The Quarterly and Annual 2024 filings for Property/Casualty filers will be modified by the NAIC through the adoption of the Blanks Working Group (BWG) item 2023-01BWG Modified. The intention of this modification is to remove the Pet Insurance line of business, formerly reported within the Inland Marine category throughout the P&C schedules, to a separate line within the existing schedules.
What does this mean?
In short, a new Pet Insurance Plans line will be added to the following schedules:
- 2024 Quarterly:
- Part 1 – Loss Experience
- Part 2 – Direct Premiums Written
- 2024 Annual Statement:
- Underwriting and Investment Exhibit Part 1 – Premiums Earned
- Underwriting and Investment Exhibit Part 1A – Recapitulation of All Premiums
- Underwriting and Investment Exhibit Part 1B – Premiums Written
- Underwriting and Investment Exhibit Part 2 – Losses Paid and Incurred
- Underwriting and Investment Exhibit Part 2A – Unpaid Losses and Loss Adjustment Expense
- Exhibit of Premiums and Losses (State Page)
- Insurance Expense Exhibit (IEE), Parts 2 and 3
- Schedule P, Parts 1 through 4
- Appendix – Property and Casualty Lines of Business
Gain Compliance will be updating and supporting the Excel State Page workpaper, Schedule P workpaper and worksheet and the IEE, Part 2 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: January 1, 2024
Changes to the Blank:
The revised 2024 Quarterly Parts 1 & 2 and the 2024 Annual Underwriting and Investment Exhibits, State Page and IEE will include a new Line 9.2 – Pet Insurance Plans in the Line of Business Column and the Inland Marine Line will change from Line 9 to Line 9.1. NOTE: Any schedules that include columns with prior year 2023 data should tie in Total on Line 35. Prior year amount for Pet Insurance Plans should be manually entered on Line 9.2 and removed from Line 9.1 – Inland Marine.
Schedule P, Parts 1 through 4 will be updated to include the new Line of Business (line) for Pet Insurance Plans. Pet Insurance Plans will be presented as a short-tail line in Schedule P and the schedules will contain a “U” after the part to identify the Pet Insurance Plans line.
Q: What are the key items driving this change?
A: Regulators do not have clear visibility into who is underwriting pet coverage, the volume being sold, losses and who is selling it, which makes it difficult to assess whether or not the appropriate amount of surplus is being held. The pet insurance industry is growing rapidly and the growth rate makes the absence of visibility into each participating company’s financial information more of an acute challenge with each passing year
Q: What are potential follow-up items that could result from this change?
A: It is anticipated that once sufficient history is obtained, a separate RBC factor for pet insurance can and will be established. In addition, MCAS reporting for Pet Insurance was adopted by the Market Conduct Annual Statement Blanks (D) Working Group on May 30, 2023 for 2024 Annual reporting.
Q: Is it correct to assume the Inland Marine line (I) will need to be restated for all 10 years to back out the pet insurance formerly included in those prior years ?
A: That is our assumption, but we are going to follow up with the NAIC for confirmation.
Q: Is it correct to assume that we will also need a full 10 years (plus prior) numbers for our Pet Insurance lines?
A: Yes. While Schedule P only has the two years prior broken specifically out on the schedule that goes to the NAIC, you will need to enter an annual breakdown for your Pet Insurance lines for the full 10 years prior plus a prior line so that we can accurately report and roll forward data in future years.
Q: How are the prior year to date values required on the Quarterly Part 1 and Part 2 blanks expected to be reported to the NAIC? And, if we are expected to report them on the 2024 Quarterly filings, will these values be pulled in from somewhere in 2024 or will we manually enter these values in 2024?
A: The prior year to date values will need to be restated for the breakout of the Pet Insurance and manually entered in 2024. In 2025, we will be able to pull the prior year to date values from the prior quarterly statements.
Q: When does Gain Compliance expect to have more information on how the Inland Marine and Pet Insurance lines of business will be set up in their software for the 2024 Annual filing and are there any other special “data requirements” that we should be aware of and preparing for?
A: We expect to obtain more information regarding the underlying specifications and data requirements for the 2024 Annual filing when the NAIC distributes the first release of the Instructions, Blanks and specifications for that filing in the spring of 2024.
Q: What else should I be thinking about in regards to this change?A: If you’re unsure about your source systems’ ability to report on Inland Marine and Pet Insurance data separately in 2024, start investigating now so you can make necessary changes. Consider your ability to restate Inland Marine data for 10+ years and report Pet Insurance data for 10+ years.
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