Stakeholder Letter - Consultation Paper - Proposed Enhancements to the Public Disclosure Regime (2025-09-29)

Summary

This is a stakeholder letter from the Bermuda Monetary Authority summarising feedback received on its December 2024 Consultation Paper on enhancing public disclosure of assets and liabilities for commercial long-term insurers, and setting out the BMA's responses and next steps. It applies to all Bermuda-regulated commercial long-term insurers (Classes C, D and E), excluding domestic insurers.

• Competitiveness concerns: The BMA will consider, case by case and only in exceptional circumstances, requests to modify (not waive) disclosure requirements where an insurer demonstrates that granular disclosure would create an uneven playing field versus peer jurisdictions.
• Granularity of disclosure: CUSIP-level disclosure will proceed, but registrants will be asked to answer qualitative questions on investment strategy and asset-liability matching, and a summary sheet will be auto-generated for general audiences.
• Operational burden: The disclosure template will leverage existing regulatory returns (e.g. Lapse and Liquidity SBA Return, Bermuda Solvency and Capital Return) and GAAP-based financial statements; the BMA will engage directly with run-off entities concerned about erosion of policyholder value.
• Duration metrics: The BMA has replaced the previously proposed weighted average life metric with a requirement to calculate effective duration for both asset and liability disclosures.
• Next steps: The BMA will publish draft Rules governing the public disclosure requirements and a separate guidance document to help registrants complete the disclosure template correctly.

No final rules have yet been issued; this letter communicates the direction the BMA intends to take before formal Rules and guidance are published. Registrants with questions can contact the BMA's insurance regulatory affairs team.

Key obligations

• Registrants seeking modified public disclosure must submit a request to the BMA with compelling justification demonstrating that disclosure would create an uneven playing field; an uneven playing field alone does not qualify for a waiver from filing.
• Registrants will be required to respond to qualitative questions on their investment strategy and asset-liability matching as part of the disclosure template.
• Registrants will be required to calculate and disclose effective duration for both assets and liabilities in place of the previously proposed weighted average life metric.

Applies to

Bermuda-regulated commercial long-term insurers (Class C), Bermuda-regulated commercial long-term insurers (Class D), Bermuda-regulated commercial long-term insurers (Class E)