2022 Year-End Filing Requirements for Insurance Groups

Summary

This document sets out the Bermuda Monetary Authority's filing requirements for insurance groups for the 2022 financial year end, covering the Group Statutory Financial Return, Group Capital and Solvency Return, audited group financial statements, and quarterly financial returns. It also details changes made to the 2022 Bermuda Solvency Capital Requirement (BSCR) model for insurance groups compared to the 2021 version.

• Group Statutory Financial Return (SFR): A designated insurer must submit a group SFR (cover sheet, solvency certificate, statutory financial statements Forms 1, 2 and 8, ceded reinsurance particulars, EBS reconciliation, list of non-insurance regulated entities, and qualifying member particulars) within five months after financial year end, extendable to up to eight months with Authority approval.
• Group Capital and Solvency Return (CSR): Must be filed within the same five to eight month window, reported in US dollars only, comprising the BSCR schedules, GSSA, catastrophe risk return, group minimum margin of solvency, eligible capital schedule, operational risk assessment, Financial Condition Report (FCR) and Group Actuary's Opinion.
• CSR declaration and FCR signatures: The CSR declaration must be signed by two directors (one may be the CEO) plus the CRO or CFO of the parent company; the FCR must be signed by the CEO and either the CRO or CFO.
• FCR publication: The Financial Condition Report must be published on the insurance group's website within 14 days of filing with the Authority, or if no website exists, furnished to the public within 10 days of a written request.
• Submission format: Both an electronic version (via the BSCR model's submit macro) and a printed copy of the Group CSR, including SFR Forms, must be submitted.
• 2018 vs 2019 BSCR methodology: For 2022 year end, groups must complete the BSCR under both the 2018 and revised 2019 methodologies unless they apply by email to RiskAnalytics@bma.bm for permission to use the 2019 methodology only.
• Audited group financial statements: Groups must prepare consolidated financial statements under IFRS, Bermuda/Canada/UK/US GAAP or other recognised GAAP, have them audited annually, and file them within five to eight months after financial year end.
• Quarterly financial returns: Groups must file quarterly financial returns on or before the last day of May, August and November each year, covering unaudited consolidated statements, intra-group transactions, largest unaffiliated counterparty exposures, ECR ratio, solvency self-assessment, bond holdings, and catastrophe event details.
• 2022 BSCR model changes: Amendments include revised Schedule IIF asset/liability linkages, a switch to gross basis reporting for Claims Paid in Schedule IV(f), updated financial market and cyber underwriting stress tests in Schedule V(e), new look through schedules for fixed assets and funds held by ceding reinsurers, and an updated ECR ratio validation check including eligible capital compliance.

Insurance groups and their designated insurers should confirm which filing deadline (five or eight months) applies to them and ensure IT teams test the BSCR submit functionality ahead of the deadline.

Key obligations

• A designated insurer must submit a Group Statutory Financial Return within five months after the end of the financial year, or up to eight months if the Authority allows an extension.
• A designated insurer must file the Group Capital and Solvency Return within five months after financial year end (extendable to eight months), reported in US dollars only.
• The Group CSR declaration must be signed by two directors (one may be the CEO) and either the CRO or CFO of the parent company.
• The Financial Condition Report must be signed by the CEO and either the CRO or CFO of the parent company.
• The Financial Condition Report must be published on the insurance group's website within 14 days of filing with the Authority, or furnished to the public within 10 days of a written request if no website exists.
• Both an electronic version (via the BSCR model submit macro) and a printed copy of the Group CSR, including SFR Forms, must be submitted.
• For the 2022 year end, insurance groups must complete the BSCR based on both the 2018 and 2019 year end methodologies unless granted permission by the Authority to use only the 2019 methodology.
• Every insurance group must prepare annually audited consolidated financial statements of the parent company under IFRS, applicable GAAP, or other Authority-recognised standards, and file them within five to eight months after financial year end.
• Every insurance group must prepare and file quarterly financial returns on or before the last day of May, August and November each year.

Applies to

insurance groups, designated insurers

Deadlines

• within five months after the end of the financial year (extendable up to eight months with Authority approval): Filing of the Group Statutory Financial Return
• within five months after the end of the financial year (extendable up to eight months with Authority approval): Filing of the Group Capital and Solvency Return
• within five months after the end of the financial year (extendable up to eight months with Authority approval): Filing of audited group financial statements
• on or before the last day of May, August and November of every year: Filing of quarterly financial returns
• within 14 days of the date the report was filed with the Authority: Publication of the Financial Condition Report on the insurance group's website
• within 10 days of receipt of a written request: Furnishing a copy of the latest financial condition report to the public if the group has no website