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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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