NAIC 2014 Fall Meeting Newsletter
Transcription
NAIC 2014 Fall Meeting Newsletter
Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 Contents Overview ………………………………………....1 Captive Insurance Update………..……………2 NAIC 2014 Fall Meeting Newsletter “Wrapping Up the Year” Principles-Based Reserving Update...………5 Private Equity Issues.…..……………..……….6 Corporate Governance………………………...6 Capital Adequacy and Risk Capital…….……7 Other Committee and Working Group Highlights Statutory Accounting Principles Working Group and Emerging Accounting Issues…...………………………….………....8 Blanks Working Group……………………..13 Valuation of Securities Task Force……….14 Overview The NAIC was very pleased with the accomplishments that were made this year in executing their charges for 2014. Overall, it was a successful year. The NAIC completed or significantly completed its 2014 agenda by passing regulation on lifeinsurance owned captives, adopting the Corporate Governance Model Reporting Act and Disclosures, and risk-based capital changes, to name a few. We have highlighted the key discussion topics below, along with a summary of the relevant committee meetings held during the conference. Reinsurance Task Force……………...…...15 1 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 Captive Insurance Update Actuarial Guideline XLVIII (AG 48) The Principles-Based Reserving Implementation (EX) Task Force achieved a significant milestone during the 2014 Fall Meeting with the adoption of Actuarial Guideline XLVIII (AG 48). AG 48 formalizes the actuarial requirements associated with XXX/AXXX captive arrangements. The purpose and intent of AG 48 is to establish uniform, national standards governing XXX or AXXX reserve financing arrangements and, in connection with such arrangements, to ensure that permitted assets, in an amount at least equal to the required level of reserves is held by or on behalf of the ceding insurer. AG 48 is not intended to apply to policies that were issued prior to 1/1/2015 if those policies were included in a captive reserve financing arrangement as of 12/31/2014. In summary the ceding insurer may only receive credit for reinsurance, if, but only if: – The ceding insurer establishes gross reserves, in full, using principle-based reserving under Valuation Method 20 (VM-20). – The ceding insurer receives as collateral, cash and Securities Valuation Office listed securities, in at least the amount determined by VM-20. – Portions of the statutory reserve exceeding the VM-20 reserve may be collateralized by any other security in which the NAIC has developed a Risk Based Capital (RBC) charge. – At least one party to the financing transaction holds an appropriate RBC “cushion”. – The reinsurance arrangement is approved by the ceding insurer’s domestic regulator. – Qualified actuarial opinion is required. – The effective date is January 1, 2015. Status of Other Completed XXX/AXXX Framework Projects The Blanks (E) Working Group adopted blanks proposal 2014-18BWG on a September 19, 2014 conference call. The proposal added a new supplemental XXX/AXXX reinsurance exhibit to the 2014 Life and Fraternal blank. The exhibit is intended to capture the reporting of XXX/AXXX reinsurance contemplated by the XXX/AXXX Reinsurance Transactions Framework adopted in concept by the Principle-Based Reserving Implementation (EX) Task Force on June 2 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 30, 2014. The Blanks (E) Working Group will await a proposal from the Principle-Based Reserving Implementation (EX) Task Force regarding 2015 annual statement reporting. Consideration will be given to having different disclosures for “grandfathered” transactions and the transactions that must comply with AG 48. On November 5, 2014 the Financial Analysis Handbook (E) Working Group adopted new procedures and guidance for the 2014 Annual Edition of the Financial Analysis Handbook. The new procedures and guidance focuses on: 1) Considerations for an analyst’s review of holding company Form D captive reinsurance transactions proposed to be entered into on or after January 1, 2015. 2) Analyst’s assessment of a group’s collective use of reinsurance with captive insurers. 3) Review of the Supplemental XXX/AXXX Reinsurance Exhibit with a primary focus on transactions identified in Part 2 and a general review of Part 1 to obtain an understanding of the insurer’s use of reinsurance. Additionally, on November 5, 2014, the Financial Analysis Handbook (E) Working Group adopted a referral to the Financial Regulation Standards and Accreditation (F) Committee recommending Part B standards for a financial analyst to utilize the Handbook procedures for analysis of domestic insurers that cede XXX/AXXX business to affiliated or unaffiliated captives or special purposes vehicles. 3 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 XXX/AXXX Framework Projects in Process Committee Capital Adequacy (E) Task Force Charge Reinsurance (E) Task Force Statutory Accounting Principles (E) Working Group Financial Condition (E) Committee Financial Regulation Standards and Accreditation (F) Committee Develop an appropriate “RBC cushion” for an insurer ceding XXX/AXXX policies when the assuming reinsurer does not file an RBC report using the NAIC RBC formula and instructions. Develop appropriate asset charges for the forms of “other security” used by insurers under the XXX/AXXX Reinsurance Model Regulation. These charges should then be considered for incorporation into the RBC cushion developed in accordance with the previous charge. Determine whether the current RBC C-3 treatment of qualified actuarial opinions is adequate for the purposes of the risks of XXX/AXXX reinsurance transactions that receive qualified actuarial opinions. Request permission from the Executive (EX) Committee to create a new model regulation to establish requirements regarding the reinsurance of XXX/AXXX policies. The Principle-Based Reserving Implementation (EX) Task Force’s XXX/AXXX Reinsurance Framework Exhibit 4 should be considered for this model regulation, modified as deemed appropriate by the Task Force. Request permission from the Executive (EX) Committee to amend the Credit for Reinsurance Model Law (#785) and draft the amendments to reference the new model regulation drafted in accordance with the previous charge. Develop the proposed definition for “primary security” for use in the Principle-Based Reserving Implementation (EX) Task Force’s future consideration of a proposed XXX/AXXX Reinsurance Model Regulation. Develop a note to the annual audited financial statement regarding compliance with the XXX/AXXX Reinsurance Model Regulation. Evaluate the risk-transfer rules applicable to XXX/AXXX reserve financing transactions to make sure they appropriately apply to situations such as those where parental/affiliate guarantees are used, resulting in the risk effectively being kept within the holding company system even though the reinsurance arrangement involves an unrelated third party. As the various work products are adopted by the Principle-Based Reserving Implementation (EX) Task Force, the Executive (EX) Committee and Plenary, consider them for inclusion in the Part A and Part B standards of the NAIC Financial Regulation Standards and Accreditation Program. At their November 15, 2014 meeting, this committee directed NAIC staff to draft new versions of Part A and Part B Preambles that would include in the scope of the Accreditation Program captives insurers and special purpose vehicles that assume XXX/AXXX reinsurance, variable annuities and long-term care insurance. 4 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 Principles Based Reserving Implementation Update Adoption Update There are currently 18 states, representing 28% of premiums that have adopted PBR. It is expected that in 2015, 12 more states will introduce legislation. If all of these states adopt in 2015, there would be 30 states representing 60% of the premium that have adopted PBR. For PBR to become effective, 42 states representing 75% of premium most adopt. The PBR Task Force commented that it would be unlikely that PBR would be completely effective prior to January 1, 2017. Small Company Exemption The PBR task force voted to expose for comment a small company exemption provision that was proposed by American Council of Life Insurers (ACLI). The ACLI proposal for the exemption of small companies from PBR sought to establish a size threshold that would allow qualification for exemption for about 15% of the industry leaving 85% of the industry automatically subject to PBR. The proposal allows companies to qualify for the exemption only if they are well capitalized and have a mix of business that excludes the generally recognized risky products. As the proposal developed further, the specific exemption criteria proposed by the ACLI and reviewed by the Life Actuarial (A) Task Force is as follows: 1) The company must have less than $300 million of ordinary life premiums and, if the company is a member of an NAIC group of life insurers, the group has combined ordinary life premiums of less than $600 million; and 2) The company reported Total Adjusted Capital must be at least 450% of the authorized control level RBC in the company’s most recent RBC report, and the appointed actuary must have provided an unqualified opinion on the reserves; and 3) Any ULSG policies issued or assumed by the company after the operative date of the valuation manual must meet the definition of a non-material secondary guarantee ULSG product, as defined in the proposal. The comment period ends January 15, 2015. 5 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 Private Equity Issues The Private Equity Issues (E) Working Group (PEIWG) was appointed as part of the Financial Analysis (E) Working Group (FAWG), charged to develop procedures that regulators can use when considering ways to mitigate and monitor risk associated with private equity/hedge fund ownership and control of insurance company assets, including the development of best practices and consideration of possible changes in NAIC policy positions as deemed appropriate. PEIWG is currently drafting amendments to the Financial Analysis Handbook, which will then be exposed for a 45 day comment period. The current amendments are focused on Form A to guide examiners in evaluating the appropriate risks of an acquisition of an insurance company, including unique risks that would be relevant for the acquisition of an insurance company by a private equity firm. Corporate Governance The Corporate Governance (E) Working Group (CGWG) approved a memorandum recommending Part A accreditation standards for revisions made to the Annual Financial Reporting Model Regulation (#205) to incorporate an internal audit function requirement for large insurers into the regulation. The revisions require individual insurers writing more than $500 million or insurance groups writing more than $1 billion in annual premium to maintain an internal audit function providing independent, objective and reasonable assurance to the audit committee and insurer management regarding the insurer’s governance, risk management and internal controls. The function is required to be organizationally independent from management and required to report at least annually to the audit committee on the results of internal audit activities. The CGWG also approved a memorandum recommending Part A accreditation standards for the Corporate Governance Annual Disclosure Model Act (#305) and the Corporate Governance Annual Disclosure Model Regulation (#306). These models were adopted as a result of a multiyear project of the CGWP to study and compare existing governance requirements for U.S. insurers to established best practices, international standards and U.S. regulatory needs. Upon the conclusion of this study, the Working Group identified a number of proposed enhancements to strengthen corporate governance standards within the U.S. solvency system, including the annual collection of detailed information on an insurer’s corporate governance practices. Together, Model #305 and Model #306 require an insurer (or group of insurers) to provide a confidential disclosure regarding its corporate governance practices to the lead state and/or domestic regulator annually by June 1. The insurer (or group of insurers) may choose to provide information on governance activities that occur at the ultimate controlling parent level, an intermediate holding company level and/or the individual legal entity level, based on its 6 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 determination of the level at which decisions are made, oversight is provided and governance accountability is assessed in relation to the insurance activities of the insurer. Capital Adequacy and Risk Based Capital The Property and Casualty Risk-Based Capital (E) Working Group (PCRBCWG) voted to expose the following proposals for a 45-day public comment period ending December 31, 2014: Agenda item #2014-30-P, adding a sensitivity test for the federal Affordable Care Act (ACA) risk adjustment and risk corridor; and agenda item #2014-31-P, breaking out the premiums, claims and the medical loss ratio (MLR) by individual, small group and large group plans as well as a break out of claims and MLR for Medicare, Medicaid and Other Health. The PCRBCWG also voted to expose the Affiliated Investment Proposal for 45-day public comment period ending December 31, 2014. The Proposal would simplify the RBC charge for the ownership of Investment Affiliates (affiliate Type 7) to be a fixed factor times the carrying value of the common stock, preferred stock and bonds. The Life Risk-Based Capital (E) Working Group continued its deliberations regarding the XXX/AXXX Reinsurance Framework charges assigned to the Capital Adequacy (E) Task Force. Other Committee and Working Group Highlights Statutory Accounting Principles (E) Working Group and Emerging Accounting Issues (E) Working Group This section summarizes the actions of the Statutory Accounting Working Group (SAPWG) and Emerging Accounting Issues Working Group (EAIWG) relating to the adoption or exposure of the Statements of Statutory Accounting Principles. SAPWG adopted Issue Paper No. 150 – Accounting for the Risk Sharing Provisions of the Affordable Care Act (Ref #2014.12). This Issue Paper recommends accounting for three programs known as risk adjustment, reinsurance and risk corridors that take effect in 2014. On August 16, 2014, SAPWG directed NAIC staff to redraft the exposed issue paper to address a number of issues for the risk adjustment and risk corridors programs, including, but not limited to: 1) replacing the nonadmission guidance with criteria that incorporates conservatism and sufficiency of data; 2) removing the exposed 90-day guidance and adding language to be consistent with other government receivables; and 3) removing a reference to a Health and Human Services (HHS) document. SAPWG adopted this issue paper incorporating these changes. The following is a summary of non-substantive accounting changes or revisions that was adopted by the SAPWG during the Fall 2014 Meeting: 7 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 Ref # Statement Reference Title Description of Change or Revision Effective Date 2014-16 SSAP No. 1 Disclosure of Accounting Policies, Risks & Uncertainties, and Other Disclosures and SSAP No. 4—Assets and Nonadmitted Assets Revisions clarify asset restrictions and that restricted assets are included in the disclosure. Immediately 2014-19 SSAP No. 55 Unpaid Claims, Losses and Loss Adjustment Expenses Technical revisions incorporate information from prior interpretations that 1) claims related losses for extra-contractual obligations and bad faith lawsuits are included in losses; and 2) technical revisions related to the prepaid adjusting expenses guidance. Immediately 2014-18 SSAP No. 56 Separate Accounts Technical revisions clarify the reporting of the disclosures currently captured within Note 34 on separate accounts. Immediately 2014-06 SSAP No. 57 Title Insurance Revisions delete the disclosure for the Gross All-Inclusive and Gross Risk Rate premium revenue basis, with corresponding revisions to risk rate terminology. Immediately 2014-20 SSAP No. 101 Income Taxes Revisions clarify that the RBC authorized control level used in the annual deferred tax asset realization threshold calculation is from the RBC ratio in process of being filed. Immediately 2014-17 SSAP No. 104R Share-Based Payments Revisions adopt ASU 2014-12: Accounting for Share-Based Payments When the Terms of an January 1, 2016 8 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 Award Provide That a Performance Target Could Be Achieved after the Requisite Service Period. 2014-21 Revisions incorporate changes to Appendix A-010 adopted by the Health Actuarial (B) Task Force in the Health Insurance Reserves Model Regulation (#10) requiring the 2012 Group Long-Term Disability (2012 GLTD) table. January 1, 2017 Actuarial Guideline XLVII Revisions to Appendix C description and to add Actuarial Guideline XLVII, providing guidance on blending company experience with the 2012 GLTD table. January 1, 2017 Non-applicable GAAP Pronouncements Revisions reject ASU 2014-10: Development Stage Entities as not applicable to statutory accounting and consolidate previously rejected GAAP items from INT 99-00: Compilation of Rejected GAAP into Issue Paper No. 99. SSAP No. 54 Individual and Group Accident and Health Contracts SSAP No. 59 Credit Life and Accident and Health Contracts 2014-22 Appendix C 2014-14 Issue Paper 99 2014-26 Immediately 9 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 The following is a summary of substantive accounting changes or revisions that was exposed for comment by the SAPWG during the Fall 2014 Meeting: Ref # Title Description of Change 2013-017 SSAP No. 40 – Real Estate Investments Revised Simultaneously exposed with a shortened exposure period, Issue Paper No. 149 and substantively revised SSAP No. 40R to move Single-Member and Single-Asset LLCs, Underlying Asset is Real Estate into SSAP No. 40R as of Jan. 1, 2015; and directed preparation of an annual financial statement blanks proposal. 2014-12 SSAP No. 107 – Accounting for RiskSharing Provisions of the Affordable Care Act Revisions provide guidance on the three risksharing provisions known as risk adjustment program, transitional reinsurance program and temporary risk corridors program, with a shortened comment deadline. The following is a summary of non-substantive accounting changes or revisions that was exposed for comment by the SAPWG during the Fall 2014 Meeting: Ref # Title Description of Change 2014-29 SSAP No. 1 - Disclosure of Accounting Policies, Risks & Uncertainties, and Other Disclosures and SSAP No. 4 - Assets and Nonadmitted Assets and various other statements Exposed revisions to adopt ASU 2014-15: Presentation of Financial Statements – Going Concern and incorporate audited disclosure requirements for a reporting entity to evaluate and disclose whether there is substantial doubt on the entity’s ability to continue as a going concern. In addition, changes to SSAPs 48, 68, and 97 were exposed that would non-admit investments in related affiliate holdings whose audited financial statements include going concern notes from management. 2014-35 SSAP No. 11 - Postemployment Benefits and Compensated Absences Exposed revisions to delete disclosures that pertain to defined benefit and defined contribution plans, with a reference to complete the disclosures in SSAP No. 92 if the entity is 10 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 providing special or contractual termination benefits. 2014-36 SSAP No. 25 - Accounting for and Disclosures about Transactions with Affiliates and Other Related Parties Exposed revisions reject ASU 2013-06, Not-forProfit Entities; Services Received from Personnel of an Affiliate. In addition, incorporated disclosures regarding services for not-for profit entities. 2014-30 SSAP No. 36 -Troubled Debt Restructuring, Exposed revisions to adopt with modification ASU 2014-04, Receivables – Troubled Debt Restructuring by Creditors – Reclassification of Residential Real Estate Collateralized Consumer Mortgage Loans Upon Foreclosure and to adopt ASU 2014-14, Receivables – Troubled Debt Restructuring by Creditors – Classification of Certain Government-Guaranteed Mortgage Loans Upon Foreclosure with an effective date of 2015. The proposed revisions would prescribe accounting and reporting for foreclosed mortgage loans collateralized by real estate and foreclosed mortgage loans guaranteed by a governmentsponsored program. SSAP No. 37- Mortgage Loans SSAP No. 40 - Real Estate Investments: 2014-31 SSAP No. 61R - Life, Deposit-Type Contracts and Accident and Health Reinsurance Received a response from the Principle-Based Reserving Implementation (EX) Task Force confirming that the reference to Actuarial Guideline XLVIII (AG 48) within the Notes disclosure, as well as the reference to the XXX/AXXX Reinsurance Model Regulation or any state variation from those standards, is consistent with the intent of the Task Force. The proposed revisions require disclosure for the annual audited financial statements indicating compliance with AG 48 or the XXX/AXXX Reinsurance Model Regulation. 2014-28 SSAP No. 62R - Property Casualty Reinsurance Exposed revisions to clarify the amounts to be included in Schedule F related to an asbestos and environmental reinsurance reporting exception for retroactive counterparties (using the 11 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 reporting option one), along with updates for the proposed reporting. 2014-32 SSAP No. 74 - Accounting for the Issuance of Insurance-Linked Securities Issued by a Property and Casualty Insurer Through a Protected Cell Exposed technical revisions to update the references from aggregate write-in lines to specific preprinted lines for protected cells. 2014-37 SSAP No. 86 - Accounting for Derivative Instruments and Hedging, Income Generation, and Replication (Synthetic Asset) Transactions Exposed revisions to reject ASU 2014-16; Derivatives and Hedging, Determining Whether the Host Contract in a Hybrid Financial Instrument Issued in the Form of a Share is More Akin to Debt or to Equity (ASU 2014-16) as not applicable to statutory accounting. 2014-33 SSAP No. 92 - Accounting for Postretirement Benefits Other Than Pensions Exposed revisions to consolidate the guidance from INT 13-03—Clarification of Surplus Deferral in SSAP No. 92 and SSAP No. 102 into the applicable SSAPs. SSAP No. 102 - Accounting for Pensions 2014-24 SSAP No. 93 - Accounting for Low Income Housing Tax Credit Property Investments Exposed revisions to adopt with modification ASU 2014-01: Accounting for Investments in Qualified Affordable Housing Projects to prohibit the elective proportional amortization method, reject net reporting and update terminology. 2014-34 Issue Paper No. 99 - Non-applicable GAAP Pronouncements Exposed revisions to reject ASU 2014-13: Measuring the Financial Assets and Financial Liabilities of a Consolidated Collateralized Financing Entity. The comment deadline for these exposed items is January 16, 2015, except for items 2013-17 and 2014-12, which have a comment deadline of December 8, 2014. 12 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 Blanks Working (E) Group The following is a summary of adopted changes or revisions that was adopted by the Blanks Working Group during the Fall 2014 Meeting: Ref # Description of Change or Revision Effective Date 2014-18BWG Add a new Supplemental XXX/AXXX Reinsurance Exhibit (Parts 1, 2 and 3) to the Life and Fraternal Blank. Annual 2014 Guidance SHCE Adopted guidance for reporting Medicare Advantage, Part C and Medicare Part D business in the “Government Business (Excluded by Statute)” column of the Supplemental Health Care Exhibit notwithstanding that, effective in 2014, these coverages are no longer “excluded by statute” pursuant to the May 23, 2013 federal Affordable Care Act (ACA) final rule, 42 CFR Parts 422 and 423 but will be excluded from this column in future filings. For details on the changes to the Supplemental Health Care Exhibits, please refer to link below: Annual 2014 Instructions Medicare Advantage & Medicare Part D Business http://www.naic.org/documents/committees_e_app_blanks _related_guidance_for_shce.pdf Group Solvency Issues (E) Working Group The main topic of conversation at the Group Solvency Issues (E) Working Group (GSIWG) pertained to the group-wide supervision of Internationally Active Insurance Groups (IAIGs). An IAIG is, as currently defined, an insurance holding company system that (1) includes an insurer registered according to the Insurance Holdings Company System Regulatory Act (the “Act”); and (2) meets the following criteria: (a) premiums written in at least three countries, (b) the percentage of gross premiums written outside the United States is at least ten percent (10%) of the insurance holding company system’s total gross written premiums, and (c) based on a three-year rolling average, the total assets of the insurance holding company system are at least fifty billion dollars ($50,000,000,000) or the total gross written premiums of the insurance holding company system are at least ten billion dollars ($10,000,000,000). The proposed revisions to the Act focus on how to assign the Group-wide Supervisor to the IAIG. The Group-wide Supervisor is currently define as, the regulatory official authorized to engage in conducting and coordinating group-wide supervision activities who is determined or 13 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 acknowledged by the commissioner to have sufficient significant contacts with the internationally active insurance group. Some members of industry are concerned with this designation in the Act because it could result in a different Group-wide Supervisor than their lead state supervisor. Industry is concerned that this will create confusion on who has group supervision responsibilities, and could potentially not lead to the selection of the most appropriate state to be the Group-wide Supervisor. GSIWG will hold one additional conference call in December 2014 to finalize changes and potentially vote on the adoption of these amendments. Valuation of Securities (E) Task Force The Valuation of Securities (E) Task Force: Adopted the report of the Securitization Data Quality (E) Working Group, which included its September 29 and September 11 minutes and an amendment to the Purposes and Procedures Manual of the NAIC Investment Analysis Office (Purposes and Procedures Manual) to provide documentation standards for residential mortgage-backed securities (RMBS) Re-REMIC securities. Having completed its charge, the Task Force voted to disband the Securitization Data Quality (E) Working Group. Voted to refer to the Financial Regulation Standards and Accreditation (F) Committee a technical document developed by the SVO providing guidance on how to refer to NAIC designations and related processes in state laws based on NAIC model laws. The document recommends textual changes that would align state law references to SVO processes with NAIC practices. The Financial Regulation Standards and Accreditation (F) Committee has an informal process it could use to bring these types of issues before the states. Adopted an amendment to the Purposes and Procedures Manual to modify a reference to Canadian GAAP to refer to Canadian Accounting Standard for Private Enterprises (Canada’s new accounting standard for private entities) and added French GAAP as a new National Financial Presentation Standard in the definition of Audited Financial Statement in the Purposes and Procedures Manual. Adopted an amendment to the Purposes and Procedures Manual to make a single credit rating standard applicable to both domestic and foreign banks that apply to be listed on the NAIC Bank List as issuers of letters of credit for reinsurance purposes, and directed SVO staff to study the regulation of financial 14 Dixon Hughes Goodman Insurance Services Group Industry News | December 2014 institutions other than banks to determine if the regulation was at least as experienced and well regulated as banks. The NAIC Bank List currently requires foreign banks to attain a higher “double A” credit rating, (i.e., Aa/AA) while domestic banks must attain a “triple B”, (i.e., Baa/BBB) credit rating. Reinsurance (E) Task Force The Reinsurance (E) Task Force adopted the report from the Qualified Jurisdiction (E) Working Group where they have recommended the following jurisdictions be considered Qualified Jurisdictions and placed on the NAIC List of Qualified Jurisdictions: Bermuda Monetary Authority France: Autorité de Contrôle Prudentiel et de Résolution (ACPR) Germany: Federal Supervisory Authority (BaFin) Central Bank of Ireland United Kingdom: Prudential Regulation Authority of the Bank of England (PRA) Insurance Services Group Contacts and Contributors John Roberts - Partner 1829 Eastchester Drive High Point, NC 27265 336-822-4482 john.roberts@dhgllp.com Kevin Lee Ryals - Partner 214 N Tryon St 40th Floor; Suite 4000 Charlotte, NC 28202 704-367-7043 kevin.ryals@dhgllp.com Rand Meyer - Partner 225 Peachtree Street NE Suite 300 Atlanta, GA 30303 404-575-8956 rand.meyer@dhgllp.com Brian Kilbane - Sr. Manager 225 Peachtree Street NE Suite 300 Atlanta, GA 30303 404-575-8954 brian.kilbane@dhgllp.com About Dixon Hughes Goodman LLP: With more than 1,800 people in 12 states, Dixon Hughes Goodman ranks among the nation’s top 20 public accounting firms. 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