2023 Year-End Filing Requirements for Class C

Summary

This is a filing requirements notice issued by the Bermuda Monetary Authority setting out what Class C (re)insurers must submit for their 2023 financial year end. It compiles the components of the Statutory Financial Return (SFR) and Capital and Solvency Return (CSR), the audited GAAP financial statements requirement, and BSCR model changes applicable to Long Term insurers for the 2023 filing cycle.

• 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 (or approved internal capital model), including the CSR Declaration, AML Questionnaire (direct long-term insurers), Sanctions form, 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; also due within four months of year end (extendable to seven months).
• Updated CSR calculation: For 2023 year end, insurers must complete the BSCR under both the 2018 and revised 2019 methodologies unless permission is obtained from BMA (via RiskAnalytics@bma.bm) to use only the revised methodology.
• Audited financial statements: Additional GAAP based financial statements (IFRS, or GAAP of Bermuda, Canada, UK or US, or other BMA recognised GAAP), with notes and auditor's report, due within four months of year end (extendable to seven months); condensed general purpose financial statements may be substituted without prior approval.
• Alternative capital: Insurers with alternative capital arrangements (e.g. cat bonds, sidecars, collateralized reinsurance) must complete Schedule V(m) of the BSCR model.
• FCR publication: The Financial Condition Report, signed by the CEO and relevant senior executive, must be published on the insurer's website within 14 days of filing with BMA, or furnished to the public within 10 days of a written request if no website exists.
• Submission format: Both an electronic and printed copy of the CSR (including SFR forms) must be submitted, using the submit macro embedded in the BSCR model; insurers are encouraged to test this functionality with IT ahead of the deadline.
• 2023 BSCR model changes (Long Term insurers): IFRS 17 reporters must use Forms 1ASFS, 2ASFS and 8ASFS; Schedule V(e) stress/scenario tests updated (EBS basis, updated rates for R3, R4, R6, R7, R8, new R9 liquidity stress test instructions, removal of Mortgage Loan Stress Test for Class C, D and E); Schedules VI and VIA updated for clarity.
• Additional guidance: Insurers must correctly complete the Information Sheet filing period start date and currency exchange/translation rate fields, as these affect the BSCR calculation; a qualified audit opinion solely due to condensed general purpose financial statements reporting is not treated as a qualification under paragraph (m)(iv).

These requirements apply specifically to the 2023 financial year end filing cycle for Class C (re)insurers, with related model changes noted for Long Term commercial insurers.

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 BSCR, CISSA, Eligible Capital schedule, FCR and Actuary's Opinion, within four months after financial year end, or up to seven months with BMA approval.
• Complete the BSCR under both the 2018 and 2019 methodologies for 2023 year end, unless BMA grants permission to use only the revised methodology.
• File audited GAAP based financial statements (or condensed general purpose financial statements) within four months after financial year end, or up to seven months with BMA approval.
• Complete Schedule V(m) of the BSCR model if the insurer has alternative capital arrangements.
• Publish the Financial Condition Report on the insurer's website within 14 days of filing with BMA, or furnish it to the public within 10 days of a written request if no website exists.
• Submit both electronic and printed copies of the CSR (including SFR forms), using the BSCR model's submit macro for electronic filing.
• Ensure the Declaration of the CSR is signed by two directors and the insurer's principal representative.
• Correctly complete the Information Sheet tab's filing period start date and currency exchange/translation rate fields.
• For Long Term insurers reporting under IFRS 17, complete Forms 1ASFS, 2ASFS and 8ASFS.

Applies to

Class C insurers, Class C reinsurers, Long Term commercial insurers (Bermuda)

Deadlines

• within four months after the end of the financial year (extendable up to seven months with BMA approval): Filing deadline for the Statutory Financial Return (SFR).
• within four months after the end of the financial year (extendable up to seven months with BMA approval): Filing deadline for the Capital and Solvency Return (CSR).
• within four months after the end of the financial year (extendable up to seven months with BMA approval): Filing deadline for audited financial statements under Section 17A of the Act.
• 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 the latest FCR to the public if the insurer has no website.