Letters

APRA commences consultation on increased transparency of general insurance and life insurance data
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The purpose of this letter is to advise affected general insurers (GIs) and life insurers (LIs), other market participants, analysts, academics and other potential user of APRA statistics that APRA is proposing to determine class of business and product group data to be non-confidential, and to provide an opportunity for consultation with the GI and LI industries. 

By publishing a greater breadth of industry-aggregate data, APRA will promote greater transparency and accountability in the LI and GI industry. This will enhance competition, efficiency, and contestability in the financial sector and boost innovation and productivity in the economy, which is ultimately beneficial to all participants in the market. Furthermore, APRA’s proposed sharing of data will facilitate greater consumer understanding and more informed public discussion of insurance-related issues. Publishing complete, unmasked data will also support informed decision-making for all market participants, consultants, analysts and other users by facilitating public access to data of all classes of business/product types. This aligns with the Australian Government Public Data Policy Statement.  

APRA also proposes to begin publishing explanations from individual GIs/LIs in relation to large movements or material revisions in their data, including whether APRA requested the revision of data.

Background

In 2013 APRA released discussion papers for both GI and LI, including a consultation on the confidentiality of GI and LI data submitted to APRA.1 As a result of this consultation, a number of data items in certain reporting documents were determined as non-confidential.2 For data items where it was not clear on the available evidence at that time that the public benefit of disclosure outweighed commercial detriment of disclosure, APRA made no determination, and  continued to apply protection measures for industry-level publications. This ensured that confidential information of an individual institution was unable to be derived from APRA’s published statistics.

In responding to industry in 2015, APRA noted the representations put forward against class of business (GI) and product group (LI) data being determined as non-confidential, as well as other submissions that argued in favour of non-confidentiality.3 At the time APRA noted it was not entirely convinced by the representations and the possible commercial detriment. APRA flagged its intention to undertake additional consultation on the disclosure of class of business and product group data before making a decision about determining the data’s confidentiality.

Proposed determination 

APRA is now proposing to determine all class of business and product group data items to be non-confidential, excluding data relating to descriptions of individual adjustments to risk charges or data where individual counterparties are named. The proposed determination will include the data items reported by GIs (including both Level 1 insurers and Level 2 groups) and LIs in the forms listed in the Appendix. 

Publication of industry aggregate data that is subsequently determined to be non-confidential is proposed to take effect in the second half of 2020. This will not involve a change to APRA’s current suite of publications, but will mean that data previously masked in these publications will now be included in the relevant publications. 

The proposed determination would apply to all such data from the date the GI/LI was required to provide the information to APRA under the relevant reporting standard. The proposed determination will apply prospectively to data of the kind specified in the determination in reporting documents yet to be received by APRA.
 
APRA also proposes to begin publishing explanations from individual GIs/LIs in relation to material revisions to, or large movements in, their data, including whether or not APRA requested the revision. This is to support informed decision-making and greater transparency by providing detail on significant data movements.

Any future changes to the data included in APRA’s GI and LI industry publications, including any future publication of entity-level class of business and/or product group data, will be subject to further consultation.

Consultation process 

Data in a reporting document required to be given to APRA under the Financial Sector (Collection of Data) Act 2001 is protected information under section 56 of the Australian Prudential Regulation Authority Act 1998 (APRA Act). APRA may disclose protected information in certain circumstances, including where APRA has determined the data in a reporting document to be non-confidential under section 57 of the APRA Act. 

Before APRA determines data in a reporting document to be non-confidential, it is obliged to give interested parties a reasonable opportunity to make representations whether or not the reporting document contains confidential information. 

APRA may then determine data in a reporting document to be non-confidential if, after taking into account representations by interested parties, it considers that the benefit to the public from the disclosure of the data in the reporting document, outweighs any detriment to commercial interests that the disclosure may cause. 

Invitation to provide representations 

APRA is seeking feedback from GIs and LIs, industry associations and other representative bodies, other market participants, analysts, academics and any other potential user of APRA statistics. APRA encourages all parties to make submissions on:

  • details of specific class of business or product group data items that would create detriment if they were made non-confidential;
  • specific information on how the disclosure of these data items would lead to detriment to the GIs/LIs or other parties’ commercial interests, and the extent to which that could occur;
  • the time period within which data items might be regarded as no longer being confidential, if there are market sensitivity issues;
  • the benefits or costs associated with the voluntary or mandatory non-confidential determination and publication of explanations from individual GIs/LIs in relation to material revisions to, or large movements in, their data, including whether or not APRA requested the revision; and
  • any other comments regarding APRA’s proposal. 

The proposed changes to the data in the reporting documents to be determined non-confidential will be subject to a six week public consultation. Written representations on the proposed changes should be sent to dataanalytics@apra.gov.au by 31 March 2020 and addressed to Manager, Regulatory Reporting, Data Analytics, or write to:

Manager, Regulatory Reporting, Data Analytics
Australian Prudential Regulation Authority
GPO Box 9836
Sydney NSW 2001

Yours sincerely,

Alison Bliss
General Manager
Data Analytics and Insights

Important disclosure notice – publication of submissions 

All information in submissions will be made available to the public on the APRA website unless a respondent expressly requests that all or part of the submission is to remain in confidence. Automatically generated confidentiality statements in emails do not suffice for this purpose. Respondents who would like part of their submission to remain in confidence should provide this information marked as confidential in a separate attachment.

Submissions may be the subject of a request for access made under the FOIA. APRA will determine such requests, if any, in accordance with the provisions of the FOIA. Information in the submission about any APRA-regulated entity that is not in the public domain and that is identified as confidential will be protected by section 56 of the APRA Act and will therefore be exempt from production under the FOIA.

 

Footnotes

1GI: Confidentiality of general insurance data and changes to general insurance statistical publications
  LI: Confidentiality of life insurance data and changes to life insurance statistical publications
2https://www.legislation.gov.au/Details/F2015L00930; https://www.legislation.gov.au/Details/F2015L00897
3GI: Confidentiality of general insurance data and changes to general insurance statistical publications
  LI: Confidentiality of life insurance data and changes to life insurance statistical publications

Appendix – Impacted reporting forms

General Insurance – Level 1 Insurers

Reporting Form

Current data deemed non-confidential (1)

Proposed determination of non-confidential data

GRF_115_0: Outstanding Claims Liabilities - Insurance Risk Charge

Were actuarial services used to complete this return (Yes/No)
Section 3:
Total direct business - All data items
Total reinsurance business - All data items
Adjustments to OCL Insurance Risk Charge as approved by APRA – Total OCL insurance risk charge
Total - All data items

All data items, excluding 'Adjustments and exclusions to prudential requirements for the OCL Insurance Risk Charge'

GRF_115_1: Premiums Liabilities - Insurance Risk Charge

Were actuarial services used to complete this return (Yes/No)
Section 3A: GPS 320 Total
Total direct business - All data items
Total reinsurance business - All data items
Adjustments to PL Insurance Risk Charge as approved by APRA – Total PL insurance risk charge
Total - All data items
Section 3B: AASB 1023 Total
Total direct business - All data items
Total reinsurance business - All data items
Total - All data items
Other items description
Section 3C: Total premiums liabilities surplus / deficit
Total direct business – premiums liabilities surplus/deficit
Total reinsurance business– premiums liabilities surplus/deficit
Total deferred reinsurance expenses for future business not yet written
Total premiums liabilities surplus/deficit

All data items, excluding 'Adjustments and exclusions to prudential requirements for the PL Insurance Risk Charge'

GRF_310_1_L: Premium Revenue and Reinsurance Expense (L)

Section 3:
Total direct business - All data items
Total reinsurance business - All data items
Total - All data items
Of which is from/with: Parent entity - All data items
Of which is from/with: Controlled entities/ Controlled entities of the parent - All data items
Of which is from/with: Associates/Joint ventures - All data items
Of which is from/with: Other related entities - All data items

All data items

GRF_310_2_L: Claims Expense and Reinsurance Recoveries (L)

Section 3:
Total direct business - All data items
Total reinsurance business - All data items
Total - All data items
Of which is from/with: Parent entity - All data items
Of which is from/with:  Controlled entities/ Controlled entities of the parent - All data items
Of which is from/with:  Associates/Joint ventures - All data items
Of which is from/with:  Other related entities - All data items

All data items

GRF_310_3_L: Details of Income and Expenses

1. Investment income – All data items
2. Operating income – All data items
3. Operating expenses – All data items
4. Underwriting expenses and Acquisition costs
Section 3:
Total direct business - All data items
Total reinsurance business - All data items
Total – All data items

All data items

GRF_410_0_L: Movement in Outstanding Claims Liabilities

Section 3:
Total direct business - All data items
Total reinsurance business - All data items

Total – All data items

All data items

GRF_420_0_L: Premium Revenue by State and Territory of Australia (L)

None

All data items

GRF_430_0_L: Claims Expense by State and Territory of Australia (L)

None

All data items

GRF_440_0_L: Claims Development Table (L)

Section 3:
Total direct business - All data items
Total reinsurance business - All data items

Total – All data items

All data items

 (1) Australian Prudential Regulation Authority (confidentiality) determination No. 11 of 2015

General Insurance – Level 2 Groups

Reporting Form

Current data deemed non-confidential (1)

Proposed determination of non-confidential data

GRF_115_0A_G: Outstanding Claims Liabilities - Insurance Risk Charge - Australia by Class of Business (G)

Were actuarial services used to complete this return (Yes/No)
Section 2: Direct business (International) - All data items
Section 4: Reinsurance business (International) - All data items
Section 5: Total
Total direct Australian business - All data items
Total direct International business - All data items
Total reinsurance Australian business - All data items
Total reinsurance International business - All data items
Group adjustments – All data
Adjustments to OCL Insurance Risk Charge as approved by APRA
Total - All data items
OCL surplus / (deficit)

All data items, excluding 'Adjustments to OCL Insurance Risk Charge'

GRF_115_1A_G: Premiums Liabilities - Insurance Risk Charge - Australia by Class of Business (G)

Were actuarial services used to complete this return (Yes/No)
Basis of preparation

PART A: PREMIUMS LIABILITIES - GPS 320 BASIS
Section 2: Direct business (International) - All data items
Section 4: Reinsurance business (International) - All data items
Section 5: Total
Total direct Australian business - All data items
Total direct International business - All data items
Total reinsurance Australian business - All data items
Total reinsurance International business - All data items
Total premiums liabilities - GPS 320 basis – All data items

PART B: PREMIUMS LIABILITIES - AASB BASIS
Section 7: Direct business (International) - All data items
Section 9: Reinsurance business (International) - All data items
Section 10: Total
Total direct Australian business - All data items
Total direct International business - All data items
Total reinsurance Australian business - All data items
Total reinsurance International business - All data items
Total premiums liabilities - AASB basis – All data items

 

PART C: ADDITIONAL POLICIES RISK CHARGE
Section 12: Direct business (International) - Net written premium for material business that incepts in the next reporting period – All data items
Section 14: Reinsurance business (International) - Net written premium for material business that incepts in the next reporting period – All data items

PART D: TOTAL PREMIUMS LIABILITIES
Section 15: Total
Total Australian direct business - All data items
Total Australian reinsurance business - All data items
Total International direct business - All data items
Total International reinsurance business - All data items
Group adjustments
Adjustments to PL Insurance Risk Charge as approved by APRA
Total - All data items
PL surplus / (deficit) – All data items

All data items, excluding 'Adjustments to PL Insurance Risk Charge'

(1) Australian Prudential Regulation Authority (confidentiality) determination No. 11 of 2015

Life Insurance

Reporting Form

Current data deemed non-confidential (2)

Proposed non-confidential data

LRF_200_0: Capital Adequacy Supplementary Information

Section 2: Insurance risk charge
(i) 3. Total impact of stress margins – all data items
Section 3: Variable annuities – all data items

All data items

LRF_330_0: Summary of Revenue and Expenses

(i) Totals by class of business – all data items

All data items

LRF_400_0: Statement of Policy Liabilities

(i) 2. Totals by class of business and basis – all data items

All data items

LRF_420_0: Assets Backing Policy Liabilities

(i) 3.Totals by class of business – all data items

All data items

LRF_430_0: Sources of Profit

(i) 2. Totals by class of business and profit allocation – all data items

All data items

 (2) Australian Prudential Regulation Authority (confidentiality) determination No. 12 of 2015

2020

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