2021 Year-End Filing Requirements for Class C

Summary

This BMA document sets out the year-end filing requirements for Class C (re)insurers for the 2021 financial year, listing the returns, statements and schedules that must be submitted and the applicable deadlines. It also details specific changes made to the 2021 Bermuda Solvency Capital Requirement (BSCR) model for Long-Term Commercial Insurers compared to 2020.

• Statutory Financial Return (SFR): 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 BMA approval).
• Capital and Solvency Return (CSR): Includes the BSCR and schedules, CSR Declaration, AML Questionnaire (direct long-term insurers only), 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.
• CSR signing 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 provided to the public within 10 days of a written request if no website exists).
• 2018 versus 2019 BSCR methodology: For 2021 year end, insurers must complete the BSCR under both the 2018 and 2019 year end calculation methodologies unless they have obtained BMA permission 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), including notes and auditor's report, 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 separate BMA approval.
• Alternative capital disclosure: Insurers with alternative capital arrangements (e.g. cat bonds, sidecars, hybrid securities) must complete Schedule V(m) of the BSCR model.
• BSCR model changes for Long-Term insurers: 2021 updates include revised Schedule IV(f) exposure of risk reporting by location, updated Schedule V(e) financial market stress scenarios, and dual reporting of deferred taxes under both 2018 and 2019 methodologies.
• Information Sheet completion guidance: Insurers must correctly complete the filing period start date, the currency exchange/translation rate to Bermuda or US Dollars, and note that a qualified audit opinion solely due to condensed general purpose financial statements reporting is not treated as a qualification.

The document is a technical filing guide rather than a rule change; it consolidates existing statutory deadlines and highlights specific 2021 BSCR model updates that Class C and Long-Term Commercial insurers must apply when preparing their year-end submissions.

Key obligations

• File the Statutory Financial Return (SFR) within four months after financial year end, or up to seven months with BMA approval.
• File the Capital and Solvency Return (CSR), including the BSCR, CISSA, FCR and Actuary's Opinion, within four months after financial year end, or up to seven months with BMA approval.
• Ensure the CSR Declaration is signed by two directors and the insurer's principal representative.
• Ensure the Financial Condition Report is signed by the chief executive and a senior executive responsible for actuarial, risk, audit or compliance functions.
• Publish the FCR on the insurer's website within 14 days of filing with the BMA, or furnish a copy within 10 days of a written public request if no website exists.
• Submit both an electronic and printed copy of the CSR (including SFR forms), using the BSCR model's submit macro for electronic submission.
• Complete the BSCR under both the 2018 and 2019 year-end methodologies for the 2021 year end, unless BMA permission has been obtained to use the revised methodology only, via email request to RiskAnalytics@bma.bm.
• File audited financial statements (or condensed general purpose financial statements for Class C and D insurers) within four months of financial year end, extendable to seven months with BMA approval.
• Complete Schedule V(m) of the BSCR model if the insurer has alternative capital arrangements.
• Complete Schedule IV(f) with subsidiary location, claims paid and reserves data for the 2021 year end (Long-Term insurers).
• Ensure the Information Sheet tab's filing period start date and currency exchange/translation rate are correctly completed.

Applies to

Class C insurers, Class C (re)insurers, Long-Term Commercial Insurers, Class D insurers (referenced for financial statement alternative)

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 14 days of filing the FCR 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.
• 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 BMA approval): Extended deadline for filing audited financial statements on application to the Authority.