2019 Year-End Filing Requirements for Class 4 and Class 3B

Summary

This BMA notice sets out the specific filing requirements applicable to Class 4 and Class 3B (re)insurers for the 2019 financial year-end, covering statutory financial returns, capital and solvency returns, audited financial statements, quarterly returns, and alternative capital reporting. It also lists changes made to the 2019 Bermuda Solvency Capital Requirement (BSCR) model compared to 2018 for Class 3A, 3B and 4 insurers.

• Statutory Financial Return (SFR): Comprises the 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 on application).
• Capital and Solvency Return (CSR): Includes the BSCR, supporting schedules, CISSA, catastrophe risk return, loss triangles, eligible capital schedule, Financial Condition Report (FCR) and loss reserve specialist opinion; filed within four months of year-end (extendable to seven months).
• 2019 CSR calculation: Insurers must complete the BSCR under both the 2018 and revised 2019 methodologies for year-end 2019, unless they apply by email to use the revised methodology only.
• Audited financial statements: GAAP or IFRS compliant statements (with notes and auditor's report) must be filed within four months of year-end (extendable to seven months); the Authority will publish filed statements.
• Quarterly financial return: Insurers not part of a BMA-supervised group must file quarterly unaudited financial statements and intra-group transaction/risk concentration details by the last day of May, August and November each year.
• Alternative capital: Insurers with alternative capital arrangements (e.g. cat bonds, sidecars, collateralised reinsurance) must complete Schedule V(m) of the BSCR model.
• FCR publication: The Financial Condition Report must be published on the insurer's website within 14 days of filing, or furnished to the public within 10 days of a written request if no website exists.
• BSCR model changes for 2019: New Sanctions/Suspicious Activity Reporting confirmation, added outsourcing/employee/tax residency questions in Schedule V(a), updated stress scenarios in Schedule V(e), and integration of the Alternative Capital Schedule V(m) into the model.

Submissions should generally be made electronically via the BSCR model's submit macro; any insurer using another method (e.g. email) must also file a hardcopy.

Key obligations

• File the Statutory Financial Return within four months of the financial year end, or up to seven months if an extension is granted by the Authority on application.
• File the Capital and Solvency Return (including BSCR, CISSA, catastrophe risk return, eligible capital schedule, FCR and loss reserve specialist opinion) within four months of year end, extendable to seven months.
• Have the Capital and Solvency Return declaration signed by two directors (one may be the chief executive) and either the chief risk officer or chief financial officer.
• Have the Financial Condition Report signed by the chief executive and a senior executive responsible for actuarial, risk management, internal audit or compliance.
• Publish the Financial Condition Report on the insurer's website within 14 days of filing with the Authority, or if no website exists, furnish a copy to the public within 10 days of a written request.
• Complete the BSCR for 2019 year-end under both the 2018 methodology and the revised 2019 methodology, unless permission is obtained via email request to use the revised methodology only.
• File audited financial statements prepared under IFRS or recognised GAAP within four months of financial year end, extendable to seven months.
• Insurers not part of a group for which the Authority is group supervisor must file quarterly financial returns (including intra-group transactions and largest unaffiliated counterparty exposures) by the last day of May, August and November each year.
• Insurers with alternative capital arrangements must complete Schedule V(m) of the BSCR model.
• Submit returns electronically via the BSCR model's submit macro; if using any other submission method, also file a hardcopy version.
• Confirm the Suspicious Activity Reporting and Sanctions questionnaire in the Sanctions Schedule of the BSCR model.

Applies to

Class 4 insurers, Class 3B insurers, Class 3A insurers (BSCR model changes only)

Deadlines

• within four months after the end of the financial year (extendable up to seven months on application): Filing deadline for the Statutory Financial Return, Capital and Solvency Return, and audited financial statements.
• 14 days of the date the report was filed with the Authority: Deadline to publish the Financial Condition Report on the insurer's website.
• 10 days of receipt of a written request: Deadline to furnish the public with a copy of the latest Financial Condition Report if the insurer has no website.
• last day of May, August and November of every year: Deadline for filing quarterly financial returns (for insurers not part of a BMA-supervised group).