2018 Year-End Filing Requirements for Class 3A

Summary

This BMA document sets out the specific filing requirements for Class 3A (re)insurers for the 2018 financial year end, listing the returns, statements and schedules that must be submitted and describing the changes made to the 2018 Bermuda Solvency Capital Requirement (BSCR) model compared to 2017.

• Statutory Financial Return (SFR): Must include the Insurer Information Sheet, auditor's report, Statutory Financial Statements (Forms 1SFS, 2SFS, 8SFS with notes), and Statutory Declaration of Compliance, filed within four months of financial year end (extendable to seven months on application).
• Capital and Solvency Return (CSR): Comprises the BSCR and schedules, CISSA, Catastrophe Risk Return (where applicable), Eligible Capital schedule, Financial Condition Report (FCR), loss reserve specialist opinion and various attachments; also due within four months (extendable to seven months).
• CSR signatures: The capital and solvency return declaration must be signed by two directors and the insurer's principal representative; the FCR must be signed by the chief executive and a senior executive responsible for actuarial, risk, internal audit or compliance functions.
• FCR publication: Insurers must publish the FCR on their website within 14 days of filing it with the Authority, or, if no website exists, provide a copy to the public within 10 days of a written request.
• Updated 2019 CSR calculation: Insurers are not required to use the revised 2019 year end BSCR methodology for 2018, but may voluntarily use the revised schedules if desired.
• Audited financial statements: Insurers must file audited GAAP or IFRS financial statements (with notes and auditor's report) within four months of year end (extendable to seven months), unless submitting condensed general purpose financial statements under the Insurance Accounts Rules 2016.
• Alternative capital: Insurers with alternative capital arrangements (e.g. cat bonds, sidecars, hybrid securities) must complete the Alternative Capital Schedule and attach it to the BSCR model.
• 2018 BSCR model changes: Includes new AML questions on the Information Sheet, removal of a duplicative reserves note, updated stress/scenario tests (new extreme US yield curve widening scenario, revised mortgage loan shocks, new liability loss accumulation scenarios, revised cyber risk schedule), and additional beneficial ownership disclosure for segregated accounts.

The document is purely a filing instruction and does not itself impose new legal obligations beyond restating statutory filing deadlines and requirements already found in the Insurance Act 1978 and related Rules; it functions as guidance for the 2018 year end filing cycle.

Key obligations

• File the Statutory Financial Return within four months of the 2018 financial year end, or within seven months if an extension is granted by the Authority.
• File the Capital and Solvency Return (CSR), including the BSCR, CISSA, Eligible Capital schedule and Financial Condition Report, within four months of the 2018 financial year end, or within seven months if extended.
• Ensure the CSR declaration is signed by two directors and the insurer's principal representative.
• Ensure the Financial Condition Report is signed by the chief executive and a senior executive responsible for actuarial, risk, internal audit or compliance.
• Publish the Financial Condition Report on the insurer's website within 14 days of filing it with the Authority, or provide it to the public within 10 days of a written request if no website exists.
• File audited financial statements prepared under GAAP or IFRS within four months of the 2018 financial year end (or up to seven months if extended), unless submitting condensed general purpose financial statements under the Insurance Accounts Rules 2016.
• Insurers with alternative capital arrangements must complete and submit the Alternative Capital Schedule as an attachment to the BSCR model.

Applies to

Class 3A insurers, Class 3A reinsurers

Deadlines

• within four months after the end of the financial year: Deadline for filing the Statutory Financial Return, Capital and Solvency Return, and audited financial statements
• not exceeding seven months: Maximum extended deadline the Authority may grant on application for filing the SFR, CSR, and audited financial statements
• within 14 days of the date the report was filed with the Authority: Deadline to publish the Financial Condition Report on the insurer's website
• within 10 days of receipt of a written request: Deadline to furnish the public with the latest Financial Condition Report if the insurer has no website