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From the Readers
What an Actuary Wants
Dear Editor:Paul Lacko was on the money in his "In My Opinion" column (The Actuarial Review, February 2003) in which he wrote, "We actuaries are too sensitive to criticism that we are only average at nontechnical business skills." I do not disagree with anything Gail Ross wrote in the same issue in her "From The President" column encouraging actuaries to improve their business skills. However, by unduly emphasizing this, we seem to be buying into our own stereotype. In my experience both in and out of actuarial circles, I have found little correlation, either positive or negative, between technical and business ability.
This topic has been a point of emphasis within the CAS since the well-publicized CEO survey of a few years ago, in which CEOs suggested that some actuaries "need to develop general business skills and a broader business perspective." We should certainly listen to what CEOs have to say about us, but we need to take their criticisms with a grain of salt. Earlier in my career, after I delivered news of the need for a significant reserve increase, my company's CEO ordered the study redone and dispatched me to a branch underwriting office to learn some "business skills."
The next survey I would like to see is one commissioned by CEOs, asking actuaries what the CEOs could do to better serve their own companies.
Clive L. Keatinge, FCASClear and Defensible in Word and Deed
Dear Editor:I would like to join Mike Miller ("From the Readers," The Actuarial Review, February 2003) in applauding "Cruising for an Ethical Bruising" (The Actuarial Review, November 2002) and in asking for more of the same. Such articles help us all develop greater awareness of the increased professionalism we need to demonstrate as we take our turn as an attack target of the plaintiffs' bar. Mike's prediction of a significant increase in the need for us to defend our work is fully justified. As is so often the case however, the good news and the bad news are the same: we have become sufficiently notable so as to be a target. Being in the lawyers' crosshairs is not a very pleasurable measure of success, but it is a real one nonetheless.
In his discussion of honesty, integrity, skill, and care, Mike has eloquently demonstrated the sophistry with which our legal profession has made relevant, if not productive, investigations into what the definition of "is" is. They will attempt to use our words, no matter what they are, against us.
Ambiguity in both language and action is a given. It is a basic reason we have both criminal and civil courtsso that when there is harm with greater ambiguity surrounding it than that with which criminal courts can deal, the civil courts can take up the challenge. Of course, whether there is harm is often ambiguous in itself.
If we are a profession, and I believe it is incontrovertible that we are, we undertake responsibilities to others that supersede our individual and collective self-interest. Because we stand close to arenas in which unintended and unpredictable harm can and will occur, we will inevitably be called to task and others will judge our actions. We hope to be judged fairly, remembering that judgment never seems fair when you are in the crosshairs.
All of this is to say that it is important that both our words and our work are clear and defensibleit benefits others as well as ourselves. It is the very reason so many people from every corner of our profession have worked so hard through the years to craft, word by word, a code to govern our professional conduct and standards to govern our professional qualifications and practice.
I am very uncomfortable with Mike's suggested rewrite of Precept 1. It would simply change the focus of the debate and could ultimately be seen as removing from the individual actuary the responsibility to be a professional. It would be the first step in moving from principle-based standards to procedure-based standards. If we believe there is a desirable safe harbor in such an approach, we completely miss the ambiguity inherent in the reality in which we live. It is telling that the questioning Mike describes related to an unanticipated reserve deficiency has nothing to do with standards. It has everything to do with the work we undertake.
None of this is meant to suggest we do not need to aggressively pursue clarification and improvement in our standards and, perhaps, in our code. I will push for, support, and participate in these efforts. They are critically important to us in the difficult times we face. Profession-wide, we need to engage in debate, discussion, and deliberation on this subject so we can make improvements that can better help our publics and reduce the potential ammunition the plaintiffs' bar can unfairly use against us.
Robert A. Anker, FCAS, MAAAEditor's note: Robert Anker is president of the American Academy of Actuaries.
Can We Do Better?
Dear Editor:A recent article in the Wall Street Journal and one earlier this year about sizable increases in loss reserves of the property/casualty insurers certainly got my attention. Reserving is actuarial territory. When we hear about sudden increases, measured in billions of dollars, will our credibility be affected? Whereas actuaries may tolerate sizeable increases when accepted actuarial methodologies were followed, the financial public may not. One has to wonder, "Can we do better?"
Initially the primary job of most actuaries was establishing premium rates for exisiting coverages and for newly designed types of insurance. Therefore, it is not surprising that loss-reserving methodologies, for the most part, mimic ratemaking procedures. (Perhaps that's why the term "reserve" has been favored over "liability.") On this basis, reserves are the "tails" of estimated incurred extrapolations (or the unused portions of pure premiums in the Bornheutter-Ferguson method). These methodologies work well in ratemaking where the measurement of the whole is important. In reserving, the "tail" is 100 percent of the liability. For long-tailed lines, it is the tail that wags the dog, and not vice-versa. When the tail dominates, perhaps the emphasis should be placed on measuring the liability directly by using only relevant "tail" data: the same accumulations less closed claim data (accumulated paid less paid-on-open claims) through the development age of the liability piece under review. The analysis would then be limited to data for similarly aged populations of claims. This shift in approach would produce a "stand-alone" liability rather than a remainder (or complement) of estimated incurreds, or as the unused pure premium similar to policy reserves in life insurance.
Methodology alone won't produce adequate reserves and past history in third-party lines is often just thatonly hindsight. A shift in attitude, however, might help. From those Wall Street Journal articles we may need every bit of help we can get.
Ruth E. Salzmann, FCAS
Editor's Note: The following letter was sent to the CAS Board of Directors. A response follows the letter.
Mutual Recognition Logistics
Dear Director:The issue is not whether to pursue mutual recognition, but how. The actuarial profession in the United States is fortunate to already have the infrastructure appropriate to the issue. The structure does not require augmentation by the CAS or any other society of actuaries.
The purpose of this letter is to present argument that mutual recognition does not deserve an excessive allocation of CAS resources. After reading the material on mutual recognition in the February 2003 edition of The Actuarial Review and at the CAS Web Site, I am more convinced than ever that independent mutual recognition is an inappropriate course of action for the Casualty Actuarial Society at this time.
Please take a few moments to read the following comments before deciding the course of action for the CAS to pursue on mutual recognition. Thank you for your attention.
Current Procedures for Recognition of Foreign Actuaries' Work
Currently, if an actuary who obtained his or her credentials in another country wishes to practice in the United States with respect to casualty issues, he or she can apply to the Casualty Practice Council of the American Academy of Actuaries to be recognized as competent to practice. In this way, applicants are bound by qualification standards espoused by the American Academy, subject to the Code of Professional Conduct of the Academy, and also subject to actuarial standards of practice issued by the Actuarial Standards Board with respect to any actuarial work in the United States that the actuary performs. The Casualty Practice Council generally consists of senior casualty actuaries who are well qualified to evaluate the casualty actuarial abilities of actuaries.If the actuary wishes to establish closer ties with United States actuarial practice, membership in the Academy of Actuaries is open to actuaries who:
Have met educational requirements in an actuarial society, not necessarily in the United States, recognized by the Board of Directors of the Academy;
Has three years of responsible actuarial experience (not necessarily in the United States); and
Is either a resident of the United States or demonstrates familiarity with U.S. laws and practices in his or her respective area of actuarial practice.
In general, the combination of Academy membership and endorsement by the Casualty Practice Council will satisfy requirements applicable to casualty actuarial work in the United States.
If there are actuarial societies or regulators in other countries who deny Casualty Actuarial Society members the opportunity to practice, the CAS can work through the Academy and the Casualty Practice Council to reciprocate. For example, in situations it might be appropriate to reciprocate by putting a filter on Casualty Practice Council approvals and excluding any members of such societies from practicing in the United States.
In deciding appropriate reciprocation, we should keep in mind that it has not been uncommon for a local practitioner to work with actuaries from the United States in order to both satisfy local regulations and afford clients and employees access to appropriate actuarial expertise. We should be mindful of local conditions before implementing such a filter.
To sum, there is already an appropriate administrative infrastructure for recognition of foreign actuaries who wish to practice in the United States.
The Casualty Actuarial Society is a Learned Society
According to Article II of its constitution, the purposes of the Casualty Actuarial Society are:
To advance the body of knowledge of actuarial science applied to property, casualty, and similar risk exposures,
To establish and maintain standards of qualification for membership,
To promote and maintain high standards of conduct and competence for the members, and
To increase awareness of actuarial science.
None of these purposes relates directly to the granting of professional credentials for casualty actuarial practice in the United States or elsewhere. Indeed, the difference between a learned society and a credentialing society in part helps define the relationships between the Casualty Actuarial Society and the American Academy of Actuaries and the relationships between the Casualty Actuarial Society and the Canadian Institute of Actuaries.
In keeping with its role as a learned society, the Casualty Actuarial Society has meetings open to participation by nonmembers, publications open to contribution by nonmembers, and Web site discussion groups open to nonmembers. In each of these cases, nonmembers include actuaries from other countries.
The Casualty Actuarial Society also has a long tradition of insisting on successful completion of its examinations as a necessary step for becoming a Fellow of the Casualty Actuarial Society. There was a period in which an individual could become an Associate by writing a paper of appropriate quality. But, for most of its almost ninety-year history, the uniform and consistent answer to actuaries from other disciplines and other countries wanting to become Fellows of the Casualty Actuarial Society has been the answer that Al Skelding gave to John Gardiner in 1935"No waiver."
Intergenerational equity argues that we continue this standard. It has helped make us a strong professional society able to contribute solutions to many of today's problems.
To sum, participation in CAS activities is already open to foreign actuaries without completion of any mutual recognition process.
Mutual Recognition as Outlined Violates the Working Agreement
The Casualty Actuarial Society is a signatory to the Working Agreement among the American Academy of Actuaries (AAA), the American Society of Pension Actuaries (ASPA), the Asociacion Mexicana de Actuarios (AMA), the Canadian Institute of Actuaries (CIA), the Casualty Actuarial Society (CAS), the Colegio National de Actuarios (CONAC), the Conference of Consulting Actuaries (CCA), and the Society of Actuaries. The Working Agreement was last amended October 1, 1998.The Working Agreement recognizes the Casualty Actuarial Society and the Society of Actuaries as learned societies. Among its terms relevant to mutual recognition are:
(7) Each Participating Organization shall endeavor to encourage the actuarial profession to speak with one voice in each country on actuarial issues in the public policy arena.
(8) Each Participating Organization shall promote and enhance among its members the public interface functions as valuable and necessary activities to which all actuaries should contribute using the public policy interface bodies.
(12) In each nation of practice, the Participating Organizations shall endeavor to maintain a common code, rules, or set of guides to professional conduct, including reference to appropriate qualification standards and standards of practice, and a consistent set of counseling and disciplinary practices.
(19) The Participating Organizations agree to coordinate their IAA and other international activities as appropriate.
(24) To minimize future overlap, no new committee, task force, or other entity should be established without consideration being given to coordinating the effort with other relevant organizations.
(25) Each Participating Organization agrees to discuss, coordinate, and implement, where feasible, a program to eliminate any overlap in the functions performed by various committees and members.
Excerpts are from the Working Agreement at www.casact.org/aboutcas/workinga.htm.
The Working Agreement affords a framework for evaluating questions of mutual recognition. In this context, if other United States actuarial societies have pursued mutual recognition, it is incumbent on the CAS representatives to the Council of Presidents (COP) and the Council of Presidents Elect (COPE) to bring appropriate pressure to bear and insist that such societies amend their positions and pursue mutual recognition issues through the various practice councils at the Academy of Actuaries.
To sum, although not explicitly referencing mutual recognition, the Working Agreement suggests that American actuarial societies should continue to work through Academy practice councils on this issue. Other American societies, to the extent they exist, who have attempted to negotiate separate mutual recognition agreements need to be reprimanded at the COP/COPE and the Working Agreement enforced.
The CAS has consistently worked in support of ASTIN
On occasion casualty actuaries have used mutual recognition as a basis for arguing that there is a vacuum in international casualty actuarial science that the CAS must fill.The International Actuarial Association (IAA) created ASTIN (Actuarial Studies in Non-Life Insurance) in 1957. Today ASTIN has more than 2,000 members in approximately 50 countries. The ASTIN Bulletin is available at the CAS Web Site in keeping with our role as a learned society supporting casualty actuarial science in all areas of the world.
Inquiries regarding ASTIN should be directed to David Hartman at Chubb. My point is that the CAS has a history of working with ASTIN to support non-life actuarial activity. In this sense, ASTIN serves as an umbrella international association of casualty actuaries.
To sum, there is no vacuum of leadership in international casualty actuarial science that requires the CAS to negotiate mutual recognition agreements.
Administrative Confusion
- Two roads diverge in a wilderness. Suppose that you are a foreign actuary. How do you decide whether to apply for mutual recognition through an Academy Practice Council or through a mutual recognition agreement with the CAS? How do you determine which approach is better suited to whatever you want to do? I submit that this will not be an easy issue for English-speaking actuaries, will be more difficult for actuaries practicing in countries with a single actuarial society, and will be almost impossible for actuaries practicing in countries with a single actuarial society whose native language is not English. If you disagree, please send me a copy of the guidance that you foresee the CAS providing to foreign actuaries on this issue.
- TransitivityBy "transitivity" I mean the situation in which Society B grants recognition to a member of Society A, who then applies for membership in Society C under a mutual recognition agreement between Society B and Society C. In general, mutual recognition is pair-wise agreement between societies and not transitive. While this affords political control, it also suggests that the logic underlying mutual recognition is suspect. If we do not trust another society to evaluate qualifications for membership responsibly, why should we enter into a mutual recognition agreement?
- DisciplineWill mutual recognition agreements be supported by discipline agreements? Will we be obligated to pursue discipline in an actuary's native country if the actuary violates our code of professional conduct? Unlike tax law in which treaties prevail over U.S. code, in the area of mutual recognition we must be clear that our Code of Professional Conduct and Standards prevail over any mutual recognition agreements.
- EnfranchisementShould Fellows admitted through mutual recognition be enfranchised to vote in CAS elections? Mutual recognition could dramatically shift voting patterns in CAS elections. In particular, actuaries who have not "fought for their country" by taking examinations might have substantial influence on election results and, therefore, CAS positions. What might happen depends on the details of mutual recognition agreements. Clearly, this is not a consideration that can be taken lightly.
To sum, any mutual recognition agreement should be administratively practical. Issues such as these require consideration in its design.
Code of Professional Conduct
Precept 8 of the Code of Professional Conduct requires actuaries to take appropriate steps to ensure that they do not mislead clients. The spirit of the Code is that we not mislead people, not just paying customers, who rely on our statements. Insofar as the Casualty Practice Council already affords the necessary credentials for casualty actuarial work in the United States and membership in the Casualty Actuarial Society is a sufficient but not necessary condition for performing casualty actuarial services in the United States, there is room to argue that mutual recognition by the CAS is an approach to working in the United States that intentionally misleads actuaries in other countries and borders on a violation of the Code of Professional Conduct. Details of actual negotiations and agreements are needed to decide the question but CAS members involved in negotiating such agreements need to walk this tightrope carefully.On the other hand, current procedures for recognition of foreign actuaries are proven and can continue without interference from learned societies such as the Society of Actuaries and the Casualty Actuarial Society.
Damages
Little documentation of actual damages suffered by CAS members has been put forward. For example, as a member, I cannot name any other CAS members who believe that their ability to render valuable services to their employers and/or clients has been compromised by actions in Ireland. More information needs to be published for this to become a strong motivation for mutual recognition agreements.Summary
For the CAS to devote extensive resources to the creation of mutual recognition programs at this time appears to be a gross waste of CAS resources. We have structure and decision making procedures in place. This infrastructure took years to create. It is a wise child that knows its own father. We should recognize our tradition and established relationships in tackling mutual recognition issues.In particular, it appears that mutual recognition can be most efficiently pursued through the Academy of Actuaries using the existing Practice Councils. This approach does not require distinct agreements between the Casualty Actuarial Society and other actuarial societies.
I urge the Board to evaluate arguments in favor of mutual recognition agreements in light of the infrastructure that is already in place. Only arguments that both demonstrate clear advantages over current procedures and are consistent with current CAS agreements merit Board attention. If you agree, I ask you to reconsider the November 2002 resolution on mutual recognition.
Alfred O. Weller, FCASBob Conger, CAS Chairman of the Board; Gail Ross, CAS President; and Mary Frances Miller, CAS President-Elect and Chairwoman, 2003 Mutual Recognition Task Force respond:
Dear Al:
Thank you for your very thoughtful letter directed to CAS Board and Executive Council members. We apologize for taking so long to respond.You have brought up a number of interesting points, but you may have misunderstood the situation in some cases, and may not be fully aware of many of the controls that are being considered if mutual recognition is approved by a vote of our membership and agreements are pursued. Therefore, we wanted to take the time to address them in detail.
1. Current Procedures for Recognition of Foreign Actuaries' Work
You have significantly overstated the role of the Casualty Practice Council (CPC). The CPC becomes involved in examining the qualifications of an actuary only when the actuary desires to sign statements of actuarial opinion associated with NAIC annual statements. The CPC plays no other role in evaluating the competency of an actuary to practice. An actuary who is not a member of the Casualty Actuarial Society is free to practice in the United States in most roles undertaken by CAS members. With the exception of the appointed actuary for NAIC statements (and very few state regulations that require FCAS status like self-insured workers compensation reserve opinions), there is no requirement that an actuary be a member of the CAS to practice in the United States, nor are there standards or regulations that would require a non-CAS actuary to seek some sort of approval before practicing as a casualty actuary in the U.S.Assuming that the actuary is a member of a society that is a member of the International Actuarial Association, the actuary will be subject to a code of conduct much like the CAS Code, and will therefore be required to meet the qualification standards of the country in which the actuary would like to practice. By practicing in the U.S., the actuary places him/herself under the AAA's qualification standards and the Actuarial Standards Board's standards of practice. Should the actuary choose to join the American Academy [open, for example, to members of the Institute of Actuaries (U.K.) or the Institute of Actuaries of Australia], then the AAA's disciplinary process (ABCD) would also apply. However, if the actuary practices in the U.S. without joining any of the U.S. actuarial organizations, the only disciplinary process that applies is that of the actuary's home society, which may not have access to information concerning the actuary's U.S. practice. The ABCD would have no jurisdiction.
So, we agree with your statement that it is not difficult for qualified actuaries to practice in the casualty area in the United States. This was a finding of the 1998 mutual recognition task force and the situation has not changed. Nor would mutual recognition have much effect on the ability of a foreign-educated actuary to practice in the United States, because it would not change the application of the AAA's qualification standards. Fellowship in the CAS through mutual recognition would remove the legal requirement that the actuary seek approval of the CPC before signing an NAIC statutory opinion, but it would not remove the requirement in the AAA's qualification standards that the actuary have passed the CAS exams on ratemaking, reserving, and applicable law and regulation (currently Exams 5, 6, and 7-U.S). Nor would it affect the requirement that the actuary have completed three years of reserving experience under the supervision of an actuary who is qualified to sign NAIC statements of opinion. Where it would open practice rights is in those few cases where there is no alternative to CAS membership in a legal requirement, such as for some state self-insured workers compensation reserve opinions. Here again, however, the AAA's qualification standards would apply, ensuring that the actuary practice only if appropriately educated and experienced, just as it applies to CAS members today who are not experienced in, for example, workers compensation reserving.
The CAS Board is not endorsing the concept of mutual recognition in order to make it easier for non-CAS actuaries to practice in the United States. The Board recognizes that practice in the U.S. is not restricted for experienced actuaries. Rather, the Board's concern today is for CAS members and potential CAS members who want to have full practice rights outside North America. We have another goal, as well, to support the development of the profession in other countries.
The separation of educational credentials and practice qualifications between the CAS and the AAA/CIA in the U.S. and Canada is peculiar to North America. Outside the U.S. and Canada, the norm is for a single society to convey both credentials and qualification standards, and membership in the local society is a requirement for opining actuaries in a growing number of places. Back in 1998, the Board adopted a strategy of working through the AAA and the CIA to obtain practice rights for CAS members outside North America. That strategy was successful for Canadian actuaries. The CIA has successfully implemented mutual recognition agreements, and FCAS's who also happen to be FCIA's are covered by those agreements.
Why hasn't the AAA been equally successful? The reason is, perhaps surprisingly, due to the all-encompassing nature of the AAA membership criteria. Membership in the AAA is open to actuaries with many different credentials who practice in the United States, including some actuaries with limited qualifications, such as Enrolled Actuaries and Associates of the SOA and CAS. Because the AAA insists on only a single class of membership, it's not possible for it to come to agreement with other societies for mutual recognition of only some of the AAA's members.
So we are faced with a dilemma. Actuaries are free to practice in the U.S., with or without membership in the AAA. Membership in the AAA is relatively easy to achieve and does not require membership in the CAS, and an AAA member who is qualified can sign an NAIC statement if approved to do so by the Casualty Practice Council. There are a small number of other statements that require CAS membership, but they are so limited in number that most actuaries would not even be aware of them, much less feel that their practice was restricted by not being able to sign them.
In contrast, full membership in actuarial organizations outside the U.S. is not generally open to CAS members, and membership is increasingly often required to sign the equivalent of NAIC statutory opinions, arguably the pinnacle of actuarial practice. There are countries that require an appointed actuary's opinion for general insurance companies where a CAS member cannot sign the opinion.
Could/should we encourage the AAA and CPC to put pressure on such societies by placing reciprocal restrictions on their members? How would such a restriction be crafted? Would the AAA refuse to admit all the actuaries from another society because it doesn't admit CAS members? Or just the casualty practitioners? The AAA would be much more interested in admitting foreign actuaries who are practicing in the U.S., making them subject to the ABCD, than they would be in setting restrictions that probably wouldn't hold up under a restraint of trade challenge. And similarly, the Casualty Practice Council would not be willing to turn down an AAA member's credentials solely because they belonged to a society that didn't offer reciprocal practice rights if the actuary were otherwise qualified. Retaliatory action of that nature is so opposed to everything else that the AAA espouses, it would be astonishing if the AAA even considered it.
2. The Casualty Actuarial Society As A Learned Society
You are absolutely correct that Fellowship in the CAS is not a requirement for participation in CAS activities, including its meetings, seminars, and publications. In fact, the CAS already has an Affiliate membership category that is open to all actuaries who have achieved the equivalent of Fellowship in an IAA member organization and who practice in the casualty area, under3. Mutual Recognition Violates the Working Agreement
The Working Agreement does not apply to societies' decisions to enter into mutual recognition agreements with one another or with other societies. In particular, the working agreement is silent as to admission criteria for any of the societies. Each society can choose to admit whomsoever it chooses, without approval or agreement from the other parties to the agreement. It is very important to keep in mind that membership does not convey qualification. We have delegated the setting of qualification standards and standards of practice to the AAA, but we have certainly not delegated setting the criteria for membership in our society. The qualification standards relate to (1) what topics an actuary must demonstrate proficiency in, (2) the amount of experience an actuary must have, and (3) continuing education requirements for issuing statements of actuarial opinion. They apply to practice, not to membership. The SOA did not violate the working agreement when it removed nation-specific material from its syllabus, even though the AAA qualification standard for NAIC life statements insists on examination in that area. The SOA will not violate the working agreement when it lowers the requirements for ASA back to its old five-exam standard. And the SOA did not violate the working agreement when it chose to extend Fellowship to Fellows of the Faculty and Institute of Actuaries via mutual recognition. In fact, the SOA and the CIA both have already executed mutual recognition agreements with the Faculty and Institute of Actuaries and with the Institute of Actuaries of Australia.4. The CAS Has Consistently Worked in Support of ASTIN
This statement might be debatable. We do host the ASTIN journal on our Web site, and a small percentage of CAS members belong to ASTIN. Dave Hartman is working very hard to improve the interaction between the CAS and ASTIN. ASTIN is, however, a forum for research and a sponsor for colloquia. It is not and does not intend to be a credentialing body, and its membership is open to all actuaries with interest in non-life topics, not just those with formal training in property/casualty actuarial science.5. Administrative Confusion
All of the issues that you present are important, and the Board has considered each of them:
- Suppose you are a foreign actuary. If the CAS enters into a mutual recognition agreement with your native society and IF you want to sign NAIC statements of opinion, then you would have two routes to meeting the qualification standards. You could use the current route: join the AAA, meet the qualification standards, and present your credentials to the Casualty Practice Council for its approval. Or, you could join the CAS, meet the qualification standards (CAS exams and supervised U.S. reserving experience) and skip the CPC. Most such actuaries will join both the CAS and the AAA if their practice is in the U.S., so there's no big confusion anyway.
What if you don't want to practice in the U.S. at all? Then you probably don't need membership in the CAS and you probably won't bother to incur the extra dues. You would be unlikely to join the CAS under mutual recognition. You would not qualify to join the AAA.
On the other hand, what if you want to become a property/casualty actuary and you don't happen to live in the U.S. or Canada? Which exams should you take? The CAS is the only system that focuses entirely on your chosen area of specialization, and you recognize that it's going to give you the best grounding. You would probably prefer not to take a whole bunch of exams in other actuarial specialties. However, unless there's mutual recognition between the CAS and your local society, membership in the CAS might make you a great actuary, but it will prevent you joining your local actuarial society, which will prevent you from becoming the appointed actuary for general insurance companies in your home country. And depending on how regulated your country is, membership in your national society may become required for more and more things as your career progresses into the middle of the 21st century. Now there's a dilemma, surely. Do you take the CAS exams and forego the opportunity to be considered fully credentialed in your own home, or do you take your local exams, specialize in general insurance, and figure you've done the best you can? Or does the CAS have a mutual recognition agreement with your local society, so that you can get local membership through either exam path?
The CAS Board has recognized that, without mutual recognition, this dilemma will effectively prevent the growing number of casualty actuaries outside North America from obtaining CAS membership. With denationalization and deregulation of the property/casualty insurance industry progressing rapidly around the world, the growing need for casualty actuaries will be met by candidates who are not resident in North America and who will never practice in North America. Will they be CAS members, highly educated but restricted in practice rights, or will they have non-CAS credentials that are recognized globally through mutual recognition agreements?
- Transitivity. For the CAS, through the controls envisioned by the Board, the question of transitivity is not a significant issue. We intend to limit mutual recognition to only those actuaries who have specialized training in property/casualty insurance, through an exam process, where we will specify which exams an actuary must have completed to be considered for mutual recognition. So transitivity would not even apply unless the transitive member had also passed the property/casualty exams and met the experience requirement for mutual recognition. The CIA and SOA mutual recognition agreements with the Faculty and Institute currently ban transitivity because within the European Union mutual recognition is not optional for actuaries practicing outside their home country.
- Discipline. Actuaries who practice in the U.S. but are not members of any U.S. organizations are not subject to U.S. discipline. The only discipline for them is if their home organization knows about the alleged misconduct. If we adopt mutual recognition, then an actuary who becomes a member of the CAS through mutual recognition would be subject to the CAS discipline process like any other member of the CAS. If the actuary is practicing in the U.S., then the ABCD would handle the investigation and the CAS would administer the discipline. Similarly for the CIA/CAS relationship in Canada. If the actuary does not practice in the U.S. or Canada (e.g., if the practice is in Bermuda), then the mutual recognition member would be subject to CAS-administered investigation and discipline just as any other CAS member practicing outside the U.S. or Canada would be. This is a major plus for mutual recognition. It subjects casualty actuaries to the CAS Code of Conduct, ensures that they are subject to the same qualification and practice standards as CAS members, and enables the CAS to publicly discipline violations of the Code.
- Enfranchisement. Yes, actuaries who become Fellows of the CAS through mutual recognition would be able to vote in CAS elections. This could be a concern if there were enough property/casualty actuaries in the organizations that we contemplate mutual recognition with and if enough of them elected to join the CAS. However, the facts that neither the Faculty/Institute in the U.K. nor the Australian Institute have had a property/casualty curriculum for very long; it is far from the most popular choice for specialization in either organization; and the additional requirement that the actuary's practice be in property/casualty insurance significantly limit the number of actuaries who would even qualify for mutual recognition. The additional dues requirement will limit the number of actual mutual recognition Fellows even further.
6. Code of Professional Conduct
As pointed out above, your premise that the CPC controls qualification to practice in the U.S. is incorrect. The CPC's approval is required only for actuaries who are not members of the CAS and who wish to sign U.S. NAIC statements. Virtually all other U.S. actuarial work is open to all who choose to hold themselves out as actuaries. Rather than open the CAS itself to a violation of its own Code, adopting mutual recognition and admitting property/casualty actuaries who are practicing in the U.S. into the CAS would subject such actuaries to our Code of Conduct and discipline procedures should they attempt to mislead. As an example, the standard of practice for reserve opinions requires that the actuary affirmatively state that he/she is qualified to sign such opinions. A Fellow by mutual recognition who did not meet the qualification standards (including the requirement for three years of supervised experience) who signed a statement of opinion would be in violation of the Code of Conduct and would be subject to discipline in the U.S., just as any current member of the CAS who signs a statement without meeting the qualification standard is subject to discipline. Membership in the CAS is neither necessary nor sufficient for all property/casualty practice in the U.S., and adopting mutual recognition would not change that fact.7. Damages
We tend to agree with your statement that, as of today, there are few members of the CAS who are being seriously damaged by not being able to sign statements of opinion in some locations outside the U.S. As stated above, the CAS Board is concerned with where the actuarial profession will be for the next generation. The Board has set a long-range goal for the CAS to be globally recognized as the preeminent resource in educating casualty actuaries and conducting research in casualty actuarial science. If the growing numbers of casualty actuaries outside North America are effectively barred from joining our Society, and if the CAS credential is not recognized by law outside the U.S. and Canada, then we will not be able to claim that the CAS is "the preeminent resource" for casualty actuarial education and research.We hope that this has helped to clarify the board's position on mutual recognition and the renewed need for its consideration, Al. We would be happy to discuss it with you further.
Mutual Recognition and its Impact on Associates
Dear Editor:I attended our local actuarial club meeting last week and heard Gail Ross speak about mutual recognition. I was opposed to it at the beginning of her talk and still opposed to it afterwards. My opposition is solely based on the treatment of Associates of the CAS. During the discussion, many statements were made dealing with the high caliber of actuaries who are members of foreign actuarial associations. As actuaries we know that examples can only be used to disprove arguments, not to prove them. These statements don't support the argument that foreign actuaries should be recognized as Fellows of the CAS. They can only be used to disprove statements such as "All foreign actuaries are uneducated."
What constitutes being an actuary? In the United States, an actuary is defined by the American Academy of Actuaries (AAA) as a member of one or more of various actuarial societies. As an Associate of the Casualty Actuarial Society (ACAS), I am also a member of the American Academy of Actuaries. The AAA also defines professional standards of practice and other issues involving our profession. It has always been my understanding that the CAS is supposed to be an educational and research organization. It would seem reasonable that the CAS has the right to extend membership to any person who meets the CAS's definition for membership. Membership in the CAS allows a person to apply for membership in the American Academy of Actuaries and hence have practice rights in the United States of America.
There are two potential roads to practice rights in the United States of America, recognition by the CAS or recognition by the AAA. A true mutual recognition by the AAA would imply that all MAAAs should be recognized as actuaries. The current proposal presented by the CAS limits mutual recognition to Fellows only and hence does not benefit all members of the CAS. The existence of Associates and Fellows is a creation of the American system. Historically the difference between Associates and Fellows was that Fellowship required contributing to the body of actuarial knowledge by writing a paper published in the Proceedings. This procedure was dropped in favor of more examinations. The original requirements were somewhat parallel to the academic distinctions between a masters degree and a Ph.D. The Ph.D. requires original research. The current differentiation between the ACAS and FCAS designations is less clear other than there are two more barriers to overcome before the FCAS designation can be achieved.
If the purpose of mutual recognition is practice rights, academic requirements needed to recognize a foreign actuarial organization should be equivalent to the CAS Associateship educational requirements. Those foreign actuarial organizations whose educational requirements meet the goals of the CAS Associate examinations could be awarded the status of Member of the Casualty Actuarial Society or MCAS to distinguish them from those who had actually taken CAS examinations. This procedure would also satisfy the requirements of the AAA so that members of qualifying foreign actuarial organizations could then procure practice rights to the United States of America.
What should the CAS require in return for mutual recognition? If the academic standards of the foreign actuarial organization are deemed to be comparable to the Associate level, the CAS should require mutual recognition of all CAS members. If the educational requirements are higher than the Associate level, the CAS should require the foreign actuarial organization accept the ACAS designation as a partial fulfillment of those requirements and that the difference in the educational standard between the ACAS and full recognition be delineated with the additional requirements spelled out.
American actuaries should not be held hostage to foreign organizations that view the world differently than we do. Just because they do not have an Associate designation does not mean that Associates are not qualified actuaries. In the analysis of the educational requirements, careful consideration should be made to determine if the foreign educational requirements more closely resemble the CAS Associateship or Fellowship requirements. Only after that analysis should the CAS decide on mutual recognition. Mutual recognition is a one-shot deal. Once granted, it will be very difficult to change.
For these reasons I encourage all voting members of the CAS (i.e., Fellows) to vote against the current rule changes until such time as a complete analysis of the educational requirements has been completed and reported to the membership.
David G. Walker, ACAS, MAAAA Unique Perspective on MR
Dear Editor:My name is Chun Hua (Gary) Hoo, currently a CAS student from Kuala Lumpur, Malaysia. I have just received February's AR and have some feedback.
1. With regard to the story "CAS Board Endorses the Concept of Mutual Recognition," I would like to express my support for the board's vision and direction. In Malaysia, the recognized actuarial designation list currently does not include CAS (although I suspect this is because there are no CAS credentialed actuaries yet here). The list states a Fellow should be: FSA, FIA, or FIAA.
2. With regard to page 13 "CAS Web Site Offers P/C Insurance News Service," I have a suggestion to make: Would it be possible to offer these news articles through daily e-mails instead of having to visit the site online? I think this would be a more relevant way of keeping actuaries informed of the latest news. Furthermore, it would cut down on time needed to go to the link and view the articles.
3. With regard to "Looking for Actuarial Role Models: China's Developing P/C Insurance Market," I am interested to find out if there would be other possible future meetings as such. Is there someone I could contact through e-mail about this, perhaps someone from the Casualty Actuaries of the Far East group? I recall only seeing CAFE's mailing address in the CAS Web Site but no e-mail contact.
You are doing a great job with the AR, it really keeps me updated on events and happenings globally.
Gary HooPaul Lacko, AR Editor in Chief responds:
Dear Gary
Thank you for your letterit's nice to hear that we do some things right!
Mutual recognition is the hot topic in this issue of The Actuarial Review (see our lead story on the front page), and I'm sure we'll have more discussion about it in future issues of the AR. Thank you for telling us how it affects you directly. Most CAS members live and work in the U.S., and some have yet to travel beyond U.S. borders.
Mike Boa, CAS Manager of Communications and Research, encourages you to visit the CAS Web Site for your insurance news and to explore other parts of the Web Site when you do. Mike reports that our current news provider does not offer to deliver the news articles via e-mail, although there are other services that can provide news to you in that way.
The current president of Casualty Actuaries in the Far East (CAFE) is Kuei-Hsia Ruth Chu at Fubon Insurance Company, Ltd., and her e-mail address is ruth@fubon.com.tw. You can find this on the CAS Web site: click on "Regional Affiliates," then click on "International Affiliates" at the top of the screen, then click on "Casualty Actuaries of the Far East."