NOTICES
INSURANCE DEPARTMENT
COVID-19 Related Financial Filings Guidance; Notice 2020-10
[50 Pa.B. 2241]
[Saturday, April 25, 2020]The purpose of this notice is to advise all domestic insurance companies in this Commonwealth regarding continued compliance with regulatory requirements during the novel coronavirus (COVID-19) public health emergency.
Extensions for Regulatory Filing Deadlines
At this time, companies are still required to make all required electronic filings (for example, quarterly financial statements, audited financial statements) with the National Association of Insurance Commissioners (NAIC). Filings should also continue to be filed electronically with the company's assigned analyst. If the company believes that it will not be able to meet a deadline required by law or regulation, contact the assigned analyst by e-mail to request an extension in writing. The Insurance Department (Department) will consider providing insurers an additional 30 or 60 days, as provided as follows, to complete certain filings. The Department reserves the right to reject an extension request based upon the financial condition of the company or any other unique circumstances applicable to the company.
Filings subject to a potential 30-day extension:
• May 1, 2020, Combined Annual Statement Filing (Property)
• May 1, 2020, Combined Insurance Expense Exhibit (Property)
• June 1, 2020, Accountant's Letter of Qualifications (Property, Life/Fraternal, Health, Title)
• August 15, 2020, PBR Exemption filing due to State July 1, 2020, and to NAIC August 15, 2020, (Life/Fraternal)
Filings subject to a potential 60-day extension:
• June 1, 2020, Audited Financial Report (Property, Life/Fraternal, Health, Title)
• August 1, 2020, Communication of Internal Control Related Matters Noted in Audit (Property, Life/Fraternal, Health, Title)
• June 1, 2020, Corporate Governance Annual Disclosure
Regulatory Filing Deadlines
Components of Annual Filings
The filing deadlines for the components of the 2019 annual filings, which should be submitted only to an insurer's state of domicile, are as follows.
• April 30, 2020, Actuarial Memorandum Required by Actuarial Guideline XXXVIII 8D (Life/Fraternal)
• August 1, 2020, Management's Report of Internal Control Over Financial Reporting (Property, Life/Fraternal, Health, Title)
Filings subject to a potential 30-day extension:
Quarterly Electronic Filings
The NAIC filing deadlines and requirements for the 2020 quarterly electronic filings, as set forth as follows, are due May 15, 2020:
• Quarterly Statement Filing as of March 31, 2020, (Property, Life/Fraternal, Health, Title)
• Trusteed Surplus Statement—Quarter Ending March 31, 2020, (Property, Life/Fraternal)
• Supplement A to Schedule T (Medical Professional Liability Supplement)—Quarter Ending March 31, 2020, (Property)
• Medicare Part D Coverage Supplement—Quarter Ending March 31, 2020, (Property, Life/Fraternal, Health)
• Merger/History Quarterly Form, if Applicable (Property, Life/Fraternal, Health, Title) (electronic txt file only)
• Reasonableness of Assumptions Certification Required by Actuarial Guideline XXXV—Quarter Ending March 31, 2020, (Life/Fraternal)
• Reasonableness and Consistency of Assumptions Certification Required by Actuarial Guideline XXXV—Quarter Ending March 31, 2020, (Life/Fraternal)
• Reasonableness of Assumptions Certification for Implied Guaranteed Rate Method Required by Actuarial Guideline XXXVI—Quarter Ending March 31, 2020, (Life/Fraternal)
• Reasonableness and Consistency of Assumptions Certification Required by Actuarial Guideline XXXVI (Updated Average Market Value)—Quarter Ending March 31, 2020, (Life/Fraternal)
• Reasonableness and Consistency of Assumptions Certification Required by Actuarial Guideline XXXVI (Updated Market Value)—Quarter Ending March 31, 2020, (Life/Fraternal)
• Director and Officer Insurance Coverage Supplement—Quarter Ending March 31, 2020, (Property)
Electronic Filings and Electronic Signatures
Prior to the COVID-19 crisis, the Department generally instructed companies to file documents in hard copy form with original (wet) signature, with notary requirements. Until further notice, the hard copy, original signature, notarization and other in-person related filing requirements are currently waived. Companies shall submit all documents electronically to their assigned analyst. However, companies are expected to keep a list of all filings that were submitted electronically. Hard copies should be filed within 60 days after the Commonwealth lifts its social distancing restrictions and employees are permitted to return to work.
Onsite Examinations
Some insurers have inquired regarding whether the Department will continue to conduct onsite examinations during the COVID-19 pandemic. The Department will fully comply with any government directives or orders regarding public gatherings and essential operations. At this time, the Department will not conduct any onsite examination work that is contrary to the spirit of any public health directive. However, the Department will continue to engage in all examination functions that do not require employees onsite. Companies should be aware that the Department may need to request additional information in electronic form. The Department expects independent auditors will also take a similar position. The Department acknowledges that company response times may be slower as more employees work from home. However, the Department will continue to engage in all examination functions that do not require employees onsite.
JESSICA K. ALTMAN,
Insurance Commissioner
[Pa.B. Doc. No. 20-586. Filed for public inspection April 24, 2020, 9:00 a.m.]
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