Pisa or Actuarial Compliant?

When we talk about actuarial compliance, we usually limit this to our strict actuarial work field.
In a broader sense as 'risk managers', we (actuaries) have a more general responsibility for the sustainability of the company we work for.

Compliance is not just about security, checks, controls, protection, preventing fraud, ethical behavior. Moreover  compliance is the basis of adequate risk management and delivering high standard service and products to your companies clients.

Pisa Compliant
No matter how brilliant and professional our calculations, if the data - on which these calculations are based on -  are 'limited', 'of insufficient quality' or 'too uncertain', we as actuaries will finally fail.

Therefore , building actuarial sandcastles is great art, however completely useless. Matthew 7:26 tells us :  it's a foolish man who builds his actuarial house on the sand....

And so, let's take a look if we have indeed become 'Pisa Compliant' by checking if our actuarial compliance is build on sand or on solid ground. In other words: let's check if actuarial compliance itself is compliant...nd.

Actuarial Data Governance
To open discussion, let's start with some challenging Data Governance questions:

• Data quality compliance
  How is 'data quality compliance' integrated in your actuarial daily work? Have you addressed this issue? And if so, do you just rely on statements and reports of others (auditors, etc), can you agree upon the data quality standards (if there are any). In other words: are the data, processes and reports you base you calculations on, 100%  reliable and guaranteed? If not, what's the actual confidence level of your data en do you report about this confidence level to the board?
  
  
• 
  Data quality Conformation
  Have you checked your calculation data  set on bases of samples or second opinions?
  
  And if so, do you approve with the methods used, the confidence level and the outcome of the data audit? 
  
  Or do you just 'trust' on the blue eyes of the accountant or auditor and formally state you're "paper compliant"?
  
  Did you check if  client information, e.g. pension benefit statement, are not only in line with the administrative data, but also in line with insurance policy conditions or pension scheme rules?
  
  
• Up to date, In good time
  To what quantitative level is the administrative data  'up to date' and is it transparent?
  
  Do you receive administrative backlog and delays reporting and tracking and if so, how do you translate these findings in your calculations?
  
  
• Outsourcing
  From a risk management perspective, have you formulated quantitative and qualitative demands (standards) in outsourced contracts, like 'asset management', 'underwriting'  and 'administration' contracts?
  
  Do you agree on these contracts, do 'outsourcing partners' report on these standards and do you check these reports regularly on a detail level (samples)? 

And some more questions you have to deal with as an actuary:

• Distribution Compliance
  Is the intermediary and are the employers and customers your company deals with, compliant? What's the confidence level of this compliance and in  case of partially noncompliance, what could be the financial consequences? (Claims)
  
  
• Communication Compliance
  Is communication with employees, customers, regulators, supervisors and shareholders compliant? Has your board (and you!) defined what compliance actually means in quantitative terms?
  
  
  
  Is 'communication compliance' based on information (delivery and check) or on communication?
  
  In this case, have you've also checked if  (e.g.) customers understood what you tried to tell them?
  
  Not by asking if your message was understood, but by quantitative methods (tests, polls, surveys, etc) that undisputed 'prove' the customer really understood the message.
  
  
  
  Effective Communication Practice
  Never ask if someone has understood what you've said or explained. Never take for granted someone tells you he or she 'got the picture'.
  
  Instead act as follows: At the end of every (board) presentation, ask that final and unique question of which the answer  assures you, your audience has really understood what your tried to bring across.

Checking Compliance

Now we get to the quantitative 'hard part' of compliance:

How to check compliance?

This interesting topic will be considered in my next blog.... ;-)

To lift a little corner of the veil, just a short practical tip to conclude this blog:

Compliance Sample Test
From a large portfolio you've taken a sample of 30 dossiers to check on data quality. All of them are found compliant. What's the upper limit of the noncompliance rate in case of a 95% confidence level?

This type of question is a typical case of:

“If nothing goes wrong, is everything alright?”

Answer.

The upper limit can be roughly estimated by a simple rule of thumb, called 'Rule of three'....

'Rule of three for compliance tests'

If no noncompliant events occurred in a compliance test sample of n cases, one may conclude with 95% confidence that the rate of  noncompliance will be less than  3/n.

In this case one can be roughly 95% sure the noncompliance rate is less than 10% (= 3/30). Interesting, but slightly disappointing, as we want to chase noncompliance rates in the order of 1%.

Working backwards on the rule of three, a 1% noncompliance rate would urge for samples of 300 or more. Despite the fact that research for 46 international organizations showed that on average, noncompliance cost is 2.65 times the cost of compliance, this size of samples is often (perceived as) too cost inefficient and not practicable.

Read my next blog to find out how to solve this issue....

Related Links:
- Actuarial Compliance Guidelines
- What Is The Right Sample Size For A Survey?
- Epidemiology
- Probability of adverse events that have not yet occurred
- The True Cost of Compliance (2011)
- 'Rule of three'
- Compliance testing: Sampling Plans (accounting standards) or Worddoc

Humor: Merkozy, It's too late

Comparing 5 year exchange rates USD/EUR (decline : 17%) and USD/CNY (decline 21%) clearly shows the negative outlook of the US Dollar.

Both U.S. and Europe, are facing severe debt problems they can not solve with more debt.

Desperate actions
President Obama tries to stimulate economy by creating 1.5 mln new jobs with a $ 450 billion investment (American Job Act).

In Europe president Merkel (Germany) and Sarkozy (France) have joint their strengths and totally different characters into 'one personality', to create not only a strong financial but also economic European union.

This new economic union is necessary to establish a firm grip on the measures that weak financial European countries like, Greece, Italy, Ireland, Spain and Portugal have to take to recover from their debt.

It's too late
Unfortunately there's no support for such an initiative. Unluckily, no Merkozy will be able to prevent Europe from a financial meltdown.

The  only way out seems a European split in relative strong and weak countries.

Make up your mind on the geographic spread of the assets of your company. Get out before it's too late....

Irrational Risk

Actuarial work is demanding..., so you're arriving late at your hotel that night. The hotel manager has only two rooms left. These two rooms are exactly the same, except for one aspect: The fire alarm.....

The manager tells you that in the event of a nighttime fire due to the usual causes, guests in Room 1, equipped with Alarm 1, have an actuarial calculated  2% chance of dying. Guests in Room 2, equipped with Alarm 2, have only a 1% chance of dying.

However - things in life are always complicated -  there's a slight problem.....

According to the manager...... The wiring of Alarm 2 is such that it sometimes causes electrical fires that increase the risk of dying in a nighttime fire by an additional 0.01%.

In other words, Alarm 1 is associated with a 2% risk of death and Alarm 2 is associated with a 1% + 0.01% (betrayal) risk of death.

What room do you choose as a professional actuary?

Outcome
According to a study by Gershoff and Koehler, most participants choose the room with Alarm 1. This,  even though this room 1 has double the increased risk of fire death, according the researchers. Reason: most participants found the tiny risk of "betrayal" (product malfunction) much more frightening than the much larger risk of actually dying.  When people get upset by a tiny risk, they often paradoxically choose the much larger risk.

Personally I think a more imaginable risk 'weighs' stronger than a non-specific abstract risk and in general people are unaware of conditional probability effects......

Conclusion

This simple example proofs that emotion has a strong influence on risk decisions.

Just like in our actuarial profession, risk decisions are often irrational.

It is our duty as actuaries to demystify and to rationalize risk. However, sometimes we're victim of the same emotional bias....




Read more about this interesting subject on:

- Vaccination and betrayal aversion (2011)
- Safety First? The Role of Emotion in Safety Product Betrayal Aversion (2011)

- The Risk-as-feelings hypothesis in a Theory-of-planned-behaviour
- Behavioral economics: the missing link in the financial crisis-  
- Decisions are Never Emotional