More on the ‘C-factor’ in Regulation: Business Model Analysis

Business model analysis (BMA) is one of those terms that are becoming common currency in regulatory discussions, hence the reference to a ‘c-factor’ or common factor in an earlier post (here).  

The PRA published a useful article in the Bank of England March Quarterly Bulletin setting out how they intend to apply BMA to insurance.  It suggests that there are two aspects to a BMA.

Firstly, there is a company dimension, which is obviously not spelt out in great detail for the obvious confidentiality reasons.  In general terms, this would recognise that:

• there is an ‘inverse production function’ in insurance – the fact that insurers collect premium before the service has been delivered and can earn an investment return until claims are paid; and
• insurers must price the product without full knowledge of production costs – hence the ‘experience analysis’ of reserves.

Secondly, there is a market dimension, which recognises that a business model is not static and will respond to changes in regulation, culture, society and technology.  This is evidenced in the article by reference to two developments:

• price comparison web-sites in the UK motor industry; and
• non-standard annuities.

Overall, the PRA sets out a helpful and clear vision about BMA:

‘The PRA’s capital requirements help to make insurers resilient against short-term shocks.  But to be confident that insurers will remain viable over the longer term, the PRA needs to know whether an insurer’s profits are sustainable.  In other words, the PRA will need to analyse the risks of an insurer’s particular business model.’

I found quite remarkable and refreshing to see this level of clarity from supervisors. 

The recent UK budget announcement about removing the requirement for compulsory annuitisation will provide wide ground to test the practice of BMA from a regulatory perspective and, probably, from a company perspective as well.

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