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Reinsurance Regulation

CONNECTICUT INSURANCE DEPARTMENT PUBLISHES THREE BULLETINS MANDATING FINANCIAL REPORTING

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The Connecticut Insurance Department issued three bulletins on November 17, 2015, each of which mandate financial reporting by insurers to the Department. Bulletin Number FS-4AR-15 requires all accredited reinsurers doing business in Connecticut to submit to the Department a report of its financial condition as of December 31, 2015, by March 1, 2016, as well as a copy of the company’s 2015 independent audit report, by June 1, 2016. Bulletin Number FS-4C-15 requires each captive insurance company domiciled or licensed in Connecticut to file financial reports with the Department by either March 1 or March 15, 2016, depending on the type of captive. Finally, Bulletin Number FS-4SL-15 requires each foreign eligible surplus lines insurer to submit a report of its financial condition to the Department on a quarterly basis.

This post written by Whitney Fore, a law clerk at Carlton Fields in Washington, DC.

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MISSOURI FINANCE DEPARTMENT ADOPTS NEW RULE REGARDING CERTIFICATES OF AUTHORITY FOR SURPLUS LINES INSURERS

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On December 1, the Missouri Department of Insurance, Financial Institutions and Professional Registration adopted a new rule pertaining to certificates of authority for domestic surplus lines insurers. The rule was proposed earlier this fall and sets out the procedures that an insurer looking for domesticated authority in Missouri must follow in order to have a certificate of authority issued. The rule provides that the company must redomesticate to Missouri or form a Missouri domestic insurance company, as well as meet a series of other requirements, including proof that the insurer possesses policyholder surplus of at least $20,000,000 and is approved in at least one other jurisdiction than Missouri. Mo. Code Regs. tit. 20 § 200-6.700 (2015).

This post written by Zach Ludens.

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SPECIAL FOCUS: COVERED AGREEMENT PROCESS UNDERWAY

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The U.S. Treasury Department and the U.S. Trade Representative have given notice to Congress of the initiation of discussions with the European Union to enter into a Covered Agreement essentially addressing two major issues: (1) the equivalence of the U.S. insurance and reinsurance regulatory regime in the context of the EU’s Solvency II initiative; and (2) credit for reinsurance collateral requirements.  Covered Agreements were introduced by the Dodd-Frank Act as a vehicle for limited federal intrusion into the regulation of the business of insurance and reinsurance by the states.  Rollie Goss describes the Covered Agreement process and this initial utilization of that process in a Special Focus article.

This post written by Rollie Goss.
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ALASKA’S DIRECTOR OF INSURANCE LISTS ELIGIBLE SURPLUS LINES INSURERS

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On July 13, 2015, the director of Alaska’s Division of Insurance published a list of surplus lines insurers that are eligible to write non-admitted business within the state. The Non-admitted and Reinsurance Reform Act (“NRRA”) identified the eligibility requirements that Alaska may impose on a company to be an eligible surplus lines insurer. An insurer is deemed ineligible and removed from the list if it does not meet all of the NRRA and domestic state requirements. All alien insurers that are on the NAIC’s Quarterly Listing of Alien Insurers are eligible to write non-admitted business in Alaska.

Three statuses were assigned to the various insurers included on the director’s list. Those companies that are “white listed” are foreign companies that meet the NRRA and domestic state requirements. “IID listed” insurers are alien companies that are on the NAIC’s Quarterly Listing of Alien Insurers. Finally, “listing approved” insurers are alien companies that are not on the NAIC’s Quarterly Listing of Alien Insurers but are approved by Alaska.

Alaska Bulletin B 15-06, effective July 13, 2015.

This post written by Whitney Fore, a law clerk at Carlton Fields in Washington, DC.

See our disclaimer.

VERMONT REVISES CREDIT FOR REINSURANCE REGULATION

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The Vermont Department of Financial Regulation recently amended its regulation pertaining to credit for reinsurance. As we detailed on June 16, 2015, the amendment follows a proposal issued by the Department of Financial Regulation earlier this year. This follows a 2014 amendment to Vermont’s Credit for Reinsurance Act and brings the regulations in compliance with that act. Specifically, the amended regulation sets forth the procedural requirements through which a Vermont insurance company may take credit for insurance ceded to a reinsurer in line with the amended Credit for Reinsurance Act, as well as requires specific clauses in the reinsurance agreements in order for ceding insurers to receive credit for reinsurance.  4-3 Vt. Code R. § 32 (Oct. 28, 2015).

This post written by Zach Ludens.
See our disclaimer.