
To determine if a premium deficiency exists, the present value of expected cash outflows or “future benefits and settlement costs” and the present value of expected cash inflows or “future gross premiums” relating to the contract are considered.
- Cash outflows include all the benefits (e.g., death benefits and surrenders) and related settlement costs that accrue to the benefit of the policyholder. Expected assessments, including charges for administration, mortality, and expense that are expected to be deducted from the account balance that is ultimately paid to the policyholder, are projected.
- Cash inflows include gross premiums expected to be paid by the policyholder. For universal life contracts, “gross premiums” refers to expected deposits to be paid by the policyholder.
Unamortized DAC is not a component in the analysis; however, the unamortized present value of future profits from past business combinations is included. Maintenance costs are specifically excluded as a cash outflow in the present value of future payments for benefits and related costs.
No loss is reported currently if it results in creating future income.
Question IG 7-1 addresses the appropriate discount rate to be used in determining the present value of expected cash outflows and inflows in the premium deficiency test for universal life type contracts.
Question IG 7-1
What discount rate should be used in the loss recognition test relating to universal life type contracts?
PwC response
ASC 944-60-25-7 requires that a reporting entity assess universal life-type contracts for premium deficiency, but it does not prescribe a particular discount rate to be used in the assessment. It does mention “investment yields, along with mortality, morbidity, terminations, or expenses” as relevant assumptions in performing a loss recognition test. As a result of the lack of a prescribed rate, a discount rate such as investment yield or the account balance crediting rate may be appropriate. We believe the discount rate used should be consistent with the underlying economics and other relevant assumptions. If investment yield is used as the discount rate, it must be disclosed in accordance with
ASC 944-60-50-2. Refer to Figure IG 5-5 for considerations related to shadow adjustments.
Question IG 7-2 addresses how market risk benefits associated with universal life insurance contracts are considered in the premium deficiency analysis.
Question IG 7-2
Are market risk benefits a component of the universal life insurance premium deficiency analysis?
PwC response
No. The universal life liability for future policy benefits excludes market risk benefits because market risk benefits are measured at fair value and therefore do not meet the “liability for future policy benefits” glossary definition of “an accrued obligation to policyholders that relates to insured events, such as death or disability.” That is, premium deficiency guidance applies to balances measured under an accrual model, but not under a fair value model. Entities should ensure that the fees attributed to the market risk benefits in the fair value model are excluded from the cash inflows for the universal life liability for policy benefits premium deficiency test.