Current through Reg. 50, No. 187; September 24, 2024
The corporate governance annual disclosure filed in
accordance with Section
628.8015, F.S., must
describe:
(1) The insurer's or
insurance group's corporate governance framework and structure including
consideration of the following:
(a) The Board
of Directors ("Board") and various committees thereof ultimately responsible
for overseeing the insurer or insurance group and the level(s) at which that
oversight occurs, including ultimate control level, intermediate holding
company, and legal entity. The insurer or insurance group shall describe and
discuss the rationale for the current Board size and structure; and
(b) The duties of the Board and each of its
significant committees and how they are governed, including the bylaws,
charters, and informal mandates, as well as how the Board's leadership is
structured, including a discussion of the roles of Chief Executive Officer and
Chairman of the Board within the organization.
(2) The policies and practices of the most
senior governing entity and significant committees thereof, including a
discussion of the following factors:
(a) How
the qualifications, expertise and experience of each Board member meet the
needs of the insurer or insurance group;
(b) How an appropriate amount of independence
is maintained on the Board and its significant committees.;
(c) The number of meetings held by the Board
and its significant committees over the past year as well as information on
director attendance.; and
(d) How
the insurer or insurance group identifies, nominates, and elects members to the
Board and its committees. The discussion should include:
1. Whether a nomination committee is in place
to identify and select individuals for consideration,
2. Whether term limits are placed on
directors,
3. How the election and
re-election processes function,
4.
Whether a Board diversity policy is in place and if so, how it functions,
and
5. The processes in place for
the Board to evaluate its performance and the performance of its committees, as
well as any recent measures taken to improve performance and any Board or
committee training programs that have been put in
place).
(3) The
policies and practices for directing senior management, including a description
of the following factors:
(a) Any processes or
practices, including suitability standards, to determine whether officers and
key persons in control functions have the appropriate background, experience
and integrity to fulfill their prospective roles, including:
1. Identification of the specific positions
for which suitability standards have been developed and a description of the
standards employed, and
2. Any
changes in an officer's or key person's suitability as outlined by the
insurer's or insurance group's standards and procedures to monitor and evaluate
such changes;
(b) The
insurer's or insurance group's code of business conduct and ethics, the
discussion of which considers:
1. Compliance
with laws, rules, and regulations, and
2. Proactive reporting of any illegal or
unethical behavior;
(c)
The insurer's or insurance group's processes for performance evaluation,
compensation and corrective action to ensure effective senior management
throughout the organization, including a description of the general objectives
of significant compensation programs and what the programs are designed to
reward. The description shall include sufficient detail to allow the Office to
understand how the organization ensures that compensation programs do not
encourage and/or reward excessive risk taking. Elements to be discussed may
include:
1. The Board's role in overseeing
management compensation programs and practices,
2. The various elements of compensation
awarded in the insurer's or insurance group's compensation programs and how the
insurer or insurance group determines and calculates the amount of each element
of compensation paid,
3. How
compensation programs are related to both company and individual performance
over time,
4. Whether compensation
programs include risk adjustments and how those adjustments are incorporated
into the programs for employees at different levels,
5. Any clawback provisions built into the
programs to recover awards or payments if the performance measures upon which
they are based are restated or otherwise adjusted, and
6. Any other factors relevant in
understanding how the insurer or insurance group monitors its compensation
policies to determine whether its risk management objectives are met by
incentivizing its employees; and
(d) The insurer's or insurance group's plans
for the Chief Executive Officer and senior management
succession.
(4) The
insurer or insurance group shall describe the processes by which the Board, its
committees, and senior management ensure an appropriate amount of oversight to
the critical risk areas impacting the insurer's business activities, including
a discussion of:
(a) How oversight and
management responsibilities are delegated between the Board, its committees and
senior management;
(b) How the
Board is kept informed of the insurer's strategic plans, the associated risks,
and steps that senior management is taking to monitor and manage those
risks;
(c) How reporting
responsibilities are organized for each critical risk area. The description
should allow the Office to understand the frequency at which information on
each critical risk area is reported to and reviewed by senior management and
the Board. This description may include the following critical risk areas of
the insurer:
1. Risk management processes. An
ORSA summary report filer may refer to its ORSA summary report,
2. Actuarial function,
3. Investment decision-making
processes,
4. Reinsurance
decision-making processes,
5.
Business strategy/finance decision-making processes,
6. Compliance function,
7. Financial reporting/internal auditing,
and
8. Market conduct
decision-making processes.
Rulemaking Authority 624.308(1), 628.8015(6) FS. Law
Implemented 624.307(1), 628.8015 FS.
New 1-3-21.