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2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

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Page 1: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

2012 ERM SymposiumRisk & Risk

Management

Tom Mount, Vice PresidentA.M. Best CompanyApril 20, 2012

Page 2: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Agenda

• Risk Management – Risk Management & Rating Process– Changes to rating process– Impact on rating– Example & Sample Text– Qualitative benchmarks– Observations from last year’s ERM SRQ

Page 3: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

Risk Management is the common thread that links balance sheet strength, operating performance, and business profile.

Risk Management = (Identify + Understand + Measure + Manage) Risk

Page 4: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

AMB is Looking for a Practical Approach to Risk Management

• Tailored to your business and risk profile – Process must fit your company, not the other way around– Pick the right tool for the job, not just the most expensive one– Risk management will be defined differently by each company

• Function over form– CRO’s and sophisticated models are not absolute pre-requisites

for strong risk management – For some insurers, strong risk management may be a more

traditional approach supplemented by an understanding of how risks correlate

• Flexible and adaptive to the changing business environment– Strong risk management is not a finitely defined set of tasks– Ongoing process…emerging risks…risk learning

Page 5: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management Spectrum • Wide spectrum of risk

management tools, techniques, and approaches

• Differences in geographic and product complexity/diversity, as well as management team skill sets and mind sets, must be considered – Approaches range from a

traditional “silo” mentality to an integrated ERM platform with ICM, with many hybrids in between

– Companies may migrate from one approach to another over time as their profile, skill set and the business environment changes

• Bottom line: a company’s process must fit its profile and provide a stable, sustainable operating platform in good times and bad

Page 6: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management and the Rating Process – A Practical Approach

• An open-ended and open-minded assessment of each company’s operating practices that does not pre-judge the effectiveness of a company’s approach to risk management based on a predetermined expectation

• AMB wants companies to “show me” how your risk and capital management process provides a stable, sustainable operating platform that can weather the storm year after year

Page 7: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management and the Rating Process…

• Top 5 Exposures and Critical Success Factors to Mitigating/Managing these Risks

• Lessons Learned through your Risk Management Development Process

• “Risk Management Questions You Should Address at Every Rating Meeting”

• Next Steps in Risk Management Development

AMB recognizes risk management is an ongoing process.

Demonstrating commitment and progress toward a goal is the key.

Page 8: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Questions You Should Address at Every Rating Meeting

• What is the Board’s and Senior Management’s role in your risk management framework?

• Has your organization established and communicated any risk management objectives to your employees, and other stakeholders?

• What is your risk appetite? How is it measured?• How does your organization encourage good risk-

based decision making? • What is your organization’s process for identifying

and cataloging key risks across your organization?

Page 9: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Questions You Should Address at Every Rating Meeting

• What tools does your organization use to determine required capital? Is it a static, dynamic, or hybrid approach?

• How do you factor in correlation/dependency of individual risks?

• How are liquidity, cash flows, and financial flexibility incorporated into your risk management framework?

• How do you incorporate operational risk and strategic risk in your evaluation of required capital?

• How are emerging risks identified and evaluated?

Page 10: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

What Should You Share with AMB?

• Provide AMB whatever materials you feel will help us understand how your organization defines and strives for strong RM – Demonstrate how you identify, understand, measure and

manage risk

– Sample reports used by Board, senior management, etc.

– De-briefing on how risk tools were used to make a strategic or tactical decision…the USE TEST!

– Internal or external assessments of your overall process, or components of your process

Page 11: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

• How has our process changed?– SRQ questions on ERM– Rating committee discussion on risk

management & impact on rating– Added a new Risk Management section in

the company reports• Risk management• Stress tests performed• Cat exposure and management• Investment risk management

Page 12: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk ManagementRating committee discussion:

What is the impact of a company’s Risk Management on the company’s rating?

Need to know two things:

Company’s risk management

capability

Company’s risk profile

Page 13: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISK

MODERATE RISK

LOW RISK

MINIMAL RISK

Risk ProfileRisk Management

Capability

A company’s risk management capability needs to meet its risk profile

Superior

Strong

Good

Weak

Page 14: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISK

MODERATE RISK

LOW RISK

MINIMAL RISK

Risk ProfileRisk Management

Capability

A company’s risk management capability needs to meet its risk profile

Superior

Strong

Good

Weak

Negative Rating Factor/Potentially

Higher Capital Requirements

Page 15: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISK

MODERATE RISK

LOW RISK

MINIMAL RISK

Risk ProfileRisk Management

Capability

A company’s risk management capability needs to meet its risk profile

Superior

Strong

Good

Weak

Positive Rating Factor/Potentially

Lower Capital Requirements

Page 16: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISK

MODERATE RISK

LOW RISK

MINIMAL RISK

Risk Profile

Characteristics for Low Risk Profile:

Low volatility in earnings and capital

Favorable regulatory/judicial environment

Low severity claims / low limit policies

Limited competition / stable pricing

Standardized/unchanging coverages

Low leverage measures

Strong reinsurance protection

Strong financial flexibility

High liquid / stable investments

Stable economic environment

Strong data capture/quality

Page 17: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISK

MODERATE RISK

LOW RISK

MINIMAL RISK

Risk Profile

Characteristics for High Risk Profile:

High volatility in earnings and capital

Unfavorable regulatory/judicial environments

High severity / low frequency claims

High policy limits / excess layers

Strong competition / inadequate pricing

New/changing/complex coverages & products

High leverage measures

Weak / no reinsurance protection

Weak / no financial flexibility

Illiquid / volatile / complex investments

Unstable / multiple economic environments

Weak data capture/quality

Page 18: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

Risk Management Capability

Superior

Strong

Good

Weak

Characteristics of Good RM Capability:

Good traditional risk management (silos):• Market Risk• Credit Risk• UW Risk• Operational Risk• Strategic Risk

Good capital management:• Earnings• Debt market• Equity market• Good knowledge of BCAR

Good management and management info:• Good decision making• Traditional metrics• Reliable projections• Risk aware culture

Limited ERM Capabilities

Page 19: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

Risk Management Capability

Superior

Strong

Good

Weak

Characteristics of Superior RM Capability:

• Superior traditional risk management

• Superior capital management

• Superior management and management info

• Superior ERM Capabilities:• Corporate wide risk aware culture• Experienced CRO / ERM committee• Well quantified risk appetite / risk tolerance• Superior risk identification/

quantification/mitigation/monitoring/ controls• Superior Knowledge of Correlations

• Across lines of business• Across risk categories • Superior Economic Capital Model• Decisions based on risk metrics• Compensation based on risk metrics• Frequent “what if” scenario testing

Page 20: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

Company’s Risk Management

Capability

Therefore – A qualitative assessment of a company’s Risk Management capability requires reviewing its Traditional risk management capability and its Enterprise risk management

capability.

Superior

Strong

Good

Weak

Enterprise Risk Management

Capability

Superior

Strong

Good

Weak

Traditional Risk Management

Capability

Superior

Strong

Good

Weak

Page 21: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk ManagementLet’s do an example:LRP Company is a regional personal lines company with $200m of PHS that writes personal auto liability and physical damage in 5 states and has the following characteristics:

Low volatility in earnings – average ROE of 5% +/- 2pts over 10 yearsConsistent stable growth in PHS from UW profit and some investment incomeOnly operates in states with Favorable regulatory/judicial environmentMost policies have limits of 100K or lower, but some 300k and 500k

Some financial flexibility – publicly traded stock co. w/ debt = 10% of total capitalHighly liquid / stable investments – mostly US treasuries and AAA corpsStable economic environmentCompany has strong data capture/quality and long history of data

Company is in top 5 market share in each stateSome competition but competitors not overly aggressive so stable adeq pricingStandardized/unchanging personal auto coveragesLow leverage measures – (NPW/PHS = 0.6 :1) (Net reserves/PHS = 0.8:1)Strong reinsurance protection – losses over 100k per occ ceded to A+ reinsurer

Page 22: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISK

MODERATE RISK

LOW RISK

MINIMAL RISK

Risk ProfileRisk Management

Capability

A company’s risk management capability needs to meet its risk profile

Superior

Strong

Good

Weak

LRP Company

Page 23: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk ManagementQualitative review of LRP Company’s Traditional risk management

capability:Traditional Risk

Management Capability

Superior

Strong

Good

Weak

Strong traditional risk management (silos):Market Risk – manages to short durations, low volatility,

no concentrationsCredit Risk – manages to low credit risk - US Tbills, AAA corps, A+ reins, no overdue balUW Risk – manages different states well, monitors results

frequently, by agent, territory, etcOperational Risk – Low ee turnover, ee training, data secureStrategic Risk - extensive research before enter new states

Good capital management:Earnings – manages to good mix of UW profit vs interestDebt market – manages to low debt level (10% of capital)Equity market – has shelf registration approvedKnows BCAR score, but not how model works

Superior management and management info:Superior track record and extensive experience Traditional metrics – Combined, Operating, ROR, ROEReliable projections – consistently meets projections

Page 24: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk ManagementQualitative review of LRP Company’s Enterprise risk management

capability:Enterprise Risk Management

Capability

Superior

Strong

Good

Weak

Risk Culture:CEO meets individually with CFO, CUO, COONo CRO / No ERM committee/ No holistic viewNo risk based metrics presented to board

Risk Identification/Measurement/Monitoring:No formally quantified overall risk appetite/risk toleranceNo attempt to quantify correlations:

Across statesAcross linesAcross silos

No what if testing of:Inflation impacts on reserves, pricingBond defaultsNew competitors

Economic Capital Model – Does not have oneDecisions based on traditional metricsCompensation based on growth and Op ratio

Page 25: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

LRP Company’s Risk Management

Capability

Superior

StrongOverall RM

Good

Weak

Enterprise Risk Management

Capability

Superior

Strong

Good

Weak

Traditional Risk Management

Capability

Superior

Strong

Good

Weak

Overall qualitative assessment of LRP Company’s Risk Management capability:

Page 26: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISK

MODERATE RISK

LOW RISK

MINIMAL RISK

Risk ProfileRisk Management

Capability

LRP company’s risk management capability needs to meet its risk profile:

Superior

Strong

Overall RM

Good

Weak

Positive Rating Factor/Potentially

Lower Capital Requirements

Page 27: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

• Benefits to improved risk management– Potentially greater outside stakeholder

confidence• Policyholders/Investors• Creditors• Reinsurers• Regulators• Rating agencies

– Potentially lower capital requirements• After impacts observed in results over time

– Consistent or consistently within expectations

– Potentially more efficient capital allocation– Potential opportunities based on risk/reward

Page 28: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management and BCARRisk Management and BCAR – A.M. Best’s Traditional Approach

Exposure to Earnings and Capital Volatility

Strong Risk Management

BCAR Guidelines

Weak Risk Management

Page 29: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

The company has a chief underwriter who is responsible for ensuring the company’s underwriting guidelines are being adhered to. Loss ratios and reserves are reviewed quarterly by the company’s actuaries to ensure pricing and reserve adequacy. Results are monitored at the agent and state levels. The company also monitors competitor’s rate filings on a monthly basis. Routine claim audits ensure consistent claims settlement practices across all claim offices. Results are presented quarterly to the board using traditional statutory and GAAP financials.

The company does not have a formally stated overall risk appetite/ tolerance and does not measure results on a risk adjusted basis.

The company does not have a formal ERM program to measure risk correlations but has identified what it believes are its 5 largest risks and has developed a risk mitigation plan for these risks & assigned a risk owner.

The company has a committee to research strategic opportunities.

Sample Text in Best’s Insurance Report:

Page 30: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISKExcessLong tail liab (WC, Occ)Catastrophe Exposed

MODERATE RISKMedium tail liab (Prof, CM)Non-Cat prop (HO, CProp)

LOW RISKShort tail liab (Auto)Auto PhysSmall value property

Line of Business Correlation of Lines

Qualitative benchmarks for risk profile characteristics:

Volatility

HIGH RISKHigh volatility in:LRs, Combined, OpRatio, ROE, RORCapital, etc.

MODERATE RISKModerate volatility in:LRs, Combined, OpRatio, ROE, RORCapital, etc.

LOW RISKLow volatility in:LRs, Combined, OpRatio, ROE, RORCapital, etc.

HIGH RISKHighly correlatedmovement in losses, esp.esp. in tail

MODERATE RISKIndependent movementin losses

LOW RISKNegative correlationNatural hedges

Page 31: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISKLow frequencyHigh severity

MODERATE RISKModerate frequencyModerate severity

LOW RISKHigh frequencyLow severity

Frequency and Severity of

Claims

Product/Coverage Changes

Qualitative benchmarks for risk profile characteristics:

Policy Limits

HIGH RISKHigh limits(over $1m)(over 10% of PHS)

MODERATE RISKModerate limits($100k to $1m)(1% to 10% of PHS)

LOW RISKLow limits(under $100k)(under 1% of PHS)

HIGH RISKFrequent changesMultiple coverage optionsManuscript policiesComplex, untested

MODERATE RISKOccasional changesFew coverages offeredStandardized policies

LOW RISKMinimal changesLimited coverage optionsStandardized legallyaccepted/proven policies

Page 32: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISKAggressive competitor(s)and wide spread

MODERATE RISKSome competition on rate or localized competition

LOW RISKNo competition onrate anywhere

CompetitionJudicial

Environment

Qualitative benchmarks for risk profile characteristics:Legislative/Regulatory

Environment

HIGH RISKDifficult to get rate orpolicy changesSlow response

MODERATE RISKSmall rate changesapproved but largerrate change difficult

LOW RISKCooperative ins deptApprovals routineNo political obstacles

HIGH RISKFrequent adverse verdictsFrequent high awardsUnpredictable outcomes

MODERATE RISKOccasional adverse orvaries by jurisdiction

LOW RISKPredictable awardsConsistent outcomes

Page 33: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISKLow rated fixed incomeConcentrations, illiquidHigh % in equitiesSpeculative derivatives

MODERATE RISKMostly highly ratedMostly liquidModerate % in equitiesMinimal speculation

LOW RISKHighly rated fixed incomeWell diversified, liquidLow % in equitiesHedging with derivatives

InvestmentsEconomic

Environment

Qualitative benchmarks for risk profile characteristics:

Financial FlexibilityHIGH RISK

No access to equity mktNo access to debt mktExisting high level of debtTight credit conditions

MODERATE RISKLimited access or onlyaccess to one mktSome existing debtCredit avail, but expensive

LOW RISKProven access to equity mktProven debt raising/payoffLow levels of existing debtLoose credit conditions

HIGH RISKVolatile interest rateUnstable/high inflationProlonged recessionHigh fraud

MODERATE RISKSmall int rate movementsSmall chgs in inflation rateEconomy unpredictableSome fraud

LOW RISKStable interest rateStable manageable inflationStable economic growthLow fraud

Page 34: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISKHigh concentrationsLine, state, agent, etc.

MODERATE RISKSome concentrations inportions of operations

LOW RISKNo concentrations

Concentration Growth

Qualitative benchmarks for risk profile characteristics:

Data Quality

HIGH RISKPoor data qualityData outdatedInappropriate for decision

MODERATE RISKSome data missingSome data miscoded/bulk

LOW RISKHigh quality dataObtained quicklyAdequate for decisionRegular testing of data

HIGH RISKNew line, new state,New country, new agentsExcessive level of growthInadequate ratesInadequate expertise

MODERATE RISKNew product in existing linew/ current agentsManagement expertise ingrowth lines/jurisdictions

LOW RISKStable sustainable growthIn line with economic growthGrowth in existing line/areasFavorable rate environment

Page 35: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

HIGH RISKUnratedB or belowNo collateral

MODERATE RISKB+, B++, A-Collateral on lower ratedonly

LOW RISKA or aboveCollateralized

Credit Quality of Reinsurance

Impact of Reins Program

Qualitative benchmarks for risk profile characteristics:

Ceded Leverage

HIGH RISKRecov/PHS > 100%

MODERATE RISK100% > Recov/PHS > 25%

LOW RISKRecov/PHS < 25%

HIGH RISKHigh Retained ExposureParametric basedNo reinstatesExposure to frequencyCaps, corridors, APs

MODERATE RISKModerate RetainedExposure

LOW RISKLow Retained ExposureIndemnity basedMultiple reinstatesNo caps, corridors, APs

Page 36: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

Note:

Some of these qualitative factors vary by line of business or by location or both!

Some of these will change over time too!

The company’s risk profile is constantly changing and the appropriate level of risk management must move with it!

Therefore, risk management must be an on-going process!

Page 37: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

ERM SRQ Observations

Although the industry is making progress in its efforts toimprove its ERM, it would appear that the industry has a long way to

go.

Page 38: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk ManagementAt what level do you define risk tolerance?

86%

45%

40%

32%

29%

22%

10%

0% 20% 40% 60% 80% 100%

Overall

Line of Business

Policy

Business Unity

Legal Entity

Account

Other

Percent of All Respondents

Risk Identification / Measurement / Monitoring

Page 39: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk ManagementWhat is management’s overall appetite/tolerance for

risk?

Inadequate Responses:

Highly conservative, Moderately conservative Generally conservative at most moderately conservativeLow, Very Low, Low to moderatePrimarily low, with some tolerance for mediumRisk averse, Very limitedMaintain 250 BCAR

At least 90% of the responses fell into the category of Inadequate Responses!

Adequate Responses:

Appetite-Minimum limits NSA writer in state x w/low volatility in avg return of y%; Medium size WC account manufacturing risks in all states w/retained limits of $x w/high volatility in avg return of y%; $1m+ Homes in hurricane exposed states but purchase reins so that…

Tolerance-No more than a 2% chance of losing 10% of PHS Annually; 0.5% risk of insolvency over x year period; UW loss no more than once every 15 years and not to exceed more than 10% of PHS

Page 40: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

No Response

2%

Yes28%

No70%

EC Models - All Respondents

Risk ManagementDo you use an EC model to quantify your aggregate risk?

Commercial 54%Personal 46%

Commercial 60%Personal 40%

Large 23%Medium 35%Small 42%

Large 52%Medium 32%Small 16%

A++ & A+ 9%A & A- 68%B++ & B+ 18%Vulnerable 4%

A++ & A+ 21%A & A- 70%B++ & B+ 9%Vulnerable 1%

Page 41: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk Management

No Response

1%

No 6%

Yes 93%

Those Using EC Models

Do you use the EC model to make key business decisions?

Page 42: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk ManagementDo you use the EC model to determine any portion of

management compensation?

No Response

3%No 70%

Yes 27%

Those Using EC Models

Page 43: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Risk ManagementPlanned Mitigation Strategy for Inflation Stress Scenarios:

20%

20%

8%

0% 5% 10% 15% 20% 25%

Adjust Rates

Adjust Reserves

Change Claims Handling

Percent of All Respondents

Those Estimating Inflation Impacts

Page 44: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

One Time Reserve

Charge, 44%

Subsequent Yr Adverse Develop,

56%

Reserve Strengthenings 2001-2009

Risk Management

Sch P Part 2 by company

Page 45: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

Larger than Previous,

48%Smaller than

Previous, 52%

Reserve Strengthenings 2001-2009

Risk Management

For those companies that had a subsequent strengthening,

Subsequent strengthening was

Sch P Part 2 by company

Page 46: 2012 ERM Symposium Risk & Risk Management Tom Mount, Vice President A.M. Best Company April 20, 2012

© AM Best Company (AMB) and/or its licensors and affiliates. All rights reserved. ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY COPYRIGHT LAW AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT AM Best Company PRIOR WRITTEN CONSENT. All information contained herein is obtained by AMB from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided “AS IS” without warranty of any kind. Under no circumstances shall AM Best Company have any liability to any person or entity for (a) any loss or damage in whole or in part caused by, resulting from, or relating to, any error (negligent or otherwise) or other circumstance or contingency within or outside the control of AM Best or any of its directors, officers, employees or agents in connection with the procurement, collection, compilation, analysis, interpretation, communication, publication or delivery of any such information, or (b) any direct, indirect, special, consequential, compensatory or incidental damages whatsoever (including without limitation, lost profits), even if AM Best Company is advised in advance of the possibility of such damages, resulting from the use of or inability to use, any such information. The ratings, financial reporting analysis, projections, and other observations, if any, constituting part of the information contained herein are, and must be construed solely as, statements of opinion and not statements of fact or recommendations to purchase, sell or hold any securities. NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY SUCH RATING OR OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY AM BEST COMPANY IN ANY FORM OR MANNER WHATSOEVER. Each rating or other opinion must be weighed solely as one factor in any investment decision made by or on behalf of any user of the information contained herein, and each such user must accordingly make its own study and evaluation of each security and of each issuer and guarantor of, and each provider of credit support for, each security that it may consider purchasing, holding or selling.