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Prepared by Aon Benfield Analytics The Written & Unwritten Rules of Reinsurance Statutory Reporting IASA – Ohio Chapter 2015 Fall Conference November 23, 2015
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Page 1: The Written & Unwritten Rules of Reinsurance Statutory …€¦ ·  · 2016-11-01The Written & Unwritten Rules of Reinsurance Statutory Reporting IASA – Ohio Chapter ... Lebron

Prepared by Aon Benfield Analytics

The Written & Unwritten Rules of Reinsurance Statutory Reporting

IASA – Ohio Chapter 2015 Fall Conference November 23, 2015

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Aon Benfield Analytics Proprietary & Confidential 2

Introduction – Reinsurance Reporting in 2015 is Complicated

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Agenda Tracker

Section 1 Introduction Section 2 Multi-Beneficiary Trusts Section 3 Collateralized Reinsurance Reporting Section 4 Update on U.S. Collateral Reform Section 5 Reinsurance Reporting

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Introduction

Lebron James lives in Akron, Ohio and has a Lamborghini worth $ 670,000 Lebron bought an insurance policy from NJ Insurance (domiciled in New

Jersey) on January 1, 2015 Lebron drives his car to Nashville and gets hit by Justin Bieber on March 17th

– His car is totaled NJ Insurance bought $ 500,000 of facultative reinsurance from Bermuda Re,

(domiciled in Bermuda) effective January 1, 2015 Bermuda Re

– Unauthorized in Tennessee and has been since it’s formation in 2010 – Became Certified in Ohio on July 1, 2014 (20% collateral required) – Became Authorized in New Jersey on March 1, 2015, and has rolled in

existing liabilities into their Multi-Beneficiary Trust on March 15, 2015 How should this $ 500,000 recoverable be reported on NJ Insurance’s

Schedule F? – How much collateral is required? – Are these recoverables emanating from an Authorized, Unauthorized or

Certified reinsurer?

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Introduction

Where LeBron James Lives – Bermuda Re is Authorized Domicile of Lebron’s Insurance Company – Bermuda Re is Authorized

Where the accident occurs – Bermuda Re is Unauthorized

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Authorized Reinsurers vs. Unauthorized Reinsurers

Authorized Reinsurers – Reinsurers who are licensed to write reinsurance in a particular state – Reinsurers who are licensed in a state with “substantially similar” credit for

reinsurance regulation – Reinsurers who have met the requirements to become Accredited, Trusteed

or equivalent (the term varies by state) • Accepted, Approved, Qualified

– In most cases, authorized reinsurers do not have to post collateral in order for ceding company to get credit for the reinsurance

Unauthorized Reinsurers – Reinsurers not licensed or who have not met the requirements to be

Accredited, Trusteed or equivalent

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Authorized Reinsurers vs. Unauthorized Reinsurers

Unauthorized reinsurers are required to post collateral – If the unauthorized reinsurer does not post collateral, a provision for

reinsurance (penalty) will be calculated which offsets the value of the reinsurance recoverable asset

Therefore, it is a standard practice in all U.S. reinsurance contracts that if the reinsurer is not authorized, they agree to provide collateral to the U.S. ceding insurer

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Why is Collateral Required from Non-U.S. Reinsurers

Collateral is only required for the reinsurer’s share of the liabilities of the ceding insurer (not the full limits of exposure) – Paid losses and paid LAE – Case reserves – IBNR reserves (loss and LAE) – Unearned premiums and contingent commissions

Funded on a gross basis without allowance for retrocessions

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The Debate Over Collateral

Why it’s Needed Protects U.S. ceding insurers

and hence policyholders Ceding insurers do not have to

enforce their judgments overseas in a potentially adverse regulatory environment

Collateral is only required when there are recoverables under the reinsurance contract

Reinsurers could get licensed or accredited like a U.S. reinsurer and would not have to post collateral – It’s their choice

Why it’s Not Needed Most reinsurers pay their claims

on a timely basis This will level the playing field

for U.S. reinsurers abroad Reduced collateral will make

reinsurance more affordable, lower ceding insurers costs and lower the cost of insurance for policyholders

Collateral could still be required for the “weaker” reinsurers

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Agenda Tracker

Section 1 Introduction Section 2 Multi-Beneficiary Trusts Section 3 Collateralized Reinsurance Reporting Section 4 Update on U.S. Collateral Reform Section 5 Reinsurance Reporting

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Multi-Beneficiary Trusts (MBTs)

MBTs require state approval - Reinsurers must apply and be approved in each state where they plan to use the MBT

Reinsurers must agree to certain provisions – Agree to collateralize 100% of recoverables – Agree to increased reporting (except Lloyd’s)

Meeting all these criteria results in the MBT being approved and reinsurer being granted authorized status (“Trusteed” or “Accredited” status or equivalent) – The MBT can now be used to collateralize balances from reinsurance

contracts that incept on or after the date the trust was approved – Recoverables should be reported as authorized

Prior to MBT Approval

Recoverables are Unauthorized Post MBT Approval

Recoverables are authorized

Date Trust Approved

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Multi-Beneficiary Trusts (MBTs)

Reinsurers may also be able to “roll-in” balances from contracts that incepted prior to the date of MBT approval – No additional regulatory approvals are required for the roll-in – Typically, once the existing recoverables are “rolled-in”, the reinsurer will notify

any impacted ceding companies that LOCs are no longer needed and can be released

If the existing recoverables are rolled in to the MBT, it changes the reporting treatment of the recoverables – All balances in the MBT are reported as authorized

Treatment after Roll-in Recoverables are Authorized

Post MBT Approval Recoverables are authorized

Date Trust Approved

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Advantages and Disadvantages of Advantages of Multi-Beneficiary Trusts (MBTs)Beneficiary Trusts (MBTs)

Collateral Feature LOCs, SBTs MBTs

Collateral Procurement +

Collateral Buffer +

Who Sets the Amount of Collateral +

Commingling of Assets +

Access to the Assets +

Ceding Insurer Perspective

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MBT Permitted Assets

Trust maintenance – Updated on a quarterly basis

Permitted assets (Same as a 114 single beneficiary trust) – Cash – Money market funds – Government securities – Municipals – Investment grade securities – Equities, not more than 10% of the total trust value – Letters of credit, not more than 20% of the total trust value

In the event of insolvency of the reinsurer, the U.S. regulator of the trust is entitled to take possession of the trust for the benefit of U.S. ceding insurers

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Reinsurers Using Multi-Beneficiary Trusts (MBTs)

Aspen Bermuda Limited Aspen Insurance UK Limited AXIS Specialty Limited DaVinci Re Hannover Re (Germany) Lancashire Lloyd’s Mapfre Re Montpelier Partner Re Renaissance Re Validus

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Agenda Tracker

Section 1 Introduction Section 2 Multi-Beneficiary Trusts Section 3 Collateralized Reinsurance Reporting Section 4 Update on U.S. Collateral Reform Section 5 Reinsurance Reporting

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Category Traditional Reinsurer Collateralized Reinsurer Underwriting and Risk-Bearing

Conducted / borne by a single entity

Conducted / borne by two different entities

Financial Statements Available Typically not available

Financial Strength Ratings

Rated Typically not rated

Capital Typically $100M or more (often $1B or more)

Limited beyond assets in the trusts

Collateral For existing liabilities only Typically for the full limits of exposure, governed by collateral release

Credit Risk Ceding insurer bears the credit risk that reinsurer will post collateral & pay claims when due

Credit risk is essentially eliminated, but other risks may be present

Regulation and Reporting

High Low

Coverages Provided No limitations Typical single limit Property catastrophe Tail risk may be limited

Traditional Reinsurer vs. Collateralized Reinsurer

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Bermuda Collateralized Reinsurers

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Trustee

Alternative Market / Collateralized Reinsurer

Premium Cash and Assets (at Inception)

Fees / Profits

Assets less Losses

(upon release)

Third Party Investors

Losses

Equity / Debt or other Financing Mechanism

Dividends

Trust Agreement

Trust

Ceding Insurer

Segregated Accounts Company

Reinsurance Agreement

Underwriting Sevices Agreement

Segregated Account 1

Management Fees into the

General Account

Segregated Account 2

Collateralized Reinsurance Structure with Segregated Account Company

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Alternative Market Risk Bearing Counterparties

Schedule of Segregated Account Entities Which Comprise the Subscribing Reinsurer

Name of Grantors

Percentage Interest in

Contract

Aeolus Re Ltd. In respects of its

Underwriting Segregated Account 8.654%

Keystone Segregated Account 87.367%

Hotoru Re Segregated Account 1.764%

QVT V Segregated Account 1.008%

Pendulum Re II Ltd. (Special Purpose Insurer) 1.207%

Total 100.000%

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Collateralized Reinsurance Reporting

The risk bearing entities of collateralized reinsurers may be classified as “unauthorized reinsurers”.

Premiums and recoverables due to/from the risk bearing entities of collateralized reinsurers should be reported on Schedule F, similar to other reinsurance counterparties

Segregated accounts should be listed individually on Schedule F with their proportionate share of premiums, recoverables and collateral – Ceding insurers should include the name of the SAC as well as the name of

the segregated account

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Agenda Tracker

Section 1 Introduction Section 2 Multi-Beneficiary Trusts Section 3 Collateralized Reinsurance Reporting Section 4 Update on U.S. Collateral Reform Section 5 Reinsurance Reporting

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NAIC Credit for Reinsurance Model Law and Regulation is finalized (4th Quarter, 2011)

– Establishes new U.S. standards for collateral requirements

Collateral Reform Milestones

Individual States Adopt Collateral Reform (2008 – 2015) – 32 States have enacted a reduced collateral law – 18 States have approved reinsurers for reduced collateral

Credit for Reinsurance Model Law (1984) – Provides credit for ceded reinsurance if the reinsurer is licensed, accredited or provides sufficient collateral

NAIC & State Regulators Support Credit for Reinsurance Initiatives (2013 - 2015)

– Assists states in qualifying jurisdictions – Assists states in reviewing reinsurers for certification

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Active (State has certified reinsurers) State has adopted Model Law (#785)

State Adoption of Collateral Reform as of November 1, 2015

Adopted 785 & 786 Colorado Indiana

Active Alabama California Connecticut Delaware Florida Georgia Iowa Louisiana Maryland Maine Missouri New Hampshire New Jersey New York Ohio Pennsylvania Rhode Island Virginia

State has adopted Law (#785) & Reg. (#786)

Adopted 785 Arkansas Arizona District of Columbia Hawaii Massachusetts Montana Nebraska Nevada New Mexico North Dakota Vermont Washington

Law (#785) may be enacted by year-end

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Why Are States Adopting the Reduced Collateral Regulations

Regulators have been led to believe that the general public will benefit from these regulations – These regulations “will reduce the cost of reinsurance to ceding insurers and

reduce trade barriers allowing for more competition in the reinsurance marketplace”

– “No adverse effects are anticipated as a result of this rulemaking” – If the state “does not enact standards to certify reinsurers, it may be at a

disadvantage to other states” (that permit reduced collateral)

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Model Regulation specifies a minimum of USD 250M Submits financial information for regulatory review

NAIC will publish a list of Qualified Jurisdictions Criteria to be considered includes regulatory system,

reciprocity & information sharing

Minimum Specified Amount of Capital and Surplus

Maintain a Secure Rating from 2 Rating Agencies

Must be based on an interactive rating – No public information ratings

Model Regulation lists the following 4 rating agencies:

– A.M. Best, Fitch, Moody’s and S&P

Domiciled in a “Qualified Jurisdiction”

Certified Reinsurer Criteria

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Certified Reinsurer Requirements

Must apply and be approved in each state The reinsurer’s status in the ceding insurer’s state of domicile governs the amount of collateral required (It does not matter where the loss occurs) If approved for reduced collateral, reinsurer becomes known as a “certified reinsurer”

Application & Certification

Eligible Contracts

Only contracts that incept on or after the certification date are eligible for reduced collateral

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Certified Reinsurers: Ratings Scale

Ratings Collateral % A.M. Best Fitch/S&P Moody’s Secure-1 0% A++ AAA Aaa Secure-2 10% A+ AA+, AA, AA- Aa1, Aa2, Aa3

Secure-3 20% A A+, A, A1, A2

Secure-4 50% A- A- A3

Secure-5 75% B++, B+ BBB+, BBB, BBB-

Baa1, Baa2, Baa3

Vulnerable-6 100% Ratings B and below

Ratings BB+ and below

Ratings Ba1 and below

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Certified Reinsurers: Rating Upgrades and Downgrades

Certified reinsurer rating upgrades apply only on a prospective basis Certified reinsurer rating downgrades (and revocations) apply retroactively

– However, there is a three-month grace period for obtaining additional collateral

– Therefore, when the reporting date falls within the three month grace period, the ceding insurer may report collateral required based on the certified reinsurer’s rating prior to the downgrade or revocation

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Certified Reinsurers: Collateral Deferral for Catastrophe Losses

Certified reinsurers are not required to post collateral for recoverables that originated form a recognized catastrophe loss – The insurance department of each state determines whether any

catastrophe loss is eligible for the collateral deferral – The deferral applies to certified reinsurers at all certified rating levels – The deferral lasts up to one-year after the ceding insurer posts its initial

reserve for the loss

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Recent Developments – Qualified Jurisdictions

The NAIC is assisting states in the evaluation of Qualified Jurisdictions Criteria to be considered includes

– Appropriateness and effectiveness of reinsurance supervisory system – Adequate and prompt enforcement of U.S. judgements – Reciprocity (e.g. similar treatment of U.S. reinsurers) – Cooperation and information sharing

Seven Jurisdictions have been approved to date − Bermuda − France − Germany − Ireland

States must provide rationale if they approve a jurisdiction not on the list

− Japan − Switzerland − United Kingdom

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Recent Developments - Reinsurance Financial Analysis Working Group

Assist states in reviewing reinsurers for certification If approved by the working group, other states could rely on the assessment

without having to undertake their own review – Thus facilitating multi-state adoption of certified reinsurers (passporting)

However, it is not mandatory for any individual state to follow the working group’s determination

To date, over 30 reinsurers have been reviewed by the working group – At least, 25 reinsurers have been approved and recommended for

passporting, while the remainder have been denied passporting status

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Florida Update

Florida, which was the first to pass the law and regulation and had significant differences from the NAIC Model Law and Regulation

In July 2015, Florida implemented changes to bring it more in line with the NAIC Model Law and Regulation

Key Differences - Florida Original Revised Name for Reduced Collateral Reinsurers Eligible Certified

Amount of Collateral for “A-” Rated Reinsurers 20% 50%

Eligible Lines of Business Property Catastrophe All Lines

Collateral Deferral Applies Only to Named Hurricanes

Named Hurricanes

Acceptable Rating Agencies Includes Demotech

Includes Demotech

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Agenda Tracker

Section 1 Introduction Section 2 Multi-Beneficiary Trusts Section 3 Collateralized Reinsurance Reporting Section 4 Update on U.S. Collateral Reform Section 5 Reinsurance Reporting

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Statutory accounting – Usually recoverables over 90 days are not an admitted asset

(Exception: reinsurance recoverables) – Instead regulators impose a penalty (called the provision for

reinsurance) that effectively reduces the reinsurance recoverable asset and serves as a bad debt reserve

The provision for reinsurance is calculated on Parts 5 – 8 of Schedule F

There are three scenarios which may require a provision for reinsurance – Recoverables in dispute – Overdue recoverables – Uncollateralized recoverables

The size of the provision for each type of reinsurer reflects the regulator’s view of the potential credit risk

Provision for Reinsurance - What Happens if Collateral is Not Provided

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Part 1: Assumed Reinsurance Part 2: Portfolio Reinsurance Part 3: Ceded Reinsurance Part 4: Aging of Ceded Reinsurance Part 5: Provision for Unauthorized Reinsurance Part 6: Provision for Reinsurance Ceded to Certified Reinsurers

– Section 1 for Uncollateralized Recoverables – Section 2 for Overdue Recoverables (mimics Parts 7 & 8)

Part 7: Provision for Overdue Authorized Reinsurance (Non-Slow Payers) Part 8: Provision for Overdue Reinsurance (Slow Payers) Part 9: Restatement of Balance Sheet to Identify the Net Credit for Reinsurance

Schedule F: Reinsurance

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Schedule F: Parts 3 - 8

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Certified Reinsurers: Sample Provision (Part 6 - Section 1)

ABC Reinsurer is required to provide 20% collateral Ceding Insurer is due 1,000 from ABC Reinsurance

If no collateral is provided, what is the provision for reinsurance?

a) 200 (as only 200 is needed to meet full collateral requirements) b) 1,000 (as no collateral has been provided)

In the same scenario, if ABC Reinsurer provided collateral of 150, what would

be the provision for reinsurer a) 50 (as only 200 is needed to meet full collateral requirements) b) 250 (as 75% of required collateral has been provided)

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Size of the Provision

Classification

Under Collateralized

(a) Overdue

(b) Disputed

(c) Total

Provision 1. Unauthorized 100% 20% 20% a + b + c 2. Authorized (Non-Slow Payer) 20% 20% b + c

3. Authorized (Slow Payer) 20% 20% 20% Greater of a

or b+c

4. Certified – Section 1 Collateral Provided / Required

a

4A. Certified – Section 2 (Non-Slow Payer) 20% 20% b + c

4B. Certified – Section 2 (Slow Payer) 20% 20% 20% Greater of a

or b+c

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Schedule F: Part 6 – Section 1

SCHEDULE F - PART 6 - SECTION 1Provision for Reinsurance Ceded to Certified Reinsurers as of December 31, Current year (000, OMITTED)

Reinsurer Info Collateral Required Collateral Provided Provision Calculation

1 2 3 4 5 6 7 8 9 10 11

ID Number

NAIC Company

CodeName of Reinsurer

Domiciliary Jurisdiction

Certified Reinsurer

Rating (1 through 6)

Effective Date of Certified

Reinsurer Rating

Percent Collateral

Required for Full Credit

(0% - 100%)

Net Amount Recoverable

from Reinsurers

(Sch. F Part 3 Col. 18)

Catastrophe Recoverables Qualifying for

Collateral Deferral

Net Recoverables

Subject to Collateral

Requirements for Full Credit

(Col. 8 - Col. 9)

Dollar Amount of Collateral Required (Col. 10 x

Col. 7)ABC Reins. Bermuda 3 01/01/12 20% 1,200 200 1,000 200XYZ Re Bermuda 4 07/01/12 50% 3,000 0 3,000 1500

18 19 20 2112 13 14 15 16 17

Multiple Beneficiary

Trust

Funds Held by Company

Under Reinsurance

Treaties

Letters of

Credit

Issuing or Confirming

Bank Reference Number (a)

Other Allowable Collateral

Total Collateral Provided (Col. 12+ 13+ 14+

16)0 0 150 001 0 150 15% 75% 950 250

1500 0 0 001 0 1500 50% 100% 3,000 0

Collateral Provided

Percent of Collateral

Provided for Net

Recoverables Subject to Collateral

Requirements (Col. 17 / Col. 10)

Percent Credit Allowed on

Net Recoverables

Subject to Collateral

Requirements (Col. 18/Col.

7, not to exceed 100%)

Amount of Credit

Allowed for Net

Recoverables (Col. 9 + (Col. 10 x Col. 19))

Provision for Reinsurance

with Certified

Reinsurers Due to

Collateral Deficiency (Col. 8 - Col. 20)

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Schedule F: Part 6 – Section 2

SCHEDULE F - PART 6 - SECTION 2Provision for Overdue Reinsurance Ceded to Certified Reinsurers as of December 31, Current Year (000 OMITTED)

Note: If column 8 is less than 20%, enter zero in columns 12 and 13.

Slow Payers - GREATER OF + 20% of Uncollateralized Rec. OR + 20% of Rec. > 90 Days overdue + 20% of Disputed Recoverables

Non-Slow Payers + 20% of Rec. > 90 Days overdue + 20% of Disputed Recoverables

1 2 3 4 5 6 7 8 9

ID Number

NAIC Company

CodeName of

ReinsurerDomiciliary Jurisdiction

Reinsurance Recoverable on Paid Loss

and LAE More Than 90 Days

Overdue (a)

Total Reinsurance

Recoverable on Paid Losses and LAE (b)

Amounts Received Prior 90 Days

Percent More Than 90 Days Overdue

20% of Amounts in

Col.5ABC Reins. Bermuda 300 500 100 50% 60XYZ Re Bermuda 75 400 50 17% 15

10 11 1512 13 14

20% of Amounts in

Dispute Excluded from

Col.5

Amount of Credit Allowed for Net Recoverables (Sch. F Part 6

Section 1 Col. 20)

Total Collateral Provided

(Sch F. Part 6 Section 1,

Col. 17) not to exceed Col 11

Net Unsecured Recoverable for which Credit is

Allowed (Col. 11 - Col. 12)

20% of Col. 13

Provision for Overdue

Reinsurance Ceded to Certified

Reinsurers (Greater of Col. 9 + Col 10 or Col.

14) Not to exceed Col. 11

0 950 150 800 160 1600 3,000 0 0 0 15

Complete if Column 8 is 20% or Greater

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Multi-Beneficiary Trusts for Certified Reinsurers

Certified reinsurers may also use MBTs to collateralize their reduced collateral obligations

However, the assets for the reduced collateral obligations must be in a separate MBT than the assets for the full (100%) collateral obligations

The only difference between the full (100%) collateral MBT and the reduced collateral MBT is that the buffer layer in the reduced collateral MBT is only 10M

If a certified reinsurer uses a full collateral MBT to collateralize recoverables eligible for reduced collateral, the balances should reported as authorized

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Reporting Issues – Written or Implied Rules

Reporting Issue Impact on Schedule F Changing Classification of Reinsurer

Reinsurers may have balances reported in multiple sections of Schedule F under different classifications

Eligible Lines of Business Not all lines may be certified, so the recoverables may need to be reported under different classifications

Tracking Recognized Cats Recoverables from Recognized Cats may need to be tracked and reported separately

Rating Downgrades May need to be reported at collateral percentage prior to the rating downgrade

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Reporting Issues – Unwritten Rules

Rating Upgrades Recoverables subject to different collateral requirements must be reported on separate lines

Collateral Bifurcation Collateral may need to be bifurcated to follow the recoverables

MBT Roll-ins Changes the reporting to Authorized

Full Collateral MBTs for Certified Recoverables

Changes the reporting to Authorized

Record MBT Collateral at 100%

Ensures there is no penalty from Authorized reinsurers that use an MBT

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Reinsurance Reporting

*Note: An exception is if the reinsurer has recently become authorized through the establishment of a MBT and has not completed a roll-in of recoverables from contracts that incepted prior to the approval of the MBT. Then recoverables from contracts incepting prior to the date the MBT was approved should be reported as unauthorized.

Determining the Reporting Classification of a Reinsurer

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Reinsurance Reporting

Most U.S. reinsurers are authorized – This can be confirmed in the state insurance department websites

Most non-U.S. reinsurers are unauthorized, except – Twelve reinsurers using MBTs – Certified reinsurers (mainly certified in FL and NY) – Unauthorized reinsurers will not be listed on any state insurance website

Certified reinsurers that do not use a MBT should be reported – As certified for recoverables from contracts that incept on or after the date of

certification – As unauthorized for recoverables from contracts that incept prior to the date

of certification The reporting of recoverables from reinsurers that use MBTs is more

complicated

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Reinsurers Using Multi-Beneficiary Trusts (MBTs)

Reinsurer Approved Roll-In Certified States

Trust for Certified

Aspen Bermuda Ltd Except NY & HI Yes FL, NY No – Providing 100%

Aspen Ins. UK Ltd All states Yes None N/A

AXIS Specialty Ltd Except NY No FL No – Providing 100%

DaVinci Re All states Yes FL Yes

Hannover Re (Germany) All states Varies Various* Yes

Lancashire All states No None N/A

Lloyd’s All states Yes FL, NY, PA No – Providing 100%

Mapfre Re All states Yes None N/A

Montpelier All states Yes FL, NY Yes

Partner Re All states Yes FL, NY No – Providing 100%

Renaissance Re All states Yes FL Yes

Validus Re Except NY & FL By year-end FL No – Providing LOCs

*Note: Hannover Re (Germany) is certified in AL, CA, CO, CT, DE, FL, GA, IA, LA, ME, MD, MO, NH, NJ, NY, OH, PA and RI.

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Certified Reporting Guidance (New York - 2014)

Certified ReinsurerUses MBT?

Date of Certification Rating

Collateral Required Certified Lines

ACE Tempest Reinsurance Ltd No 01/01/11 Secure-2 10%Life, Annuities, A&H,

and Property / CasualtyAllied World Assurance Co Ltd No 07/01/11 Secure-3 20% Property / CasualtyArch Reinsurance Ltd No 07/01/11 Secure-3 20% Property / CasualtyAspen Bermuda Ltd No 07/01/11 Secure-3 20% Property / CasualtyAssured Guaranty Re Ltd No 01/01/11 Secure-5 75% Property / Casualty

Commonwealth Annuity & Life Ins Co No 07/01/12 Secure-5 75% Life, Annuities, A&H

Everest Re (Bermuda) Ltd No 07/01/12 Secure-3 20% Property / Casualty

General American Life Ins Co No 07/01/14 Secure-2 10%Life, Annuities, Endowments, A&H and Variable Contracts

1/1/11 - 9/17/12 Secure-3 20%9/18/12 - Current Secure-2 10%1/1/11 - 9/17/12 Secure-3 20%

9/18/12 - Current Secure-2 10%Hiscox Insurance Company (Bermuda) Ltd

No 07/01/11 Secure-3 20% Property / Casualty

Hannover Re (Bermuda) Ltd Property / CasualtyNo

Life, Annuities, A&H, and Property / Casualty

YesHannover Rueck SE

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Certified Reporting Guidance (New York - 2014)

Certified ReinsurerDate Of

CertificationDate

AccreditedMBT

Roll-in?Lines of Business Period

Report Recoverables

01/01/11 12/21/95 Varies All Lines Prior to Trusteed Unauthorized

All Lines Post Trusteed & Pre Cert Authorized

Certified Lines Post Trusteed & Post Cert Certified

All Other Lines Post Trusteed & Post Cert Authorized

01/01/11 09/30/10 Yes All Lines Prior to Certification Authorized

Certified Lines Post Certification Certified

All Other Lines Post Certification Authorized

01/01/11 06/08/10 Yes All Lines Prior to Certification Authorized

Certified Lines Post Certification Authorized

All Other Lines Post Certification Authorized

07/01/11 N/A No All Lines Prior to Certification Unauthorized

Certified Lines Post Certification Certified

All Other Lines Post Certification Unauthorized

01/01/11 04/22/97 Yes All Lines Prior to Certification Authorized

Certified Lines Post Certification Authorized

All Other Lines Post Certification Authorized

Varies N/A N/A All Lines Prior to Certification Unauthorized

Certified Lines Post Certification Certified

All Other Lines Post Certification Unauthorized

Hannover Rueck SE

Partner Reinsurance Company Ltd

Tokio Millennium Re AG

All Other New York Certified Reinsurers

Montpelier Reinsurance Ltd

Underwriters at Lloyd’s, London

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Contacts

Mike McClane Steve Le Market Analysis, Americas Market Analysis, Americas Aon Benfield Analytics Aon Benfield Analytics +1.215.751.1596 +1.215.751.1293 [email protected] [email protected]

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Legal Disclaimer

© Aon Benfield Inc. 2015. This document is intended for general information purposes only and should not be construed as advice or opinions on any specific facts or circumstances. This analysis is based upon information from sources we consider to be reliable, however Aon Benfield does not warrant the accuracy of the data or calculations herein. The content of this document is made available on an “as is” basis, without warranty of any kind. Aon Benfield disclaims any legal liability to any person or organization for loss or damage caused by or resulting from any reliance placed on that content. Members of the Aon Benfield Analytics will be pleased to consult on any specific situations and to provide further information regarding the matters discussed herein.


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