2022 Year-End Filing Requirements for Class 3A

Summary

This is a filing requirements document issued by the Bermuda Monetary Authority setting out what Class 3A (re)insurers must submit for their 2022 financial year end, including the Statutory Financial Return, Capital and Solvency Return, audited financial statements, and alternative capital reporting. It also sets out changes made to the 2022 Bermuda Solvency Capital Requirement (BSCR) model compared to 2021.

• 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): BSCR and schedules, CISSA, catastrophe risk return where applicable, eligible capital schedule, Financial Condition Report (FCR), loss reserve specialist opinion, and various attachments, filed within four months (extendable to seven months).
• Audited Financial Statements: GAAP-based financial statements (IFRS, Bermuda/Canada/UK/US GAAP, or other recognised GAAP) with auditor's report, filed within four months of year end (extendable to seven months); Class 3A insurers may instead file condensed general purpose financial statements under the Insurance Accounts Rules 2016 without prior approval.
• Alternative Capital: Insurers with non-shareholder capital arrangements (e.g. cat bonds, sidecars, hybrid securities) 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 if no website exists, provided to the public within 10 days of a written request.
• CSR signing and submission: The CSR declaration must be signed by two directors and the insurer's principal representative; both electronic and printed copies of the CSR (including SFR forms) must be submitted, with electronic-only submission requiring use of the BSCR model's submit macro.
• 2022 BSCR model changes: Amendments to Schedule IIF (equity holdings), Schedule IV(f) (claims paid now reported gross rather than net), Schedule V(e) stress/scenario tests (financial market and cyber underwriting updates), Schedule VI and VIA (look through reporting by jurisdiction and rating), and the ECR Ratio Met validation check in the Summary tab.

The document also provides additional completion guidance for the Information Sheet tab, covering the filing period start date, currency exchange/translation rate entries, and clarification that a qualified audit opinion arising solely from use of condensed general purpose financial statements is not treated as a qualification for paragraph (m)(iv) purposes.

Key obligations

• File the Statutory Financial Return (including Insurer Information Sheet, auditor's report, statutory financial statements, and Statutory Declaration of Compliance) within four months after financial year end, or up to seven months with BMA approval
• File the Capital and Solvency Return (BSCR, schedules, CISSA, FCR, loss reserve specialist opinion, and attachments) within four months after financial year end, or up to seven months with BMA approval
• 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 with the Authority, or if no website exists, provide a copy within 10 days of a written public request
• File audited financial statements (or condensed general purpose financial statements under the 2016 Insurance Accounts Rules) within four months after financial year end, or up to seven months with BMA approval
• Submit both electronic and printed copies of the CSR, using the BSCR model's submit macro if submitting electronically only
• 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 currency exchange/translation rate are correctly completed in the BSCR model submission

Applies to

Class 3A insurers, Class 3A (re)insurers, Bermuda general business insurers (referenced for BSCR model changes applicable to Class 3A, 3B and 4)

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 upon 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 upon application to the Authority
• within four months from the end of the financial year: Deadline to file audited financial statements
• up to seven months (with BMA approval): Extended deadline for filing audited financial statements
• 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