The March 1, 2010 deadline for insurers to submit statutory annual statements is rapidly approaching. As you and your company prepare to make the filing, keep in mind the following:
1.Consider reporting any significant operational or business developments since December 31, 2009 as subsequent events (e.g., mergers, joint ventures, discontinued operations, changes in executive officers or directors). Start planning now to be ready to address regulatory interest. Consider whether proactive contact with regulators may be helpful. (Note that the next NAIC meeting begins March 25, 2010.)
2.Pay careful attention to the disclosure of accounting practices that depart from the NAIC Practices and Procedures Manual in Footnote #1. As with last year's filing, regulators – including non-domiciliary regulators – will be closely reviewing this disclosure. Work with your accounting and finance department in advance to be ready to address questions or concerns, and consider whether proactive contact with regulators may be helpful.
3.If your company is facing any regulatory action level thresholds (either with or without the benefit of permitted practices), begin thinking now about formulating an action plan to address the issues. While accounting and finance folks may be too busy getting the filing done to focus on the details, some conceptual work upfront will put you ahead of the curve in being ready to deal with the regulators and perhaps rating agencies.
If you have already considered these steps, congratulations! If not, now is the time to put them into practice.