2021 Year-End Filing Requirements for Class 3A

Summary

This document sets out the filing requirements that Class 3A (re)insurers must meet for their 2021 financial year end reporting to the Bermuda Monetary Authority (BMA). It lists the required statutory returns and financial statements, their components, filing deadlines, and signing/publication requirements, and separately describes the changes made to the 2021 BSCR model that apply to Class 3A, 3B and 4 insurers.

• Statutory Financial Return (SFR): Includes 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, Sanctions schedule, CISSA, Catastrophe Risk Return where applicable, Eligible Capital schedule, Operational Risk assessment, Schedule of Regulated Non-Insurance Financial Operating Entities, Schedule of Solvency, Financial Condition Report (FCR), a loss reserve specialist opinion, and various supporting attachments.
• 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; Class 3A insurers may instead file condensed general purpose financial statements under the Insurance Accounts Rules 2016 without prior BMA approval.
• Alternative Capital: Insurers with capital arrangements financed other than by shareholders' capital (e.g. cat bonds, sidecars, hybrid securities) must complete Schedule V(m) of the BSCR model.
• 2021 BSCR model changes: Schedule IV(f) now requires location-based data on subsidiaries, gross premium, claims and reserves; Schedule V(e) stress/scenario tests have been updated, including new cyber underwriting stress scenarios; 2018 year end methodology calculations have been removed.

The guidance also flags practical filing points: insurers should confirm the filing period start date and currency exchange/translation rate on the Information Sheet tab, and clarifies that a qualified audit opinion arising solely from reporting condensed general purpose financial statements will not be treated as a qualification for purposes of paragraph (m)(iv).

Key obligations

• File the Statutory Financial Return (SFR) within four months after the financial year end, or up to seven months if the BMA approves a longer period on application.
• File the Capital and Solvency Return (CSR), including the BSCR and required schedules, within four months after the financial year end, or up to seven months with BMA approval.
• File audited financial statements (or condensed general purpose financial statements) within four months after the financial year end, or up to seven months with BMA approval.
• Ensure the Capital and Solvency Return 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 is filed with the Authority; if the insurer has no website, provide a copy of the latest FCR within 10 days of a written request.
• Submit both an electronic and a printed copy of the CSR (including SFR forms), unless submitting electronically only via the BSCR model's submit macro.
• Insurers with capital arrangements financed other than by shareholders' capital must complete Schedule V(m) of the BSCR model.
• Insurers with no investments in affiliates may select No Subsidiaries in the Company Information tab and complete the amended consolidated BSCR model.
• Confirm the filing period start date and the currency exchange/translation rate to Bermuda or US Dollars on the Information Sheet tab of the BSCR model.

Applies to

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

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 BMA approval): Extended deadline for filing the SFR on application to 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 BMA approval): Extended deadline for filing the CSR on application to the Authority.
• within four months after the end of the financial year: Deadline to file audited financial statements (or condensed general purpose financial statements).
• up to seven months after the end of the financial year (with BMA approval): Extended deadline for filing audited financial statements on application to the Authority.
• within 14 days of the date the FCR 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 a copy of the latest FCR to the public if the insurer has no website.