In response to the 2008 financial crisis and, in particular, the AIG bailout, the National Association of Insurance Commissioners (NAIC) adopted a significant revision to the model Insurance Holding Company System Regulatory Act (Holding Company Act) and related model regulations at the end of 2010.

Executive Summary

Senior management teams of P/C insurers need to start thinking about new regulatory Form F filings, even before they start worrying about ORSA. Eleven states have adopted the new regulatory reporting requirement related to risks posed by non-regulated entities in a holding company system, with an effective date of July 1, 2013, according to Sedgwick LLP's Hilary Rowen.

The new Enterprise Risk Report filing requirements in the Holding Company Act focus on the risk to insurance company entities presented by non-regulated entities within the holding company system.

The new Enterprise Risk provisions require the “ultimate controlling person” (UCP) of an insurer group to file a “Form F” report with the lead regulator for the holding company system and provide a copy to each state in which an insurer is domiciled.

The lead regulator will be determined according to criteria set forth in the Financial Analysis Handbook adopted by the NAIC.

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