Current through Register Vol. 49, No. 9, September, 2024
Section 1.
Authority
This Rule is promulgated by the Arkansas Insurance Commissioner
pursuant to Ark. Code Ann. §§
25-15-201,
et seq., 23-61-108, 23-63-216, and other provisions of the
Arkansas Insurance Code.
Section
2.
Purpose and Scope
The purpose of this Rule is to improve the Arkansas 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.
Every insurer, as defined in Section 3, shall be subject to this
Rule. Insurers having direct premiums written in this state of less than
$1,000,000 in any calendar year and less than 1,000 policyholders or
certificate holders of direct written policies nationwide at the end of the
calendar year shall be exempt from this Rule for such year, unless the
Commissioner makes a specific finding that compliance is necessary for the
Commissioner to carry out his or her regulatory responsibilities. However,
insurers having a combined total of direct and assumed premiums pursuant to
contracts and/or treaties of reinsurance of $1,000,000 or more will not be so
exempt.
Foreign or alien insurers filing the Audited Financial Report in
another state, pursuant to that state's requirement for filing of Audited
Financial Reports, which has been found by the Commissioner to be substantially
similar to the requirements herein, are exempt from Sections 4 through 13 of
this Rule if:
A. A copy of the Audited
Financial Report, Communication of Internal Control Related Matters Noted in an
Audit, and the Accountant's Letter of Qualifications that are filed with
another state are filed with the Commissioner in accordance with the filing
dates specified in Sections 4, 11 and 12, respectively. Canadian insurers may
submit accountants' reports as filed with the Office of the Superintendent of
Financial Institutions, Canada; and
B. When applicable, a copy of any
Notification of Adverse Financial Condition Report filed with another state is
filed with the Commissioner within the time specified in Section 10.
Foreign or alien insurers required to file Management's Report of
Internal Control Over Financial Reporting in another state are exempt from
filing the Report in this state provided the other state has substantially
similar reporting requirements and the Report is filed with the Commissioner of
the other state within the time specified.
This Rule shall not prohibit, preclude or in any way limit the
Insurance Commissioner from ordering, conducting or performing examinations of
insurers under the rules of the Arkansas Insurance Department, the provisions
of the Arkansas Insurance Code, and the practices and procedures of the
Arkansas Insurance Department.
Section 3.
Definitions
The terms and definitions contained herein are intended to
provide guidance only as the terms are used within this Rule.
A. "Accountant" or "independent certified
public accountant" means an independent certified public accountant or
accounting firm in good standing with the American Institute of Certified
Public Accountants (AICFA) and in all states in which he or she is licensed to
practice. With regard to Canadian and British companies, it means a
Canadian-chartered or British-chartered accountant.
B. An "affiliate" of or person "affiliated"
with a specific person, is a person that directly or indirectly through one or
more intermediaries controls, or is controlled by, or is under common control
with, the person specified.
C.
"Audit Committee" means a committee (or equivalent body) established by the
board of directors of an entity for the purpose of overseeing the accounting
and financial reporting processes of an insurer or group of insurers, and
audits of financial statements of the insurer or group of insurers. The Audit
Committee of any entity that controls an insurer or a group of insurers may be
deemed to be the Audit Committee for one or more of these controlled insurers
solely for the purposes of this Rule at the election of the controlling person.
Refer to Section 14(E) for exercising this election. If an Audit Committee is
not designated by the insurer, the insurer's entire board of directors shall
constitute the Audit Committee.
D.
"Audited Financial Report" means and includes those items specified in Section
5 of this Rule.
E. "Commissioner"
means the Arkansas Insurance Commissioner.
F. "Group of insurers" means those insurers
subject to the reporting requirements of the Insurance Holding Company
Regulatory Act, Ark. Code Ann. §§
23-63-501,
et seq., or a set of insurers as identified by management for
the purpose of assessing the effectiveness of Internal Control Over Financial
Reporting.
G. "Indemnification"
means an agreement of indemnity or a release from liability where the intent or
effect is to shift or limit in any manner the potential liability of the person
or firm for failure to adhere to applicable auditing or professional standards,
whether or not resulting in part from knowledge of misrepresentations made by
the insurer or its representatives.
H. "Independent board member" has the same
meaning as described in Section 14(C).
I. "Insurer" means an insurer as defined in
Ark. Code Ann. §
23-60-102(2)
or an authorized insurer as defined in Ark. Code Ann. §
23-60-102(11).
For purposes of this Rule, an insurer shall also mean hospital and medical
service corporations, as defined in Ark. Code Ann. §
23-75-101,
and health maintenance organizations, as defined in Ark. Code Ann. §
23-76-102(7).
J. "Internal Control Over Financial
Reporting" means a process effectuated by an entity's board of directors,
management and other personnel designed to provide reasonable assurance
regarding the reliability of the financial statements, i.e., those items
specified in Sections 5(B) through 5(G) of this Rule and includes those
policies and procedures that:
(1) Pertain to
the maintenance of records that, in reasonable detail, accurately and fairly
refiect the transactions and dispositions of assets;
(2) Provide reasonable assurance that
transactions are recorded as necessary to permit preparation of the financial
statements, i.e., those items specified in Sections 5(B) through 5(G) of this
Rule and that receipts and expenditures are being made only in accordance with
authorizations of management and directors; and
(3) Provide reasonable assurance regarding
prevention or timely detection of unauthorized acquisition, use or disposition
of assets that could have a material effect on the financial statements, i.e.,
those items specified in Sections 5(B) through 5(G) of this
Rule.
K. "SEC" means the
United States Securities and Exchange Commission.
L. "SOX Compliant Entity" means an entity
that either is required to be compliant with, or voluntarily is compliant with,
all of the following provisions of the Sarbanes-Oxley Act of 2002:
(i) the preapproval requirements of Section
201 (Section 10(A)(i) of the Securities Exchange Act of 1934);
(ii) the Audit Committee independence
requirements of Section 301 (Section 10(A)(m)(3) of the Securities Exchange Act
of 1934); and
(iii) the Internal
Control Over Financial Reporting requirements of SOX Section 404 (Item 308 of
SEC Regulation S-K).
M.
"SOX Section 404" means Section 404 of the Sarbanes-Oxley Act of 2002 and the
SEC's regulations promulgated thereunder.
N. "SOX Section 404 Report" means
Management's Report on "Internal Control Over Financial Reporting" as defined
by the SEC and the related attestation report of the independent certified
public accountant as defined in Section 3(A).
O. "Workpapers" are the records kept by the
independent certified public accountant of the procedures followed, the tests
performed, the information obtained, and the conclusions reached pertinent to
the accountant's audit of the financial statements of an insurer. Workpapers
may include audit planning documentation, work programs, analyses, memoranda,
letters of confirmation and representation, abstracts of company documents and
schedules, or commentaries prepared or obtained by the independent certified
public accountant in the course of his or her audit of the financial statements
of an insurer and which support the accountant's opinion.
Section 4.
General Requirements Related
to Filing and Extensions for Filing of Annual Audited Financial Reports and
Audit Committee Appointment
A. AH
insurers shall have an annual audit performed by an independent certified
public accountant and shall file an Audited Financial Report with the
Commissioner on or before June 1 for the year ended December 31 immediately
preceding. The Commissioner may require an insurer to file an Audited Financial
Report earlier than June 1 with ninety (90) days advance notice to the
insurer.
B. Extensions of the June
1 filing date may be granted by the Commissioner for periods of thirty (30)
days upon a showing by the insurer and its independent certified public
accountant of good cause for an extension. The request for extension must be
submitted in writing not less than ten (10) days prior to the due date in
sufficient detail to permit the Commissioner to make an informed decision with
respect to the requested extension. The Commissioner, in his or her sole
discretion, will determine whether good cause exists for an extension and will
notify the insurer of that decision in writing.
C. If an extension is granted in accordance
with the provisions in Section 4(B), a similar extension of thirty (30) days is
granted to the filing of Management's Report of Internal Control Over Financial
Reporting.
D. Every insurer
required to file an annual Audited Financial Report pursuant to this Rule shall
designate a group of individuals as constituting its Audit Committee, as
defined in Section 3. The Audit Committee of an entity that controls an insurer
may be deemed to be the insurer's Audit Committee for purposes of this Rule at
the election of the controlling person.
Section 5.
Contents of Annual Audited
Financial Report
The annual Audited Financial Report shall report the financial
position of the insurer as of the end of the most recent calendar year and the
results of its operations, cash flows and changes in capital and surplus for
the year then ended in conformity with statutory accounting practices
prescribed, or otherwise permitted, by the Insurance Department of the state of
domicile.
The annual Audited Financial Report shall include the
following:
A. Report of independent
certified public accountant;
B.
Balance sheet reporting admitted assets, liabilities, capital and
surplus;
C. Statement of
operations;
D. Statement of cash
flow;
E. Statement of changes in
capital and surplus;
F. Notes to
financial statements. These notes shall be those required by the appropriate
NAIC Annual Statement Instructions and the NAIC
Accounting Practices and Procedures Manual. The notes shall
include a reconciliation of differences, if any, between the audited statutory
financial statements and the annual statement filed pursuant to Ark. Code Ann.
§
23-63-216
with a written description of the nature of these differences; and
G. The financial statements included in the
Audited Financial Report shall be prepared in a form and using language and
groupings substantially the same as the relevant sections of the annual
statement of the insurer filed with the Commissioner, and the financial
statement shall be comparative, presenting the amounts as of December 31 of the
current year and the amounts as of the immediately preceding December 31.
However, in the first year in which an insurer is required to file an Audited
Financial Report, the comparative data may be omitted.
Section 6.
Designation of Independent
Certified Public Accountant
A. Each
insurer required by this Rule to file an annual Audited Financial Report must,
within sixty (60) days after becoming subject to the requirement, register with
the Commissioner in writing the name and address of the independent certified
public accountant or accounting firm retained to conduct the annual audit set
forth in this Rule. Insurers not retaining an independent certified public
accountant on the effective date of this Rule shall register the name and
address of their retained independent certified public accountant not less than
six (6) months before the date when the first Audited Financial Report is to be
filed.
B. The insurer shall obtain
a letter from the accountant, and file a copy with the Commissioner,
simultaneously with the registration required in Section 6(A), stating that the
accountant is aware of the provisions of the insurance laws and rules of the
insurance department of the state of domicile that relate to accounting and
financial matters and affirming that the accountant will express his or her
opinion on the financial statements in terms that conform to the statutory
accounting practices prescribed or otherwise permitted by that insurance
department, specifying such exceptions as he or she may believe are
appropriate.
C. If an accountant
who was the accountant for the immediately preceding filed Audited Financial
Report is dismissed or resigns, the insurer shall:
(1) Notify the Commissioner of this event
within five (5) business days;
(2)
Furnish the Commissioner with a separate letter within ten (10) business days
of the above notification stating whether in the twenty-four (24) months
preceding such event there were any disagreements with the former accountant on
any matter of accounting principles or practices, financial statement
disclosure, or auditing scope or procedure and which disagreements, if not
resolved to the satisfaction of the former accountant, would have caused him or
her to make reference to the subject matter of the disagreement in connection
with his or her opinion. The disagreements required to be reported in response
to this section include both those resolved to the former accountant's
satisfaction and those not resolved to the former accountant's satisfaction.
Disagreements contemplated by this section are those that occur at the
decision-making level, i.e., between personnel of the insurer responsible for
presentation of its financial statements and personnel of the accounting firm
responsible for rendering its report.
(3) Make a written request of the former
accountant to furnish a letter addressed to the insurer stating whether the
accountant agrees with the statements contained in the insurer's letter and, if
not, stating the reasons for which he or she does not agree;
(4) Furnish the responsive letter from the
former accountant to the Commissioner together with its own; and
(5) Register with the Commissioner in writing
the name and address of the independent certified public accountant or
accounting firm retained to replace the accountant who was dismissed or
resigned within sixty (60) days of such replacement and comply with the
requirements of Section 6(B).
Section 7.
Qualifications of
Independent Certified Public Accountant
A. The Commissioner shall not recognize a
person or firm as a qualified independent certified public accountant if the
person or firm:
(1) Is not in good standing
with the AICPA in all states in which the accountant is licensed to practice,
or, for a Canadian or British company, that is not a chartered accountant;
or
(2) Has either directly or
indirectly entered into an agreement of indemnity or release from liability
(collectively referred to as "indemnification") with respect to the audit of
the insurer.
B. Except as
otherwise provided in this Rule, the Commissioner shall recognize an
independent certified public accountant as qualified as long as he or she
conforms to the standards of his or her profession, as contained in the Code of
Professional Ethics of the AICPA, and the Rules, the Code of Ethics, and Rules
of Professional Conduct of the Arkansas State Board of Public Accountancy, or
similar code.
C. A qualified
independent certified public accountant may enter into an agreement with an
insurer to have disputes relating to an audit resolved by mediation or
arbitration. However, in the event of a delinquency proceeding commenced
against the insurer under Ark. Code Ann. §§
23-68-101,
et seq., the mediation or arbitration provisions shall operate
at the option of the statutory successor.
D.
(1) The
lead or coordinating audit partner having primary responsibility for the audit
may not act in that capacity for more than five (5) consecutive years. The
person shall be disqualified from acting in that or a similar capacity for the
same company or its insurance subsidiaries or affiliates for a period of five
(5) consecutive years. An insurer may make application to the Commissioner for
relief from the above rotation requirement based on unusual circumstances. This
application should be made at least thirty (30) days before the end of the
calendar year. The Commissioner may consider all relevant factors, including
the following, in determining whether the relief should be granted:
(a) Number of partners, expertise of the
partners or the number of insurance currents in the currently registered
firm;
(b) Premium volume of the
insurer; and
(c) Number of
jurisdictions in which the insurer transacts business.
(2) If the Commissioner grants relief under
Section 7(D)(1), the insurer shall file the approval for relief with the states
in which it is licensed or doing business and with the NAIC, with its annual
statement filing. If the nondomestic states accept electronic filing with the
NAIC, the insurer shall file the approval in an electronic format acceptable to
the NAIC.
E. The
Commissioner shall neither recognize as a qualified independent certified
public accountant, nor accept an annual Audited Financial Report prepared in
whole or in part by, a natural person who:
(1) Has been convicted of fraud, bribery, a
violation of the Racketeer Influenced and Corrupt Organizations Act,
18
U.S.C. §§
1961-
1968,
or any dishonest conduct or practices under federal or state law;
(2) Has been found to have violated the
insurance laws of this state with respect to any previous reports submitted
under this Rule; or
(3) Has
demonstrated a pattern or practice of failing to detect or disclose material
information in previous reports filed under the provisions of this
Rule.
F. The Commissioner
may, as provided in Ark. Code Ann. §§
23-61-303
through 305, hold a hearing to determine whether an independent certified
public accountant is qualified based on the evidence presented. Following the
hearing, the Commissioner may determine that the accountant is not qualified
for purposes of expressing his or her opinion on the financial statements in
the annual Audited Financial Report made pursuant to this Rule and require the
insurer to replace the accountant with another who is qualified within the
meaning of this Rule.
G.
(1) The Commissioner shall not recognize as a
qualified independent certified public accountant, nor accept an annual Audited
Financial Report prepared in whole or in part by an accountant who provides to
an insurer, contemporaneously with the audit, the following non-audit services:
(a) Bookkeeping or other services related to
the accounting records or financial statements of the insurer;
(b) Financial information systems design and
implementation;
(c) Appraisal or
valuation services, fairness opinions, or contribution-in-kind
reports;
(d) Actuarially-oriented
advisory services involving the determination of amounts recorded in the
financial statements. The accountant may assist an insurer in understanding the
methods, assumptions and inputs used in the determination of amounts recorded
in the financial statement only if it is reasonable to conclude that the
services provided will not be subject to audit procedures during an audit of
the insurer's financial statements. An accountant's actuary may also issue an
actuarial opinion or certification ("opinion") on an insurer's reserves if the
following conditions have been met:
(i)
Neither the accountant nor the accountant's actuary has performed any
management functions or made any management decisions;
(ii) The insurer has competent personnel (or
engages a third party actuary) to estimate the reserves for which management
takes responsibility; and
(iii) The
accountant's actuary tests the reasonableness of the reserves after the
insurer's management has determined the amount of the reserves;
(e) Internal audit outsourcing
services;
(f) Management functions
or human resources;
(g) Broker or
dealer, investment adviser, or investment banking services;
(h) Legal services or expert services
unrelated to the audit; or
(i) Any
other services that the Commissioner determines, by rule or otherwise, are
impermissible.
(2) In
general, the principles of independence with respect to services provided by
the qualified independent certified public accountant are largely predicated on
three basic principles, violations of which would impair the accountant's
independence. The principles are that the accountant cannot function in the
role of management, cannot audit his or her own work, and cannot serve in an
advocacy role for the insurer.
H. Insurers having direct written and assumed
premiums of less than $100,000,000 in any calendar year may request an
exemption from the provisions of Section 7(G)(1). The insurer shall file with
the Commissioner a written statement discussing the reasons why the insurer
should be exempt from these provisions. If the Commissioner finds, upon review
of this statement, that compliance with those provisions would constitute a
financial or organizational hardship upon the insurer, an exemption may be
granted.
I. A qualified independent
certified public accountant who performs the audit may engage in other
non-audit services, including tax services, that are not described in Section
7(G)(1) or that do not conflict with Section 7(G)(2), only if the activity is
approved in advance by the Audit Committee in accordance with Section
7(J).
J. All auditing services and
non-audit services provided to an insurer by the qualified independent
certified public accountant of the insurer shall be preapproved by the Audit
Committee. The preapproval requirement is waived with respect to non-audit
services if the insurer is a SOX Compliant Entity or a direct or indirect
wholly-owned subsidiary of a SOX Compliant Entity or:
(1) The aggregate amount of all such
non-audit services provided to the insurer constitutes not more than five
percent (5%) of the total amount of fees paid by the insurer to its qualified
independent certified public accountant during the fiscal year in which the
non-audit services are provided;
(2) The services were not recognized by the
insurer at the time of the engagement to be non-audit services; and
(3) The services are promptly brought to the
attention of the Audit Committee and approved prior to the completion of the
audit by the Audit Committee or by one or more members of the Audit Committee
who are the members of the board of directors to whom authority to grant such
approvals has been delegated by the Audit Committee.
K. The Audit Committee may delegate to one or
more designated members of the Audit Committee the authority to grant the
preapprovals required by Section 7(J). The decisions of any member to whom this
authority is delegated shall be presented to the full Audit Committee at its
next scheduled meeting.
L.
(1) The Commissioner shall not recognize an
independent certified public accountant as qualified for a particular insurer
if a member of the board, president, chief executive officer, controller, chief
financial officer, chief accounting officer, or any person serving in an
equivalent position for that insurer, was employed by the independent certified
public accountant and participated in the audit of that insurer during the
one-year period preceding the date that the most current statutory opinion is
due. This section shall only apply to partners and senior managers involved in
the audit. An insurer may make application to the Commissioner for relief from
the above requirement based on unusual circumstances.
(2) The insurer shall file, with its annual
statement filing, the approval for relief from Section 7(L)(1) with the states
in which it is licensed or doing business and the NAIC. If the nondomestic
states accept electronic filing with the NAIC, the insurer shall file the
approval in an electronic format acceptable to the NAIC.
Section 8.
Consolidated or
Combined Audits
An insurer may make written application to the Commissioner for
approval to file audited consolidated or combined financial statements in Meu
of separate annual audited financial statements if the insurer is part of a
group of insurance companies that utilizes a pooling or one hundred percent
(100%) reinsurance agreement that affects the solvency and integrity of the
insurer's reserves and the insurer cedes all of its direct and assumed business
to the pool. In such cases, a columnar consolidating or combining worksheet
shall be filed with the report as follows:
A. Amounts shown on the consolidated or
combined Audited Financial Report shall be shown on the worksheet;
B. Amounts for each insurer subject to this
section shall be stated separately;
C. Noninsurance operations may be shown on
the worksheet on a combined or individual basis;
D. Explanations of consolidating and
eliminating entries shall be included; and
E. A reconciliation shall be included of any
differences between the amounts shown in the individual insurer columns of the
worksheet and comparable amounts shown on the annual statements of the
insurers.
Section 9.
Scope of Audit and Report of Independent Certified Public
Accountant
Financial statements furnished pursuant to Section 5 shall be
examined by the independent certified public accountant. The audit of the
insurer's financial statements shall be conducted in accordance with generally
accepted auditing standards. In accordance with AU Section 319 of the
Professional Standards of the AICPA, Consideration of Internal Control
in a Financial Statement Audit, the independent certified public
accountant should obtain an understanding of internal control sufficient to
plan the audit. To the extent required by AU 319, those insurers filling a
Management's Report of Internal Control Over Financial Reporting pursuant to
Section 16, the independent certified public accountant should consider (as
that term is defined in Statement on Auditing Standards (SAS) No. 102,
Defining Professional Requirements in Statements on Auditing Standards
or its replacement) the most recently available Report in planning and
performing the audit of the statutory financial statements. Consideration shall
be given to the procedures illustrated in the Financial Condition
Examiners Handbook promulgated by the NAIC as the independent
certified public accountant deems necessary.
Section 10.
Notification of Adverse
Financial Condition
A. An insurer that
is required to furnish the annual Audited Financial Report shall also require
the independent certified public accountant to report, in writing, within five
(5) business days to the board of directors or its Audit Committee any
determination by the independent certified public accountant that the insurer
has materially misstated its financial condition as reported to the
Commissioner as of the balance sheet date currently under audit or that the
insurer does not meet the minimum capital and surplus requirement of the
Arkansas Insurance Code as of that date. An insurer that has received a report
pursuant to this paragraph shall forward a copy of the report to the
Commissioner within five (5) business days of receipt of the report and shall
provide the independent certified public accountant making the report with
evidence of the report being furnished to the Commissioner. If the independent
certified public accountant fails to receive the evidence within the required
five (5) business days, the independent certified public accountant shall
furnish to the Commissioner a copy of its report within the next five (5)
business days.
B. No independent
certified public accountant shall be liable in any manner to any person for any
statement made in connection with the above paragraph if the statement is made
in good faith in compliance with Section 10(A).
C. If the accountant, subsequent to the date
of the Audited Financial Report filed pursuant to this Rule, becomes aware of
facts that might have affected his or her report, it is the obligation of the
accountant to take such action as prescribed in Volume 1, Section AU 561 of the
Professional Standards of the AICFA.
Section 11.
Communication of Internal
Control Related Matters Noted in an Audit
A. In addition to the annual Audited
Financial Report, each insurer shall furnish the Commissioner with a written
communication as to any un-remediated material weaknesses in its Internal
Control Over Financial Reporting noted during the audit. Such communication
shall be prepared by the accountant within sixty (60) days after the filing of
the annual Audited Financial Report, and shall contain a description of any
un-remediated material weakness (as the term "material weakness" is defined by
Statement on Auditing Standard 60, Communication of Internal Control
Related Matters Noted in an Audit, or its replacement) in the
insurer's Internal Control Over Financial Reporting noted by the accountant
during the course of their audit of the financial statements as of December 31
immediately preceding. If no un-remediated material weaknesses were noted, the
communication should so state.
B.
The insurer is required to provide a description of remedial actions taken or
proposed to correct un-remediated material weaknesses, if the actions are not
described is the accountant's communication.
Section 12.
Accountant's Letter of
Qualifications
The accountant shall furnish the insurer in connection with, and
for inclusion in, the filing of the annual Audited Financial Report, a letter
stating the following:
A. The
accountant is independent with respect to the insurer and conforms to the
standards of his or her profession as contained in the Code of Professional
Ethics and pronouncements of the AICPA and the Rules of Professional Conduct of
the Arkansas State Board of Public Accountancy, or similar code;
B. The accountant's background and experience
in general, and the experience in audits of insurers of the staff assigned to
the engagement and whether each is an independent certified public accountant.
Nothing within this Rule shall be construed as prohibiting the accountant from
utilizing such staff as he or she deems appropriate where use is consistent
with the standards prescribed by generally accepted auditing
standards;
C. The accountant
understands the annual Audited Financial Report and his opinion thereon will be
filed in compliance with this Rule and that the Commissioner will be relying on
this information in the monitoring and regulation of the financial position of
insurers;
D. The accountant
consents to the requirements of Section 13 of this Rule and consents and agrees
to make available for review by the Commissioner, or the Commissioner's
designee or appointed agent, the workpapers as defined in Section 3;
E. The accountant is properly licensed by an
appropriate state licensing authority and is a member in good standing in the
AICPA; and
F. The accountant is in
compliance with the requirements of Section 7 of this Rule.
Section 13.
Availability and
Maintenance of Independent Certified Public Accountants' Workpapers
A. Every insurer required to file an Audited
Financial Report pursuant to this Rule shall require the accountant to make all
workpapers prepared in the conduct of the accountant's audit and any
communications related to the audit between the accountant and the insurer
available for review by the Insurance Department's examiners at the offices of
the insurer, at the Insurance Department or at any other reasonable place
designated by the Commissioner. The insurer shall require that the accountant
retain the audit workpapers and communications until the insurance department
has filed a report of examination covering the period of the audit but no
longer than seven (7) years from the date of the audit report.
B. In the conduct of the aforementioned
periodic review by the Insurance Department's examiners, it shall be agreed
that photocopies of pertinent audit workpapers may be made and retained by the
Department. Such reviews by the Department's examiners shall be considered
investigations and all working papers and communications obtained during the
course of such investigations shall be afforded the same confidentiality as
other examination workpapers generated by the Department.
Section 14.
Requirements for Audit
Committees
This section shall not apply to foreign or alien insurers
licensed in this state or an insurer that is a SOX Compliant Entity or a direct
or indirect wholly-owned subsidiary of a SOX Compliant Entity.
A. The Audit Committee shall be directly
responsible for the appointment, compensation and oversight of the work of any
accountant, including resolution of disagreements between management and the
accountant regarding financial reporting, for the purpose of preparing or
issuing the Audited Financial Report or related work pursuant to this Rule.
Each accountant shall report directly to the Audit Committee.
B. Each member of the Audit Committee shall
be a member of the board of directors of the insurer or a member of the board
of directors of an entity elected pursuant to Sections 14(E) and
3(C).
C. In order to be considered
independent for purposes of this section, a member of the Audit Committee may
not, other than in his or her capacity as a member of the Audit Committee, the
board of directors, or any other board committee, accept any consulting,
advisory or other compensatory fee from the entity or be an affiliated person
of the entity or any subsidiary thereof However, if the law requires board
participation by otherwise non-independent members, that law shall prevail and
such members may participate in the Audit Committee and be designated as
independent for Audit Committee purposes, unless they are an officer or
employee of the insurer or one of its affiliates.
D. If a member of the Audit Committee ceases
to be independent for reasons outside the member's reasonable control, that
person, with notice by the responsible entity to the Commissioner, may remain
an Audit Committee member of the responsible entity until the earlier of the
next annual meeting of the responsible entity or one (1) year from the
occurrence of the event that caused the member to no longer be independent. The
responsible entity is the entity whose board of directors established the audit
committee.
E. To exercise the
election of the controlling person to designate the Audit Committee for
purposes of this Rule, the ultimate controlling person shall provide written
notice to the commissioners of the domiciliary states of the affected insurers.
Notification shall be timely made prior to the issuance of the statutory audit
report and include a description of the basis for the election. The election
can be changed through notice to the Commissioner by the insurer, which shall
include a description of the basis for the change. The election shall remain in
effect until rescinded.
F.
(1) The Audit Committee shall require the
accountant that performs an audit required by this Rule to timely report to the
Audit Committee in accordance with the requirements of SAS 61,
Communication with Audit Committees, or its replacement,
including:
(a) All significant accounting
policies and material permitted practices;
(b) All material alternative treatments of
financial information within statutory accounting principles that have been
discussed with management officials of the insurer, ramifications of the use of
the alternative disclosures and treatments, and the treatment preferred by the
accountant; and
(c) Other material
written communications between the accountant and the management of the
insurer, such as any management letter or schedule of unadjusted
differences.
(2) If an
insurer is a member of an insurance holding company system, the reports
required by Section 7(F)(1) may be provided to the Audit Committee on an
aggregate basis for insurers in the holding company system, provided that any
substantial differences among insurers in the system are identified to the
Audit Committee.
G. The
proportion of independent Audit Committee members shall meet or exceed the
following criteria based on prior calendar year direct written and assumed
premiums, which shall be the combined total of direct premiums and assumed
premiums from non-affiliates for the reporting entities:
(1) An insurer with prior calendar year
direct written and assumed premiums of up to $300,000,000 is not subject to
minimum requirements.
(2) A
majority (50% or more) of the members shall be independent with regard to an
insurer with prior calendar year direct written and assumed premiums of between
$300,000,000 and $500,000,000.
(3)
All insurers with less than $500,000,000 in prior year direct written and
assumed premiums are encouraged to structure their Audit Committees with at
least a supermajority (75% or more) of independent Audit Committee
members.
(4) A supermajority of the
members shall be independent with regard to an insurer with prior calendar year
direct written and assumed premiums in excess of $500,000,000.
H. The Commissioner has authority
afforded by state law to require the entity's board to enact improvements to
the independence of the Audit Committee membership if the insurer is in a RBC
action level event, meets one or more of the standards of an insurer deemed to
be in hazardous financial condition, or otherwise exhibits qualities of a
troubled insurer.
I. Excluding
premiums reinsured with the Federal Crop Insurance Corporation and Federal
Flood Program, an insurer with direct written and assumed premium of less than
$500,000,000 may make application to the Commissioner for a waiver from the
Section 14 requirements based upon hardship. If the waiver is approved, the
insurer shall file, with its annual statement filing, the approval for relief
from Section 14 with the states in which it is licensed or doing business and
the NAIC. If the nondomestic states accept electronic filing with the NAIC, the
insurer shall file the approval in an electronic format acceptable to the
NAIC.
Section 15.
Conduct of Insurer in Connection with the Preparation of Required Reports and
Documents
A. No director or officer of
an insurer shall, directly or indirectly:
(1)
Make or cause to be made a materially false or misleading statement to an
accountant in connection with any audit, review or communication required under
this Rule; or
(2) Omit to state, or
cause another person to omit to state, any material fact necessary in order to
make statements made, in light of the circumstances under which the statements
were made, not misleading to an accountant in connection with any audit, review
or communication required under this Rule.
B. No officer or director of an insurer, or
any other person acting under the direction thereof shall directly or
indirectly take any action to coerce, manipulate, mislead or fraudulently
influence any accountant engaged in the performance of an audit pursuant to
this Rule if that person knew or should have known that the action, if
successfull, could result in rendering the insurer's financial statements
materially misleading.
C. For
purposes of Section 15(B), actions that "if successful, could result in
rendering the insurer's financial statements materially misleading" include,
but are not limited to, actions taken at any time with respect to the
professional engagement period to coerce, manipulate, mislead or fraudulently
influence an accountant:
(1) To issue or
reissue a report on an insurer's financial statements that is not warranted
under the circumstances due to material violations of statutory accounting
principles prescribed by the Commissioner, generally accepted auditing
standards, or other professional or regulatory standards;
(2) Not to perform audit, review or other
procedures required by generally accepted auditing standards or other
professional standards;
(3) Not to
withdraw an issued report; or
(4)
Not to communicate matters to an insurer's Audit Committee.
Section 16.
Management's Report of Internal Control Over Financial Reporting
A. Every insurer required to file an Audited
Financial Report pursuant to this Rule that has annual direct written and
assumed premiums, excluding premiums reinsured with the Federal Crop Insurance
Corporation and Federal Flood Program, of $500,000,000 or more shall prepare a
report of the insurer's or group of insurers' Internal Control Over Financial
Reporting, as these terms are defined in Section 3. The report shall be filed
with the Commissioner along with the Communication of Internal Control Related
Matters Noted in an Audit described under Section 11. Management's Report of
Internal Control Over Financial Reporting shall be as of December 31
immediately preceding.
B.
Notwithstanding the premium threshold in Section 16(A), the Commissioner may
require an insurer to file Management's Report of Internal Control Over
Financial Reporting if the insurer is in any RBC level event, or meets any one
or more of the standards of an insurer deemed to be in a hazardous financial
condition as defined in Ark. Code Ann. §
23-68-102
and Department Rule 53.
C. An
insurer or a group of insurers that is:
(1)
directly subject to SOX Section 404;
(2) part of a holding company system whose
parent is directly subject to SOX Section 404;
(3) not directly subject to SOX Section 404
but is a SOX Compliant Entity; or
(4) a member of a holding company system
whose parent is not directly subject to SOX Section 404 but is a SOX Compliant
Entity; may file its or its parent's SOX Section 404 Report and an addendum in
satisfaction of this Section 16 requirement provided that those internal
controls of the insurer or group of insurers having a material impact on the
preparation of the insurer's or group of insurers' audited statutory financial
statements (those items included in Sections 5(B) through 5(G) of this Rule)
were included in the scope of the SOX Section 404 Report. The addendum shall be
a positive statement by management that there are no material processes with
respect to the preparation of the insurer's or Group of insurers' audited
statutory financial statements (those items included in Sections 5(B) through
5(G) of this Rule) excluded from the SOX Section 404 Report. If there are
internal controls of the insurer or group of insurers that have a material
impact on the preparation of the insurer's or group of insurers' audited
statutory financial statements and those internal controls were not included in
the scope of the SOX Section 404 Report, the insurer or group of insurers may
either file (i) a Section 16 report, or (ii) the SOX Section 404 Report and a
Section 16 report for those internal controls that have a material impact on
the preparation of the insurer's or group of insurers' audited statutory
financial statements not covered by the SOX Section 404 Report.
D. Management's Report of Internal
Control Over Financial Reporting shall include:
(1) A statement that management is
responsible for establishing and maintaining adequate Internal Control Over
Financial Reporting;
(2) A
statement that management has established Internal Control Over Financial
Reporting and an assertion, to the best of management's knowledge and belief
after diligent inquiry, as to whether its Internal Control Over Financial
Reporting is effective to provide reasonable assurance regarding the
reliability of financial statements in accordance with statutory accounting
principles;
(3) A statement that
briefly describes the approach or processes by which management evaluated the
effectiveness of its Internal Control Over Financial Reporting;
(4) A statement that briefly describes the
scope of work that is included and whether any internal controls were
excluded;
(5) Disclosure of any
un-remediated material weaknesses in the Internal Control Over Financial
Reporting identified by management as of December 31 immediately preceding.
Management is not permitted to conclude that the Internal Control Over
Financial Reporting is effective to provide reasonable assurance regarding the
reliability of financial statements in accordance with statutory accounting
principles if there are one or more un-remediated material weaknesses in its
Internal Control Over Financial Reporting;
(6) A statement regarding the inherent
limitations of internal control systems; and
(7) Signatures of the chief executive officer
and the chief financial officer (or equivalent position).
E. Management shall document and make
available upon financial condition examination the basis upon which its
assertions, required in Section 16(D), are made. Management may base its
assertions, in part, upon its review, monitoring and testing of internal
controls undertaken in the normal course of its activities. Management shall
have discretion as to the nature of the internal control framework used, and
the nature and extent of documentation, in order to make its assertion in a
cost effective manner and, as such, may incorporate or reference existing
documentation.
F. Management's
Report on Internal Control Over Financial Reporting, required by Section 16(A),
and any documentation provided in support thereof during the course of a
financial condition examination, shall be kept confidential by the state
insurance department.
Section
17.
Exemptions and Effective Dates
A. Upon written application of any insurer,
the Commissioner may grant an exemption from compliance with any and all
provisions of this Rule if the Commissioner finds, upon review of the
application, that compliance with this Rule would constitute a financial or
organizational hardship upon the insurer. An exemption may be granted at any
time and from time to time for a specified period or periods. Within ten (10)
days from a denial of an insurer's written request for an exemption from this
Rule, the insurer may request in writing a hearing on its application for an
exemption. The hearing shall be held in accordance with the Arkansas
Administrative Procedure Act, Ark. Code Ann. §§
25-15-201,
et seq., and Ark. Code Ann. §§
23-61-303
through 305.
B. Domestic insurers
retaining a certified public accountant on the effective date of this Rule who
qualify as independent shall comply with this Rule for the year ending December
31, 2010 and each year thereafter unless the Commissioner permits
otherwise.
C. Domestic insurers not
retaining a certified public accountant on the effective date of this Rule who
qualifies as independent may meet the following schedule for compliance unless
the Commissioner permits otherwise:
(1) As of
December 31, 2010, file with the Commissioner an Audited Financial Report;
and
(2) For the year ending
December 31, 2010 and each year thereafter, such insurers shall file with the
Commissioner all reports and communication required by this Rule.
D. Foreign insurers shall comply
with this Rule for the year ending December 31, 2010 and each year thereafter,
unless the Commissioner permits otherwise.
E. The requirements of Section 7(D) shall be
in effect for audits of the year beginning January 1, 2010 and
thereafter.
F. The requirements of
Section 14 are to be in effect January 1, 2010. An insurer or group of insurers
that is not required to have independent Audit Committee members or only a
majority of independent Audit Committee members (as opposed to a supermajority)
because the total written and assumed premium is below the threshold and
subsequently becomes subject to one of the independence requirements due to
changes in premium shall have one (1) year following the year the threshold is
exceeded (but not earlier than January 1, 2010) to comply with the independence
requirements. Likewise, an insurer that becomes subject to one of the
independence requirements as a result of a business combination shall have one
(1) calendar year following the date of acquisition or combination to comply
with the independence requirements.
G. The requirements of Section 16 are
effective beginning with the reporting period ending December 31, 2010 and each
year thereafter. An insurer or group of insurers that is not required to file a
report because the total written premium is below the threshold and
subsequently becomes subject to the reporting requirements shall have two (2)
years following the year the threshold is exceeded (but not earlier than
December 31, 2010) to file a report. Likewise, an insurer acquired in a
business combination shall have two (2) calendar years following the date of
acquisition or combination to comply with the reporting requirements.
Section 18.
Canadian and
British Companies
A. In the case of
Canadian and British insurers, the annual Audited Financial Report shall be
defined as the annual statement of total business on the form filed by such
companies with their supervisory authority duly audited by an independent
chartered accountant.
B. For such
insurers, the letter required in Section 6(B) shall state that the accountant
is aware of the requirements relating to the annual Audited Financial Report
filed with the Commissioner pursuant to Section 4 and shall affirm that the
opinion expressed is in conformity with those requirements.
Section 19.
Severability
Provision
If any section or portion of a section of this Rule or its
applicabilty to any person or circumstance is held invalid by a court, the
remainder of the Rule or the applicability of the provision to other persons or
circumstances shall not be affected.