Sabrina Wilson, CPA, FLMI
Global Regulatory Policy Expert
Sabrina serves as a subject matter expert for regulatory filings at Clearwater. In this role, she works with internal teams for the ongoing enhancement of NAIC reports. Sabrina has over 20 years’ of statutory accounting and reporting experience and uses her background to communicate industry best practices and comment on regulatory guidance and procedures. She also handles complex statutory accounting and analytics questions posed by our user community.
Sabrina is a certified public accountant, has earned the designation of Fellow, Life Management Institute (FLMI), and has a master’s degree in accounting and taxation from Boise State University.
The NAIC recently confirmed two updates that will impact statutory accounting and reporting requirements. Here is the information pertinent to investment accountants.
Statuary Accounting Principles Working Group (SAPWG)
INT 20-03 Troubled Debt Restructuring Due to COVID-19 & INT 20-07 Troubled Debt Restructuring of Certain Instruments Due to COVID-19
On January 6, 2021, SAPWG exposed the extension of two interpretations by evote revisions: INT 20-03 Troubled Debt Restructuring Due to COVID-19 and INT 20-07 Troubled Debt Restructuring of Certain Instruments Due to COVID-19. These changes were in response to the federal Consolidated Appropriations Act of 2021 which was signed into law on December 27, 2020, extending the original CARES Act from December 31, 2020, to January 1, 2022. The public comment deadline was January 22, 2021.
On January 25, 2021, the SAPWG adopted (via evote) to extend these two interpretations through the earlier of January 1, 2022, or the date that is 60 days after the date on which the National Emergencies Act terminates.
Blanks Working Group (BWG)
2019-18BWG
BWG adopted 2019-18BWG in August 2019. This item inadvertently allows only the following four lines to have NAIC Designation/NAIC Designation Modifier/Administrative Symbol on Schedule BA Part 1: 0799999, 0899999, 1599999, and 1699999.
NAIC became aware of the guidance error in late January and inactivated a validation rule (_TASU900103) on January 25, 2021. That rule stops lines other than the above four lines from reporting NAIC Designation with Modifiers and SVO Administrative Symbol.
NAIC published this note on February 2, 2021.
Important Note for 2020 Annual Statement Filing
“A discrepancy was noted in the NAIC Designation/NAIC Designation Modifier/Administrative Symbol columns on Schedule BA Part 1. The discrepancy noted was that only four lines were open to allow entry for these columns. All lines have been opened to allow entry for these columns. Please check with your software vendor as to any updates that may be needed.”
Clearwater will not address this issue in our system until Q1 2021 (our concern is users will not be able to upload our text file into the annual statement software if the vendor did not inactivate that rule). If you have any questions, please contact your Service Delivery Manager