SSAP 101 Guidance for 2012 Quarterly Notes Reporting

The NAIC posted new guidance this afternoon for implementing the provisions of SSAP 101 in the 2012 Quarterly Statements Note 9A. The document is available for download from the Blanks Working Group website and should serve as your guide in completing the Note 9A data entry piece and printed disclosures. Review the Guidance document before completing your Notes disclosures and you should be able to match up the printed disclosures with the data entry piece.

I did notice that Note 9.A.1. was not addressed in the document and is one of the significant differences between SSAP 10R and SSAP 101. To match up your data entry disclosures with the SSAP 101 disclosures on your printed Notes page complete Note 9A1A through 9A1G per the table below. Basically, you need to flip DTA Nonadmitted with Deferred Tax Liabilities. Remember that the Prior Year amounts will also need to be flipped.

Illustration Reference #

SSAP No. 10R Reference

Data Capture 2012QS

SSAP No. 101 Reference

Printed Notes

9A1A Gross Deferred Tax Assets Gross Deferred Tax Assets
9A1B Statutory Valuation Allowance Statutory Valuation Allowance
9A1C Adj. Gross DTA (1a – 1b) Adj. Gross DTA (1a – 1b)
9A1D Deferred Tax Liabilities Deferred Tax Assets Nonadmitted
9A1E Subtotal Net DTA/(DTL)

(1c – 1d)

Subtotal Net Admitted DTA

(1c – 1d)

9A1F DTA Nonadmitted Deferred Tax Liabilities
9A1G Net Admitted DTA/(Net DTL)

(1e – 1f)

Net Admitted DTA/(Net DTL)

(1e – 1f)

The Guidance Document points out that Note 9A2 and 9A3 are no longer applicable but these parts are not data captured anyway. Note 9A4 is data captured, however; and should be completed per the Guidance. The Guidance provides a table for Note 9A4A through 9A4N illustrating where the SSAP 101 amounts should be entered in the data entry piece. Things match up pretty well until we come to note 9A4M, Total Adjusted Capital in SSAP 10R and the 2012 QS data entry piece. This is where we are to enter the “ExDTA ACL RBC Ratio, ExDTA Surplus/ Policyholders and Contingency Reserves Ratio, or the Adjusted Gross DTA/Adjusted Capital and Surplus Ratio, as applicable”. This may present a problem as the NAIC 2012 Quarterly data base is expecting a whole dollar amount in this field but the new Guidance is telling us to provide a percentage or ratio amount. Just be aware that your software vendor is not going to be able to flip the dollar field to a percent field without issuing an update which is what this whole exercise by the NAIC is trying to avoid (the NAIC does not want to update their database this late in the game so we are stuck with this one). Lastly, the disclosures for Note 9A5 are unchanged and Note 9A6 is no longer applicable and goes away.

Let me know if you have any questions by contacting me or sharing your thoughts hear. This is only one piece of the SSAP 101 puzzle so all questions on this topic are welcome.

Randy Hefel

Regulatory Accountant & NAIC Liaison, Wings Plus Annual Statement To see a video interview with Randy, please click here.

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1 comment
  1. Randy Hefel says:

    The NAIC has informed me that Note 9A1 can be completed in the PDF and the data capture per SSAP 10R for the 2012 Quarterly Statement. This would mean following the 2011 Annual Statement reporting requirements for [b]only Note 9A1[/b]. The NAIC feels this will avoid confusion when querying the NAIC database. Hopefully, filers and users of the statements will not find it confusing.

    Reply

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