Accounting Standard Updates

12 Days of SSAP: Group Capital Calculation

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JLK Rosenberger is carrying on our holiday tradition of taking a new perspective on a holiday classic – the Twelve Days of Christmas. Rather than filling your head with turtle doves and gold rings, we are focusing on the latest changes to SSAP and how they will impact your insurance entity in 2023 and beyond.

Emanating from the 2008 Solvency Modernization Initiative (SMI), the GCC process attempts to provide a method of quantifying risk across an insurance group, assist regulators in assessing how and to what degree insurance companies may be supporting their non-insurance holdings, and function as a tool to protect policyholders of the insurers in the group. Today’s post provides a synopsis of the GCC process and its status.

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In May 2022, the Group Capital Calculation (E) Working Group adopted the 2022 GCC Instructions and Template. Several states have already adopted the revised model that will be required for 2022 year-end filings. Implementation dates may vary by state, but most, if adopted, are expected to be due in the Spring of 2023.

The NAIC 2020 Model Law and supporting Model Regulation commonly require the annual filing of the GCC report by the insurance company holding system with its lead state commissioner if the state has adopted the model laws. The report is filed as a component of the Enterprise Risk Management Report, better known as the Form F filing.  The Form F filing is a part of the Annual Registration Statement annual filing required by all states, further identified as the Form B filing.

It is worth noting that the GCC is required to be filed once per holding company system. The report is filed only with the holding system’s lead state regulator. The ultimate parent, as reported in Schedule Y, Part 1, should be used to determine the lead state.

The updated calculation is expected to provide additional information to the lead state regulator for use in assessing group risks and capital adequacy, as well as information about the location and sources of capital within the group.

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