Industry Questions/Comments
Are there any specific requirements re the record keeping for this? Or is the requirement to have independent records for local vs foreign business? Should there be separate accounts for each line of business as well? What is mean by a separate shareholder account.
Central Bank of Trinidad and Tobago
1. The Central Bank will not require the physical segregation of assets in respect of the maintenance of separate accounts for participating and non-participating policies.
2. Instead, insurers will be required to report on the income and expenses for local and foreign business in Forms included in the Annual Returns for long-term and general insurance business. Reporting on the income and expenses attributable to participating policies is also dealt with in the Forms included in the Annual Returns for long-term insurers.
3. In addition to this, long-term insurers must be guided by the requirements of section 160 of the Act and the Insurance (Participating Accounts) Regulations.
4. Further, insurers should maintain records as will be necessary to facilitate and evidence compliance with the reporting requirements in the Annual Returns as well as, in the case of long-term insurers, the requirements under section 160 of the Act and the Insurance (Participating Accounts) Regulations.
5. At this point in time, the insurer is required to submit the information through the Forms specified in the Annual Returns. If at any time circumstances change and there are any further requirements, it will be communicated to the industry.
Separate Shareholder Account
Thanks for the feedback above, however, I am still not clear on what is meant to be reported as per section 42 (1) (b) Separate Shareholder Account. Kindly clarify.
Separate Shareholder Account
Thanks for the feedback above, however, I am still not clear on what is meant to be reported as per section 42 (1) (b) Separate Shareholder Account. Kindly clarify.
Section 43 Participating Account
Are there specific requirements or reporting templates for the participating account? Also, what is the expected frequency of reporting - Quarterly, annually?
Separate Accounts
For the avoidance of doubt, does this response therefore mean that there are currently no specific requirements for separate accounts or separate shareholder accounts once the insurer is able to appropriately and accurately complete the forms included in the relevant annual returns? Is it that perhaps at a later date instructions/guidelines may be given for the form and conditions or restrictions that are to be applied for separate accounts, after consultation with the industry?
Separate Accounts
The following is to address the comments posted by insurers above.
Please note that, the information contained in the Insurance Exhibits forms which are included in the Annual Returns packages captures the required reporting by classes of business as well as overseas business; these are the current separate reporting requirements required by the Inspector at this time. This includes the requirement to establish and maintain a separate shareholder account, which is reported in Form 20.10 / 20.011 of the Annual Returns for general and long term insurers; in these forms, shareholders’ amounts are reported separate from policyholders’ liabilities amounts.
In the accounts and records of an insurer, the accounts that represent shareholders’ funds are required to be kept separated.
Subsequently, the Inspector will communicate accordingly with the insurers in respect of the development of additional templates required for annual participating account reporting in accordance with the requirements of the Insurance (Participating Account) Regulations, 2020 and the Act.
