FPCA Additional Comment Time Open Until November 2: Florida Office of Insurance Regulation Reviews Proposed Revisions to Annual Audited Financial Reports Rule

Oct 22, 2009

Florida Property Casualty Association (“FPCA”) members are advised that time is still available to submit written comments for the public record regarding the Florida Office of Insurance Regulation (“OIR”) Rule Development Workshop held on October 21, 2009 on proposed Rule 690-137.002 entitled “Annual Audited Financial Reports.” 

Comments should be forwarded to Katie Webb at kwebb@cftlaw.com by Friday, October 30.

Officials from both the OIR Life and Health and Property and Casualty divisions presided over yesterday’s workshop.  The OIR officials briefly explained the proposed Rule, which would implement Sarbanes-Oxley-type financial controls for certain Florida insurers similar to the National Association of Insurance Commissioners’ (“NAIC”) 2006 Model Audit Rule.  As part of its insurance department accreditation process, the NAIC has given state insurance departments until 2010 to adopt the Model Audit Rule or substantially similar regulations.

During the public testimony portion of the Workshop, the OIR officials explained that the proposed Rule is not intended to require an additional annual audit for a foreign insurer if it is in substantial compliance with a Model Audit Rule from another state.

It also was suggested that the cost of financial auditing would “theoretically” decrease with the adoption of the proposed Rule, however, a cost impact is not expected. 

The OIR also addressed typographical errors in the proposed Rule, noting that necessary changes would be made.   

In regard to Section 17(a) in the proposed Rule that provides for circumstances warranting a exemption from compliance, Colodny Fass, represented by Katherine Webb, asked the OIR officials stating that to further clarify or define the term “financial or organization hardship.”  Explaining that “we’ll know it when we see it,” the Officials said simply that the proposed Rule is broader in scope than the existing Rule. 

The record will be open for additional written comments until November 2, 2010.

To view a comprehensive summary of proposed Rule 690-137.002, click here

To view the October 21 meeting notice, which includes statutory references and hyperlinks to the current Rule, click here.

Colodny Fass will represent the FPCA at the subsequent hearing on this matter if there are comments to present.  The Firm will continue to monitor this issue and participate in any relevant proceedings.

Should you have any questions, or comments other than those submitted for the public record, please contact Katie Webb (kwebb@cftlaw.com) at Colodny Fass