2020 Year-End Filing Requirements for Class 4 and Class 3B

Summary

This BMA document sets out the year end filing requirements applicable to Class 4 and Class 3B (re)insurers for the 2020 financial year, covering the Statutory Financial Return, Capital and Solvency Return, audited financial statements, quarterly financial returns, alternative capital reporting and changes to the 2020 BSCR model.

• 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 with Authority approval).
• Capital and Solvency Return (CSR): Comprises the BSCR, associated schedules (including CISSA, Catastrophe Risk Return, Loss Triangles, Eligible Capital, Schedule of Solvency), Financial Condition Report (FCR), and loss reserve specialist opinion; filed within four months of year end (extendable to seven months); declaration must be signed by two directors and the CRO or CFO; FCR must be signed by the CEO and a relevant senior executive and published on the insurer's website within 14 days of filing (or provided to the public within 10 days of a written request if no website).
• 2020 BSCR calculation: Insurers must complete the BSCR under both the 2018 methodology and the revised 2019 methodology; to use only the revised methodology, insurers must request permission by email to RiskAnalytics@bma.bm.
• Audited Financial Statements: Must be prepared under IFRS, or GAAP recognised in Bermuda, Canada, UK, US or other Authority-recognised GAAP, and filed with notes and auditor's report within four months of year end (extendable to seven months); the Authority will publish these statements.
• Quarterly Financial Return: Insurers not part of a group for which the Authority is group supervisor must file quarterly unaudited financial statements and details of intra-group transactions, reinsurance arrangements and largest unaffiliated counterparty exposures, due by the last day of May, August and November each year.
• Alternative Capital: Insurers with alternative capital arrangements (e.g. cat bonds, sidecars, collateralised reinsurance) must complete Schedule V(m) of the BSCR model.
• 2020 BSCR model changes: Updated stress scenarios in Schedule V(e) Financial Market Scenario and a revised Schedule V(L) Segregated Accounts schedule, plus guidance on completing the Information Sheet tab (filing period dates, exchange rate reporting, and qualified opinion clarification).

The requirements apply specifically to the 2020 year end filing cycle and reflect existing statutory obligations under the Insurance Act 1978 and associated Rules, with some updated guidance and model changes for that year.

Key obligations

• File the Statutory Financial Return within four months after financial year end (or up to seven months with Authority approval)
• File the Capital and Solvency Return, including BSCR schedules, CISSA, Catastrophe Risk Return, Financial Condition Report and loss reserve specialist opinion, within four months after financial year end (or up to seven months with Authority approval)
• Have the CSR declaration signed by two directors and either the chief risk officer or chief financial officer
• Have the Financial Condition Report signed by the chief executive and a relevant senior executive, and publish it on the insurer's website within 14 days of filing (or provide it to the public within 10 days of a written request if no website exists)
• Submit both an electronic and printed copy of the CSR (including SFR forms), or use the BSCR model's submit macro for electronic-only submission
• Complete the BSCR under both the 2018 and revised 2019 year end methodologies, or request permission via email to use the revised methodology only
• File audited financial statements prepared under IFRS or recognised GAAP, with notes and auditor's report, within four months after financial year end (or up to seven months with approval)
• File quarterly financial returns (balance sheet, income statement, intra-group transaction details and largest unaffiliated counterparty exposures) by the last day of May, August and November each year, if not part of a group for which the Authority is group supervisor
• Complete Schedule V(m) of the BSCR model if the insurer has alternative capital arrangements
• Ensure the Information Sheet tab's filing period start date and exchange rate fields are completed correctly in the BSCR model

Applies to

Class 4 insurers, Class 3B insurers, Class 3A insurers (for BSCR model changes)

Deadlines

• within four months after the end of the financial year (extendable to seven months with Authority approval): Filing of the Statutory Financial Return, Capital and Solvency Return, and audited financial statements
• within 14 days of the date the FCR was filed with the Authority: Publication of the Financial Condition Report on the insurer's website
• within 10 days of receipt of a written request: Providing a copy of the latest financial condition report to the public if the insurer has no website
• on or before the last day of May, August and November of every year: Filing of quarterly financial returns