Summary
The Annual 2024 filings for Property/Casualty filers have been modified by the NAIC through the adoption of the Blanks Working Group (BWG) item 2023-16BWG Modified. The intention of this modification is to bring consistency to the lines of business within Schedule P by requiring all parts of the schedule to show ten years of data and a “prior”row.
What does this mean?
This modifies requirements for six lines of business that previously reported two years of data and a “prior” row. The I, J, K, L, S and T lines will be modified for this change in Schedule P, Parts 1 through 4. Part 5 will also be modified for Warranty (line of business T).
For 2024, all rows will be reported rows that will render in the PDF and be captured in the electronic filing. Additional cross-check validations will be added to the Schedule P Summary tables.
Gain Compliance will be updating and supporting the Schedule P workpaper and in-app worksheet to incorporate all of the modifications.
For additional information, please click on the link to the BWG proposal above and/or continue reading.
Details of the changes
Effective Date: Annual 2024
Changes to the Blank:
The snapshots of the blanks changes included below detail the modifications to Inland Marine (line of business I) and are representative of the modifications to all of the short-tail lines (I, J, K, L, S and T). The first image under each Part represents how the information should be reported in 2024 and the second image is from the 2023 Annual.
Part 1
Part 2
Part 3
Part 4
Q&A
Q: What are the key items driving this change?
A:
- Ten years of accident year data are required for the summary schedules and RBC reporting
- The two-year reporting requires unneeded calculations that can result in errors on the “Prior” row
- With all lines having 10 years of data, Schedule P will be easier to understand because a reconciliation of the summary data and line of business data is more apparent
- Current technology results in no material time, printing or cost savings derived by only showing two years of data for the six lines of business
Q: What are potential follow-up items that could result from this change?
A: Actuaries at the NAIC are working on clarifying the instructions for the calculation of all prior rows. They will sponsor a BWG proposal once they have adopted the changes to the instructions. The effective date of the proposal, if adopted, would be no sooner than the 2025 Annual.
Q: Are there any other changes to Schedule P I should be aware of?
A: Yes! Schedule P has also been modified to break out Pet Insurance (Line of Business U) from Inland Marine (Line of Business I) in Parts 1 through 4. Please see our related blog post for additional information.
Q: What else should I be thinking about in regards to this change?
A: Gain Compliance, as well as several of the other annual statement vendors, have historically supported the collection of ten years of accident year data for all lines of business so we expect the impact of this change to be minimal. If you are a first time filer with Gain for 2024 Annual reporting we will need to obtain your historical data for the short-tail lines in order to roll all of the prior year values forward
Q: Who should I contact if I have any questions about implementing the modifications or need additional assistance?
A: If you have any questions or need further assistance, please contact our Customer Support team by emailing support@gaincompliance.com.
As always, Gain Compliance integrates the latest changes into the NAIC guidelines to streamline the reporting process. If there are any further questions or comments, please do not hesitate to reach out.
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