In order to promote uniformity among the various states, the National Association of Insurance Commissioners (NAIC) promulgates that financial statements are prepared on forms (also referred to as “Blanks”) which vary by insurance industry. In addition, the NAIC created the Accounting Practices and Procedures Manual (the “Manual”) which is a comprehensive guide to and codification of statutory accounting principles (SAP), composed of the Preamble, the Statements of Statutory Accounting Principles (SSAPs), and the Appendices. All states have adopted the Manual as a comprehensive basis of accounting if not in conflict with state statutes and/or regulations. If the domiciliary state sets forth accounting guidance that differs from the Manual, reporting entities are required to disclose the departure within the notes to financial statements. The SAP generally differ from GAAP.
The NAIC also created the Annual Financial Reporting Model Regulation (also referred to as the “Model Audit Rule”) with the objective to improve the state insurance department’s surveillance of the financial condition of insurers by requiring (1) an annual audit of financial statements reporting the financial position and the results of operations of insurers by independent certified public accountants, (2) communication of internal control related matters noted in an audit, and (3) management’s report of internal control over financial reporting. The Model Audit Rule also provides model laws and regulations that define filing requirements for annual audited financial reports, including specific information concerning the filing and content of audited financial reports and other related letters and reports that should be filed with the state insurance department. Although the requirements can differ for each state, as not all states have adopted the Model Audit Rule or certain filing requirements differ from the Model Audit Rule, here is an overview of some of the Model Audit Rule filing deadlines:
- Designation of Auditor letter must be filed by the reporting entity within 60 days after becoming subject to regulation.
- Awareness Letter from Auditor which must be filed by the reporting entity. The Model Audit rule does not specify a due date for it.
- Audit Report and Qualification Letter is due June 1. Be aware, certain states require filing by April 1.
- Internal Control Letter is due within 60 days after filing of audited financial statements; none if no significant deficiencies noted.
- Insurer must notify Commissioner within five days of dismissal or resignation of auditor.
LBMC’s Insurance Experts are very familiar with all the compliance requirements that apply to financial statement audits for each state. As part of the financial statement audit process, we will communicate all the filing requirements to you which will help you stay in compliance!