For an asset class that represents just 1.4% of insurer's
asset holdings1, equity release mortgages (ERMs) have
consumed a remarkable amount of firm and supervisory time. A decade
or so ago, the regulatory challenge of this asset class lay on the
conduct side. More recently, however, and not without some irony,
the main mitigant of these conduct risks, the no negative equity
guarantee2 (NNEG), has switched the focus primarily onto
the inherent prudential risks of equity release, namely its
illiquidity and, owing to the NNEG, the long term exposure it
brings to the fortunes of the housing market without further
recourse to the borrower.
The PRA has recently published supervisory statement SS3/17 on illiquid
unrated assets and ERMs in the context of the Solvency II Matching
Adjustment (MA). SS3/17 (summarised in the Annex to this blog) follows a
discussion and consultation process stretching over some 21 months
- a reflection no doubt of the technical debates,