2019 Year-end Limited Purpose Insurers Filing Notice (2020-06-19)

Summary

This is a notice from the Bermuda Monetary Authority to Limited Purpose Insurers (LPIs) clarifying several requirements for their 2019 year-end Electronic Statutory Financial Return (E-SFR) filings. It covers restatements, COVID-19 subsequent events disclosure, outsourcing schedules, and an updated compliance schedule.

• Restatements: If management, in consultation with auditors, determines a restatement of prior-year figures is needed (due to accounting changes or error correction), material changes must follow GAAP and prior-year statutory figures must be restated appropriately.
• Subsequent events disclosure: All filings received from 1 May 2020 onwards must include a detailed subsequent events disclosure covering underwriting, financial and operational exposure resulting from COVID-19, per the Authority's 20 April 2020 notice.
• Schedule of Outsourcing Services: Completing the Schedule of Outsourcing Services is required for all 2019 year-end filings. Insurers who filed before the schedule was issued must complete the attached Solo Schedule and email it to ESFRApplications@bma.bm by 31 July 2020.
• Schedule of Compliance (SAR and Sanctions): The Schedule of Compliance has been updated to include Suspicious Activity Reporting and Sanctions for 2019 year-end filings; the updated version accompanying the supplementary schedules sent 19 March 2020 must be completed.
• Applications: E-SFR related application submissions (filing extensions, exemptions, extended period filings) must continue to be submitted via the E-SFR system; all other applications must be emailed to Authorisations_eApplications@bma.bm.
• System access issues: Any E-SFR system access or system constraint issues should be directed to ESFR@bma.bm.

Key obligations

• Restate prior-year statutory figures in accordance with GAAP where a restatement is determined necessary
• Include a detailed subsequent events disclosure covering COVID-19 underwriting, financial and operations exposure for all filings received from 1 May 2020 onwards
• Complete the Schedule of Outsourcing Services as part of all 2019 year-end filings
• Insurers who filed before the Schedule of Outsourcing Services was issued must complete the Solo Schedule and email it to ESFRApplications@bma.bm by 31 July 2020
• Complete the updated Schedule of Compliance including Suspicious Activity Reporting and Sanctions for 2019 year-end filings
• Submit E-SFR related applications (extensions, exemptions, extended period filings) via the E-SFR system
• Submit all other applications via email to Authorisations_eApplications@bma.bm

Applies to

Limited Purpose Insurers

Deadlines

• 31 July 2020: Deadline for insurers who filed prior to issuance of the Schedule of Outsourcing Services to complete and email the Solo Schedule to ESFRApplications@bma.bm
• 1 May 2020 onwards: Requirement to include detailed COVID-19 subsequent events disclosure applies to all filings received from this date onward