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Adverse Selection on the Livestock Risk
Protection Contract
Adverse
Selection. The
Livestock Risk Protection (LRP) contract is based on yesterday’s market
and premium cost. If the
market closes down today, producers will be able to purchase their LRP
coverage not based on today’s lower market price but yesterday’s
higher market price and associated premium costs.
Therefore, LRP may meet the technical definition for adverse
selection but it is very limited because of the length of time until
expiration of the contract.
This is similar to the
situation with the loan deficiency payment that is based on a one day lag
in the market. Farmers have
traditionally made LDP claims on days when the market moves in their favor
based on the previous day’s market.
However, in the marketing loan program for cotton there is a one
week lag in the prices. Also
farmers can take out the loan and effectively have a 60 day window to
repay the loan and take advantage of a market that is moving in their
favor. Those are certainly
much longer time lags than available in the LRP contract which only has a
single day lag. Under normal
market circumstances the one day lag in the LRP is not a great advantage
for producers. Other than an
academic definition of adverse selection this one day lag is of little
concern to RMA or the insurance industry.
Adverse
Selection with Catastrophic Price Move.
One scenario that would change
this viewpoint is a catastrophic price event in the cattle market.
Examples might include: a
disease outbreak such as “mad cow disease” or a bio terrorism act that
would scare customers away from purchasing beef, limit exports and create
other negative market impacts. Under
this catastrophic market scenario one would expect the market to lock
limit down if it is open when the event happens.
The question then
becomes, if this were to occur, will producers be able to lock in LRP
coverage and premium costs based on the previous day’s market close
before the current catastrophic event was bid into the market?
It is also possible the catastrophic news might be revealed after
the Chicago Mercantile Exchange (CME) market closes.
Under current procedure producers would have from the CME market
close until
8:00 p.m.
central standard time to purchase their
LRP coverage by submitting a Specific Coverage Endorsement (SCE) contract.
In the event of a catastrophic market event it is
possible RMA would shut off sales. However,
there is some question how quick this might occur and producers might be
able to get their SCE accepted before the system is shut off.
It is unclear if there is a formal procedure for LRP offers
following a lock limit down CME price move.
Presumably in the event of a lock limit down move there would be no
SCE’s offered the next day because the previous day was a lock limit
down price move.
Even without this
limited adverse selection window producers may still want to consider an
LRP contract just to protect themselves against such a catastrophic event.
Because producers can buy coverages with higher levels of
deductibles for lower premium costs, there may be producers willing to buy
LRP just to protect against such a catastrophic event.
If one buys an LRP contract with a high deductible, then if such an
event were to occur; the LRP contract would provide a significant
indemnity payment.
From the “other side
of the desk” this is also a major concern of private insurance
company’s and reinsurers. Unlike
crop insurance where one gets geographic spread on the risk because not
all yields will be a 100 percent loss, every LRP contract sold on the same
day that is currently held will be paid.
The losses could be significant because all contracts will have
claims unlike the crop insurance contracts where only some contracts, even
in the most severe drought, will have claims.
Even those crop insurance contracts that do have claims will not
all be 100 percent claims. For
a given coverage level, the LRP indemnity payment will be the same for all
buyers. It is likely LRP
contracts will generate underwriting losses over 100% or 100% underwriting
gains. This is very different
from other forms of insurance.
Recommendation
to Producers.
A reasonable management strategy certainly would be to submit an
application for an LRP contract. This
application through one’s insurance agent will establish the
producer’s eligibility to attach coverage with the SCE later.
This will allow producers to be in a position to put the coverage
on should market conditions change or even potentially get an SCE approved
after a major negative market announcement such as a disease outbreak.
Because markets move so quickly, if producers don’t already have
the policy established it is unlikely they will have time to have the
policy approved and in a position to submit the SCE in the event of a
major negative market news event.
There is no cost for
establishing the policy and one is only committed for premium after the
coverage is attached by submitting the SCE.
Therefore, there is little reason for cattle producers to not
contact their crop insurance agent and establish the policy that makes
them eligible to submit the SCE in the event that one becomes concerned
about the price risk.
Clearly, the other
approach is to create a written market/risk management strategy for
livestock as many do with other commodities.
The LRP could be a part of a written risk management plan that
would protect against major losses in the cattle market.
LRP will also leave the upside open so that if prices go higher
producers will capture those returns less the premium they paid for the
LRP contract.
Unless RMA changes the
underwriting rules, every eligible livestock producer will likely find it
to their advantage to submit an application for an LRP contract.
There is no cost for the policy but producers will be able to move
quickly in the event of a market change.
It may even allow producers to take advantage of a catastrophic
price move. Only when the SCE
has been accepted does the producer have coverage and owe premium.
Producers need to get a LRP policy now to be in a position to
execute an SCE if they see a change in the price risk.
Underwriting
Issue.
From the RMA/insurance industry “side of the desk” there
appears to be an underwriting problem if there is a catastrophic price
event caused by a mad cow disease case in the
USA
or a bio-terrorism attack on the beef
supply. If the CME market
locks limit down then producers may be able to purchase a SCE based on the
previous day close. The bad
news could also occur after the CME closes.
Currently RMA has no public policy on how to handle such an event.
Most of the Livestock
Gross Margin (LGM) sales occurred on the last day of the sales period
based on a decline in the hog market.
LGM was only in
Iowa
so the exposure is relatively small.
The LGM has been reduced from a 2 week purchase window to a 2 day
window. However, RMA did not
shut off sales on the last day of the contract but some companies did
reach their company underwriting limit and that did shut off sales.
“Needed”
Underwriting Rules. Based on
this history it is reasonable to concluded RMA needs two more underwriting
rules on LRP:
1.
RMA would shut off LRP sales if the CME lock limits down.
2.
RMA would limit daily LRP sales as a percentage of the total book
A daily sales limit
would also spread risk over time because it would prevent a large
percentage of sales on a single day like happened with LGM.
There is no geographic spread on the risk as there is with the
yield risk on crops. The only
spread is over time but that spread is lost if most of the sales occur on
a single day. The daily limit
would also put a limit on sales if bad news came after the CME closed.
Why
Point Out the Underwriting “Hole”?
At a recent conference
producers raised the question why is the author calling attention to this
underwriting issue? In order
for the current private/public insurance program to work rates and
underwriting rules need to be “fair”.
If the underwriting rules allow for producers to adversely select
then private companies and their reinsurers will drop out of the market.
There was a recent consolidation of two companies and the sale of
another, so there are fewer companies in the crop insurance business.
Insurance contracts need to work for the producers, private
insurance companies and RMA. If
one side has an advantage then in the long run (probably two years in the
private market) then the other side will drop out of the market.
Either producers will not buy or companies will not make the
insurance offer. If this were
a total government program these underwriting issues may not be a problem
if taxpayers were willing to support the losses.
Limitations
on LRP.
Currently the LRP is not available on heifers or breeds containing
significant amounts of Brahma or dairy genetics. The other limitation on
the LRP contract is that producers are not allowed to take an offsetting
position in the futures market. For
example, they buy an LRP contract on their cattle and then write a put
option on the CME. Clearly,
this is probably an unenforceable underwriting rule simply because
producers could write the put option on their cattle (heifers?) that have
no SCE coverage or they could simply open a speculative account.
Probably this
underwriting rule effectively prevents marketing consulting firms from
marketing their service to producers on how to extract the subsidy from
the LRP contract. Remember
this is suppose to be a risk management protection tool that will reduce
the negative effects on producers’ revenues caused by declining prices.
In addition, most lenders who are financing cattle want the
protection. They don’t want
producers simply extracting the subsidy because the subsidy is a very
small amount of the total dollars at risk in a livestock operation.
“Unnecessary”
Underwriting Rules.
Because this is an index product and the basis (difference between
cash price and futures price) risk is retained by the producer there is no
reason not to insure heifers and other breeds.
During the recent conference one cattle producer raised the
question how much Brahma or dairy “blood” is too much?
Who will determine if the Brahma or dairy genetics in the cattle
exceeds the LRP limit?
Based on these current
LRP policies, RMA probably does not need the follow underwriting rules:
1.
Remove the limit on LRP sales for heifers, Brahma or dairy breeds.
2.
Remove the restriction on taking an offsetting board position
because the rule probably cannot be enforced.
No
Moral Hazard. There is little chance of
moral hazard in the LRP contract simply because the contract is not tied
to the individual’s production level or price received.
The payment is triggered totally on a market decline and that will
affect everyone who has bought an LRP contract.
For example, if 50 people purchased a 30 week contract today and
the market declines by $10 below the guarantee, they would all receive a
$10 indemnity payment assuming they bought the same coverage level.
The number of head and
the target weight are simply a way to determine eligibility for the
contract. RMA does not want
non-livestock producers purchasing the LRP contract because this is a
subsidized product. Therefore
the calculations used to determine the weight and head of cattle are
simply to verify LRP purchasers actually owned that number of cattle and
approximate weight certified in the application.
Market
for LRP. This contract may be very
attractive to certain classes of producers over a CME feeder cattle put
contract even if there is no adverse selection.
Producers may buy LRP only on the number of head they actually own
and that may be fewer head than would be required for a CME contract.
For example, if a full CME feeder contract represents about 67 head
of 750 pound steers but the producer only has 50 steers then he/she would
be able to purchase LRP on just the 50 steers.
Potentially this is a
very large market because
Kansas
is an important beef cow/calf state.
During 2002 there were 28,000 beef cow/calf operations in
Kansas
that produced 1.51 million calves.
The bulk of these calves came from relatively small operations.
During 2002, approximately 48 percent of
Kansas
calves were produced on farms that had a
beef cow inventory of less than 100 head, and virtually all operations had
fewer than 500 cows (table 1). This
is the segment of the market that is most likely to purchase an LRP feeder
cattle contract because the flexible contract size matches their operation
as opposed to an option on feeder cattle futures that represents roughly
67 steers weighing 750 pounds. The
LRP also allows producers the flexibility to buy incremental price
protection on a few head at a time to secure an average minimum price.
This is not a readily available alternative for small cow/calf
operations using the Chicago Mercantile Exchange (CME) traded options.
LRP is an insurance
contract because once purchased it can not be cancelled as can be done
with a put option. Because it
is an insurance contract with a specified insurance length it will be
attractive for lending institutions who are lending money on cattle
serving as collateral.
Because LRP is an
insurance contract there is also no question that it is a tax deductible
expense and would be included as a farm expense item.
Options are also a tax deductible expense although some trading
strategies sometimes are not considered deductible expenses.
One of the attractive
features of LRP is that producers will be able to have their coverage
accepted at the stated premium rate and guarantee as posted on the RMA web
site. Because put options are
traded in an active market, one may submit a purchase order at a specified
premium but not get a fill on the contract.
This is an even greater issue with put options that are on the
deferred months. The deferred
months are often thinly traded option markets and that increases the odds
the order will not be filled. Even
if the producer is purchasing an LRP contract, that will expire in 30
weeks or more, one will still have the contract filled.
Many producers will probably prefer knowing the exact guarantee and
premium cost at the time their insurance agent submits their SCE.
Coverage has attached as soon as the SCE has been accepted by RMA
and a confirmation number is returned to the insurance agent.
One major advantage of
the LRP is the 13 percent premium subsidy and there is no commission paid
by the producer. The insurance
agent commissions and operating expenses of the insurance company are all
funded from a separate line item in the RMA budget.
Summary.
This is a very “clean” contract with the exception that the
catastrophic price risk appears not to be covered.
Without the proposed underwriting rules listed above, it is the
equivalent of being able to call one’s insurance agent and purchase
“fire insurance when the house is already on fire”.
If RMA were to adopt those proposed underwriting rules, then
producers could still “buy fire insurance if they see a fire off in the
distance but has not yet reached their house”.
This is okay for LRP because the premium and guarantees change
daily but not if the “house is already on fire”.
In any case, eligible
producer should apply
for a policy because there is no cost.
Once the producer has an LRP policy they will be able to purchase
coverage quickly if market conditions change suddenly.
However, if they have not submitted an application for the LRP
policy before the event they will not have time to react.
If cattle producers don’t later submit an SCE that establishes
coverage, producers are only out their time for submitting the policy
application because they owe no premium.
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