We compare the regulatory environment for the maximum technical interest rate of life insurance contracts in four European countries and the United States. In Germany, Austria and Switzerland, the maximum rate is driven by a long-term rolling average of government bond yields and is adjusted by the regulator. In the U.S., corporate bond yields are used and the regulator is not directly involved in setting the maximum rate. The regime implemented in the United Kingdom is unique: instead of a rules-based "one-size-fits-all" approach, the maximum rate is determined by a company-specific principle-based method. We provide a comparative analysis of the different systems and conduct a numerical analysis to investigate how the maximum rate will develop under predefined interest rate scenarios. The discussion is highly relevant in light of Solvency II, a regime that may fundamentally change regulation of the maximum technical interest rate.

We compare cliquet-style interest rate guarantees used in German participating life insurance contracts across different economic environments. These guarantees are proportional to the average market interest rate at contract inception and typically determined as 60 percent of the 10-year rolling average of government bond yields. Currently, however, in the face of prolonged low interest rates and stricter solvency regulation, the continued existence of this product type is being seriously questioned. A discussion of alternative guarantee designs is thus highly relevant. To this end, we perform a comparative analysis of contracts sold in different interest rate environments with regard to the guarantee value and show that the current practice of proportional guarantees leads to higher guarantee values the lower the market interest rate is. We also observe an increased interest rate sensitivity. Additionally, alternative product designs that mitigate the interest rate dependency of the guarantee value are illustrated and assessed from the policyholder perspective.