2018 Year-End Filing Requirements for Class D and Class C

Summary

This document sets out the year end filing requirements that the Bermuda Monetary Authority expects Class D and Class C (re)insurers to meet for the 2018 financial year, and separately lists the changes made to the 2018 Bermuda Solvency Capital Requirement (BSCR) model for long term commercial insurers 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 a Statutory Declaration of Compliance, filed within four months of financial year end (extendable to seven months with Authority approval).
• Capital and Solvency Return (CSR): Includes the BSCR and schedules (or an approved internal capital model), the CSR Declaration, AML Questionnaire (direct long term insurers only), BSCR Schedules, CISSA, Eligible Capital schedule, Operational Risk assessment, schedules of regulated non-insurance entities and solvency, the Financial Condition Report (FCR), and the actuary's opinion; also due within four months (extendable to seven).
• CSR signatures and publication: The CSR declaration must be signed by two directors and the principal representative; the FCR must be signed by the chief executive and a relevant senior executive, and published on the insurer's website within 14 days of filing (or made available to the public within 10 days of a written request if no website exists).
• Submission format: Both an electronic and a printed copy of the CSR (including SFR forms) plus original audit opinions must be submitted; separate SFR and CSR submissions are not required.
• 2019 revised BSCR calculation: Insurers are not required to use the revised 2019 year end CSR calculation methodology for 2018 year end, but may voluntarily use the revised schedules if desired.
• Audited financial statements: Additional GAAP financial statements (IFRS, or Bermuda/Canada/UK/US GAAP, or other Authority-recognised GAAP) with notes and auditor's report must be filed within four months of year end (extendable to seven months); Class C and D insurers may instead submit condensed general purpose financial statements without prior approval.
• Alternative capital: Insurers with alternative capital arrangements (e.g. cat bonds, sidecars, collateralised reinsurance, contingent capital) must complete the latest Alternative Capital Schedule and attach it as BSCR model attachment number 18.
• 2018 BSCR model changes for long term insurers: Includes new AML questions on the Information Sheet, a revised AML Schedule, removal of a duplicative reserve disclosure in Form 1SFS notes, updated stress and scenario tests in Schedule V(e) (including a new extreme US yield curve widening scenario, updated mortgage loan shocks, and a revised cyber risk schedule), and a revised Schedule L segregated accounts schedule requiring additional beneficial ownership details.

The requirements draw on the Insurance Act 1978 and related rules, and apply specifically to the 2018 financial year end filing cycle for Class D and Class C (re)insurers, with a separate section addressing model changes affecting long term commercial insurers.

Key obligations

• File the Statutory Financial Return within four months after financial year end (or up to seven months if an extension is approved by the Authority).
• File the Capital and Solvency Return, including the BSCR, CISSA, Eligible Capital schedule, Financial Condition Report and actuary's opinion, within four months after financial year end (or up to seven months with approval).
• Ensure the CSR declaration is signed by two directors and the principal representative.
• Ensure the Financial Condition Report is signed by the chief executive and a relevant senior executive.
• Publish the Financial Condition Report on the insurer's website within 14 days of filing with the Authority, or if no website exists, furnish a copy to the public within 10 days of a written request.
• Submit both an electronic and a printed copy of the CSR (including SFR forms) together with original audit opinions.
• File additional audited GAAP financial statements (or condensed general purpose financial statements) within four months of year end (or up to seven months with approval).
• Insurers with alternative capital arrangements must complete the Alternative Capital Schedule and attach it to the BSCR model as attachment 18.

Applies to

Class D insurers, Class C insurers, Bermuda long term commercial insurers

Deadlines

• within four months after the end of the financial year: Deadline to file the Statutory Financial Return (SFR)
• up to seven months after the end of the financial year with Authority approval: Extended deadline for filing the SFR if approved by the Authority
• within four months after the end of the financial year: Deadline to file the Capital and Solvency Return (CSR)
• up to seven months after the end of the financial year with Authority approval: Extended deadline for filing the CSR if approved by the Authority
• within 14 days of filing 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 a copy of the latest Financial Condition Report to the public if the insurer has no website
• within four months from the end of the financial year: Deadline to file audited GAAP financial statements
• up to seven months from the end of the financial year with Authority approval: Extended deadline for filing audited GAAP financial statements if approved