CFTC Interprets “Swap” Definition In the Context of Longevity Risk Transfer

Eversheds Sutherland (US) LLP

The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) recently addressed for the first time the CFTC’s definition of a “swap” as it applies to a specific insurance transaction.1 On the basis of the Division’s guidance in no action letter 14-67 (NAL14-67),2  U.S. life insurers will be able, via a Bermuda cell insurer intermediary in a properly structured transaction, to provide a reinsurance hedge to banks active in protecting non-U.S. pensions against the mortality improvements of specified individual beneficiaries (Plan Beneficiaries).

Background. NAL 14-67 addresses a four-part transfer of the longevity and related inflation risk of a pool of Plan Beneficiaries under a non-U.S. defined benefit pension plan. To view a diagram of the transfer, please click here.

  1. A financial institution not regulated as an insurer (Non-U.S. Longevity Hedger) would enter into a swap providing to a non-U.S. pension plan a longevity hedge for the actual Plan Beneficiaries.
  1. The Non-U.S. Longevity Hedger, presumably a bank, would transfer longevity and related inflation risk under a longevity swap (Longevity Swap) to a non-U.S. insurance company, which could be a cell of a Bermuda insurance company (Insured Cell), or another insurance company.
  1. The Insured Cell would enter into an agreement (Insurance Agreement) with a second non-U.S. insurance company, which could be a cell of the same Bermuda insurance company (Ceding Cell). The Insurance Agreement  would insure the Insured Cell’s payment obligations relating to the same longevity and related inflation risk.
  1. A U.S. insurer’s (U.S. Insurer) subsidiaries domiciled in New Jersey and Connecticut, respectively (NJ and CT Insurers), would enter into a reinsurance agreement (Reinsurance Agreement) with the Ceding Cell reinsuring 100% or less of the longevity and related inflation risk assumed by the Ceding Cell under the Insurance Agreement.  

In this context, the U.S. Insurer had requested no-action relief out of concern that the Reinsurance Agreements between the cell insurer and the NJ and CT Insurers might be characterized as “swaps” under the Commodity Exchange Act (CEA) and regulations thereunder, or as guarantees or insurance of CFTC-regulated swaps. The U.S. Insurer was concerned that in such case the NJ and CT Insurers might be viewed as parties to, or providers, guarantors or insurers of, a CFTC-regulated swap. 

Conclusion. The Division concluded that

  • the Reinsurance Agreements should not be characterized as swaps under the CEA, and did not guarantee or insure a swap.
  • the NJ and CT Insurers were not parties to, or guarantors or insurers of, a swap. 

In granting the U.S. Insurer’s no-action request without expressly confirming whether the Reinsurance Agreements qualified for the Insurance Safe Harbor, the Division concluded that the “Reinsurance Agreement [was] a traditional Reinsurance Contract.”3 According to the Division, the Longevity Swap was merely a conduit for the longevity risk coverage and the Division viewed payments under the Reinsurance Agreement as “being passed through a conduit (a conduit created by unaffiliated third persons for their own business reasons) and not as insurance or as a guarantee of any portion of the conduit or any of the conduit’s obligations...”4 Accordingly, the Division stated that it would not recommend that the CFTC recharacterize the reinsurance agreements or take enforcement action against the NJ and CT Insurers as parties to, or as providers, guarantors or insurers of, a swap.

  1. Context: The Insurance Safe Harbor 

Title VII of the Dodd-Frank Act empowered the CFTC to regulate a broad range of swaps, except for those swaps, not relevant in this context, which Title VII empowered the Securities and Exchange Commission (together with the CFTC, the Commissions) to regulate. Title VII contained a broad definition of “swap”,5 and the Commissions likewise adopted a broad definition of swap6 for use in connection with Title VII’s regulatory requirements. Since this swap definition could be interpreted to include many insurance products, the CFTC excluded from the definition agreements or transactions that qualify for a non-exclusive insurance safe harbor (Insurance Safe Harbor).7

The agreements and transactions that qualify for the Insurance Safe Harbor include certain “Enumerated Products,”8 subject to the condition that such Products are provided by an entity meeting the “Provider Test” requirements.9 In particular, a reinsurance agreement of an annuity would qualify for the Insurance Safe Harbor and therefore be excluded from CFTC swap regulation if the agreement in fact reinsured an annuity, since an “annuity” and “reinsurance” thereof are both Enumerated Products, and the requirements of the Provider Test were met. 

Based on the conclusions reached by the Division in NAL 14-67, it appears that the U.S. Insurer had three concerns relating to possible recharacterization of the Reinsurance Agreements.

The first concern was apparently that the CFTC could recharacterize the Reinsurance Agreement as a guarantee of a CFTC-regulated swap. This recharacterization could cause the Reinsurance Agreement to be regulated as a swap since the CFTC interprets the term “swap” to include certain guarantees of swaps.

The second concern was apparently that the CFTC could recharacterize the Reinsurance Agreement as financial guaranty insurance. Financial guaranty insurance might qualify for the Insurance Safe Harbor, but only if, “in the event of payment or other default or insolvency of the obligor, any acceleration of payments under the policy is at the sole discretion of the insurer.”10 This requirement would apparently not have been met with respect to the Reinsurance Agreements, and so the Reinsurance Agreements would have fallen outside the Insurance Safe Harbor were they characterized as financial guaranty insurance.

The third concern was apparently that the CFTC could recharacterize the Reinsurance Agreements as CFTC-regulated swaps with either the Ceding Cell or potentially the Non-U.S. Longevity Risk Hedger. If the CFTC had decided to disregard the cell insurer (e.g., as an agent of the NJ and CT Insurers), the following warning in the preamble to the Swap Definition Release might have been relevant:

An agreement, contract, or transaction that is labeled as “reinsurance” or “retrocession”, but is executed as a swap . . . or otherwise structured to evade Title VII of the Dodd-Frank Act, would not satisfy the Insurance Safe Harbor, and would be a swap...”11

  1. The Division’s Facts and Assumptions 

In reaching its conclusions, the Division cited the following facts and assumptions.

  • Terms of Reinsurance Agreement. Under the Reinsurance Agreement, the Ceding Cell would pay to the NJ and CT Insurers a reinsurance premium “not different from” the premium that an insurer would charge if it were providing longevity risk coverage directly to the pension plan. The premium would equal an amount that, with respect to the longevity risk transfer, was based on the Ceding Cell’s actuarially determined best estimate of future longevity risk, plus a premium to compensate the U.S. Insurer for assuming potential mortality improvements of the Plan Beneficiaries. The U.S. Insurer in return would agree to pay to the Ceding Cell the actual benefits owed to Plan Beneficiaries, and the amounts payable by both parties would be netted. The Reinsurance Agreement called for two-way variation margin. The Reinsurance Agreement would be terminable on a party’s bankruptcy, failure to make a payment or post margin, a material breach of a covenant, or an adverse change in the tax or regulatory treatment of the Reinsurance Agreement. Upon termination of the Reinsurance Agreement, a final settlement payment would be due, based on the present value of the premium and the present value of expected future reinsurance benefits and, in some cases, the expected cost to the Ceding Cell of securing a replacement transaction.
  • Assumptions Relevant to the Product. The U.S. Insurer asked that the Division assume that
    • the Insurance Agreement was “an ‘annuity’ within the use of such term” and that the Reinsurance Agreement was “reinsurance” of an annuity “within the use of such term,” in each case as defined in the Swap Definition Release.
  • the NJ and CT Insurers concluded that the Reinsurance Agreements were not financial guaranty insurance under state law or under the Swap Definition Release.12
  • Assumptions Relevant to the Provider Test. The NJ and CT Insurers are each licensed and regulated by the insurance departments of their respective states, and are authorized to conduct annuity and annuity reinsurance business. Further, under applicable state insurance law, the coverage of longevity risk constitutes an annuity risk and the Reinsurance Agreement will be treated as reinsurance for state insurance regulatory purposes. Each Reinsurance Agreement would be subject to state insurance regulatory capital and reserving requirements and would be treated as an annuity product for applicable tax and accounting purposes.
  • Non-control of Cell Insurer. Each of the NJ and CT Insurers is not, and will not contemplate becoming, an affiliate13 of the Non-U.S. Longevity Risk Hedger, the Insured Cell or the Ceding Cell. This assumption is presumably important to establishing that the cell insurer was not merely the agent of the NJ and CT Insurers.
  • Inflation Risk. Any mismatch between (i) the amount the U.S. Insurer is required to pay with respect to an inflation risk and (ii) the actual inflation adjustment owed by the pension plan is small and not structured to achieve tax treatment for the Reinsurance Agreement as a notional principal contract. 
  1. The Division’s Conclusion

In recommending not to take enforcement action against the NJ and CT Insurers on the basis that the Reinsurance Agreement should be characterized as a swap, or as a guaranty or insurance of a swap, the Division concluded that the Reinsurance Agreement was a traditional reinsurance contract and that the transaction between the Insured Cell and the Ceding Cell was an insurance policy for longevity risk. The Division’s conclusion depended on the existence of only minimal basis risk between the longevity risk of the Plan Beneficiaries and the risk assumed by the NJ and CT Insurers under the Reinsurance Agreement. In particular, the Division highlighted that, according to the request for relief, the NJ and CT Insurers’ obligations under the Reinsurance Agreement

  • are “tied directly to (1) whether the actual Plan Beneficiaries live, in the aggregate, longer than expected  and (2) the obligations of the pension plan to pay such Plan Beneficiaries”14 and
  • are not tied to or otherwise affected by any other obligations that the Non-U.S. Longevity Hedger may assume under its derivative with the pension plan. 

Regarding its decision not to characterize the Reinsurance Agreement as financial guaranty insurance, the Division noted that obligations under the Reinsurance Agreements were not derived in any way from the ability of any other party in the related transactions to meet its obligations in any of the underlying transactions.15

The Division also pointed out that its conclusion might have been different if the swap entered into by the Non-U.S. Longevity Hedger “required, for tax or regulatory purposes, a mismatch between payments under the swap and the longevity risk assumed by the pension plan, and if the payment obligations under Reinsurance Agreement increased to support payments owed by the [Non-U.S. Longevity Hedger] under its swap, resulting in the reinsurance payments exceeding the actual longevity risk borne by the pension plan.”16

1 See “Further Definition of ‘Swap,’ ‘Security-Based Swap,’ and ‘Security-Based Swap Agreement’;  Mixed Swaps; Security-Based Swap Agreement  Recordkeeping,” 77 Fed. Reg. 48207 (Aug. 13, 2012) (Swap Definition Release).

2 CFTC No-Action Letter No. 14-67, April 8, 2014. A link to Sutherland’s memo on the Insurance Safe Harbor is here:

3 NAL 14-67, p. 7.

4 NAL 14-67, p. 8.

5 See Section 721(a) of the Dodd-Frank Act.

6 CEA section 1a(47)(A), 7 U.S.C. § 1a(47)(A).

7 See 17 C.F.R. § 1.3(xxx)(4) (2012).

8 17 CFR § 1.3(xxx)(4)(i)(C).

9 17 CFR § 1.3(xxx)(4)(i)(B).

10 17 CFR § 1.3(xxx)(4)(i)(A).

11 Swap Definition Release, p. 48213.

12 NAL 14-67, p. 7.

13 According to the Division, “affiliate” means the definition given that term in Rule 405 of the Securities Act of 1933.

14 NAL-14-67, p. 3.

15 NAL 14-67, footnote 7.

16 NAL 14-67, p. 8.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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