The “Committee Substitute” to H.B. 3622 is a very different animal

I have now received a copy of the “Committee Substitute” to H.B. 3622 (CSHB 3622 Bill Text). This committee substitute house bill is a very different animal than the original H.B. 3622.

Changes to the Funding Structure in the Committee Substitute House Bill

Here are the changes to the funding structure that I note.

1. Under original H.B. 3622 (and the status quo), Class 2 post-events would be repaid 70% by coastal insureds via premium surcharges and 30% by insurers by assessment. The maximum amount of Class 2 bonds was $1 billion.  Now, the insurers are simply supposed to pay 30% of the bill up front via assessment and coastal insureds are supposed to repay up to $700 million in borrowings through premium surcharges.

2. TWIA is required, apparently no matter what the price and no matter what its financial condition, to purchase a base level minimum of $1 billion in reinsurance at the top of its stack.  I would be pleasantly surprised if such reinsurance could be purchased for less than $100 million. This is so because of the low attachment point  for the reinsurance that will now exist in light of the depleted Catastrophe Reserve Trust Fund, the fact that the mandate puts TWIA over a barrel, and the historic pricing evidence. Standing alone, this reinsurance requirement should, however, bring the height of the stack for 2013 to about $2.98 billion ($180 million in CRTF, $800 million in assessment on insurers ($300 million interest free loan repaid by Texas through premium tax credits and $500 million true payment), $300 million in Class 2 assessments on insurers, $700 million in Class 2 post-event bonds paid for by coastal policyholders, and $1 billion in reinsurance)

3. If the catastrophe reserve fund has less than $1 billion in it, TWIA is required to purchase additional reinsurance so that the total height of its stack is the probable maximum loss for a 1 in 75 year storm.  By my calculations this will be a stack of roughly $3.7 billion. This provision thus requires TWIA to buy an additional $700 million in reinsurance. I would expect this extra level of reinsurance to cost between 50 and 70% of the cost of the first layer. Why so much?  Much of the premium for reinsurance is to pay the reinsurer for having to actually have ready access to its maximum exposure.  Moreover, the purchase of the first $1 billion will have shrunk limited global reinsurance capacity,

4. If the catastrophe reserve fund has more than $1 billion it, TWIA is required to purchase additional reinsurance so that the total height of its stack is the probable maximum loss for a 1 in 100 year storm.  By my calculations, this will be a stack of roughly $4.4 billion. If the CRTF has $1 billion, then the height of the stack with baseline reinsurance will be about $3.8 billion (see note below). TWIA will thus be required to purchase $600 million in additional reinsurance. I would expect this extra level of reinsurance to cost between 40 and 60% of the cost of the first layer.  Why?  Again, much of the premium for reinsurance is to pay the reinsurer for having to actually have ready access to its maximum exposure. And, again, there is not an unlimited supply of catastrophe reinsurance money.    The purchase of the first $1 billion will have shrunk limited global reinsurance capacity

5. The cost of the baseline reinsurance is borne by TWIA policyholders.  The cost of additional reinsurance, however, is borne by insurers in Texas, who will presumably figure out a way to pass the cost on. This, I now understand, is what insurance lobbyist Floyd Beamon was complaining about at the hearing yesterday.

Visualizations of the Funding Stack in the Committee Substitute House Bill

Here are some pictures of what the TWIA stack would look like under the Committee Substitute to H.B. 3622. Clearly there is a lot of “Piggy Pink” in these pictures — the color code for Texas insurers — and not very much “Teal Blue” — the color code for TWIA insureds. You’ll also notice some ‘Burnt Orange,” which, apologies to other Texas schools in advance, is the color code for the Texas fisc.  I hope to be able to post a more detailed analysis later today. My interim suspicion is that the Committee Substitute significantly decreases the risk of insolvency below that of the original bill (look at the last graph in this post). It does so, however, by forcing insurers to endure a far greater amount of what is euphemistically called “lift.”  In plain English, TWIA is yet again propped up for yet further expansion by using other people’s money. But at least it is made somewhat solvent for the near future and the reliance on the worst of the post-event bonds is eliminated.

 

TWIA Stack Under HBCS 3622 for various CRTF values

TWIA Stack Under HBCS 3622 for various CRTF values

 

 

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