40
policyholders withdrew at an estimated quarterly rate of 20.3 percent of annuities and 9.5 percent
of life insurance policies during the first quarter of 1990, and First Capital policyholders
withdrew at an estimated quarterly rate of 15.6 percent during the second week of May 1991.
117
Regulatory stays were imposed at Executive Life that stopped any further runs. In another
example over a six-week period in June and July of 1991, pension liabilities were withdrawn
from Mutual Benefit at a rate of 37.7 percent per quarter.
118
Given its size and prominence, if
AIG were to experience material financial distress during a period of overall stress in the
financial services industry and in a weak macroeconomic environment, there could be a more
significant policyholder response.
119
However, there have also been significant changes to the
regulatory environment for insurance companies since these examples occurred, including risk-
based capital requirements that penalize insurers for owning higher-risk investments; risk-
focused regulatory examination procedures; and the Own Risk and Solvency Assessment
(ORSA) project, which requires insurers to report annually on material risks and how the
company’s capital model addresses those risks.
A.M. Best calculates a short-term (30-day) stress liquidity ratio to evaluate the overall liquidity
strength of life insurance companies. This test assumes that 15 percent of life policies and 50
percent of annuities are surrendered in one month, several multiples higher than the historical
examples cited above.
120
the April 1991 takeovers of Executive Life and Executive Life of New York spurred policyholder runs on junk bond
laden First Capital and Fidelity Bankers.” Richard L. Fogel, Insurer Failures: Regulators Failed to Respond in
Timely and Forceful Manner in Four Large Life Insurer Failures, GAO/T-GGD-92-43 (September 9, 1992), p. 6,
available at http://www.gao.gov/assets/110/104752.pdf
.
117
See DeAngelo, H., L. DeAngelo and S. Gilson, The Collapse of First Executive Corporation: Junk Bonds,
Adverse Publicity, and the ‘Run on the Bank’ Phenomenon, Journal of Financial Economics (1994), pp. 36, 287-
336; Annual Statement of the Executive Life Insurance Company of Los Angeles in the State of California to the
Insurance Department of the State of California for the year ended December 31, 1990; DeAngelo, H., L. DeAngelo
and S. Gilson, Perceptions and the Politics of Finance: Junk Bonds and the Regulatory Seizure of First Capital Life,
Journal of Financial Economics (1996), pp. 41, 475-511. Withdrawal rates at individual insurance companies can
be significantly higher. For example, the annuity portfolio of Executive Life Insurance Company experienced a
surrender rate of 42 percent for annuities (excluding single premium immediate annuities), and more than 40 percent
of its annuities were single premium immediate annuities or structured settlements with no cash value. The text
above cites the surrender rates for First Executive as a consolidated organization in order to compare it to AIG as a
consolidated organization.
118
Cohen, L. and C. Storch, The Run that Shook Mutual Benefit, Chicago Tribune, August 11, 1991, available at
http://articles.chicagotribune.com/1991-08-11/business/9103270714 1 mutual-benefit-life-insurer-tax-sheltered
;
Berg, Eric N., Mutual Benefit Backs State Control, The New York Times (July 16, 1991), available at
http://www.nytimes.com/1991/07/16/business/mutual-benefit-backs-state-control.html.
119
The year before its failure, Executive Life had $13 billion in assets and was the 33rd largest life insurer in the
United States. See The Collapse of Executive Life Insurance Co. and its Impact on Policyholders, hearing before the
House Committee on Government Reform, 107th Congress (2002).
120
See A.M. Best, A.M. Best’s Stress Liquidity Ratio for U.S. Life Insurers, December 18, 2015, available at
http://www3.ambest.com/ambv/ratingmethodology/OpenPDF.aspx?rc=197655
. On a call with staff on June 8,
2017, A.M. Best analysts did not cite specific historical examples that were used to support the A.M. Best model
assumptions, but did note that the company provides industry with periodic opportunities to comment on its model,
which may indicate that industry participants view the model’s assumptions as reasonable.