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Figure 1: Results for the                                       of the different level of economic and financial development
Milliman ASEAN Liberalisation Index (MALI)                                   in each member state, is expected to become a key hurdle
                                                                             hindering any meaningful integration between countries.
Rank    Country  Index (0-100)                                               In a survey of senior regional management conducted by
                                                                             Milliman in 2014, life insurance executives around the
1 Singapore      70                                                          region warned that the disparity in the maturity and
                                                                             sophistication of markets are likely to be the main barrier
2 Philippines    58                                                          to implementation of the AEC, although they have also
                                                                             expressed optimism that the concept of the AEC would be a
3 Malaysia       49                                                          positive development to the overall life insurance industry.

4 Indonesia      49                                                             The survey also suggested that life insurance executives
                                                                             are concerned that the AEC may disadvantage the less
5 Thailand       46                                                          developed markets within ASEAN, engender increased
                                                                             competitive pressure and would be costly to implement.
6 Brunei         41
                                                                             What does it take to achieve the goal of the AEC?
7 Vietnam        40
                                                                             While the progress to date suggests that the goal of fully
8 Cambodia       33                                                          fledged common regulation, with cross-border sales
                                                                             and flow of talent, may be more realistic as a long-term
9 Laos           33                                                          aspiration, there is scope to focus on what integration could
                                                                             mean in the immediate short- to medium-term time frame.
10 Myanmar       15
                                                                                Identifying some minimum standards for the life
Note: Due to the rapidly evolving nature of the life insurance industry the  insurance industry for all ASEAN member states to follow
 underlying data and considerations upon which the MALI is scored are        could be a good start. Areas such as capital and reserving
  extremely time-sensitive. While the intention is to adopt an objective     frameworks, sales practices, policyholder protection and
 approach to determining the underlying scores that make up the MALI,        others should be streamlined in such way so that it they will
 some aspects could be considered subjective and as such may be more         benefit life insurance players across all markets in ASEAN.
                     open to interpretation and judgement.
                                                                                Perhaps also recognising the complications of national
   To reinforce the differences in insurance practices                       policy objectives and wide disparity between each member
across various countries, within the report cited above,                     state, the AEC framework adopts an “ASEAN Minus X”
the Milliman ASEAN Liberalisation Index (MALI) ranks the                     approach, essentially allowing countries that are ready
relative state of liberalisation of the life insurance industry              to liberalise to proceed first, with others joining at a later
within each ASEAN country, taking account of the following                   stage. An alternative may be to categorise countries at
dimensions:                                                                  similar development stages (for example, ASEAN 5, Brunei
                                                                             Plus CLMV) or cultural links (for example, “Thailand Plus
• Product development: The extent to which product                           CLMV”).
   innovation is allowed and encouraged, as well as
   restrictions on product design imposed.                                      Even though the ASEAN Secretariat has declared that the
                                                                             European Union should not be seen as a model for the AEC,
• Distribution: The openness of each jurisdiction to                         possibly more so in light of recent developments occurring
   employ different distribution channels, taking into                       within the European region, one should not completely
   account the regulatory restrictions for each channel.                     disregard the potential lessons that may be drawn from the
                                                                             EU, especially given its similarity in terms of the existence of
• Investment: The extent to which life insurers have the                     vast cultural diversity. To ensure all citizens have the chance
   flexibility to determine investment strategies.                           to understand issues, legislations in the EU are translated
                                                                             into 24 national languages. Similar efforts should be carried
• Sophistication of Capital Regime: The progressiveness                      out also within the AEC.
   of capital regimes in each jurisdiction towards an
   “Economic Capital” framework.                                                As multinationals continue to seek opportunities to
                                                                             expand into new territories in the ASEAN region, the
• Policyholder Protection: The extent to which local                         MALI could serve as a regional benchmarking tool to help
   insurance regulators have put in place meaningful                         management assess the relative stage of development of
   mechanism aimed at protecting policyholders.                              respective markets. It would be interesting to see how
                                                                             countries transition along the MALI index in the coming
• Foreign Ownership: The extent to which participation                       years.
   of foreign insurers is allowed or encouraged to operate
   in the local life insurance market                                           Once greater cooperation is shown to be demonstrably
                                                                             beneficial to member countries, and with the introduction
• New Licences: The availability of new life insurance                       of common minimum standards in key areas, it could then
   licenses and the typical duration required for licence                    be easier for the AEC to target more ambitious goals in the
   approvals                                                                 future.

• Talent Mobility: The ease of issuance/renewal of work                      Mr Richard Holloway is Managing Director South East Asia & India Life;
   permit for foreign staff and other issues around talent                   Mr Michael Daly is Principal & Consulting Actuary; and Mr David Kong
   mobility across ASEAN countries.                                          is Consulting Actuary for Milliman

   The higher the MALI score, the greater is the state of                                  AEC – IMPACT ON INSURANCE • DECEMBER 2015 19
liberalisation. Singapore is ranked with the highest overall
score, confirming the widely held view that it has the most
advanced life insurance industry in ASEAN. Perhaps more
surprising, the Philippines has the second highest MALI
score. Myanmar has the lowest MALI score, reflecting the
nascent state of its life insurance industry.

   The differences in insurance regulations, largely a result

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