2020 Year-End Filing Requirements for Class D and Class C

Summary

This BMA document sets out the year end filing requirements for the 2020 financial year for Class D and Class C (re)insurers. It lists the statutory returns, capital and solvency filings, and audited financial statements that must be submitted, along with related deadlines and content requirements, and separately notes changes to the 2020 BSCR model for long term insurers.

• 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; may be reported in the insurer's chosen currency.
• 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), Sanctions questionnaire, BSCR Schedules, CISSA, Eligible Capital schedule, Operational Risk assessment, Schedule of Regulated Non-Insurance Financial Operating Entities, Schedule of Solvency, Financial Condition Report (FCR), and Actuary's Opinion on EBS Technical Provisions.
• Updated CSR calculation for 2019 year end: For 2020 year end, insurers must complete the BSCR under both the 2018 methodology and the revised 2019 methodology, unless they obtain BMA permission (via email to RiskAnalytics@bma.bm) to use the revised methodology only.
• Audited Financial Statements: Additional GAAP financial statements (IFRS, or GAAP of Bermuda, Canada, UK or US, or other BMA recognised GAAP) with notes and auditor's report; from 2016 year end onward, condensed general purpose financial statements under Insurance Account Rules may be submitted instead without prior approval.
• Alternative Capital: Insurers with alternative capital arrangements (e.g. cat bonds, sidecars, collateralised reinsurance, hybrid securities) must complete Schedule V(m) of the BSCR model.
• 2020 BSCR model changes (Long Term insurers): Updated Schedule V(e) stress/scenario tests (including new R3 Extreme US Yield Curve Widening scenario) and a revised Schedule V(L) Segregated Accounts schedule; additional guidance on completing the Information Sheet tab (filing period dates, currency exchange rate reporting, and treatment of qualified audit opinions relating to condensed financial statements).

Filing deadlines apply to the SFR, CSR and Audited Financial Statements, with possible extensions on application to the BMA, and the Financial Condition Report carries its own publication deadline once filed.

Key obligations

• File the Statutory Financial Return (SFR) within four months after the financial year end, or up to seven months if the BMA grants an extension on application.
• File the Capital and Solvency Return (CSR) within four months after the financial year end, or up to seven months if the BMA grants an extension on application.
• Ensure the CSR declaration is signed by two directors and the insurer's principal representative.
• Ensure the Financial Condition Report (FCR) is signed by the chief executive and a senior executive responsible for actuarial, risk management, internal audit or compliance functions.
• Publish the FCR on the insurer's website within 14 days of the date it was filed with the BMA, or if no website exists, furnish a copy to the public within 10 days of a written request.
• Submit both an electronic version (via the BSCR model submit macro) and a printed copy of the CSR, which includes the SFR forms.
• File audited financial statements (GAAP or approved condensed general purpose financial statements) within four months of the financial year end, or up to seven months with BMA approval.
• Complete the BSCR under both the 2018 and revised 2019 year end methodologies for 2020 year end, unless permission is obtained from the BMA (via email to RiskAnalytics@bma.bm) to use only the revised methodology.
• Insurers with alternative capital arrangements must complete Schedule V(m) of the BSCR model.
• Long term insurers must ensure the Information Sheet tab's filing period start date and currency exchange rate fields are correctly completed in the 2020 BSCR model.

Applies to

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

Deadlines

• within four months after the end of the financial year (extendable up to seven months with BMA approval): Filing deadline for the Statutory Financial Return (SFR)
• within four months after the end of the financial year (extendable up to seven months with BMA approval): Filing deadline for the Capital and Solvency Return (CSR)
• within four months from the end of the financial year (extendable up to seven months with BMA approval): Filing deadline for audited financial statements under section 17A
• within 14 days of filing with the Authority: Deadline to publish the Financial Condition Report (FCR) 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