2024 Year-End Filing Requirements for Class D and E

Summary

This BMA document sets out the specific filing requirements applicable to Class D and Class E (re)insurers for the 2024 financial year end, listing the returns, statements, and supporting schedules that must be submitted, along with related deadlines and details of changes to the 2024 BSCR model for long term insurers.

• Statutory Financial Return (SFR): Insurer Information Sheet, auditor's report, statutory financial statement forms (1SFS, 2SFS, 8SFS) and Statutory Declaration of Compliance; may be reported in the insurer's chosen currency.
• Capital and Solvency Return (CSR): Includes the BSCR and schedules (Capital and Solvency Declaration, AML Questionnaire for direct long term insurers, Sanctions questionnaire, BSCR Schedules, CISSA, Eligible Capital, Operational Risk assessment, Schedules XVI and XVII, Financial Condition Report, and Actuary's Opinion on EBS Technical Provisions).
• Updated CSR methodology: For 2024 year end, insurers must complete the BSCR under the 2018, 2019 and 2024 methodologies unless they obtain the Authority's permission (via email to RiskAnalytics@bma.bm) to use the 2024 methodology alone.
• Audited Financial Statements: Additional GAAP based financial statements (IFRS, or GAAP of Bermuda, Canada, UK, US, or other Authority recognised GAAP) with notes and auditor's report must be filed; the Authority will publish these once filed.
• Quarterly Financial Return: Insurers not supervised as part of a group by the Authority must file quarterly unaudited financial statements, intra group transaction and risk concentration details, Enhanced Capital Requirement ratio, and bond holdings by BSCR rating.
• Alternative Capital: Insurers with alternative capital arrangements (e.g. cat bonds, sidecars, hybrid securities) must complete Schedule V(m) of the BSCR model.
• 2024 BSCR model changes for Long Term insurers: Updates to Schedule VI and VIA to capture rating agencies used, inclusion of Lapse Risk (Schedule VIIA) and Expense Risk (Schedule VIIB) as capital requirements, and new Risk Margin information fields.

The document also provides guidance on completing specific BSCR model tabs, including selecting a valuation basis, confirming filing period dates and exchange rates, and clarifying that qualified audit opinions relating to condensed general purpose financial statements are not treated as disqualifying qualifications.

Key obligations

• File the Statutory Financial Return within four months after the financial year end, or up to seven months with BMA approval.
• File the Capital and Solvency Return (CSR), including the BSCR, CISSA, Eligible Capital schedule, Financial Condition Report and Actuary's Opinion, within four months after the 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 it with the Authority, or if no website, furnish a copy within 10 days of a written request.
• Submit both an electronic and printed copy of the CSR (including SFR forms), or use the BSCR model's submit macro for electronic-only submission.
• Complete the BSCR calculation under the 2018, 2019 and 2024 year end methodologies, unless permission is obtained to use only the 2024 methodology.
• File audited financial statements (with notes and auditor's report) prepared under IFRS or recognised GAAP within four months after the financial year end, or up to seven months with BMA approval.
• File quarterly financial returns (balance sheet, income statement, intra-group transaction details, top ten counterparty exposures, Enhanced Capital Requirement ratio, and bond holdings) by the last day of May, August and November, for insurers not supervised as part of a group by the Authority.
• Complete Schedule V(m) of the BSCR model if the insurer has alternative capital arrangements.

Applies to

Class D insurers, Class E insurers, Bermuda Long-Term Commercial Insurers

Deadlines

• within four months after the end of the financial year (extendable up to seven months with BMA approval): Deadline to file the Statutory Financial Return, Capital and Solvency Return, and Audited Financial Statements
• on or before the last day of May, August and November of every year: Deadline for insurers not supervised as part of a group by the Authority to file quarterly financial returns
• within 14 days of the date the Financial Condition Report was filed with the Authority: Deadline to publish the FCR on the insurer's website
• within 10 days of receipt of a written request: Deadline to furnish a copy of the latest FCR if the insurer has no website