2019 Year-End Filing Requirements for Class D and Class C

Summary

This BMA guidance document sets out the filing requirements that Class C and Class D (re)insurers must meet for their 2019 financial year-end, covering the Statutory Financial Return (SFR), Capital and Solvency Return (CSR), audited financial statements, and treatment of alternative capital arrangements. It also lists specific changes made to the 2019 Bermuda Solvency Capital Requirement (BSCR) model for Long-Term insurers compared to 2018.

• Statutory Financial Return (SFR): Comprises 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 with Authority approval).
• Capital and Solvency Return (CSR): Includes the BSCR, AML Questionnaire (direct long-term insurers), Sanctions schedule, BSCR Schedules, CISSA, Eligible Capital schedule, Financial Condition Report (FCR) and Actuary's Opinion; same four/seven month filing window as the SFR.
• 2019 BSCR dual calculation: Insurers must complete the BSCR using both the 2018 and the revised 2019 methodology for the 2019 year-end, unless they obtain the Authority's permission (via email to RiskAnalytics@bma.bm) to use the revised methodology only.
• Audited financial statements: Additional GAAP-basis financial statements (IFRS, or recognised Bermuda/Canada/UK/US GAAP) must be filed within four months of year end (extendable to seven months); condensed general purpose statements may be used instead without prior approval since 2016 year-end.
• Alternative capital: Insurers with capital arrangements financed other than by shareholders' capital (e.g. cat bonds, sidecars, letters of credit) must complete Schedule V(m) of the BSCR model.
• FCR publication: The Financial Condition Report must be published on the insurer's website within 14 days of filing with the Authority, or provided to the public within 10 days of a written request if the insurer has no website.
• 2019 BSCR model changes for Long-Term insurers: Includes new AML questions on the Information Sheet, a revised AML schedule, updated stress/scenario tests (including a new extreme yield curve widening scenario and revised cyber risk and mortgage loan shock schedules), integration of the Alternative Capital Schedule, and additional beneficial ownership details for segregated accounts.

The document is a technical filing checklist rather than new rulemaking; it operationalises existing statutory requirements under the Insurance Act 1978 and related Rules for the specific 2019 reporting cycle.

Key obligations

• File the Statutory Financial Return within four months after the financial year end, or within a longer period not exceeding seven months if approved by the Authority
• File the Capital and Solvency Return (CSR) within four months after the financial year end, or within a longer period not exceeding seven months if approved by the Authority
• Have the Capital and Solvency Return declaration signed by two directors and the insurer's principal representative
• Have the Financial Condition Report signed by the chief executive and a senior executive responsible for actuarial, risk management, internal audit or compliance functions
• Publish the Financial Condition Report on the insurer's website within 14 days of filing it with the Authority, or, if no website exists, furnish a copy to the public within 10 days of a written request
• Complete the BSCR using both the 2018 year-end methodology and the revised 2019 year-end CSR calculation, unless permission is obtained from the Authority to use the revised methodology only
• File audited financial statements (or condensed general purpose financial statements) within four months of the financial year end, or within a longer period not exceeding seven months if approved by the Authority
• Insurers with alternative capital arrangements must complete Schedule V(m) of the BSCR model
• Insurers submitting electronically must use the embedded submit macro in the BSCR model; those submitting by other methods (e.g. email) must also file a hardcopy version

Applies to

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

Deadlines

• within four months after the end of the financial year: Deadline to file the Statutory Financial Return (SFR)
• not exceeding seven months (with Authority approval): Extended deadline for filing the SFR upon application to the Authority
• within four months after the end of the financial year: Deadline to file the Capital and Solvency Return (CSR)
• not exceeding seven months (with Authority approval): Extended deadline for filing the CSR upon application to 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 if the insurer has no website
• within four months from the end of the financial year (extendable to seven months): Deadline to file audited financial statements under Section 17A