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
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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
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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.
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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.
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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.
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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
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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:
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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