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    OpenPayerPolicy UpdatesAdministrative/Operational PolicyDelaware DOI filing deadline extensions | OpenPaye…
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    CurrentDelaware Department of InsurancePolicy 118

    Compliance with Regulatory Filing Requirements During the COVID-19 (Coronavirus) Crisis

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    Guidance allowing domestic and foreign insurers transacting in Delaware to request 30- or 60-day extensions for specified regulatory filing deadlines during the COVID-19 public health emergency; applies to insurers subject to Delaware Department of Insurance oversight.

    Policy Summary
    PayerDelaware Department of Insurance
    PolicyCompliance with Regulatory Filing Requirements During the COVID-19 (Coronavirus) Crisis
    Policy CodePolicy 118
    Change TypeInformational bulletin
    Effective DateApr 9, 2020
    Next Review Date
    Key ActionInsurers must request filing deadline extensions by emailing David Lonchar at dave.lonchar@delaware.gov.
    SourceLink
    POLICY UPDATE CHANGES

    No material clinical or coverage changes in this revision.

    30-day30-day extension
    60-day60-day extension
    NAIC requiredNAIC filings still required
    email request to DeptRequest method

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    Extension eligibility and exceptions

    Extension eligibility and exceptions

    Filings eligible for extensions and any applicable exceptions or conditions:

    Filings eligible for extensions are grouped by extension length; companies must request extensions via email to the Director of the Bureau of Company Examination, Rehabilitation & Guaranty (dave.lonchar@delaware.gov). The Department may deny requests based on the company’s financial condition or unique circumstances; regardless of granted extensions, companies must still make required NAIC electronic filings per NAIC deadlines.

    One of the following extension groups applies

    • 30-day extension list

      • Combined Annual Statement Filing (Property) — original deadline April 1, 2020; extended deadline May 1, 2020.
      • Combined Insurance Expense Exhibit (Property) — original deadline April 1, 2020; extended deadline May 1, 2020.
      • Accountant's Letter of Qualifications (Property, Life/Fraternal, Health) — original deadline May 1, 2020; extended deadline June 1, 2020.
      • PBR Exemption filing (Life/Fraternal) — original deadline July 15, 2020; extended deadline August 15, 2020 (note: PBR exemption references state and NAIC timing as described in the bulletin).

    • 60-day extension list

      • Audited Financial Report (Property, Life/Fraternal, Health) — original deadline June 1, 2020; extended deadline August 1, 2020.
      • Communication of Internal Control Related Matters Noted in Audit (Property, Life/Fraternal, Health) — original deadline August 1, 2020; extended deadline October 1, 2020.
      • Corporate Governance Annual Disclosure — original deadline June 1, 2020; extended deadline August 1, 2020.
      • Form B Registration Statement & Related Form C — original deadline June 1, 2020; extended deadline August 1, 2020.
      • Risk Assessment Report (Form F) — original deadline June 1, 2020; extended deadline August 1, 2020.

    • Additional 30-day extensions for certain NAIC quarterly electronic filings

      • Selected NAIC quarterly electronic filings due May 15, 2020 may be extended for 30 days (examples in the bulletin include specified actuarial memoranda and internal control reports).

    • Components of 2019 annual filings

      • Certain components of 2019 annual filings, where applicable, should be submitted only to an insurer’s state of domicile (no Delaware state-wide extension specified for those components).

    Operational note: To request an extension an insurer must email dave.lonchar@delaware.gov; the Department reserves discretion to deny requests based on company-specific financial condition and circumstances. NAIC electronic filings (e.g., quarterly and audited financial statements) must still be submitted according to NAIC deadlines regardless of any state extension.

    Specified filings, deadlines, and extension lengths

    30-day extension filingsmixed
    Combined Annual Statement Filing (Property)Original deadline: April 1, 2020; Extended deadline: May 1, 2020
    Combined Insurance Expense Exhibit (Property)Original deadline: April 1, 2020; Extended deadline: May 1, 2020
    Accountant's Letter of Qualifications (Property, Life/Fraternal, Health)Original deadline: May 1, 2020; Extended deadline: June 1, 2020
    PBR Exemption filing (Life/Fraternal)Original deadline: July 15, 2020; Extended deadline: August 15, 2020
    60-day extension filingsmixed
    Audited Financial Report (Property, Life/Fraternal, Health)Original deadline: June 1, 2020; Extended deadline: August 1, 2020
    Communication of Internal Control Related Matters Noted in Audit (Property, Life/Fraternal, Health)Original deadline: August 1, 2020; Extended deadline: October 1, 2020
    Corporate Governance Annual DisclosureOriginal deadline: June 1, 2020; Extended deadline: August 1, 2020
    Form B Registration Statement & Related Form COriginal deadline: June 1, 2020; Extended deadline: August 1, 2020
    Risk Assessment Report (Form F)Original deadline: June 1, 2020; Extended deadline: August 1, 2020
    Quarterly electronic filings (selected NAIC filings due May 15, 2020)Examples include Actuarial Memorandum required by Actuarial Guideline XXXVIII (8D) — Original deadline March 30, 2020; Extended deadline April 30, 2020; Management's Report of Internal Control Over Financial Reporting (8D) — Original deadlines July 1, 2020; Extended deadlines August 1, 2020; and various actuarial/certification supplements with original/extended quarter-end dates as noted in Bulletin
    Other quarterly/statement supplements and actuarial certificationsVarious quarterly statement filings, supplements (e.g., Trusteed Surplus Statement Supplement A to Schedule T, Medicare Part D Coverage Supplement), and actuarial certifications/assumption validations with original quarter-end dates of March 31, 2020 and extended deadlines as detailed in Bulletin
    Director and Officer Insurance Coverage Supplement (Property)Original quarter-end: March 31, 2020; Extended quarter-end: March 31, 2020 (as listed among quarterly filings)
    Notesmixed
    Component filings to state of domicileCertain components of 2019 annual filings should be submitted only to an insurer's state of domicile, if applicable.
    inv-03: Extension length — 30 or 60 days depending on filing type
    Extension lengths30 days for certain filings (see 30-day list) or 60 days for other filings (see 60-day list)
    30-day examplesCombined Annual Statement Filing (Property) extended from April 1, 2020 to May 1, 2020; Accountant's Letter of Qualifications extended from May 1, 2020 to June 1, 2020
    60-day examplesAudited Financial Report extended from June 1, 2020 to August 1, 2020; Corporate Governance Annual Disclosure extended from June 1, 2020 to August 1, 2020

    How to request a filing extension

    Prior Authorization

    Request filing deadline extension via email to Director

    An insurer who believes it will be unable to meet required financial filing deadlines must request a filing deadline extension by emailing David Lonchar, Director of the Bureau of Company Examination, Rehabilitation & Guaranty, at dave.lonchar@delaware.gov; the Department may reject requests based on the company’s financial condition and unique circumstances.

    Key terms and required filings

    inv-05: Insurer-initiated extension request — definition/description
    DefinitionAn insurer-initiated email to the Director of the Bureau of Company Examination, Rehabilitation & Guaranty (David Lonchar) requesting additional time to meet statutory or ordered filing deadlines.
    Submission methodSubmit request by sending an email to dave.lonchar@delaware.gov
    Department discretionThe Department may reject any filing deadline extension request based upon the financial condition and unique circumstances of the applicant company.
    inv-06: Required electronic filings — NAIC electronic filings that must still be submitted per NAIC deadlines
    RequirementCompanies must still make all required electronic filings with the NAIC in accordance with NAIC filing deadlines (e.g., quarterly financial statements, audited financial statements).
    Examples
    Policy Summary
    PayerDelaware Department of Insurance
    PolicyCompliance with Regulatory Filing Requirements During the COVID-19 (Coronavirus) Crisis
    Policy CodePolicy 118
    Change TypeInformational bulletin
    Effective DateApr 9, 2020
    Next Review Date
    Key ActionInsurers must request filing deadline extensions by emailing David Lonchar at dave.lonchar@delaware.gov.
    SourceLink
    On This Page
    Extension eligibility and exceptionsSpecified filings, deadlines, and extension lengthsHow to request a filing extensionKey terms and required filings
    Quarterly financial statements and audited financial statements are specifically noted as required NAIC electronic filings.
    Effect of state extensionA Delaware-granted state extension does not relieve the insurer of its obligation to submit NAIC electronic filings on NAIC deadlines.