Another issue that insurers have to consider is the potential impact these measures will have on their financial statements, including admitted asset treatment for premium receivables and proper accounting for premium refunds. Typically, premium receivables more than 90 days past due are not eligible for admitted asset treatment on an insurer’s statutory financial statements. However, the NAIC Statutory Accounting Principles (E) Working Group has issued interpretive guidance (INT 20-02
) temporarily extending the “90-day rule” through September 29, 2020, for policies that were current prior to March 13, 2020 (the date the US federal government declared a state of emergency). The Working Group has also issued five additional proposals for COVID-19-related accounting guidance
, which were exposed for public comment through May 1, 2020. With respect to accounting treatment for premium refunds, proposed INT 20-08T provides that premium refunds that are outside of policy terms should be reported as a reduction of premium (and not as an expense.)
II. NAIC Data Call on BI Coverage
Following separate information requests from California, New York, and Washington, the NAIC has issued a data call to all US property/casualty insurers that wrote BI coverage in the US in 2019 or 2020. The data call is intended to assist state insurance regulators in analyzing “the financial condition of commercial insurers to understand which insurers are writing business interruption coverage, the size of the market, the extent of exclusions related to COVID-19, and claims and losses related to COVID-19.” The data call includes both admitted and non-admitted domestic insurers, but does not include alien insurers, life or health insurers, monoline financial guaranty, mortgage guaranty, title, fidelity, non-medical professional liability insurers, or reinsurers. It follows a request from NAIC President, Director Ray Farmer (SC) that states refrain from issuing separate information requests on BI coverage issues until the NAIC could prepare a single, nationwide data call.