AA Qualifications vs AA Expectations

edited September 2025 in OSFI.AA

What is currently stated in the Battlecards as the expectations regarding the AA, in the updated version of the source is now under qualifications of the AA.

Also, what is stated in the Battle cards as the 3 rules of qualifications are not mentioned in the latest version of the source. Same for the peer reviewer.

Comments

  • Thank you for the spot on this - Do agree that the expectations in the Battlecards are not the qualifications.

    For the qualifications, yes I feel the new version of the source does not have this as well!

    Just for the part on the peer reviewer, which bit are referring to? Thanks!

  • For the peer review part, I was refering to BattleQuiz 6, card 1. Thanks!

  • Ah got it! Ya agree with you there, will take this back to correct. Thanks for spotting this!

  • edited October 2025

    Are these all the PR eligibility requirements:

    Musts:
    1 - 3 yrs Canada exp (1 yr val) cia sop, 2+ unrelated companies
    3 - 3 yrs removed from comp
    4 NO INV in company unless mutual fund
    5 NOT same firm/friends with AA
    6 ok same firm doing FS (not in work),
    7 ok same audit (if big company, not preferred)


    1) anything missing? PR for multiple companies etc.
    2) for PR being same audit firm as AA - can they not be involved in audit itself (point 5 -> 6)? like FS?
    3) what if you have 1 consulting company and worked with 3 different clients?

  • edited October 2025

    As listed per the source:
    https://www.osfi-bsif.gc.ca/en/guidance/guidance-library/appointed-actuary-legal-requirements-qualifications-peer-review-guideline-2023

    OSFI believes that the following criteria should be applied in determining the objectivity of a peer reviewer:

    • A peer reviewer may not be an employee of the company or any affiliated companies and may not have been employed by the company or served as AA of the company during the three years prior to the date of the work being reviewed.
    • A peer reviewer must not be a shareholder of or have a direct financial investment (other than as a policyholder, depositor, beneficiary or insured) in the company.
    • A peer reviewer may have an indirect interest (for example, through a diversified mutual fund investment) in the company.
    • If a member of a consulting firm is the AA, another member of the same firm may not be the peer reviewer.
    • If a member of a consulting firm is involved in any actuarial work related to the financial statements or financial condition reporting for the company, another member of the same firm may be the peer reviewer only if they are not involved in this work for the company. In this context, "actuarial work" includes deciding on methodology, selecting assumptions, relying on the work of others, and producing results.
    • It is acceptable, and in fact expected, that the AA will be in contact with the peer reviewer during the year to discuss the potential acceptability of changes in methodologies and assumptions that the AA is considering.

    I'm not sure I fully understand your questions, so I'll try to best answer them from what I think is being asked

    1. I think you covered it. Not sure what your comment "PR for multiple companies" means.. Do you mean to ask "can you be a PR for multiple companies?" Nothing from the source on this but I think the answer is yes, as long as for each company you peer review:
    • You have no conflicting relationship with that company or its AA that impairs objectivity, and
    • You are not involved in that same company’s actuarial work that is subject to peer review.
    1. As for PR being from the same external audit firm, this is what the source states - However, using an actuary from the external audit firm can accommodate smaller and simpler companies. For a small and less complex companies, OSFI regards an actuary working for the external audit firm to be sufficiently independent to be a peer reviewer if the peer reviewer is not an actuarial specialist who is a member of the audit team for the company. -> So yes can be from same external audit firm, and they cannot be involved (must not be an actuarial specialist as mentioned above)
      However, as noted in subsection 4.7, if an actuary in the external audit firm is used for peer review, the peer review of any work that is subject to audit should be completed before the audit opinion is issued. In addition, this peer review work should be performed under a stand-alone engagement that is separate from the audit engagement. -> further highlighting how they cannot/should not be involved
    2. Not sure what you are trying to ask here, we have a firm and 3 clients.. Are we the PR for the 3 clients or the AA for the 3 clients? What are we doing here?
      If I presume we are the AA for all 3 clients, we cannot peer-review as mentioned up top "If a member of a consulting firm is the AA, another member of the same firm may not be the peer reviewer."
  • for 3: If a PR had experience with 3 unrelated insurers with they were with the SAME consulting form.

  • edited March 30

    following up, I meant to say while*

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