Current through Register Vol. 41, No. 3, September 23, 2024
A. When a ceding insurer takes credit
pursuant to subdivision 2 of § 38.2-1316.4 of the Act for reinsurance
transactions secured by funds held in trust, the underlying trust agreement
shall meet the following conditions:
1. The
trust agreement shall be entered into between the beneficiary, the grantor and
a trustee which shall be a qualified United States financial institution, as
those terms are defined in this chapter.
2. The trust agreement shall create a trust
account into which assets shall be deposited.
3. All assets in the trust account shall be
held by the trustee at the trustee's office in the United States.
4. The trust agreement shall provide that:
a. The beneficiary shall have the right to
withdraw assets from the trust account at any time, without notice to the
grantor, subject only to written notice from the beneficiary to the
trustee;
b. No other statement or
document is required to be presented in order to withdraw assets, except that
the beneficiary may be required to acknowledge receipt of withdrawn
assets;
c. It is not subject to any
conditions or qualifications outside of the trust agreement; and
d. It shall not contain references to any
other agreements or documents except as provided for under subdivisions 11 and
12 of this subsection.
5. The trust agreement shall be established
for the sole benefit of the beneficiary.
6. The trust agreement shall require the
trustee to:
a. Receive assets and hold all
assets in a safe place;
b.
Determine that all assets are in such form that the beneficiary, or the trustee
upon direction by the beneficiary, may whenever necessary negotiate any such
assets, without consent or signature from the grantor or any other person or
entity;
c. Furnish to the grantor
and the beneficiary a statement of all assets in the trust account upon its
inception and at intervals no less frequent than the end of each calendar
quarter;
d. Notify the grantor and
the beneficiary, within 10 days, of any deposits to or withdrawals from the
trust account;
e. Upon written
demand of the beneficiary, immediately take any and all steps necessary to
transfer absolutely and unequivocally all right, title and interest in the
assets held in the trust account to the beneficiary and deliver physical
custody of such assets to such beneficiary; and
f. Allow no substitutions or withdrawals of
assets from the trust account, except on written instructions from the
beneficiary, except that the trustee may, without the consent of but with
notice to the beneficiary, upon call or maturity of any trust asset, withdraw
such asset upon condition that the proceeds are paid into the trust
account.
7. The trust
agreement shall provide that at least 30 days, but not more than 45 days, prior
to termination of the trust account, written notification of termination shall
be delivered by the trustee to the beneficiary.
8. The trust agreement shall be made subject
to and governed by the laws of the state in which the trust is
established.
9. The trust agreement
shall prohibit invasion of the trust corpus for the purpose of paying
compensation to, or reimbursing the expenses of, the trustee. In order for a
letter of credit to qualify as an asset of the trust, the trustee shall have
the right and the obligation pursuant to the deed of trust or some other
binding agreement (as duly approved by the commission), to immediately draw
down the full amount of the letter of credit and hold the proceeds in trust for
the beneficiaries of the trust if the letter of credit will otherwise expire
without being renewed or replaced.
10. The trust agreement shall provide that
the trustee shall be liable for its negligence, willful misconduct, or lack of
good faith. The failure of the trustee to draw against the letter of credit in
circumstances where such draw would be required shall be deemed to be
negligence or willful misconduct, or both.
11. Notwithstanding other provisions of this
chapter, when a trust agreement is established in conjunction with a
reinsurance agreement covering risks other than life, annuities, and accident
and health, where it is customary practice to provide a trust agreement for a
specific purpose, the trust agreement may provide that the ceding insurer shall
undertake to use and apply amounts drawn upon the trust account, without
diminution because of the insolvency of the ceding insurer or the assuming
insurer, only for the following purposes:
a.
To pay or reimburse the ceding insurer for the assuming insurer's share under
the specific reinsurance agreement regarding any losses and allocated loss
expenses paid by the ceding insurer, but not recovered from the assuming
insurer, or for unearned premiums due to the ceding insurer if not otherwise
paid by the assuming insurer;
b. To
make payment to the assuming insurer of any amounts held in the trust account
that exceed 102% of the actual amount required to fund the assuming insurer's
obligations under the specific reinsurance agreement; or
c. Where the ceding insurer has received
notification of termination of the trust account and where the assuming
insurer's entire obligations under the specific reinsurance agreement remain
unliquidated and undischarged 10 days prior to the termination date, to
withdraw amounts equal to the obligations and deposit those amounts in a
separate account, in the name of the ceding insurer in any qualified United
States financial institution as defined in § 38.2-1316.1 of the Act apart
from its general assets, in trust for such uses and purposes specified in
subdivisions 11 a and b of this subsection as may remain executory after such
withdrawal and for any period after the termination date.
12. Notwithstanding other provisions of this
chapter, when a trust agreement is established to meet the requirements of
14VAC5-300-110 in conjunction with
a reinsurance agreement covering life, annuities or accident and health risks,
where it is customary to provide a trust agreement for a specific purpose, the
trust agreement may provide that the ceding insurer shall undertake to use and
apply amounts drawn upon the trust account, without diminution because of the
insolvency of the ceding insurer or the assuming insurer, only for the
following purposes:
a. To pay or reimburse the
ceding insurer for:
(1) The assuming
insurer's share under the specific reinsurance agreement of premiums returned,
but not yet recovered from the assuming insurer, to the owners of policies
reinsured under the reinsurance agreement on account of cancellations of the
policies; and
(2) The assuming
insurer's share under the specific reinsurance agreement of surrenders and
benefits or losses paid by the ceding insurer, but not yet recovered from the
assuming insurer, under the terms and provisions of the policies reinsured
under the reinsurance agreement;
b. To pay to the assuming insurer amounts
held in the trust account in excess of the amount necessary to secure the
credit or reduction from liability for reinsurance taken by the ceding insurer;
or
c. Where the ceding insurer has
received notification of termination of the trust and where the assuming
insurer's entire obligations under the specific reinsurance agreement remain
unliquidated and undischarged 10 days prior to the termination date, to
withdraw amounts equal to the assuming insurer's share of liabilities, to the
extent that the liabilities have not yet been funded by the assuming insurer,
and deposit those amounts in a separate account, in the name of the ceding
insurer in any qualified United States financial institution apart from its
general assets, in trust for the uses and purposes specified in subdivisions 12
a and b of this subsection as may remain executory after withdrawal and for any
period after the termination date.
13. Either the reinsurance agreement or the
trust agreement shall stipulate that assets deposited in the trust account
shall be valued according to their current fair market value and shall consist
only of cash in United States dollars, certificates of deposit issued by a
United States bank and payable in United States dollars, and investments
permitted by the Code of Virginia or any combination of the above, provided
investments in or issued by an entity controlling, controlled by or under
common control with either the grantor or the beneficiary of the trust shall
not exceed 5.0% of total investments. The agreement may further specify the
types of investments to be deposited. If the reinsurance agreement covers life,
annuities or accident and health risks, then the provisions required by this
subdivision shall be included in the reinsurance agreement.
B. When a ceding insurer seeks
credit pursuant to subdivision 2 of § 38.2-1316.4 for reinsurance
transactions secured by funds held in trust, the underlying trust agreement may
contain the following provisions subject to all conditions set forth:
1. The trust agreement may provide that the
trustee may resign upon delivery of a written notice of resignation, effective
not less than 90 days after receipt by the beneficiary and grantor of the
notice and that the trustee may be removed by the grantor by delivery to the
trustee and the beneficiary of a written notice of removal, effective not less
than 90 days after receipt by the trustee and the beneficiary of the notice,
provided that no such resignation or removal shall be effective until a
successor trustee has been duly appointed and approved by the beneficiary and
the grantor and all assets in the trust have been duly transferred to the new
trustee.
2. The grantor may have
the full and unqualified right to vote any shares of stock in the trust account
and to receive from time to time payments of any dividends or interest upon any
shares of stock or obligations included in the trust account. Any such interest
or dividends shall be either forwarded promptly upon receipt to the grantor or
deposited in a separate account established in the grantor's name.
3. The trustee may be given authority to
invest, and accept substitutes of, any funds in the account, provided that no
investment or substitution shall be made without prior approval of the
beneficiary, unless the trust agreement specifies categories of investments
acceptable to the beneficiary and authorizes the trustee to invest such funds
and to accept such substitutions which the trustee determines are at least
equal in current fair market value to the assets withdrawn and that are
consistent with the restrictions in subdivision C 1 b of this
section.
4. The trust agreement may
provide that the beneficiary may at any time designate a party to which all or
part of the trust assets are to be transferred. Such transfer may be
conditioned upon the trustee receiving, prior to or simultaneously, other
specified assets.
5. The trust
agreement may provide that, upon termination of the trust account, all assets
not previously withdrawn by the beneficiary shall, with written approval by the
beneficiary, be delivered over to the grantor.
C. Conditions applicable to reinsurance
agreements entered into by a ceding insurer which takes credit pursuant to
subdivision 2 of § 38.2-1316.4 for reinsurance transactions secured by
funds held in trust.
1. The reinsurance
agreement may contain provisions that:
a.
Require the assuming insurer to enter into a trust agreement and to establish a
trust account for the benefit of the ceding insurer, and specifying what such
agreement is to cover;
b. Require
the assuming insurer, prior to depositing assets with the trustee, to execute
assignments or endorsements in blank, or to transfer legal title to the trustee
of all shares, obligations or any other assets requiring assignments, in order
that the ceding insurer, or the trustee upon the direction of the ceding
insurer, may whenever necessary negotiate any such assets without consent or
signature from the assuming insurer or any other entity;
c. Require that all settlements of account
between the ceding insurer and the assuming insurer be made in cash or its
equivalent; and
d. Stipulate that
the assuming insurer and the ceding insurer agree that the assets in the trust
account, established pursuant to the provisions of the reinsurance agreement,
may be withdrawn by the ceding insurer at any time, notwithstanding any other
provisions in the reinsurance agreement, and shall be utilized and applied by
the ceding insurer or its successors in interest by operation of law, including
without limitations any liquidator, rehabilitator, receiver or conservator of
such company, without diminution because of insolvency on the part of the
ceding insurer or the assuming insurer, only for the following purposes:
(1) To pay or reimburse the ceding insurer
for:
(a) The assuming insurer's share under
the specific reinsurance agreement of premiums returned, but not yet recovered
from the assuming insurer, to the owners of policies reinsured under the
reinsurance agreement because of cancellations of such policies;
(b) The assuming insurer's share of
surrenders and benefits or losses paid by the ceding insurer pursuant to the
provisions of the policies reinsured under the reinsurance agreement;
and
(c) Any other amounts necessary
to secure the credit or reduction from liability for reinsurance taken by the
ceding insurer; or
(2)
To make payment to the assuming insurer of amounts held in the trust account in
excess of the amount necessary to secure the credit or reduction from liability
for reinsurance taken by the ceding insurer.
2. The reinsurance agreement also may contain
provisions that:
a. Give the assuming insurer
the right to seek approval (which shall not be unreasonably or arbitrarily
withheld) from the ceding insurer to withdraw from the trust account all or any
part of the trust assets and transfer such assets to the assuming insurer,
provided:
(1) The assuming insurer shall, at
the time of such withdrawal, replace the withdrawn assets with other qualified
assets having a current fair market value equal to the market value of the
assets withdrawn so as to maintain at all times the deposit in the required
amount, or
(2) After such
withdrawal and transfer, the current fair market value of the trust account is
no less than 102% of the required amount.
b. Provide for the return of any amount
withdrawn in excess of the actual amounts required for subdivision C 1 d of
this section, and for interest payments, at a rate not in excess of the prime
rate of interest on such amounts.
c. Permit the award by any arbitration panel
or court of competent jurisdiction of:
(1)
Interest at a rate different from that provided in subdivision 2 b of this
subsection;
(2) Court or
arbitration costs;
(3) Attorney's
fees; and
(4) Any other reasonable
expenses.
D. With regard to financial reporting, a
trust agreement may be used to reduce any liability for reinsurance ceded to an
unauthorized assuming insurer in financial statements required to be filed with
the commission in compliance with the provisions of this chapter when
established on or before the date of filing of the financial statement of the
ceding insurer. Further, the reduction for the existence of an acceptable trust
account may be up to the current fair market value of acceptable assets
available to be withdrawn from the trust account at that time, but such
reduction shall be no greater than the specific obligations, as defined in this
chapter, under the reinsurance agreement that the trust account was established
to secure.
E. With regard to
existing agreements and notwithstanding the effective date of this chapter, any
trust agreement or underlying reinsurance agreement in existence prior to July
1, 2012, will continue to be acceptable until January 1, 2013, at which time
the agreements will have to be in full compliance with this chapter for the
trust agreement to be acceptable.
F. The failure of any trust agreement to
specifically identify the beneficiary as defined in
14VAC5-300-40 shall not be
construed to affect any actions or rights which the commission may take or
possess pursuant to the provisions of the laws of this Commonwealth.
§§ 38.2-223, 38.2-1316.7 and 12.1-13 of the Code
of Virginia.