2022 Year-End Filing Requirements for Class C

Summary

This document sets out the Bermuda Monetary Authority's filing requirements for Class C (re)insurers for the 2022 financial year end. It lists the returns and supporting documents that must be submitted, filing deadlines, and changes made to the 2022 Bermuda Solvency Capital Requirement (BSCR) model compared to 2021, with additional guidance for Long-Term insurers.

Required filings

• Statutory Financial Return (SFR): Includes 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 (up to seven months with BMA approval).
• Capital and Solvency Return (CSR): Comprises the BSCR, associated Schedules, CSR Declaration, AML Questionnaire (direct long-term insurers), Sanctions section, 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; same four to seven month filing window.
• CSR calculation methodology: For 2022 year end, insurers must complete the BSCR under both the 2018 and revised 2019 methodologies unless they obtain BMA permission (via email to RiskAnalytics@bma.bm) to use the revised methodology only.
• Audited financial statements: GAAP or IFRS financial statements (or condensed general purpose statements under Insurance Account Rules) must be filed within the same four to seven month period.
• Alternative capital: Insurers with alternative capital arrangements (e.g. cat bonds, sidecars, collateralized reinsurance) must complete Schedule V(m) of the BSCR model.
• 2022 BSCR model changes (Long-Term insurers): Amendments to Schedule IIF equity holdings linkages, updated Schedule V(e) stress/scenario tests, new look-through requirements in Schedules VI and VIA, and an amended ECR Ratio validation check on the Summary tab.

The document also gives practical guidance on completing the Information Sheet tab (filing period start date, currency exchange/translation rate) and clarifies that a qualified audit opinion arising solely from reporting condensed general purpose financial statements will not be treated as a qualification under paragraph (m)(iv).

Key obligations

• File the Statutory Financial Return within four months after financial year end, or up to seven months if a longer period is approved by the BMA on application
• File the Capital and Solvency Return within four months after financial year end, or up to seven months if approved by the BMA
• Sign the Capital and Solvency Return declaration 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 BMA, or if no website, furnish a copy to the public within 10 days of a written request
• Submit both an electronic version and a printed copy of the CSR (including SFR Forms)
• File audited financial statements (or condensed general purpose financial statements) within four months after financial year end, or up to seven months if approved
• Complete the BSCR under both the 2018 and 2019 year end methodologies for 2022, unless BMA permission is obtained to use the revised methodology only
• Complete Schedule V(m) of the BSCR model if the insurer has alternative capital arrangements

Applies to

Class C insurers, Class C (re)insurers, Bermuda Long-Term Commercial Insurers, Class D insurers (referenced for certain provisions), Class E insurers (referenced for certain provisions)

Deadlines

• within four months after the end of the financial year (or up to seven months with BMA approval): Filing deadline for the Statutory Financial Return
• within four months after the end of the financial year (or up to seven months with BMA approval): Filing deadline for the Capital and Solvency Return
• within four months after the end of the financial year (or up to seven months with BMA approval): Filing deadline for audited financial statements under Section 17A
• 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