I FIA this my actuarial exit

I FIA this my actuarial exit

My views are my own and are a personal reflection on how the new actuarial standards' application will impact me. They do not represent the view of my employer or other actuaries at that firm.

Passing the actuarial exams and becoming a Fellow (FIA) of the Institute and Faculty of Actuaries (IFoA) was hugely worthwhile, but cost me a lot. I lost contact with friends, missed out on holidays and gave up a chunk of my 20s to focus on them. The qualification opened the door to my last two career moves to RBS and then to Legal & General Investment Management. To give it up would hurt greatly, but I'm increasingly concerned I will have to do so at the end of the month.

Following failings in the profession and the Morris Review in 2005, the Financial Reporting Council (FRC) took responsibility for setting professional standards for UK actuaries. The latest changes, which come into effect from the 1st July, will apply those requirements more broadly, including potentially to the pure investment work I do. As head of the team, the standards would apply to any other work I could "veto" where actuarial techniques were central to the analysis (as set out the Framework for FRC technical actuarial standards 5.13).

But the problem is "actuarial techniques" are not well defined and so the application of the standards is not well defined either, leaving me personally open to their future interpretation by others. In the IFoA guidance they say the following counts as actuarial work:

"Asset/liability modelling work which uses techniques of actuarial science to project and value asset and/or liability cash flows, which might be carried out by members and other investment professionals".

That definition is so broad as to potentially include all asset related analysis that projects asset cashflows, as is standard within much of our investment analysis and risk management. The IFoA's guidance look to allay such fears with the statement that:

"TAS 100 does not require work to be performed in order to comply with the standard if or where such work would be disproportionate to the needs of users".

My view is that no single decision in our investment process is sufficiently dependent on actuarial techniques to justify any changes to our current approach for managing data, assumption setting, models communication and documentations. But I have no way of establishing ex ante if others would share my view and so the personal risks seem unquantifiable. Ultimately our decision making is discretionary and draws on the wider experience and knowledge of team members to deliver diversified portfolios. To achieve high quality outcomes for investors we hire the best people we can and rely on a combination of their skills and peer review to balance the robustness of analysis against the opportunity cost of excessive structure and rigidity. Ensuring the systematic application of the actuarial standards, to a sufficiently rigorous level to cover the significant uncertainty around how they should be applied, would be excessive and value destructive in my team.

Therefore it seems that I need to make personal sacrifice and give up membership, to ensure I can complete my role to the best of my ability. I absolutely understand the importance of quality control within work that is aimed at informing actuarial decisions, but I fear that their potential application more broadly to any technique that could be considered actuarial will limit the scope for actuaries to take senior roles in non-traditional fields.

I still cling on to the hope I've misinterpreted the new rules and am worrying unnecessarily. If others feel they can be of help in that regard then please get in contact, otherwise by the end of June my time as a member of the actuarial professional will be at an end.

 

Steve Mills

The Artistic Actuary

7 年

Were you persuaded to stay in the end John?

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Paul Macro

Partner, ndapt

7 年

John Roe - I've long been concerned about this sort of thing - actuaries who are proud of their profession but who are not performing traditional actuarial functions / using actuarial techniques on a day to day basis - and it seems I'm not alone - some clarity on the position (made publicly) would be welcome. A (tangentially) related point is the level of annual subscriptions for fellows who (as above) are proud of their membership but who are not performing actuarial duties but who are still required to pay fees - this may be less of an issue for those who work in large organisations and have them paid, but for those striving out on their own its a significant burden. Whilst the profession and its members have made great advances in recent years in widening the areas that actuaries work in (including many which place much greater importance on how an actuary thinks than the use of actuarial techniques) we seem not to have fully grasped the implications of this, and the potential for many to to say "I qualified as an actuary in XXXX" rather than "I am a Fellow of the IFoA" seems high.

Russell Gill

Commercial Risk Leader | Problem Solver | Advisor | Pensions, Banking, FinTechs

7 年

Me too. Given that the profession aims to support actuaries working in wider fields outside of traditional consultancy roles, I would like to see more proactive support for those already doing so. e.g. Clear real world examples on applying the standards, training courses... and the application of proportionality. I understand the desire to set minimum standards and protect the reputation of the profession, as well as public interest - this is to be commended - but this needs to be balanced against commercial considerations and supporting the wider membership base.

John, I'd certainly be interested to understand where you get with this. Worrying

Ben Kemp

General Counsel at Institute and Faculty of Actuaries

7 年

Hi John. Thanks for sharing your thoughts and concerns. I am General Counsel at the IFoA, with responsibility for our regulatory team. Perhaps we can discuss? I know that the intention behind the FRC's TAS 100 is not to create the excessive impact you fear- I do however understand the concern. I think to some extent there is a question about how one interprets and applies a principles based standard of this sort, which should be seen I think as premised upon considerations of reasonableness and proportionality (albeit this does call I recognise for a greater element of individual judgement/ discretion, as compared to more traditional and, I would argue, more burdensome, prescriptive rules based regimes). Perhaps we can speak? We certainly don't want to lose you! I can be reached at [email protected]. Very happy also to discuss with others who may have similar concerns. Best regards, Ben

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