Comments End July 10 for UCAA Pro Forma Updates
Jun 29, 2018
By Jeff Rainey and Claude Mueller
The NAIC National Treatment and Coordination (E) Working Group is exposing for comments updated Proforma Financial Statement Templates, formally known as Form 13. These forms are required in many state application scenarios such as UCAA Primary and Expansion Applications as well as UCAA Corporate Amendment – Line of Business Applications. The 60-day comment period ends on July 10, 2018. Updates have been made to each of the four available templates (Health Proforma, Life Proforma, P&C Proforma, and the Title Proforma). In addition to updates to the existing tabs in each of these templates, two new tabs have been added.
The two new tabs are located in the Excel Spreadsheet labeled Authorized Premium by LOB (Agg) and Authorized Incurred Loss by LOB. These tabs have been added to help improve the user experience by reducing the amount of data input required. The user will now only complete the State specific tabs with the “planned” premium and “planned” losses for that State and then use the Authorized Premium by LOB (Agg) tab and Authorized Incurred Loss by LOB tab to fill in all of the premium and loss data for the States in which the company is currently operating. For example, an insurer is currently writing in five states and plans to expand into one new state. In this scenario the insurer would only fill out a State specific tab for the one expansion state and then aggregate the remaining five states premium into the new Authorized Premium by LOB (Agg) tab and losses into the new Authorized Incurred Loss by LOB tab. The Excel Spreadsheet will then use the State specific tab and the two new tabs to automatically populate the Nationwide Premium by LOB tab and the Nationwide Incurred Loss by LOB tab.
Changes to the existing tabs have been made to align them more closely with the Annual Statement Blank. The Balance Sheet will see a change in the Admitted Assets section in which the line items for Affiliated Investments and Affiliated Receivables have been removed as these are not specific line items on the Annual Statement Balance Sheet. Lines are being added to include Other Invested Assets, Aggregate Write-Ins for Invested Assets, and All Other Assets line items. Similarly, there have been modifications to the line items in the Capital and Surplus section to align with the Annual Statement. While the Profit and Loss Statement will not see any changes to line items, the user will want to take note that the entire new Proforma will be in whole dollars and nothing will be in thousands anymore. The Cash Flow Statement has line item updates to also more appropriately reflect the format of the Annual Statement Cash Flow.
We encourage insurance carriers to review and test the new Proformas and report any issues, comments, or concerns to us at jrainey@colodnyfass.com or cmueller@colodnyfass.com. You may also direct your comments directly to NAIC staff member Crystal Brown at cbrown@naic.org. Please note the official comment period ends July 10, 2018.
To view the proposed updated Proformas please visit the following link: http://www.naic.org/cmte_e_nat_treat.htm?tab_2
To view the current Proformas please visit the following link, then select either the Primary App tab or the Expansion App tab and you will find the Proformas: http://www.naic.org/industry_ucaa.htm
About the Authors
Jeff Rainey is an insurance Regulatory Consultant at Colodny Fass in Tallahassee, Florida. He can be reached at (850) 577-0398 or jrainey@colodnyfass.com.
Claude Mueller, CPCU, ARe, is an Insurance Regulatory Consultant at Colodny Fass in Tallahassee, Florida. He can be reached at (850) 570-4763 or cmueller@colodnyfass.com.