Notice - 2018 FYE Hard Copy BSCR Submissions (2019-04-04)

Summary

This notice from the Bermuda Monetary Authority relaxes the hard copy filing requirement for 2018 year end Statutory Financial Returns (SFR) and Capital and Solvency Returns (CSR) for insurers that submit electronically using the macro functionality built into the Authority's BSCR model. It clarifies what counts as a complete electronic submission and confirms that insurers using other submission methods must still file hard copies.

• Who can skip hard copy: Bermuda Groups and commercial insurers (Classes C, D, E, 3A, 3B and 4) that submit their CSR using the BSCR model's embedded macro submission functionality no longer need to also file a hard copy, from 2018 year end onward.
• Completeness requirement: Electronic submissions must be complete, including all disclosures that would otherwise be in the hard copy, such as the Auditor's Report, and must be received by the Authority by the filing deadline.
• Attachment format: Attachments must be in a searchable format, i.e. Word, Excel, or PDF with text recognised.
• Wet signature documents: Documents previously requiring wet signatures, including the CSR Declaration, Financial Condition Report and Declaration of Compliance, must be scanned and attached to the BSCR model under the Attachments tab.
• Who must still file hard copy: Bermuda Groups and insurers filing a CSR in a format other than the BSCR model, or submitting the BSCR via e-mail, must continue to file hard copies as well.
• Record-keeping unchanged: Record-keeping obligations under Section 17 of the Insurance Act 1978 and Section 6(4) of the Insurance (Prudential Standards) Rules are not affected.
• Late filing penalties: The Authority retains the right to impose late filing penalties on insurers that do not file by the filing deadline, regardless of submission method.

The Authority also reminds insurers that it re-published the 2018 year end BSCR models for Groups and all commercial insurer classes in January 2019, and encourages all insurers to move to electronic submission via the BSCR macro functionality as the most secure and convenient filing method.

Key obligations

• Insurers and groups submitting via the BSCR model's macro functionality must ensure the electronic submission is complete, including all disclosures such as the Auditor's Report, and received by the Authority by the filing deadline
• Attachments to electronic BSCR submissions must be in a searchable format (Word, Excel, or text-recognised PDF)
• Documents requiring wet signatures (CSR Declaration, Financial Condition Report, Declaration of Compliance) must be scanned and attached to the BSCR model under the Attachments tab
• Insurers and groups filing a CSR in a format other than the BSCR model must continue to file hard copies
• Insurers and groups that submit the BSCR via e-mail must continue to also file a hard copy
• Record-keeping requirements under Section 17 of the Insurance Act 1978 and Section 6(4) of the Insurance (Prudential Standards) Rules remain in effect

Applies to

Bermuda Groups, commercial insurers (Class C), commercial insurers (Class D), commercial insurers (Class E), commercial insurers (Class 3A), commercial insurers (Class 3B), commercial insurers (Class 4)

Deadlines

• the filing deadline: Electronic BSCR submissions (and hard copies where still required) must be received by the Authority by the applicable filing deadline; late filings may incur penalties regardless of submission method