Aon Benfield Analytics | Market Analysis Market Analysis Update: U.S. Collateral Reform Guide to 2016 Year-End Statutory Reporting December 2016 Risk. Reinsurance. Human Resources. Proprietary and Confidential Aon Benfield Analytics | Market Analysis Proprietary and Confidential Table of Contents Introduction 2 Disclaimer 2 2016 Regulatory Developments Related to U.S. Collateral Reform 3 Certified Reinsurers as a New Reporting Category 7 Multi-Beneficiary Trusts and their Impact on Statutory Reporting 8 Certified Reinsurer Reporting Concepts 12 Special Reporting Instructions for Recoverables from Lloyd’s Syndicates, Tokio Millennium, Endurance Specialty and Montpelier Reinsurance 16 Links to Individual State Instructions 24 Additional Guidance on Schedule F Reporting 25 Contacts 25 About Aon 25 Appendix I: 2016 State Specific Certified Reinsurer Reporting Instructions 26 Appendix II: The Credit for Reinsurance Model Law and Regulation 72 Appendix III: Changes to Schedule F to Accommodate Certified Reinsurers 75 Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 1 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Introduction The statutory reporting of reinsurance recoverables changed significantly in 2012 with the introduction of “certified” reinsurers and a new Part 6 of Schedule F. Previous to 2012, all reinsurance recoverables were reported as emanating from a reinsurer classified as “authorized” or “unauthorized”. With only three potential classes of reinsurers, one might assume that the statutory reporting of recoverables would be relatively straight-forward. However, there are numerous factors that may make the tracking and reporting of recoverables more convoluted, including: The treatment of certified reinsurer upgrades, downgrades, revocations or lapses The collateral deferral on recognized property catastrophe losses or named hurricanes The impact of certified reinsurers who use Multi-Beneficiary Trusts (MBTs) to collateralize recoverables The potential need to bifurcate collateral on Schedule F In short, recoverables from a single reinsurer may have to be split into more than one of the three classes depending upon the interplay of the above variables. With respect to the 2016 annual statutory statement, only ceding insurers domiciled in the 26 states where reinsurers have been certified are potentially impacted by the reporting requirements for certified reinsurers on the new Schedule F-Part 6. The purpose of this Market Analysis Update is to: 1. Provide an update on regulatory developments associated with the Credit for Reinsurance Model Law and Regulation 2. Provide ceding insurers with guidance on reporting recoverables emanating from certified reinsurers on the 2016 statutory annual statement Disclaimer Aon Benfield has compiled information from a number of public sources and has attempted only to summarize the information in order to help clarify certain issues which may impact statutory reporting conducted by the recipient. The information included in this document is from sources that we believe to be reliable, but whose accuracy and completeness cannot be guaranteed. The public sources include insurance department websites and correspondence with state insurance department staff, NAIC staff and reinsurers. This document is not intended to be an exhaustive guide or compilation of relevant principles and clients should undertake further research as needed before making statutory reporting decisions. Aon Benfield does not provide and this document does not constitute any form of legal, accounting, taxation, regulatory or actuarial advice, including but not limited to advice on the preparation of financial statements (including notes and schedules thereto). Ultimately, statutory reporting is regulated by each ceding insurer’s state of domicile and recipients are encouraged to contact their state insurance department to ensure proper statutory reporting. All recipients are also advised to consult their own professional advisers to undertake an independent assessment of any legal, accounting, taxation or regulatory implications of anything described in this document. This document is made available on an “as is” basis, without warranty of any kind, including with respect to the accuracy, completeness, timeliness or sufficiency of the information contained herein. Aon Benfield undertakes no obligation to update or revise this document based on changes, new developments or otherwise, nor any obligation to correct any errors or inaccuracies in this document. Aon Benfield and its affiliates shall not incur and hereby expressly disclaim any and all liability to any person or organization for loss or damage caused by, arising out of or resulting from any use or reliance of this document. Aon Benfield reserves all rights to the content of this document. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 2 Aon Benfield Analytics | Market Analysis Proprietary and Confidential 2016 Regulatory Developments Related to U.S. Collateral Reform The most important developments in 2016 related to collateral reform are: The Financial Regulation Standards and Accreditation Committee adopted the certified reinsurer provisions from the Model Law and Regulation as an accreditation requirement effective January 1, 2019 Representatives of the Treasury Department and U.S. Trade Representative have been attempting to negotiate a “covered agreement, which would likely preempt current state collateral requirements but potentially provide Solvency II equivalency for U.S. insurers and reinsurers operating in the EU Five additional states (Arizona, Arkansas, Nebraska, North Dakota and Washington) have started certifying reinsurers, Massachusetts has adopted the Credit for Reinsurance Model Regulation and three additional states (Oklahoma, Tennessee and Utah) have adopted the Credit for Reinsurance Model Law There are also some revisions to the Model Law that were adopted in early 2016 in response to reinsurance arrangements entered into, directly or indirectly, with life/health insurer-affiliated captives, special purpose vehicles or similar entities that may not have the same statutory accounting requirements or solvency requirements as US-based multi-state life/health insurers. Adoption of the Credit for Reinsurance Model Law & Regulation is Required for Accreditation When the Credit for Reinsurance Model Law and Regulation were adopted by the NAIC, non-U.S. reinsurers were pleased that collateral requirements and their costs would be reduced significantly. However, the pace of states adopting the Model Law and Regulation has been much slower than anticipated. In response to this, non-U.S. reinsurers began lobbying that the Credit for Reinsurance Model Law and Regulation be required for state accreditation. Below is a description of the NAIC accreditation program. The NAIC Accreditation Program was established to develop and maintain standards to promote effective insurance company financial solvency regulation. The purpose of the accreditation program is for state insurance departments to meet baseline standards of solvency regulation, particularly with respect to regulation of multi-state insurers. This creates substantial efficiencies for insurance regulators, who are then able to coordinate and rely on each other's work. It also creates far greater efficiencies for insurance companies licensed in accredited states, which are then not subject to financial examinations or other financial oversight by multiple jurisdictions. All fifty states, the District of Columbia and Puerto Rico are currently accredited In essence, this would compel states to adopt the Credit for Reinsurance Model Law and Regulation or lose their accreditation from the NAIC. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 3 Aon Benfield Analytics | Market Analysis Proprietary and Confidential However, when there appeared to be delays in making the adoption of the Model Law and Regulation an accreditation requirement, non-U.S. reinsurers began pushing for a federally negotiated “covered agreement” which could potentially preempt the state regulations. At the NAIC meeting in April 2016, the Financial Regulation Standards and Accreditation Committee adopted the certified reinsurer provisions from the Model Law and Regulation as an accreditation requirement. The certified reinsurer provisions are currently optional, but will become mandatory as of January 1, 2019 Update on the Covered Agreement Under Dodd-Frank, the Treasury Department and the Office of the U.S. Trade Representative are empowered to bind the U.S. into an agreement on insurance supervision. The motivation for entering into a bilateral agreement with the EU is to ensure that U.S. companies operating in the EU get equal treatment to EU domiciled companies. During 2016, some EU regulators (e.g. Austria, Belgium, Germany and Poland) have all announced interpretations of Solvency II that limit the ability of reinsurers from nonequivalent jurisdictions to act as reinsurers on a cross-border basis. From the U.S. perspective, one of the goals of the covered agreement is to obtain Solvency II equivalency status. One of the main motivations for EU domiciled reinsurers to support a covered agreement is to ensure reduced collateral requirements are adopted nationwide. The parties have met several times to discuss the covered agreement, but as of December 2016, no agreement was reached. If the agreement is not reached prior to President Elect Trump taking office, it is expected that the negotiations could be delayed as several of the U.S. negotiators are likely to change. Also, at this time, it is not clear if there would be any substantial shift in position on the covered agreement from the Obama Administration to the Trump Administration. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 4 Aon Benfield Analytics | Market Analysis Proprietary and Confidential State Adoption of the Credit for Reinsurance Model Law As of December 15, 2016, 34 states and the District of Columbia have adopted the law that allows for reduced amounts of collateral to be provided by approved reinsurers to ceding insurers domiciled in their state. Many of these states have also adopted the accompanying Credit for Reinsurance Model Regulation, which outlines the practices and procedures of the reduced collateral law. However, only 26 states have begun certifying reinsurers. The map below depicts the status of state adoption of collateral reform as of December 15, 2016. Active (state has certified reinsurers) State has adopted Law (#785) and Regulation (#786) State has adopted Model Law (#785) The states that have certified reinsurers as of December 2016 are: Alabama Arizona Arkansas California Colorado Connecticut Delaware Florida Georgia Indiana Iowa Louisiana Maine Maryland Missouri Nebraska New Hampshire New Jersey New York North Dakota Ohio Pennsylvania Rhode Island Vermont Virginia Washington Only ceding insurers domiciled in these 26 states are potentially impacted by the reporting requirements for certified reinsurers and the new Schedule F-Part 6 on the 2016 statutory annual statement. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 5 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Collateral Reform in Florida In 2008, Florida became the first state to pass collateral reform legislation. They crafted their legislation to mirror the Model Law and Regulation (as it was constructed in 2008). There were a few significant differences from the Model Law and Regulation that was finalized in 2011 including: Reinsurers eligible for reduced collateral were called “eligible reinsurers” The amount of collateral required for “A-“ or “A3” rated reinsurers was 20%, instead of 50% Most reinsurers were only permitted to provide reduced collateral on property catastrophes reinsurance The collateral deferral only applied to “named hurricanes” On July 28, 2015, Florida implemented changes to bring it more in line with the current NAIC Model Law and Regulation. The most significant changes are outlined in the table below. Key Differences between the Model Law / Regulation & Florida Name for Reduced Collateral Reinsurers Amount of Collateral for “A-” or “A3” Rated Reinsurers Eligible lines of business Collateral Deferral Applies only to Model Law / Regulation Florida Original Florida Revised Certified Eligible Certified 50% 20% 50% All lines Property & Casualty, but most reinsurers only were approved for property catastrophe All lines – The Florida OIR will now allow reinsurers to be approved for reduced collateral on lines other than property catastrophe Recognized catastrophes Named hurricanes Named hurricanes Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 6 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Certified Reinsurers as a New Reporting Category Previous to 2012, all reinsurance recoverables were reported as emanating from a reinsurer classified as either authorized or unauthorized. With the introduction of the new Credit for Reinsurance Model Law and Regulation, a third class of reinsurer was developed, a “certified reinsurer”. 1. Authorized Reinsurer: Reinsurers may meet the requirement to become authorized in one of three ways: They may be licensed to write insurance (which typically also includes reinsurance) or reinsurance in a ceding insurer’s state of domicile. They may be licensed in a state with “substantially similar” credit for reinsurance regulation. Also, the reinsurers must agree that it will submit to the authority of the accrediting state. Submitting to the authority of a state usually requires a yearly filing of an annual statement and the submission of audited financial statements. The accredited reinsurer must also meet the minimum capital and surplus requirements of the accrediting state. When all these requirements are met the reinsurer is awarded “accredited” (or equivalent status) and is considered an authorized reinsurer. Most U.S. reinsurers that are licensed in one state are awarded authorized treatment via this provision. A handful of non-U.S. reinsurers have also become authorized through the establishment and maintenance of a Multi-Beneficiary Trust (MBT) as well as meeting other state imposed requirements (increased reporting etc.). The term for these reinsurers may differ by state, but includes “accredited”, “trusteed”, “qualified”, “approved” etc. 2. Certified Reinsurer: A reinsurer that has been approved to provide reduced amounts of collateral for its reinsurance liabilities due to ceding insurers domiciled in a state that has adopted the new Credit for Reinsurance Model Law and Regulation. 3. Unauthorized Reinsurer: A reinsurer that was not authorized nor certified. Recoverables from reinsurers at any point in time should now be reported in one of the following categories; authorized, unauthorized or certified. In 2013, Schedule F was expanded to accommodate the reporting of recoverables from certified reinsurers. Specifically, a new part 6 was introduced and the former parts 6, 7, 8 and were relabeled parts 7, 8, and 9 respectively. Important Note: The definitions of the above terms have been provided to clarify the statutory reinsurance reporting treatment of recoverables. However, the terms may have a different meaning when used in another context. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 7 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Multi-Beneficiary Trusts and their Impact on Statutory Reporting Several non-U.S. reinsurers have elected to use Multi-Beneficiary Trusts (MBTs) as collateral instead of Letters of Credit (LOCs) or Single Beneficiary Trusts. There are several unique characteristics of MBTs. These characteristics and how the MBT is used to collateralize recoverables may impact the statutory account treatment of recoverables from both certified and authorized reinsurers. Before dissecting the specific statutory reporting treatment, it may be beneficial to review some background information on MBTs. Background Information on MBTs Most reinsurers currently using MBTs to collateralize recoverables were previously providing collateral through Letters of Credit (LOCs) and/or Single Beneficiary Trusts. However, MBTs are more cost efficient and much easier to manage than dozens of LOCs or Single Beneficiary Trusts. MBTs allow reinsurers to set the amount of collateral based on claim notices from the ceding insurer and the reinsurer’s calculation of IBNR. Non-U.S. reinsurers wishing to use a MBT to secure obligations due to U.S. ceding insurers must meet a number of requirements: The MBT must be regulated by a state insurance department (Originally it was New York Division of Financial Services (NY DFS) but New Jersey and Delaware have also been used.) The MBT must be approved in every state where it will be used to collateralized recoverables due to ceding insurers domiciled in the state The reinsurer must agree to a number of additional requirements including additional reporting and an agreement to collateralize 100% of all obligations due to ceding insurers in any state that has approved the MBT (except certified reinsurers who are permitted to collateralize their recoverables at less than 100%) The reinsurer must also agree to provide an additional buffer layer of collateral in the MBT – The buffer is USD 20mn for MBTs that secure full (i.e. 100%) collateral obligations – The buffer is USD 10mn for MBTs that secure certified reinsurer (i.e. reduced collateral) obligations If the reinsurer meets all the requirements and the MBT is approved, the reinsurer is granted “trusteed” status, “accredited” status or equivalent. (Please note states may have different terms for these reinsurers that have been approved to use MBTs.) If a reinsurer is trusteed, accredited or equivalent, then for statutory reporting purposes, recoverables emanating from the reinsurer may be classified as authorized. There are some exceptions to this for certified reinsurers, which are outlined in the “MBT Issues Impacting Statutory Reinsurance Reporting” section on the following pages. It should be noted that trusts that are used for full (or 100%) collateral obligations cannot also be used for reduced collateral obligations. Therefore, reinsurers who are certified in some states may elect to establish a second MBT for their reduced collateral obligations. Reinsurers may also use a MBT for their full collateral obligations and LOCs or Single Beneficiary Trusts for their reduced collateral obligations. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 8 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Notable Reinsurers that utilize MBTs There are 14 prominent non-U.S. reinsurers as well as Lloyd’s syndicates (a.k.a. Underwriters at Lloyd’s) that utilize MBTs to secure their obligations due to U.S. ceding insurers. These reinsurers have had their MBT approved in all 50 states as well as the District of Columbia, except where noted: Aspen Bermuda Limited (All states except New York) Aspen Insurance UK Limited AXIS Specialty Limited (All states except New York) DaVinci Reinsurance Limited Endurance Specialty Insurance Limited (Please see pages 18 - 21 for additional information) Hannover Rueck SE (f.k.a. Hannover Rueckversicherung AG) Lancashire Insurance Company Limited Mapfre Re, Compania de Reaseguros, S.A. Markel Bermuda Limited (All states except Florida, Hawaii, Louisiana, Massachusetts, Montana and New York) Markel International Insurance Company Limited (All states except Louisiana, Maine, Michigan, Minnesota and Rhode Island) Partner Reinsurance Company, Limited Renaissance Reinsurance Limited Underwriters at Lloyd’s Validus Reinsurance, Limited (All states except Florida and New York) Validus Reinsurance (Switzerland) Ltd. (All states except Florida, Illinois, Minnesota, Nevada, New Mexico and New York as of December 31, 2016) Note: 1. This excludes some P&C run-off companies. (ex. Reinsurance Limited (UK) and Unionamerica Insurance Co Ltd (UK) 2. Montpelier Reinsurance Limited used a MBT, but this company was merged with Endurance Specialty Insurance Limited in December 2015. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 9 Aon Benfield Analytics | Market Analysis Proprietary and Confidential MBT Issues Impacting Statutory Reinsurance Reporting There are four issues that potentially impact the reporting of recoverables collateralized by a reinsurer using a MBT. 1. Reinsurers using MBTs may roll-in existing liabilities changing the reporting treatment of the existing liabilities Most of the reinsurers who elect to utilize a MBT to secure their recoverables were unauthorized prior to the approval of the MBT. Once the MBT is approved, all recoverables from contracts that incept on or after the date the MBT is approved should be classified as emanating from an authorized reinsurer. To facilitate communication, we will refer to the date that the MBT is approved by a state as the “Date Trusteed”. A second step (often called a “roll-in”) is required to move existing recoverables (i.e. recoverables from contracts that incept prior to the Date Trusteed) into the MBT. Outlined below is the reporting treatment of the recoverables from contracts that incept prior to and after the Date Trusteed - assuming the reinsurer is not also certified and has yet to enact a roll-in). Reporting Treatment (Prior to any MBT Roll-in) Prior to Date Trusteed All recoverables = Unauthorized Post Date Trusteed All recoverables = Authorized Therefore, if there is no roll-in of existing recoverables, ceding insurers should report recoverables as follows: Report all recoverables from contracts incepting prior to the Date Trusteed as unauthorized Report all recoverables from contracts incepting on or after the Date Trusteed as authorized Often reinsurers who elect to use an MBT want to also collateralize their existing recoverables in the MBT. From the reinsurer’s perspective, it is usually more efficient and cost effective if all recoverables (existing and prospective) are collateralized by the MBT. Therefore, some reinsurers elect to roll-in existing recoverables. By existing recoverables, we are referring to recoverables from contracts that incepted prior to the Date Trusteed. Aon Benfield has not identified any laws or regulations preventing the roll-in of these existing recoverables. However, the language of the MBT appears to allow the roll-in of these existing recoverables. In addition, the NY DFS (the regulator of most MBTs currently in use) has permitted the roll-in of existing recoverables. It appears that other states that regulate MBTs are permitting the rollin of existing recoverables. There appears to be no official approval process for the roll-in of existing recoverables into a MBT. In most cases, the reinsurer will prepare a listing of the ceding insurers and associated recoverables that they intend to roll-in to the MBT. This listing (which may also be referred to as a “Rollover Certificate”) is provided to the regulator of the MBT. Reinsurers who roll-in existing balances also notify impacted ceding insurers, so their existing collateral (typically a LOC or Single Beneficiary Trust) may be released. If a reinsurer rolls-in existing recoverables to their MBT, it changes the reporting treatment of the existing recoverables. In essence, all recoverables are treated as if emanating from an authorized reinsurer as shown in the diagram on the next page. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 10 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Treatment - Post Roll-in Prior to Date Trusteed All recoverables = Authorized Post Date Trusteed All recoverables = Authorized Therefore, if there is a roll-in of existing recoverables, ceding insurers should report all recoverables as authorized (assuming the reinsurer is not also certified, which is addressed in the following section). 2. Reinsurers using MBTs may also be certified One of the current complications of statutory reporting of recoverables from non-U.S. reinsurers is that the classification of a reinsurer may change over time. Often reinsurers that are unauthorized become authorized. Some of these same reinsurers elect to become certified. Therefore, recoverables from reinsurers that use MBTs may be authorized, unauthorized and/or certified. The total recoverables from a reinsurer must be split among these three reporting classifications. 3. Certified reinsurers may use their full collateral MBT to secure reduced collateral liabilities The type or amount of collateral provided does not dictate the reporting treatment of recoverables from a certified reinsurer, with one significant exception. The exception occurs if the certified reinsurer agrees to collateralize the recoverables at 100% through its MBT used for full (i.e. 100%) collateral. In this case, the recoverables should be reported as emanating from an authorized reinsurer and be reported on Schedule F – Parts 3, 4, 7 and 8 (as necessary). Alternatively, if a certified reinsurer is only required to provide 20% collateral and provides 60% collateral via a LOC, the recoverables should still be reported as emanating from a certified reinsurer and be reported on Schedule F – Parts 3, 4 and 6 (as necessary). 4. Ceding insurers may not know the amount of collateral in the MBT securing their liabilities In Schedule F – Part 6 – Section 1, ceding insurers are required to indicate the amount of collateral provided by their certified reinsurers. The collateral may be met in several ways, including: cash, Letters of Credit (LOCs), Single Beneficiary Trusts and MBTs. For all but the MBTs, the ceding insurer is aware of the amount of collateral provided. However, the amount held in a MBT (on behalf of a ceding insurer) is typically not known by the ceding insurer. In practice, the amount held in the MBT by a reinsurer should be equal to the recoverable balances due to the ceding insurer. There may be some variances due to differences in the calculation of IBNR by the ceding insurer and the reinsurer. The responsibility for ensuring that the MBT is sufficiently funded lies with the regulator of the trust. Representatives of the NY DFS have indicated that ceding insurers that are provided collateral through a MBT regulated by the NY DFS can assume their recoverables are adequately collateralized by the reinsurer’s MBT. This view has been supported by the NAIC and other regulators. With respect to reinsurance reporting on Schedule F – Part 6, ceding insurers may indicate that all recoverables that are collateralized by a MBT are funded adequately. Specifically, the amount of collateral required is indicated in column 11 of Part 6 – Section 1. Therefore, ceding insurers (whose recoverables are collateralized by a MBT) may enter an identical balance in column 12. Representatives of the NAIC have stated that this reporting treatment was contemplated and agreed upon during the development of Schedule F – Part 6. This approach ensures that ceding insurers will get full credit (and not suffer a provision for reinsurance) for their recoverables that are collateralized by a MBT. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 11 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Certified Reinsurer Reporting Concepts The introduction of certified reinsurers, as well as the increased use of MBTs, has unintentionally complicated the reporting of recoverables from reinsurers. Outstanding recoverables from the same reinsurer may be subject to different reporting treatment. These recoverables may appear on different parts (Part 5, 6, 7 and/or 8) of Schedule F and may need to appear on different lines within the same Part of Schedule F. Below are important concepts and additional information that may be used to guide the reporting of recoverables from certified reinsurers and reinsurers that utilize MBTs. 1. The ability to provide reduced amounts of collateral to ceding insurers domiciled in a particular state only applies on a prospective basis. Specifically, only recoverables from contracts that incept on or after the date of certification are eligible for reduced collateral. Recoverables that emanate from a contract that incepts prior to the date of certification must be reported as emanating from either an authorized and/or unauthorized reinsurer. 2. The certified reinsurer’s ability to provide reduced amounts of collateral may be restricted by type or line of business. Each reinsurer must apply and be approved for reduced collateral for specific lines or classes of business (e.g. property/casualty, life, accident, health etc.). If approved by a state, the lines that are eligible for reduced collateral are known as certified lines. Therefore, ceding insurers must confirm that all recoverables subject to certified reporting treatment emanate from certified lines of business. This has become less of an issue since Florida updated its Administrative Code on July 28, 2015 to more closely follow the NAIC Credit for Reinsurance Model Law and Regulation. However, prior to July 28, 2015, only Hannover Rueck SE and XL Re Ltd were eligible to provide reduced amounts of collateral to Florida domiciled ceding insurers on all property and casualty lines. All other reinsurers that were certified in Florida prior to July 28, 2015 were only eligible to provide reduced collateral on property catastrophe reinsurance recoverables. Appendix I provides specific reporting instructions for all reinsurers that were certified in Florida prior to July 28, 2015. In some cases, the certified lines may not be listed by the state insurance department. When the specific lines of business are not indicated on the state website, ceding insurers often assume all lines are certified. 3. Certified reinsurers may be able to defer the posting of collateral on recoverables resulting from a property catastrophe event. Certified reinsurers are able to defer collateralizing recoverables if the recoverables on specified lines of business result from a catastrophe event that is “recognized for collateral deferral” by the insurance department of the ceding insurer’s state of domicile. The deferral lasts for a period of one year from when the ceding insurer posted its initial reserve for the loss. Schedule F – Part 6 of the statutory annual statement has been redesigned to accommodate this collateral deferral. Therefore, ceding insurers may need to track certified reinsurer recoverables resulting from a property catastrophe event (or “named hurricane” for Florida domiciled companies) separately. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 12 Aon Benfield Analytics | Market Analysis Proprietary and Confidential 4. The upgrade of a certified reinsurer applies on a prospective basis. Also, the upgrade may require ceding insurers to report recoverables on separate lines within Schedule F – Part 6 in order to reflect different collateral requirements. The amount of collateral required to be provided by a certified reinsurer is dependent upon the rating (e.g. Secure-1, Secure-2) assigned by the Insurance Commissioner of the ceding insurer’s state of domicile. The ratings assigned by the Insurance Commissioner are based on commercial ratings assigned by rating agencies such as A.M. Best, Fitch, Moody’s and Standard and Poor’s. In the event the commercial ratings are upgraded, it may lead to an upgrade of the Insurance Commissioner’s rating. Any upgrade in certified ratings only applies on a prospective basis. In other words, once upgraded, the reinsurer will be able to fund at a lower level of collateral. This lower level of collateral only applies to recoverables from contracts that incept on or after the date the Insurance Commissioner upgrades the rating of the certified reinsurer. Contracts that incept prior to the certified rating upgrade date will still need to be collateralized at the higher level. Therefore, recoverables from the certified reinsurer may be subject to different collateral amounts. Recoverables from a certified reinsurer that are subject to different collateral levels will need to be reported on separate lines on Schedule F – Part 6 or an inaccurate provision for reinsurance may be calculated. 5. Any downgrade of a certified reinsure applies prospectively and retroactively. Also, certified reinsurers that are downgraded or decertified by the Insurance Commissioner within the last three months of the calendar year may be reported at the required amount of collateral before the downgrade or decertification occurred. If a certified reinsurer is downgraded by the Insurance Commissioner (usually resulting from a downgrade of commercial ratings), the reinsurer may be subject to higher amounts of collateral. The new higher collateral requirement applies prospectively and to all existing certified recoverables that were collateralized at a lower percentage. Once downgraded or decertified, reinsurers have three months to bring collateral up to the new required level. During this three month grace period, ceding insurers should not be penalized (via the Provision for Reinsurance) for any collateral shortfall directly due to the downgrade or decertification th of the reinsurer. Therefore, if a downgrade occurs in the 4 quarter, ceding insurers are permitted to report the required collateral at the level before the downgrade or decertification occurred. For example, assume a Secure-3 certified reinsurer was eligible to provide 20% collateral. If this reinsurer st was downgraded to a Secure-4 reinsurer on December 1 , they would need to provide 50% st collateral. However, the reinsurer may not have increased collateral to 50% by December 31 . Therefore, the ceding insurer may still report this reinsurer as Secure-3, requiring 20% collateral on their statutory annual statement. Ceding insurers are also required to disclose any certified reinsurer downgrades or revocations in the Notes to Financials. Under Note 23 I, ceding insurers are required to identify the following information: Name of certified reinsurer downgraded or whose certification was revoked Date of Insurance Commissioner’s downgrade or revocation Collateral requirements pre and post downgrade or revocation Net obligations subject to collateral Additional collateral required, but not received as of the filing date Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 13 Aon Benfield Analytics | Market Analysis Proprietary and Confidential 6. Collateral provided by a non-U.S. reinsurer should follow the reporting treatment of the recoverables that are being collateralized. Therefore, there may be a need to bifurcate the collateral reported on Schedule F. Ceding insurers need to report recoverables and the corresponding collateral accurately on Schedule F or an inaccurate provision for reinsurance may result. For example, suppose a ceding insurer domiciled in New York was owed USD 10mn in paid recoverables on two separate contracts incepting January 1, 2012 and January 1, 2013 respectively. Suppose that the recoverables were due from a non-U.S. unauthorized reinsurer that became certified on January 1, 2013 and was eligible to provide 20% collateral. Therefore, the amount that should be collateralized by the reinsurer is USD 12mn (USD 10mn for the 100% obligations and USD 2mn for the reduced collateral obligations). If the ceding insurer received a LOC for USD 12mn from the reinsurer, the recoverables and collateral should be reported as follows (assuming there were no recoverables subject to the collateral deferral outlined in item 3 above): Part 3: Ceded Reinsurance Recoverables of USD 10mn should be reported under Unauthorized – Other Non-U.S. Reinsurers Recoverables of USD 10mn should be reported under Certified – Other Non-U.S. Reinsurers Part 5: Provision for Unauthorized Reinsurance Recoverables of USD 10mn should be reported under Unauthorized – Other Non-U.S. Reinsurers LOC of USD 10mn should be reported on the same line (in column 7) Part 6 – Section 1: Provision for Reinsurance Ceded to Certified Reinsurers Recoverables of USD 10mn should be reported in columns 8 and 10 and USD 2mn should be reported in column 11 under Certified – Other Non-U.S. Reinsurers LOC of USD 2mn should be reported on the same line (in column 14) Note: The recoverables may also need to be reported on other parts of Schedule F (e.g. Part 4 and Part 6 – Section 2) if any of the recoverables are more than 90 days past due.) 7. Certified reinsurers are assigned a Certified Reinsurer Identification Number (CRIN) that should be reported in Schedule F – Part 6. The CRIN for a certified reinsurer will be its Alien ID number with a “CR” replacing the “AA” at the beginning of the number. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 14 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions for Certified Reinsurers Reporting for most certified reinsurers is relatively straight forward. Most reinsurers were unauthorized before they became certified. The certification applies only on a prospective basis. Therefore, recoverables from contracts incepting prior to the certification date, should be reported as unauthorized. Recoverables from contracts that incept on or after the certification date, should be reported as certified – PROVIDED they emanate from a certified line of business. In most cases reinsurers obtain certification for all lines of business that they are authorized to write. The only significant exception to the certified lines occurred in Florida where up until 07/28/15, most reinsurers were certified for property catastrophe reinsurance only. As mentioned in the previous sections, there are a number of factors which can complicate the reporting of recoverables including: The use of a multi-beneficiary trust for full (i.e. 100%) collateral obligations Reserve upgrades and downgrades The collateral deferral on recognized catastrophes or named hurricanes (Florida only) Therefore, our approach to providing reporting instructions will be as follows: If there are any known reporting complications (reserve changes, use of an MBT etc.), we will provide specific reporting guidance at the state level. If the reinsurer is certified and there are no other complications, then ceding insurers should report recoverables as follows: Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 15 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Special Reporting Instructions for Recoverables from Lloyd’s Syndicates, Tokio Millennium, Endurance Specialty and Montpelier Reinsurance Lloyd’s Syndicates (2016 Statutory Statement) Underwriters at Lloyd’s, London (Lloyd’s), is a market and obtains licensing on behalf of all syndicates in each state. As of December 2016, Lloyd’s (and therefore all Lloyd’s syndicates) has been certified and approved for reduced collateral in California, Florida, New York and Pennsylvania. Lloyd’s has yet to be approved as a certified reinsurer in any other state. Each Lloyd’s syndicate has the option to provide reduced amounts of collateral to ceding insurers domiciled in: California, for all property casualty recoverables from contracts that incept on or after July 1, 2015 Florida o For all property catastrophe reinsurance recoverables from contracts that incept on or after October 6, 2011 through July 27, 2015 o For all property casualty recoverables from contracts that incept on or after July 28, 2015* New York, for all property casualty recoverables from contracts that incept on or after January 1, 2011 Pennsylvania, for all recoverables from contracts that incept on or after December 1, 2014 *Note: This is the date the Florida OIR changed its Administrative Code to remove the restriction that only property catastrophe reinsurance recoverables could be certified. To date, very few syndicates have elected to provide reduced collateral to ceding insurers domiciled in California, Florida, New York or Pennsylvania. If a syndicate elects to provide reduced collateral, they would need to establish a Letter of Credit (LOC) or Single Beneficiary Trust. (To date, Lloyd’s has yet to establish a parallel MBT fund structure.) The syndicate would also notify the ceding insurer that they plan to collateralize recoverables outside of their MBT established for 100% collateral. In this case, the associated recoverables should be reported as certified (instead of authorized) and follow the applicable statutory reporting guidelines. As more recoverables become eligible for reduced collateral, more syndicates may be collateralizing recoverables at a reduced percentage. Conclusion: Unless the ceding insurer has agreed with a Lloyd’s syndicate to a specific collateral arrangement with a LOC or Single Beneficiary Trust or funds withheld, all recoverables from Lloyd’s should be reported as authorized. Cedant specific collateral arrangements should be reported as certified where reduced collateral has been agreed to by the cedant or unauthorized where the funding is 100% (but not collateralized through an MBT). Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 16 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Tokio Millennium (2016 Statutory Statement) Special reporting instructions are required for Tokio Millennium as some of the state websites are not 100% clear. Background on Tokio Millennium In October 2013, Tokio Millennium Re, Ltd redomesticated from Bermuda to Switzerland and became known as “Tokio Millennium Re AG”. The Bermuda operations of Tokio Millennium Re then became a branch now known as “Tokio Millennium Re AG, Bermuda Branch”. Per Tokio Millennium, references to “Tokio Millennium Re, Ltd.” or “Tokio Millennium Re AG” refer to the same legal entity - now organized under the laws of Switzerland. In 2014, Tokio Millennium Re AG (the Swiss entity) established a U.S. branch - Tokio Millennium Re AG (U.S. Branch). This U.S. branch is separately capitalized. According to Tokio Millennium, the U.S. branch has the full backing of the Swiss entity as the branch is simply an extension of the Swiss legal entity. Aon Benfield spoke with state regulators who shared this view. The U.S. branch is licensed by the state of New York and as of December 15, 2016 is now licensed and/or accredited in all 50 states and in Washington DC. Recoverables from Tokio Millennium should be reported as outlined below. 1. Tokio Millennium Re AG (U.S. Branch) Recoverables from contracts where the U.S. Branch is the reinsurer should be reported as “authorized”. 2. Tokio Millennium Re AG or Tokio Millennium Re AG (Bermuda Branch) Tokio Millennium Re AG became certified in Florida on 02/25/11. However, as previously noted, Florida updated its Administrative Code regarding reduced collateral to bring it more in line with the NAIC Credit for Reinsurance Model Law and Regulation. One of the main changes was that the reduced collateral could apply to all reinsurance recoverables and not just property catastrophe reinsurance recoverables. Therefore, the reporting of recoverables from Tokio Millennium Re AG Tokio Millennium Re AG and the Tokio Millennium Re AG (Bermuda Branch) differ by the type of recoverables and from the reinsurance contract Inception date as outlined in the table below: For Florida Domiciled Ceding Insurers (Does not include recoverables due from the U.S. Branch) Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 17 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Tokio Millennium Re AG and the Tokio Millennium Re AG (Bermuda Branch) are certified in the following states: State Alabama California Connecticut Delaware Georgia Missouri New Jersey New York Ohio Pennsylvania Rhode Island Certification Date 07/01/15 07/01/14 05/14/15 04/01/15 10/27/14 07/01/15 04/30/14 07/01/11 01/01/16 07/01/15 07/07/15 Ceding insurers domiciled in the above states: Recoverables from contracts issued on non-U.S. branch paper and incepting on or after the certification date should be reported as “certified”. All recoverables from contracts incepting prior to the certification date should be reported as “unauthorized” Ceding insurers domiciled in all other states: All recoverables on contracts issued on non-U.S. branch paper should be reported as “unauthorized”. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 18 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Endurance Specialty Limited (2016 Statutory Statement) Reporting of recoverables from Endurance Specialty Insurance Limited (Endurance Specialty) is currently complicated for several reasons: Endurance Specialty is certified in some states, authorized in some states and unauthorized in other states Some states where Endurance is operating as a certified reinsurer have yet to recognize (or have yet to update their records) a rating upgrade which should lead to lower collateral requirements Aon Benfield does not have complete information on whether recoverables from contracts that incepted prior to Endurance Specialty’s Multi-Beneficiary Trust (MBT) being approved have been rolled-in to the MBT (thereby changing their reporting classification to authorized from unauthorized). If there is any uncertainty regarding how to report recoverables from Endurance Specialty, we suggest that ceding insurers contact Endurance Specialty and / or the Department of Insurance (DOI) in the domicile of the ceding insurer. The following is the information that we have assembled to date, based primarily on DOI websites and DOI staff. States where Endurance Specialty is not Certified nor Authorized According to our findings, Endurance Specialty is not authorized nor certified in any of the following states: Idaho Illinois Maryland Minnesota Montana New Mexico New York Pennsylvania Washington Wyoming In all the above states, recoverables from Endurance Specialty should be reported as unauthorized. Reporting Certified Recoverables from Endurance Specialty According to our findings, Endurance Specialty is certified in the following states (but not also authorized): State Alabama Colorado Connecticut Florida Georgia Iowa Certification Date 11/10/15 05/31/12 12/30/15 05/31/12 12/29/15 12/14/15 Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 19 Aon Benfield Analytics | Market Analysis Louisiana Maine Nebraska New Hampshire New Jersey North Dakota Ohio Vermont Virginia Proprietary and Confidential 02/05/16 10/29/15 10/27/15 10/27/15 11/01/16 07/01/16 01/01/16 07/01/15 01/05/16 All recoverables from contracts that incept prior to the certification date should be reported as unauthorized. With the exception of Florida, all recoverables due to ceding insurers domiciled in these states should be reported as certified if the reinsurance contract incepts on or after the certification date. Please be advised that Endurance Specialty was upgraded by Moody’s on August 9, 2016. This upgrade, if recognized by the Ceding Insurer’s state of domicile, should result in lower collateral requirements on a prospective basis (i.e. for recoverable from contracts that incept on or after this date). To ensure an accurate provision of reinsurance is calculated, recoverables that are collateralized at different percentages should appear on separate line items in Schedule F Parts 6 – Sections 1 and 2. Reporting recoverables from Endurance Specialty by Florida domiciled ceding insurers is more difficult as until 07/28/15 only property catastrophe recoverables were eligible for reduced collateral. Also, Florida had a slightly different rating scale (i.e. A- and A3 rated reinsurers only needed to provide 20% collateral). Therefore, to the best of our knowledge, recoverables from Endurance Specialty (if there are any) should be reported as follows: Note: Recoverables resulting from Hurricane Matthew may be subject to the one-year collateral deferral. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 20 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Authorized Recoverables from Endurance Specialty According to our findings, Endurance Specialty is authorized in the following states (but not also certified): State Alaska Arizona Arkansas District of Columbia Hawaii Indiana Kansas Kentucky Massachusetts Michigan Mississippi Nevada North Carolina Oklahoma Oregon South Carolina South Dakota Tennessee Texas Utah West Virginia Wisconsin Date Trusteed 10/27/15 11/06/15 01/06/16 04/25/16 12/29/15 12/17/15 07/06/16 11/23/15 12/23/15 12/08/15 01/01/15 08/22/16 10/20/15 07/01/11 12/31/15 10/27/15 11/09/15 11/06/15 03/14/16 05/02/16 08/12/16 11/02/15 All recoverables due to ceding insurers domiciled in these states should be reported as authorized if the reinsurance contract incepts on or after the Date Trusteed. Recoverables from contracts that incept prior to the Date Trusteed (a.k.a. existing balances), should be reported as unauthorized, unless the existing balances were roll-in to the MBT (in which case they should be reported as authorized.) Ceding insurers should be notified of any roll-ins by Endurance Specialty. These communications typically also request the release of any Letters of Credit. Reporting of Recoverables from Delaware, Missouri and Rhode Island According to our records, Endurance Specialty is both certified and authorized in the following states: State California Delaware Missouri Rhode Island Date Certified 07/01/15 07/01/15 01/01/16 12/29/15 Date Trusteed 12/23/16 08/25/15 04/01/16 09/15/16 Based on our findings, recoverables due to ceding insurers domiciled in the above three states, should be reported as follows: Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 21 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting for Ceding Insurers Domiciled in California (where Endurance Specialty is both Certified and Authorized) Notes: 1. Endurance Specialty recoverables from contracts incepting prior to 07/01/15 should be reported as unauthorized, unless these recoverables have been rolled-in to a full collateral MBT. 2. The California DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Reporting for Ceding Insurers Domiciled in Delaware (where Endurance Specialty is both Certified and Authorized) Notes: 1. Endurance Specialty recoverables from contracts incepting prior to 07/01/15 should be reported as unauthorized, unless these recoverables have been rolled-in to a full collateral MBT. 2. On 08/09/16, the Delaware DOI assigns Secure 3 rating (20% collateral required) to Endurance Specialty Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 22 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting for Ceding Insurers Domiciled in Missouri (where Endurance Specialty is both Certified and Authorized) Notes: 1. Endurance Specialty recoverables from contracts incepting prior to 07/01/15 should be reported as unauthorized, unless these recoverables have been rolled-in to a full collateral MBT. 2. The Missouri DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Reporting for Ceding Insurers Domiciled in Rhode Island (where Endurance Specialty is both Certified and Authorized) Notes: 1. Endurance Specialty recoverables from contracts incepting prior to 12/29/15 should be reported as unauthorized, unless these recoverables have been rolled-in to a full collateral MBT. 2. The Rhode Island DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Again, we recommend that all ceding insurers check with Endurance Specialty and the DOI of the state of domicile to confirm reporting for year-end 2016. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 23 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Links to Individual State Instructions Below are links to the state specific certified reinsurer reporting instructions for ceding insurers with specific instructions on how to report the recoverables emanating from certified reinsurers on the 2016 statutory annual statement Alabama Maryland Arizona Missouri Arkansas Nebraska California New Hampshire Colorado New Jersey Connecticut New York Delaware North Dakota Florida Ohio Georgia Pennsylvania Iowa Rhode Island Indiana Vermont Louisiana Virginia Maine Washington Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 24 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Additional Guidance on Schedule F Reporting If looking for detailed guidance on the completion of Schedule F, or a thorough discussion of reinsurance accounting, consult Booke’s 2016 P&C Annual Statement Handbook, a 1,500 page manual explaining the completion of the entire Yellow Book. Booke, an Aon company, is the leading provider of finance and accounting education specific to the insurance industry. Booke courses are available through customized onsite training, group live seminars, webinars or self-studies. Also, Booke’s annual statement software product — The Complete Package (TCP) — includes all the 2016 changes to Schedule F. TCP has the industry’s largest market share, is fast and intuitive, is available with the Handbook as a context sensitive help file, has a new federal income tax module, and includes supporting consultation with Booke instructors. For more information on Booke’s products and services, visit www.bookeseminars.com or call 336-728-2929. Contacts For additional information on U.S. Collateral Reform or the reporting of recoverables on the 2016 Statutory Annual Statement, please contact your local Aon Benfield Broker or a member of the Aon Benfield Analytics – Market Analysis team, including: Mike McClane Market Analysis, Americas Aon Benfield Analytics +1.215.751.1596 [email protected] Steven Le Market Analysis, Americas Aon Benfield Analytics +1.215.751.1293 [email protected] Sources: Aon Benfield Market Analysis, National Association of Insurance Commissioners, State Insurance Department websites and staff, Aspen Bermuda Limited, Lancashire Insurance Company Limited, Lloyd’s U.S., Renaissance Reinsurance Limited, Tokio Millennium Re AG, and Validus Reinsurance Limited. About Aon Aon plc (NYSE:AON) is the leading global provider of risk management, insurance and reinsurance brokerage, and human resources solutions and outsourcing services. Through its more than 66,000 colleagues worldwide, Aon unites to empower results for clients in over 120 countries via innovative and effective risk and people solutions and through industry-leading global resources and technical expertise. Aon has been named repeatedly as the world’s best broker, best insurance intermediary, best reinsurance intermediary, best captives manager, and best employee benefits consulting firm by multiple industry sources. Visit aon.com for more information on Aon and aon.com/manchesterunited to learn about Aon’s global partnership with Manchester United. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 25 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Appendix I: 2016 State Specific Certified Reinsurer Reporting Instructions Important Note: Not all states have identified which lines of business have been approved as certified lines. For many states, all lines reinsured by a certified reinsurer are approved as certified lines. Alabama Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? No MBT Roll-in N/A Trusteed Date N/A Endurance Specialty Insurance Ltd No N/A N/A Hannover Ruck SE Yes No 02/06/96 Tokio Millennium Re AG No N/A N/A Certified Reinsurer Arch Reinsurance Ltd Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential Certification Date 07/01/14 11/10/15 12/31/16 01/01/17 Current Rating Secure-3 Collateral Required 20% Secure-4 50% Secure-3 20% 07/01/14 Secure-2 10% Life, Annuities, A&H, Property / Casualty 07/01/15 Secure-3 20% Property / Casualty Certified Lines Property / Casualty Property Cat 26 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Alabama Certified Reinsurer Endurance Specialty Insurance Ltd. Certification Date Date Trusteed 11/10/15 N/A Contract Inception Date Prior to 11/10/15 On/after 11/10/15 but before 01/01/17 On/after 01/01/17 Prior to 02/06/96 Hannover Rueck SE 07/01/14 02/06/96 On/after 02/06/96 but before 07/01/14 On/after 07/01/14 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Certified All Other Certified All Other All Reporting Treatment Unauthorized Certified Unauthorized Certified Authorized Unauthorized² Collateral Required 100% 50% 100% 20%¹ 100% 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized Certified Certified See Previous Page All Other Unauthorized 100% 100% Notes: 1. On January 1, 2017, Endurance Specialty Insurance Ltd’s Secure-4 rating was upgraded to Secure-3. As a result, recoverables from contracts that incept on or after this date require only 20% collateral. 2. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 27 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Arizona Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required Arch Reinsurance Ltd No N/A N/A 04/26/16 Secure-3 20% Hannover Ruck SE Yes No 12/28/98 04/21/16 Secure-2 10% Life, Annuities, A&H, Property / Casualty Ironshore Insurance Ltd. No N/A N/A 04/21/16 Secure-5 75% Property / Casualty Certified Reinsurer Certified Lines Life, Annuities, A&H, Property / Casualty Reporting Instructions: Arizona Certified Reinsurer Certification Date Date Trusteed Hannover Rueck SE 04/21/16 12/28/98 Contract Inception Date Prior to 12/28/98 On/after 12/28/98 but before 04/21/16 On/after 04/21/16 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized Certified Certified See Previous Page All Other Unauthorized 100% 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 28 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Arkansas Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Certified Reinsurer Allied World Assurance Co. Ltd. Hannover Ruck SE Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required Certified Lines No N/A N/A 01/01/16 Secure-3 20% Property / Casualty No No 09/26/97 01/01/16 Secure-2 10% Life, Annuities, A&H, Property / Casualty Reporting Instructions: Arkansas Certified Reinsurer Allied World Assurance Co. Ltd. Certification Date Date Trusteed 01/01/16 N/A Contract Inception Date Prior to 01/01/16 On/after 01/01/16 Prior to 09/26/97 Hannover Ruck SE 01/01/16 09/26/97 On/after 09/26/97 but before 01/01/16 On/after 01/01/16 Lines All Certified All Other All Reporting Treatment Unauthorized Certified Unauthorized 1 Unauthorized All Authorized Certified All Other Certified Authorized Collateral Required 100% 20% 100% 100% 100% 10% 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 29 Aon Benfield Analytics | Market Analysis Proprietary and Confidential California Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required No N/A N/A 01/01/14 Secure-2 10% Arch Reinsurance Ltd. No N/A N/A 07/01/14 Secure-3 20% Life, A&H, Property / Casualty Endurance Specialty Insurance, Ltd. No N/A N/A 07/01/15 Secure-4¹ 50% Property / Casualty Hannover Ruck SE Yes No 10/09/96 01/01/14 Secure-2 10% Life, A&H, Property / Casualty Swiss Reinsurance Company Ltd. No N/A N/A 07/01/14 Secure-2 10% Life, A&H, Property / Casualty Tokio Millennium Re AG No N/A N/A 07/01/14 Secure-3 20% Property / Casualty Underwriters at Lloyd's London Yes Yes 12/22/06 07/01/16 Secure-3 20% Property / Casualty Certified Reinsurer Chubb Tempest Reinsurance Ltd. Certified Lines Life, Property / Casualty Notes: 1. The California DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 30 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: California Certified Reinsurer Endurance Specialty Insurance Limited Certification Date Date Trusteed 07/01/15 12/23/16 Contract Inception Date Prior to 07/01/15 On/after 07/01/15 but before 12/23/16 On/after 12/23/16 Prior to 10/09/96 Hannover Ruck SE 01/01/14 10/09/96 On/after 10/09/96 but before 01/01/14 On/after 01/01/14 Prior to 12/02/06 Underwriters at Lloyd's London 07/01/16 12/22/06 On/after 12/02/06 but before 07/01/16 On/after 07/01/16 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Certified All Other Certified All Other All Reporting Treatment Unauthorized Certified Unauthorized Certified Authorized Unauthorized³ Collateral Required 100%¹ 50%² 100% 50% 100% 100% All Authorized 100% Certified All Other All Certified Authorized Authorized⁴ 10% 100% 100% All Authorized 100% Certified All Other Authorized⁵ Authorized 100% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. Receivables prior to 07/01/15 should be collateralized at 100% and reported as unauthorized (unless ceding insurers domiciled in California have received notice that these recoverables have been rolled-in to Endurance Specialty’s MBT. If recoverables were rolled into a 100% MBT, they should be reported as authorized). 2. Endurance Specialty Insurance Limited became certified on July 1, 2015. Aon Benfield believes that all lines written by Endurance Specialty are eligible for reduced collateral (but there is no indication of certified lines on the DOI website). Therefore, all recoverables from contracts on or after this date should be reported as certified and only require 50% collateral. 3. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. 4. Prior to the Date Trusteed, some recoverables from Lloyd’s may need to be reported as unauthorized. In these cases, the Lloyd’s syndicate must be supplying the ceding insurer with a Letter of Credit or single Beneficiary Trust. 5. Post Certification - Most Lloyd's syndicates are providing 100% collateral for all recoverables through their MBT. Ceding insurers will be notified and provided with a LOC or Single Beneficiary Trust, if a syndicate elects to provide a reduce Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 31 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Colorado Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required Arch Reinsurance Ltd No NA N/A 07/01/11 Secure-3 20% Endurance Specialty IC Hannover Ruck SE No Yes NA No N/A 07/01/96 05/31/12 10/01/15 Secure-3 Secure-2 20% 10% Certified Reinsurer Certified Lines Life, Annuities, A&H, Property / Casualty Property / Casualty Property / Casualty Reporting Instructions: Colorado Certified Reinsurer Certification Date Date Trusteed Hannover Ruck SE 10/01/15 07/01/96 Contract Inception Date Prior to 07/01/96 On/after 07/01/96 but before 10/01/15 On/after 10/01/15 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized Certified Certified See Previous Page All Other Unauthorized 100% 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 32 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Connecticut Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required Arch Reinsurance Ltd. (Bermuda) No N/A N/A 04/27/15 Secure-3 20% Endurance Specialty Insurance Ltd. No N/A N/A 12/30/15 Secure-4¹ 50% Hannover Rueck SE Yes No 09/11/95 05/22/14 Secure-2 10% Swiss Reinsurance Company Ltd No N/A N/A 01/01/13 Secure-2 10% Tokio Millennium Re AG No N/A N/A 05/04/15 -9/17/15 09/18/15 - Current Secure-2 Secure-3 10% 20% Certified Reinsurer Certified Lines Life, Annuities, A&H, Property / Casualty Property / Casualty Life, Annuities, A&H, Property / Casualty Life, Annuities, A&H, Property / Casualty Property / Casualty Notes: 1. The Connecticut DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 33 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Connecticut Certified Reinsurer Certification Date Date Trusteed Hannover Rueck SE 05/22/14 09/11/95 Contract Inception Date Prior to 09/11/95 On/after 09/11/95 but before 05/22/14 On/after 05/22/14 Prior to 05/14/15 Tokio Millennium Re AG 05/14/15 N/A On/after 05/14/15 but before 09/17/15 On/after 09/17/15 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other All Certified Authorized Unauthorized 10% 100% 100% Certified Certified 10% All Other Unauthorized 100% Certified Certified 20% All Other Unauthorized 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% 2 Notes: 1 For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized 2 On September 17, 2015, Tokio Millennium Re AG's Secure-2 rating was downgraded to Secure-3. As a result, recoverables from contracts that incept on or after this date require 20% collateral. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 34 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Delaware Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required Certified Lines No N/A N/A 01/01/17 Secure-2 10% Not identified Allied World Assurance Company, Ltd. No N/A N/A 10/01/14 Secure-3 20% Not identified Arch Reinsurance Ltd. No N/A N/A Yes N/A 08/25/15 Secure-3 Secure-4 Secure-3 20% 50% 20% Not identified Endurance Specialty Insurance Limited 10/01/14 07/01/15 - 08/08/16 08/09/16 - Current Everest Reinsurance (Bermuda), Ltd. No N/A N/A 10/01/14 Secure-3 20% Not identified Hamilton Re Ltd Hannover Ruck SE No Yes N/A No N/A 08/21/96 11/03/16 10/01/14 Secure-5 Secure-2 75% 10% Not identified Not identified Münchener RückversicherungsGesellschaft Aktiengesellschaft in Munchen (Munich Re) No N/A N/A 10/01/14 Secure-2 10% Not identified SCOR Global Life Reinsurance Ireland Ltd. No N/A N/A Tokio Millennium Re AG TransRe London Limited No No N/A N/A N/A N/A 10/01/14 - 12/31/16 01/01/17 - Current 04/01/15 01/01/16 Secure-3 Secure-2 Secure-3 Secure-3 20% 10% 20% 20% Certified Reinsurer ACE INA Overseas Insurance Company Ltd. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential Not identified Not identified Not identified Not identified 35 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Delaware Certified Reinsurer Endurance Specialty Insurance Limited Certification Date Date Trusteed Contract Inception Date Prior to 07/01/15 On/after 07/01/15 but before 08/25/15 07/01/15 08/25/15 On/after 08/25/15 but before 08/09/16 On/after 08/09/16 Prior to 08/21/96 Hannover Ruck SE 10/01/14 08/21/96 On/after 08/21/96 but before 10/01/14 On/after 10/01/14 Prior to 10/01/14 SCOR Global Life Reinsurance Ireland Ltd. All other Certified Reinsurers 10/01/14 N/A On/after 10/01/14 but before 01/01/17 On/after 01/01/17 See previous page See previous page Prior to Certification Date On/after Certification Date Reporting Treatment Unauthorized Collateral Required 100%¹ Certified 50%² Unauthorized Certified Authorized Certified Authorized Unauthorized⁴ 100% 50% 100% 20%³ 100% 100% Lines All Certified All Other Certified All Other Certified All Other All All Authorized 100% Certified All Other All Certified All Other Certified All Other Certified Authorized Unauthorized Certified Unauthorized Certified Unauthorized 10% 100% 100% 20% 100% 10%⁵ 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. Receivables prior to 07/01/15 should be collateralized at 100% and reported as unauthorized (unless ceding insurers domiciled in Delaware have received notice that these recoverables have been rolled-in to Endurance Specialty’s MBT. If recoverables were rolled into a 100% MBT, they should be reported as authorized). 2. Endurance Specialty Insurance Limited became certified on July 1, 2015. Aon Benfield believes that all lines written by Endurance Specialty are eligible for reduced collateral (but there is no indication of certified lines on the DOI website). Therefore, all recoverables from contracts on or after this date should be reported as certified and only require 50% collateral. 3. On August 9, 2016, Endurance Specialty’s Secure-4 rating was upgraded to Secure-3. As a result, recoverables from contracts that incept on or after this date require only 20% collateral 4. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. 5. On January 1, 2017, SCOR Global Life Reinsurance Ireland Ltd.’s Scure-3 rating was upgraded to Secure-2. As a result, recoverables from contracts that incept on or after this date require only 10% collateral Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 36 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Florida Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Rollin Trusteed Date No N/A N/A Arch Reinsurance Ltd. No N/A N/A Aspen Bermuda Ltd. Yes Yes 06/06/12 Axis Specialty Limited Yes No 09/27/13 Certified Reinsurer Allied World Assurance Company, Ltd. Chubb Tempest Reinsurance Ltd. No DaVinci Reinsurance Ltd. Yes Endurance Specialty Insurance, Ltd. No N/A Yes N/A N/A 08/25/11 N/A Hannover Re (Bermuda) Ltd. No Hannover Ruck SE Yes No 10/16/00 Hiscox Insurance Company (Bermuda) Limited No N/A N/A Markel Bermuda Limited No N/A N/A N/A N/A Certification Date Rating Collateral Required Certified Lines 03/01/11 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty 03/31/11 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty 05/06/11 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty 05/23/11 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property Cat. Reins. 10/06/10 - 12/31/14 Secure -3 20% Property Cat. Reins. 01/01/15 - 07/27/15 Secure -2 10% Property Cat. Reins. 07/28/15 - Current Secure -2 10% Property / Casualty 06/01/11 - 07/27/15 Secure-3 20% Property Cat. Reins. 07/28/15 - Current Secure -4 50% Property / Casualty 05/31/12 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - 08/08/16 Secure -4 50% Property / Casualty 08/09/16 - Current Secure -3 20% Property / Casualty 09/21/10-12/31/14 Secure -3 20% Property Cat. Reins. 01/01/15 - 07/27/15 Secure -2 10% Property Cat. Reins. 07/27/15 - Current Secure -2 10% Property / Casualty 01/01/10 - 12/31/14 Secure -3 20% Property / Casualty 01/01/15 - Current Secure -2 10% Property / Casualty 11/04/10 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty 03/23/11 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 37 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Certified Reinsurer List as of December 2016 – Florida Continued Certified Reinsurer MS Frontier Reinsurance Limited Partner Reinsurance Company Ltd. Platinum Underwriters Bermuda, Ltd. Uses MBT? MBT Roll-in Trusteed Date No N/A N/A Yes Yes 11/04/10 No N/A N/A Renaissance Reinsurance Ltd. Yes Yes 06/29/11 Tokio Millennium Re AG No N/A N/A Underwriters at Lloyd’s, London Yes Yes 08/01/95 Validus Reinsurance, Ltd. No XL Bermuda Ltd. No N/A N/A N/A N/A Certification Date 06/13/13 - 07/27/15 Rating Secure -3 Collateral Required 20% Certified Lines Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty 11/04/10 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty 12/31/11 - 12/30/15 Secure-3 20% Property Cat. Reins. 12/31/15 - Current Secure -4 50% Property Cat. Reins. 12/29/10 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty 02/25/11 -07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty 10/06/11 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - Current Secure -3 20% Property / Casualty 06/01/12 - 07/27/15 Secure -3 20% Property Cat. Reins. 07/28/15 - 08/08/16 Secure -4 50% Property / Casualty 08/09/16 - Current Secure -3 20% Property / Casualty 06/17/10 - Current Secure -3 20% Property / Casualty Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 38 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Florida Certified Reinsurer Certification Date Date Trusteed Contract Inception Date Prior to 05/06/11 On/after 05/06/11 but before 07/28/15 Aspen Bermuda Ltd. 05/06/11 06/06/12 On/after 07/28/15 Prior to 05/23/11 Axis Specialty Limited On/after 05/23/11 but before 09/27/13 05/23/11 09/27/13 On/after 09/27/13 but before 07/28/15 On/after 07/28/15 Prior to 10/06/10 Chubb Tempest Reinsurance Ltd. On/after 10/06/10 but before 12/31/14 10/06/10 N/A On/after 01/01/15 but before 07/28/15 On/after 07/28/15 Prior to 06/01/11 DaVinci Reinsurance Ltd. 06/01/11 08/25/11 On/after 06/01/11 but before 07/28/15 On/after 07/28/15 Reporting Treatment Authorized Collateral Required 100% Property Cat Authorized or 1 Certified 100% if Authorized or 20% if Certified All Other Authorized 100% Property / Casualty Authorized or 1 Certified 100% if Authorized or 20% if Certified All Other All Property Cat All Other Property Cat All Other Property Cat All Other All Property Cat All Other Property Cat All Other Property / Casualty All Other All Property Cat All Other Property / Casualty All Other Authorized Unauthorized Certified Unauthorized Certified Authorized Certified Authorized Unauthorized Certified Unauthorized Certified Unauthorized Certified Authorized Authorized Certified Authorized Certified Authorized 100% 100% 20% 100% 20% 100% 20% 100% 100% 20% 100% 10%² 100% 10% 100% 100% 20% 100% 50%* 100% Lines All Notes: 1. Recoverables from Aspen Bermuda due to ceding insurers domiciled in Florida will be evaluated on a case-by-case basis to determine if reduced collateral will be applied (assuming the recoverables are due from contracts incepting on or after the certification date) or collateralized in our Multi-Beneficiary Trust at 100%. 2. On January 1, 2015, Chubb Tempest Reinsurance Ltd.'s Secure-3 rating was upgraded to Secure-2. As a result, recoverables from contracts that incept on or after this date require only 10% collateral. * On 07/28/15, Florida changed its Administrative Code. Reinsurer’s with an “A3” Moody’s rating have to provide 50% collateral as opposed to 20%. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 39 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Florida - Continued Certified Reinsurer Endurance Specialty Insurance, Ltd. Certification Date Date Trusteed Contract Inception Date Prior to 05/31/12 On/after 05/31/12 but before 07/28/15 05/31/12 N/A On/after 07/28/15 but before 08/09/16 On/after 08/09/16 Prior to 10/16/00 On/after 10/06/00 but before 01/01/10 Hannover Ruck SE 01/01/10 10/16/00 On/after 01/01/10 but before 01/01/15 On/after 01/01/15 Prior to 11/04/10 Partner Reinsurance Company Ltd. 11/04/10 Renaissance Reinsurance Ltd. 12/29/10 11/04/10 06/29/11 On/after 11/04/10 but before 07/28/15 On/after 07/28/15 Prior to 12/29/10 On/after 12/29/10 but before 07/28/15 On/after 07/28/15 Lines All Property Cat All Other Property / Casualty All Other Property / Casualty All Other All Reporting Treatment Unauthorized Certified Unauthorized Certified Unauthorized Certified Unauthorized Collateral Required 100% 20% 100% 50%* 100% 20%³ 100% 100% All Unauthorized⁴ Authorized 100% Property / Casualty All Other Property / Casualty All Other All Certified Authorized Certified Authorized Authorized 20% 100% 10%⁵ 100% 100% All Authorized⁶ 100% All All Property Cat All Other Property / Casualty All Other Authorized⁶ Authorized Certified Authorized Certified Authorized 100% 100% 20% 100% 20% 100% Notes: 3. On August 9, 2016, Endurance Specialty’s Secure-4 rating was upgraded to Secure-3. As a result, recoverables from contracts that incept on or after this date require only 20% collateral. 4. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this exhibit. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. 5. On February 2, 2015, Hannover Ruck SE's Secure-3 rating was upgraded to Secure-2. As a result, recoverables from contracts that incept on or after this date require only 10% collateral. 6. Partner Re has elected to provide 100% collateral for all recoverables through their MBT * On 07/28/15, Florida changed its Administrative Code. Reinsurer’s with an “A3” Moody’s rating have to provide 50% collateral as opposed to 20%. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 40 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Florida - Continued Certified Reinsurer Underwriters at Lloyd’s, London Certification Date 10/06/11 Date Trusteed 08/01/95 Contract Inception Date Prior to 08/01/95 All On/after 08/01/95 but before 10/06/11 All On/after 10/06/11 Prior to 06/01/12 Validus Reinsurance, Ltd. On/after 06/01/12 but before 07/28/15 08/10/12 N/A On/after 07/28/15 but before 08/09/16 On/after 08/09/16 XL Re Ltd. 06/17/10 N/A Prior to 06/17/10 On/after 06/17/10 Prior to Certification Date All other Certified Reinsurers See previous page See previous page Lines On/after Certification Date but before 07/28/15 On/after 07/28/15 Notes: Property / Casualty All Other All Property Cat All Other Property / Casualty All Other Property / Casualty All Other All Property / Casualty All Other Reporting Treatment Unauthorized (but could be Authorized)⁷ Collateral Required Most likely Authorized (but eligible for Certified)⁹ Most likely 100% (but eligible for 20%) Authorized⁸ 100% 100% Authorized Unauthorized Certified Unauthorized Certified Unauthorized Certified Unauthorized Unauthorized Certified Unauthorized 100% 100% 20% 100% 50%* 100% 20%¹⁰ 100% 100% 20% 100% All Unauthorized 100% Property Cat Certified See Previous Page All Other Unauthorized 100% Property / Casualty Certified See Previous Page All Other Unauthorized 100% 7. In most cases, recoverables from contracts that incepted before 08/01/95 are unauthorized. However, Lloyd’s has advised that some pre-08/01/95 recoverables have been rolled-in to MBTs, which requires authorized reporting treatment. Lloyd’s has stated that NY domiciled ceding insurers should have been made aware of any of these exceptions. 8. Recoverables from contracts that incepted on or after 08/01/95 until 10//06/11 should be reported as authorized (100% collateral required.) 9. Post certification, most Lloyd's syndicates are providing 100% collateral for all recoverables through their MBT. Ceding insurers will be notified and provided with a LOC or Single Beneficiary Trust, if a syndicate elects to provide a reduced amount of collateral. 10. On August 9, 2016, Validus Reinsurance, Ltd.'s Secure-4 rating was upgraded to Secure-3. As a result, recoverables from contracts that incept on or after this date require only 20% collateral. * On 07/28/15, Florida changed its Administrative Code. Reinsurer’s with an “A3” Moody’s rating have to provide 50% collateral as opposed to 20%. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 41 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Georgia Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? No MBT Roll-in N/A Trusteed Date N/A Certification Date 08/28/15 Rating Secure-3 Collateral Required 20% Certified Lines Property / Casualty Endurance Specialty Insurance Limited No N/A N/A 12/29/15 Secure-4¹ 50% Property / Casualty Hannover Ruck SE Yes No 03/14/96 04/17/14 Secure-2 10% Münchener RückversicherungsGesellshaft No N/A N/A 12/03/14 Secure-2 10% Tokio Millennium Re AG No N/A N/A 10/27/14 Secure-2 10% Certified Reinsurer Arch Reinsurance Ltd. Life, Annuities, A&H, Property / Casualty Life, Annuities, A&H, Property / Casualty Property / Casualty Notes: 1. The Georgia DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 42 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Georgia Certified Reinsurer Certification Date Date Trusteed Hannover Ruck SE 04/17/14 03/14/96 Contract Inception Date Prior to 03/14/96 On/after 03/14/96 but before 04/17/14 On/after 04/17/14 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 43 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Iowa Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? No MBT Roll-in N/A Trusteed Date N/A Certification Date 05/06/16 Rating Secure-3 Collateral Required 20% Certified Lines Not identified Endurance Specialty Insurance Limited No N/A N/A 12/14/15 Secure-4 50% Not identified Hannover Ruck SE Yes No 10/04/96 09/22/14 Secure-2 10% Not identified Certified Reinsurer Arch Reinsurance Ltd. Reporting Instructions: Iowa Certified Reinsurer Certification Date Date Trusteed Hannover Ruck SE 09/22/14 10/04/96 Contract Inception Date Prior to 10/04/96 On/after 10/04/96 but before 09/22/14 On/after 09/22/14 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 44 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Indiana Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Certified Reinsurer Arch Reinsurance, Ltd Chubb Tempest Reinsurance Ltd. Equator Reinsurances Ltd. Hannover Rück SE Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required No N/A N/A 11/18/16 Secure-3 20% No N/A N/A 01/01/16 Secure-2 10% No N/A N/A 01/01/16 Secure-3 20% Property / Casualty Yes No 02/21/96 03/15/16 Secure-2 10% Life, Annuities, A&H, Property / Casualty Certified Lines Life, Annuities, A&H, Property / Casualty Life, Property / Casualty Reporting Instructions: Indiana Certified Reinsurer Certification Date Date Trusteed Hannover Rück SE 03/15/16 02/21/96 Contract Inception Date Prior to 02/21/96 On/after 02/21/96 but before 03/15/16 On/after 03/15/16 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 45 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Louisiana Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required Certified Lines No N/A N/A 12/09/14 Secure-2 10% Not identified Arch Reinsurance Ltd No N/A N/A 10/01/14 Secure-3 20% Not identified Endurance Specialty Insurance Ltd. No N/A N/A 02/05/16 Secure-4¹ 50% Not identified Hannover Rueck SE Yes No 12/15/09 10/01/14 Secure-2 10% Not identified Certified Reinsurer ACE Tempest Reinsurance Ltd Notes: 1. The Louisiana DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. Reporting Instructions: Louisiana Certified Reinsurer Certification Date Date Trusteed Hannover Rueck SE 10/01/14 12/15/09 Contract Inception Date Prior to 12/15/09 On/after 12/15/09 but before 10/01/14 On/after 10/01/14 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 46 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Maine Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? No MBT Roll-in N/A Trusteed Date N/A Certification Date 02/18/15 Rating Secure-3 Collateral Required 20% Certified Lines Not identified Endurance Specialty Insurance Ltd No N/A N/A 10/29/15 Secure-4¹ 50% Not identified Hannover Rück Yes No 01/10/96 05/15/15 Secure-2 10% Not identified Certified Reinsurer Arch Reinsurance Ltd Notes: 1. The Maine DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. Reporting Instructions: Maine Certified Reinsurer Hannover Rück Certification Date Date Trusteed 05/15/15 01/10/96 Contract Inception Date Prior to 01/10/96 On/after 01/10/96 but before 05/15/15 On/after 05/15/15 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 47 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Maryland Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Certified Reinsurer Arch Reinsurance Ltd Legal & General Assurance Society Limited Hannover Ruck SE Uses MBT? No MBT Roll-in N/A Trusteed Date N/A Certification Date 07/01/16 Rating Secure-3 Collateral Required 20% Certified Lines Not identified No N/A N/A 12/10/14 Secure-2 10% Not identified Yes No 08/21/98 03/27/15 Secure-2 10% Not identified Reporting Instructions: Maryland Certified Reinsurer Certification Date Date Trusteed Hannover Ruck SE 03/27/15 08/21/98 Contract Inception Date Prior to 08/21/98 On/after 08/21/98 but before 03/27/15 On/after 03/27/15 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 48 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Missouri Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required No N/A N/A 07/01/16 Secure-3 20% Arch Reinsurance Ltd. (Bermuda) No N/A N/A 01/01/14 Secure-3 20% Endurance Specialty Insurance, Ltd Yes N/A 04/01/16 01/01/16 Secure-4¹ 50% Hannover Rück SE Yes No 08/06/99 01/01/15 Secure-2 10% A&H, Property / Casualty No N/A N/A 10/01/16 Secure-2 10% Life, Annuities, A&H No N/A N/A 10/01/16 Secure-5 75% Property / Casualty No N/A N/A 10/01/14 Secure-3 20% Life, Annuities, A&H Swiss Re Company Ltd. No N/A N/A 01/01/14 Secure-2 10% Swiss Re Corporate Solutions Ltd. No N/A N/A Secure-3 20% N/A N/A 01/01/14 12/31/16 01/01/17 - Current Secure-2 10% Tokio Millennium AG No N/A N/A 07/01/15 Secure-3 20% Wilton Reinsurance Bermuda, LTD No N/A N/A 01/01/16 Secure-3 20% Certified Reinsurer American International Reinsurance Company, Ltd. Legal and General Assurance Society, Ltd. Maiden Reinsurance Company, Ltd. RGA Americas Reinsurance Co. Ltd. Certified Lines Life, Annuities, A&H, Property / Casualty Life, Annuities, A&H, Property / Casualty Property / Casualty Life, Annuities, A&H, Property / Casualty Life, Annuities, A&H, Property / Casualty Property / Casualty Life, Annuities Notes: 1. The Missouri DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 49 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Missouri Certified Reinsurer Endurance Specialty Insurance Ltd Certification Date Date Trusteed 01/01/16 04/01/16 Contract Inception Date Prior to 01/01/16 On/after 01/01/16 but before 04/01/16 On/after 04/01/16 Prior to 08/06/99 Hannover Rück SE 01/01/15 08/06/99 On/after 08/06/99 but before 01/01/15 On/after 01/01/15 Prior to 01/01/14 Swiss Re Corporate Solutions Ltd. All other Certified Reinsurers 01/01/14 N/A On/after 01/01/14 but before 01/01/17 On/after 01/01/17 See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% Property / Casualty Certified 50% All Other Unauthorized 1 100% Property / Casualty All Other All Certified Authorized Unauthorized² 50% 100% 100% All Authorized 100% Certified All Other All Certified All Other Certified All Other Certified Authorized Unauthorized Certified Unauthorized Certified Authorized 10% 100% 100% 20% 100% 10%³ 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. Endurance Specialty recoverables from contracts incepting prior to 01/01/16 should be reported as unauthorized, unless these recoverables have been rolled-in to an MBT. 2. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. 3. On January 1, 2017, Swiss Re Corporate Solutions Ltd.'s Secure-3 rating was upgraded to Secure-2. As a result, recoverables from contracts that incept on or after this date require only 10% collateral. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 50 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Nebraska Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Certified Reinsurer Arch Reinsurance Ltd. Hannover Rück SE Münchener RückversicherungsGesellschaft Aktiengesellschaft in München (Munich Re) Uses MBT? No Yes MBT Roll-in N/A No Trusteed Date N/A 10/22/96 Certification Date 08/23/16 06/20/16 Rating Secure-3 Secure-2 Collateral Required 20% 10% Certified Lines Not identified Not identified No N/A N/A 12/24/15 Secure-2 10% Not identified Reporting Instructions: Nebraska Certified Reinsurer Certification Date Date Trusteed Hannover Rück SE 06/20/16 10/22/96 Contract Inception Date Prior to 10/22/96 On/after 10/22/96 but before 06/20/16 On/after 06/20/16 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment Unauthorized¹ Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 51 Aon Benfield Analytics | Market Analysis Proprietary and Confidential New Hampshire Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required Certified Lines No N/A N/A 07/01/14 Secure-3 20% Not identified Arch Reinsurance Ltd No N/A N/A No N/A N/A Hannover Rück SE Yes No 07/17/97 Swiss Re Corporate Solutions, Ltd No N/A N/A Secure-3 Secure-4 Secure-3 Secure-2 Secure-3 Secure-2 20% 50% 20% 10% 20% 10% Not identified Endurance Specialty Insurance Ltd. 07/01/14 10/27/15 - 12/31/16 01/01/17 - Current 07/01/14 1/1/2014 - 12/31/16 01/01/17 - Current Swiss Reinsurance Company, Ltd No N/A N/A 01/01/14 Secure-2 10% Not identified Validus Reinsurance, Ltd Yes Yes 10/22/15 7/1/2016 - 12/31/16 01/01/17 - Current Secure-4 Secure-3 50% 20% Not identified Certified Reinsurer Allied World Assurance Company, Ltd Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential Not identified Not identified Not identified 52 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: New Hampshire Certified Reinsurer Endurance Specialty Insurance Ltd. Certification Date Date Trusteed 10/27/15 N/A Contract Inception Date Prior to 10/27/15 On/after 10/27/15 but before 01/01/17 On/after 01/01/17 Prior to 07/17/97 Hannover Rück SE 07/01/14 07/17/97 On/after 07/17/97 but before 07/01/14 On/after 07/01/14 Prior to 01/01/14 Swiss Re Corporate Solutions, Ltd 01/01/14 N/A On/after 01/01/14 but before 01/01/17 On/after 01/01/17 Prior to 07/01/16 Validus Reinsurance, Ltd All other Certified Reinsurers 07/01/16 See previous page 10/22/15 See previous page On/after 07/01/16 Prior to Certification Date On/after Certification Date Lines All Certified All Other Certified All Other All Reporting Treatment Unauthorized Certified Unauthorized Certified Authorized Unauthorized² Collateral Required 100% 50% 100% 20%¹ 100% 100% All Authorized 100% Certified All Other All Certified All Other Certified All Other All Certified Authorized Unauthorized Certified Unauthorized Certified Authorized Authorized 10% 100% 100% 20% 100% 10%³ 100% 100% Certified Authorized (but eligible for Certified)⁴ 100% All Other Authorized 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. On January 1, 2017, Endurance Specialty’s Secure-4 rating was upgraded to Secure-3. As a result, recoverables from contracts that incept on or after this date require only 20% collateral. 2. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. 3. On January 1, 2017, Swiss Re Corporate Solutions, Ltd’s Secure-3 rating was upgraded to Secure-2. As a result, recoverables from contracts that incept on or after this date require only 10% collateral. 4. Recoverables from Validus Reinsurance Ltd. due to ceding insurers domiciled in New Hampshire are currently all being collateralized at 100% in their full collateral MBT. However, this practice could change in 2017. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 53 Aon Benfield Analytics | Market Analysis Proprietary and Confidential New Jersey Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? No MBT Roll-in N/A Trusteed Date N/A Certification Date 11/23/15 Rating Secure-3 Collateral Required 20% Certified Lines Not identified Chubb Tempest Reinsurance Ltd. No N/A N/A 10/08/13 Secure-2 10% Not identified Endurance Specialty Insurance Ltd No N/A N/A 11/01/16 Secure-3 20% Not identified Hannover Rück SE Yes No 08/05/02 10/31/13 Secure-2 10% Not identified Hiscox Insurance Company (Bermuda) Limited No N/A N/A 12/05/13 Secure-3 20% Not identified Tokio Millennium Re AG No N/A N/A 4/30/14 - 9/28/15 9/29/15 - Current Secure-2 Secure-3 10% 20% Not identified Certified Reinsurer Arch Reinsurance Ltd. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 54 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: New Jersey Certified Reinsurer Certification Date Date Trusteed Hannover Rück SE 10/31/13 08/05/02 Contract Inception Date Prior to 08/05/02 On/after 08/05/02 but before 10/31/13 On/after 10/31/13 Prior to 04/30/14 Tokio Millennium Re AG 04/30/14 N/A On/after 04/30/14 but before 09/29/15 On/after 9/29/15 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other All Certified Authorized Unauthorized 10% 100% 100% Certified Certified 10% All Other Unauthorized Certified Certified All Other Unauthorized 100% 20%² 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. 2. On September 29, 2015, Tokio Millennium Re AG's Secure-2 rating was downgraded to Secure-3. As a result, recoverables from contracts that incept on or after this date require 20% collateral. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 55 Aon Benfield Analytics | Market Analysis Proprietary and Confidential New York Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: Assured Guaranty Re Ltd.’s certified reinsurer status expired effective April 8, 2015. Montpelier Reinsurance Ltd. (Bermuda)'s certified reinsurer status was terminated effective December 31, 2015, as the result of a merger. Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required No N/A N/A 07/01/11 Secure-3 20% No N/A N/A 07/01/11 Secure-3 20% No N/A N/A 07/01/11 Secure-3 20% Chubb Tempest Reinsurance, Ltd No N/A N/A 01/01/11 Secure-2 10% Commonwealth Annuity and Life Insurance Company No N/A N/A 07/01/12 07/27/16 07/28/16 Current Secure-5 75% Secure-4 50% Everest Reinsurance (Bermuda) Ltd. No N/A N/A 07/01/12 Secure-3 20% General American Life Insurance Company No N/A N/A 07/01/14 Secure-2 10% Secure-3 20% Secure-2 10% Secure-3 20% Secure-2 10% Certified Reinsurer Allied World Assurance Company Ltd. Arch Reinsurance Ltd (Bermuda) Aspen Bermuda Limited 01/01/11 09/17/12 09/18/12 Current 01/01/11 09/17/12 09/18/12 Current Certified Lines Property / Casualty Property / Casualty Property / Casualty Life, Annuities, A&H, Property / Casualty Life, Annuities, A&H, Property / Casualty Life, Annuities, Endowments, A&H, Variable Contracts Hannover Re (Bermuda) Ltd No N/A N/A Hannover Rück SE Yes No 12/21/95 Hiscox Insurance Company (Bermuda) Limited No N/A N/A 07/01/11 Secure-3 20% Property / Casualty Legal & General Assurance Society Limited No N/A N/A 07/01/12 Secure-2 10% Life, Annuities, A&H, Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential Property / Casualty Life, Annuities, A&H, Property / Casualty 56 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Certified Reinsurer List as of December 2016 – New York Continued Uses MBT? MBT Roll-in Trusteed Date Markel Bermuda Limited (f/k/a Alterra Bermuda Limited) No N/A N/A Mitsui Sumitomo Insurance Company No N/A N/A MS Frontier Reinsurance Ltd. No N/A Münchener RückversicherungsGesellshaft Aktiengesellschaft No N/A Partner Reinsurance Company Ltd Yes Swiss Re Corporate Solutions Ltd. No Certified Reinsurer Certification Date 07/01/11 05/28/14 05/29/14 Current Rating Collateral Required Secure-4 50% Secure-3 20% 01/01/15 Secure-3 20% Property / Casualty 07/01/12 Secure-3 20% Property / Casualty N/A 07/01/15 Secure-2 10% Life, Annuities, A&H, Property / Casualty Yes 06/08/10 01/01/11 Secure-3 20% Property / Casualty N/A N/A 07/01/15 Secure-3 20% Property / Casualty Secure-3 20% Secure-2 10% Life, Annuities, A&H, Property / Casualty Certified Lines Property / Casualty No N/A N/A 01/01/1106/30/14 07/01/14 Current No N/A N/A 07/01/11 Secure-3 20% Property / Casualty No N/A N/A 07/01/14 Secure-3 20% Property / Casualty Yes Yes 04/22/97 01/01/11 Secure-3 20% Property / Casualty United Healthcare Insurance Company No N/A N/A 07/01/13 Secure-3 20% Wilton Reassurance Company No N/A N/A 07/01/11 Secure-3 20% No N/A N/A 07/01/11 Secure-3 20% Life, Annuities No N/A N/A 01/01/11 Secure-3 20% Property / Casualty Swiss Reinsurance Company Ltd. Tokio Millennium Re AG TransRe London Limited Underwriters at Lloyd's, London Wilton Reinsurance Bermuda Limited XL Bermuda Ltd. (f/k/a XL Insurance (Bermuda) Ltd and XL Re Ltd.) Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential Life, A&H, Workmen's Compensation Life, Annuities, A&H 57 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: New York Certified Reinsurer Aspen Bermuda Limited Commonwealth Annuity and Life Insurance Company Certification Date 07/01/11 07/01/12 Date Trusteed N/A N/A Contract Inception Date Prior to 07/01/11 Lines All Reporting Treatment Unauthorized Collateral Required 100% On/after 07/01/11 Property / Casualty Authorized or Certified¹ 100% if Authorized or 20% if Certified Prior to 07/01/12 All Other All Unauthorized Unauthorized 100% 100% Certified Certified 75% All Other Certified All Other All Unauthorized Certified Unauthorized Unauthorized 100% 50%² 100% 100% Certified Certified 20% All Other Certified All Other All Unauthorized Certified Unauthorized 100% On/after 07/01/12 but before 07/28/16 On/after 07/28/16 Prior to 01/01/11 Hannover Re (Bermuda) Ltd 01/01/11 N/A On/after 01/01/11 but before 09/18/12 On/after 09/08/12 Prior to 12/21/95 On/after 12/21/95 but before 01/01/11 Hannover Rück SE 01/01/11 12/21/95 On/after 01/01/11 but before 09/18/12 On/after 09/18/12 10%³ 100% 100% All Unauthorized⁴ Authorized 100% Certified Certified 20% All Other Certified All Other Authorized Certified Authorized 100% 10%³ 100% Notes: 1. Recoverables from Aspen Bermuda due to ceding insurers domiciled in New York will be evaluated on a case-by-case basis to determine if reduced collateral will be applied (assuming the recoverables are due from contracts incepting on or after the certification date) or collateralized in our Multi-Beneficiary Trust at 100%. 2. On July 28, 2016, Commonwealth Annuity and Life Insurance Company's Secure-5 rating was upgraded to Secure-4. As a result, recoverables from contracts that incept on or after this date require 50% collateral. 3. On September 18, 2012, Hannover Re (Bermuda) Ltd and Hannover Rück SE's Secure-3 rating was upgraded to Secure-2. As a result, recoverables from contracts that incept on or after this date require 10% collateral. 4. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this exhibit. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 58 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: New York - Continued Certified Reinsurer Certification Date Date Trusteed 07/01/11 N/A Markel Bermuda Limited (f/k/a Alterra Bermuda Limited) Contract Inception Date Prior to 07/01/11 On/after 07/01/11 but before 05/29/14 On/after 05/29/14 Prior to 01/01/11 Partner Reinsurance Company Ltd 01/01/11 06/08/10 On/after 01/01/11 Prior to 01/01/11 Swiss Reinsurance Company Ltd. 01/01/11 N/A On/after 01/01/11 but before 07/01/14 On/after 07/01/14 Lines All Lines Reporting Treatment Unauthorized Collateral Required 100% Certified Lines Certified 50% All Other Lines Certified Lines All Other Lines All Unauthorized Certified Unauthorized 100% Authorized⁶ 20%⁵ 100% 100% Authorized (but eligible for Certified)⁷ 100% (but eligible for 20%) Authorized Unauthorized 100% 100% Certified Certified 20% All Other Certified All Other Unauthorized Certified Unauthorized 100% Certified All Other All 10%⁸ 100% Notes: 5. On May 29, 2014, Markel Bermuda Limited's Secure-4 rating was upgraded to Secure-3. As a result, recoverables from contracts that incept on or after this date require 20% collateral. 6. Partner Re has completed a roll-in of existing recoverables into their MBT, so all recoverables prior to 01/01/11 should be reported as authorized. 7. Partner Re has elected to provide 100% collateral for all certified recoverables through their full collateral MBT and therefore all recoverables should be reported as authorized 8. On July 1, 2014, Swiss Reinsurance Company Ltd.'s Secure-3 rating was upgraded to Secure-2. As a result, recoverables from contracts that incept on or after this date require 10% collateral. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 59 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: New York – Continued Certified Reinsurer Certification Date Underwriters at Lloyd’s, London 01/01/11 Date Trusteed 04/22/97 Contract Inception Date See previous page See previous page Collateral Required Authorized¹⁰ 100% Property / Casualty Most likely Authorized (but eligible for Certified)¹¹ Most likely 100% (but eligible for 20%) All Other Authorized 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Prior to 04/22/97 All On/after 04/22/97 but before 01/01/11 All On/after 01/01/11 All other Certified Reinsurers Reporting Treatment Unauthorized (but could be Authorized)⁹ Lines Prior to Certification Date On/after Certification Date 100% Notes: 9. In most cases, recoverables from contracts that incepted before 04/22/97 are unauthorized. However, Lloyd’s has advised that some recoverables from contracts that incepted prior to 04/22/97 have been rolled-in to MBTs, which requires authorized reporting treatment. Lloyd’s has stated that NY domiciled ceding insurers should have been made aware of any of these exceptions. 10. Recoverables from contracts that incepted on or after 04/22/97 until 12//01/14 should be reported as authorized (100% collateral required.) 11. Post certification, most Lloyd's syndicates are providing 100% collateral for all recoverables through their MBT and these recoverables should be reported as authorized. Ceding insurers will be notified and provided with a LOC or Single Beneficiary Trust, if a syndicate elects to provide a reduced amount of collateral. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 60 Aon Benfield Analytics | Market Analysis Proprietary and Confidential North Dakota Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? No Yes MBT Roll-in N/A Yes Trusteed Date N/A 08/21/12 Certification Date 08/05/16 01/01/16 Rating Secure-3 Secure-3 Collateral Required 20% 20% Certified Lines Not identified Not identified Endurance Specialty Insurance, Ltd. Yes N/A N/A 07/01/16 Secure-3 20% Not identified Equator Reinsurances Limited No N/A N/A 09/12/16 Secure-3 20% Not identified Hannover Ruck SE Yes No 07/31/96 04/29/16 Secure-2 10% Not identified Certified Reinsurer Arch Reinsurance, Ltd. Aspen Bermuda Limited Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 61 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: North Dakota Certified Reinsurer Aspen Bermuda Limited Certification Date Date Trusteed 01/01/16 08/21/12 Contract Inception Date Prior to 01/01/16 On/after 01/01/16 Prior to 07/31/96 Hannover Ruck SE 04/29/16 07/31/96 On/after 07/31/96 but before 04/29/16 On/after 04/29/16 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Reporting Treatment Authorized Collateral Required 100% Property Cat Authorized or Certified¹ 100% if Authorized or 20% if Certified All Other All Authorized Unauthorized² 100% 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Lines All Notes: 1. Recoverables from Aspen Bermuda due to ceding insurers domiciled in North Dakota will be evaluated on a case-bycase basis to determine if reduced collateral will be applied (assuming the recoverables are due from contracts incepting on or after the certification date) or collateralized in our Multi-Beneficiary Trust at 100%. 2. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 62 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Ohio Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Certified Reinsurer Arch Reinsurance, Ltd Endurance Specialty Insurance Ltd Hannover Rück SE Tokio Millennium Re AG Uses MBT? No MBT Roll-in N/A Trusteed Date N/A Certification Date 07/01/15 Rating Secure-3 Collateral Required 20% Certified Lines Not identified No N/A N/A 01/01/16 Secure-4¹ 50% Not identified Yes No 12/31/96 07/01/15 Secure-2 10% Not identified No N/A N/A 01/01/16 Secure-3 20% Not identified Notes: 1. The Ohio DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. Reporting Instructions: Ohio Certified Reinsurer Certification Date Date Trusteed Hannover Rück SE 07/01/15 12/31/96 Contract Inception Date Prior to 12/31/96 On/after 12/31/96 but before 07/01/15 On/after 07/01/15 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Reporting Treatment 1 Unauthorized Collateral Required 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 63 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Pennsylvania Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date 07/01/14 - 12/31/16 01/01/17 - Current Rating Secure-3 Secure-2 Collateral Required 20% 10% No N/A N/A ACE Reinsurance (Switzerland) Ltd No N/A N/A 01/01/15 Secure-2 10% Not identified Arch Reinsurance Ltd No N/A N/A 12/01/14 Secure-3 20% Not identified No N/A N/A 07/01/14 Secure-2 10% Not identified No N/A N/A 06/19/14 Secure-3 20% Not identified Yes No 02/16/96 12/01/14 Secure-2 10% Not identified Münchener RückversicherungsGesellschaft Aktiengesellschaft in München (Munich Re) No N/A N/A 07/01/15 Secure-2 10% Not identified Swiss Reinsurance Co Ltd No N/A N/A 10/01/14 Secure-2 10% Not identified Tokio Millennium Re AG No N/A N/A 07/01/15 Secure-3 20% Not identified Underwriters at Lloyd's London Yes Yes 04/22/97 12/01/14 Secure-3 20% Not identified Certified Reinsurer ACE INA Overseas Insurance Company Chubb Tempest Reinsurance Ltd. Equator Reinsurance Ltd Hannover Rueck SE Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential Certified Lines Not identified 64 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Pennsylvania Certified Reinsurer ACE INA Overseas Insurance Company Certification Date 07/01/14 Date Trusteed N/A Contract Inception Date Prior to 07/01/14 Lines All Reporting Treatment Unauthorized Collateral Required 100% Certified Certified 20% All Other Certified All Other All Unauthorized Certified Unauthorized Unauthorized² 100% 10%¹ 100% 100% All Authorized 100% On/after 12/01/14 Certified All Other Certified Authorized 10% 100% Prior to 04/22/97 All Unauthorized (but could be Authorized)³ 100% On/after 04/22/97 but before 12/01/14 All Authorized⁴ 100% Property / Casualty Most likely Authorized (but eligible for Certified)⁵ Most likely 100% (but eligible for 20%) All Other Authorized 100% All Unauthorized 100% Certified Certified All Other Unauthorized On/after 07/01/14 but before 01/01/17 On/after 01/01/17 Hannover Rueck SE Underwriters at Lloyd’s, London 12/01/14 12/01/14 02/16/96 04/22/97 Prior to 02/16/96 On/after 02/16/96 but before 12/01/14 On/after 12/01/14 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date See Previous Page 100% Notes: 1. On January 1, 2017, ACE INA Overseas Insurance Company's Secure-3 rating was upgraded to Secure-2. As a result, recoverables from contracts that incept on or after this date require only 10% collateral. 2. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. 3. In most cases, recoverables from contracts that incepted before 04/22/97 are unauthorized. However, Lloyd’s has advised that some pre-04/22/97 recoverables have been rolled-in to MBTs, which requires authorized reporting treatment. Lloyd’s has stated that NY domiciled ceding insurers should have been made aware of any of these exceptions. 4. Recoverables from contracts that incepted on or after 04/22/97 until 12//01/14 should be reported as authorized (100% collateral required.) 5. Post certification, most Lloyd's syndicates are providing 100% collateral for all recoverables through their MBT. Ceding insurers will be notified and provided with a LOC or Single Beneficiary Trust, if a syndicate elects to provide a reduced amount of collateral. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 65 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Rhode Island Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? No MBT Roll-in N/A Trusteed Date N/A Certification Date 04/08/15 Rating Secure-3 Collateral Required 20% Certified Lines Property / Casualty Endurance Specialty Insurance Ltd. Yes N/A 09/15/16 12/29/15 Secure-4¹ 50% Property / Casualty Hannover Ruck SE Yes No 12/10/96 04/13/15 Secure-2 10% Swiss Reinsurance Company Ltd. No N/A N/A 06/21/16 Secure-2 10% Tokio Millennium Re AG No N/A N/A 07/07/15 Secure-3 20% Property / Casualty Life, Annuities, A&H, Property / Casualty Multi-Peril Crop, Crop & Hail, Property Cat, Terrorism Cat and Workers Comp Cat Certified Reinsurer Arch Reinsurance Ltd Notes: 1. The Rhode Island DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 66 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Rhode Island Certified Reinsurer Endurance Specialty Insurance Ltd. Hannover Ruck SE All other Certified Reinsurers Certification Date Date Trusteed 12/29/15 09/15/16 04/13/15 12/10/96 Contract Inception Date Prior to 12/29/15 Lines All Property / Casualty Reporting Treatment 1 Unauthorized Certified Collateral Required 100% 50%² All Other Unauthorized 100% On/after 09/15/16 Property / Casualty All Other Certified Authorized Prior to 12/10/96 All Unauthorized On/after 12/10/96 but before 04/13/15 All Authorized 100% Certified All Other Certified Authorized 10% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% On/after 12/29/15 but before 09/15/16 On/after 04/13/15 See previous page See previous page Prior to Certification Date On/after Certification Date 1 50%² 100% ³ 100% Notes: 1. Endurance Specialty recoverables from contracts incepting prior to 12/2915 should be reported as unauthorized, unless these recoverables have been rolled-in to an MBT. 2. The Rhode Island DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. 3. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this exhibit. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 67 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Vermont Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required Arch Reinsurance Ltd. No N/A N/A 12/14/15 Secure-3 20% Endurance Specialty Insurance Ltd. No N/A N/A 11/3/2015 - 08/08/16 08/09/16 - Current Secure-4 Secure-3 50% 20% Hannover Rück SE Yes No 02/15/96 10/26/15 Secure-2 10% Wilton Re Bermuda No N/A N/A 01/01/16 Secure-3 20% Certified Reinsurer Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential Certified Lines Life, Annuities, A&H, Property / Casualty Property / Casualty Property / Casualty Life / Annuities 68 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Reporting Instructions: Vermont Certified Reinsurer Endurance Specialty Insurance Ltd. Certification Date Date Trusteed Contract Inception Date Prior to 11/03/15 On/after 11/03/15 but before 12/29/15 11/03/15 N/A On/after 12/29/15 but before 08/09/16 On/after 08/09/16 Prior to 02/12/96 Hannover Rück SE 10/26/15 02/12/96 On/after 02/12/96 but before 10/26/15 On/after 10/26/15 All other Certified Reinsurers See previous page See previous page Prior to Certification Date On/after Certification Date Lines All Certified All Other Certified All Other Certified All Other All Reporting Treatment Unauthorized Certified Unauthorized Certified Authorized Certified Authorized Unauthorized² Collateral Required 100% 50% 100% 50% 100% 20%¹ 100% 100% All Authorized 100% Certified All Other Certified Authorized 20% 100% All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% Notes: 1. On August 9, 2016, Endurance Specialty Insurance Ltd.’s Secure-4 rating was upgraded to Secure-3. As a result, recoverables from contracts that incept on or after this date require only 20% collateral. 2. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 69 Aon Benfield Analytics | Market Analysis Proprietary and Confidential Virginia Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? No MBT Roll-in N/A Trusteed Date N/A Certification Date 10/07/14 Rating Secure-3 Collateral Required 20% Certified Lines Not identified Endurance Specialty Insurance Ltd. Yes N/A N/A 01/05/16 Secure-4¹ 50% Not identified Swiss Reinsurance Company, Ltd No N/A N/A 12/17/14 Secure-2 10% Not identified Certified Reinsurer Arch Reinsurance Ltd. Notes: 1. The Virginia DOI still lists Endurance Specialty as a Secure-4 certified reinsurer (50% collateral required). However, Endurance Specialty was upgraded by Moody’s from A3 to A2 and technically should be assigned a Secure-3 certified reinsurer (20% collateral required). Ceding insurers should check with Endurance Specialty Limited and the DOI of their state of domicile to confirm reporting for year-end 2016. Reporting Instructions: Virginia Certified Reinsurer All Certified Reinsurers Certification Date See previous page Date Trusteed See previous page Contract Inception Date Prior to Certification Date On/after Certification Date Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential Lines Reporting Treatment Collateral Required All Unauthorized 100% Certified Certified See Previous Page All Other Unauthorized 100% 70 Aon Benfield Analytics | Market Analysis Washington Property Catastrophe Events Eligible for the Collateral Deferral: None identified (Check with State of Domicile Insurance Department as needed) Certified Reinsurer Retirements or Status Subject to Revocation: None Certified Reinsurer List as of December 2016 (Includes new certified reinsurers, rating upgrades and downgrades) Uses MBT? MBT Roll-in Trusteed Date Certification Date Rating Collateral Required Arch Reinsurance (Bermuda), Ltd. No N/A N/A 11/06/16 Secure-3 20% Hannover Rück SE Yes No 06/09/98 05/03/16 Secure-2 10% Certified Reinsurer Certified Lines Life, Annuities, A&H, Property / Casualty Life, Annuities, A&H, Property / Casualty Reporting Instructions: Washington Certified Reinsurer Arch Reinsurance (Bermuda), Ltd. Certification Date Date Trusteed 11/06/16 N/A Contract Inception Date Prior to 11/06/16 On/after 11/06/16 Prior to 06/09/98 Hannover Rück SE 05/03/16 06/09/98 On/after 06/09/98 but before 05/03/16 On/after 05/03/16 Lines All Certified All Other All Reporting Treatment Unauthorized Certified Unauthorized Unauthorized¹ Collateral Required 100% 20% 100% 100% All Authorized 100% Certified All Other Certified Authorized 10% 100% Notes: 1. For the majority of ceding insurers, recoverables due from Hannover Rueck SE should be reported as outlined in this table. However, Hannover Rueck SE has advised that in some cases, recoverables for a small number of U.S. ceding insurers were rolled into their full collateral MBT. In these select cases, all recoverables emanating prior to the Date Trusteed should be reported as authorized. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 71 Aon Benfield Analytics | Market Analysis Appendix II: The Credit for Reinsurance Model Law and Regulation Background on U.S. Collateral Reform The NAIC’s Solvency Modernization Initiative began in June 2008 as a critical examination of the U.S. insurance solvency regulation framework focusing on five solvency areas, one of which is reinsurance. In the winter of 2008, the NAIC’s Reinsurance Task Force developed a Reinsurance Framework with a goal of facilitating reinsurance transactions to enhance competition. As part of this initiative, the Reinsurance Task Force explored the possibility of relaxing collateral standards for some classes of nonU.S. assuming insurers. As a result, the Reinsurance Task Force introduced a number of amendments to the NAIC Credit for Reinsurance Model Law (#785) and Regulation (#786). These draft amendments were discussed and debated by regulators, U.S. ceding insurers, reinsurers and other interested parties. The draft amendments were modified to some extent based on the feedback and recommendations of all the parties involved in the discussions. In late 2011, the NAIC Executive Committee and Plenary unanimously approved the proposed revisions to the Credit for Reinsurance Model Law and Regulation. This Model Law and Regulation is intended to serve as the standard for states that wish to enact reduced collateral regulations. The key aspects of the Credit for Reinsurance Model Law and Regulation are outlined in the remaining parts of Appendix II. To be eligible for reduced collateral, reinsurers must apply in each state and meet certain minimum requirements including: 1. Have a minimum specified amount of capital and surplus as determined by the State Insurance Commissioner. The Model Regulation specifies a minimum of USD 250mn. 2. Be domiciled in a “Qualified Jurisdiction”. The NAIC is maintaining a list of Qualified Jurisdictions through a committee process which considers the reinsurer’s domiciliary regulatory system, reciprocity of information sharing and several other factors. 3. Be authorized in their domiciliary jurisdiction to assume the line(s) of business for which they are seeking certification. 4. Maintain a secure financial strength rating from at least two statistical rating organizations deemed acceptable by the commissioner. The Model Regulation specifically lists four rating organizations (A.M. Best, Fitch, Moody's and Standard & Poor’s), which implies these organizations are acceptable. A reinsurer who has applied for and is approved for reduced collateral by a state regulator will be classified as a “certified reinsurer”. States certifying reinsurers will use the financial strength ratings to assign a rating which will then determine the percentage of collateral required. The ratings scale is shown on the following page. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 72 Aon Benfield Analytics | Market Analysis Certified Reinsurer Ratings Scale Rating Secure-1 Secure-2 Secure-3 Secure-4 Secure-5 Collateral Required 0% 10% 20% 50% 75% Vulnerable-6 100% A.M. Best A++ A+ A AB++, B+ Ratings B and below S&P / Fitch Moody's AAA Aaa AA+, AA, AAAa1, Aa2, Aa3 A+, A A1, A2 AA3 BBB+, BBB, BBB- Baa1, Baa2, Baa3 Ratings BB+ Ratings Ba1 and below and below Collateral Deferral on Recognized Catastrophe Losses Under the Credit for Reinsurance Model Law and Regulation, certified reinsurers do not have to post any collateral for losses due from property catastrophe events recognized by the insurance regulator of the state. Property catastrophe losses are defined as losses from a catastrophe in one or more of the following statutory lines of business: Fire Allied Lines Farmowners Multiple Peril Homeowners Multiple Peril Commercial Multiple Peril Inland Marine Earthquake Auto Physical Damage Qualified Jurisdictions One of the requirements to become a certified reinsurer is that a reinsurer must be domiciled and licensed to transact insurance or reinsurance in a qualified jurisdiction. In 2013, the process for reviewing non-U.S. jurisdictions as qualified jurisdictions was finalized and a new Qualified Jurisdiction Working Group was developed and assigned with evaluating and approving international jurisdictions. The goal of the Qualified Jurisdiction Working Group was to develop a list of NAIC Qualified Jurisdictions, which then can be relied upon by the individual states. This NAIC listing relieves the individual states from conducting their own due diligence of non-U.S. jurisdictions. If a state approves a jurisdiction that does not appear on the NAIC Qualified Jurisdictions list, the state must thoroughly document the justification for its approval based on all the applicable criteria. The process to determine a qualified jurisdiction involves a review and evaluation of the jurisdiction’s: Laws, regulations, practices and procedures Regulatory cooperation, information sharing and reciprocity History of the performance of the domestic reinsurers Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 73 Aon Benfield Analytics | Market Analysis Restrictions on the enforcement of foreign judgments and information about reinsurers from the jurisdiction to propose or participate in any solvent scheme of arrangement or similar procedure In December 2014, the following seven jurisdictions were approved as qualified jurisdictions effective January 1, 2015: Bermuda - Bermuda Monetary Authority (BMA) France - French Autorité de Contrôle Prudentiel et de Résolution Germany - German Federal Financial Supervisory Authority Ireland - Central Bank of Ireland Japan - Financial Services Agency of Japan (FSA) Switzerland - Financial Market Supervisory Authority (FINMA) United Kingdom - United Kingdom's Prudential Regulation Authority of the Bank of England (PRA) These approved qualified jurisdictions will be reevaluated every 5 years, unless a significant change prompts an earlier reevaluation. Each jurisdiction has a lead state for purposes of regulatory cooperation and information sharing. Lead State California Connecticut Delaware Florida New York Jurisdictions Germany, Japan Switzerland Ireland Bermuda France, United Kingdom Reinsurance Financial Analysis Working Group (ReFAWG) In 2013, ReFAWG was developed and assigned with providing support to states in reviewing non-U.S. reinsurers for certification. If a state has approved a reinsurer for certification, ReFAWG will review the due diligence process of the approving state. If ReFAWG agrees with and accepts the state’s determination, other states could rely on the assessment without having to undertake their own review (a.k.a. passporting). ReFAWG has the authority to accept or reject the state’s determination, but not assign ratings or the associated collateral requirements. To date, ReFAWG has analyzed over 30 reinsurers. Many of these reinsurers were approved for passporting. Reinsurers approved for passporting will still have to apply for certification in each state. However, they will not have to include all the supporting documentation. Another benefit of passporting is that reinsurers will be eligible to provide the same amount of collateral in all states in which they are certified. Additional details on the Credit for Reinsurance Model Law and Regulation and U.S. collateral reform can be obtained by contacting Aon Benfield’s Market Analysis Team. Please see “Contacts” for additional information. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 74 Aon Benfield Analytics | Market Analysis Appendix III: Changes to Schedule F to Accommodate Certified Reinsurers Schedule F is intended to provide additional details about reinsurance cessions and assumptions. To accommodate the new class of certified reinsurers, a new Part 6 was developed in 2012. For 2016 yearend reporting, only ceding insurers domiciled in the aforementioned 25 states that have approved reinsurers for certification may need to complete the new Part 6. Schedule F consists of 9 Parts: Parts 1 through 3 provide a summary of all assumed and ceded reinsurance transactions and outstanding balances by ceding insurer or assuming reinsurer (including reinsurance ceded or cancelled on a portfolio basis) Parts 4 through 8 calculate the “provision for reinsurance” Part 9 restates the Balance Sheet on a gross basis As mentioned above, Parts 4 through 8 are designed to calculate the provision for reinsurance. The intent of the provision is to serve as a minimum reserve for uncollectible reinsurance. Under statutory accounting, most recoverables 90 days past due are non-admitted assets, unless they are collateralized. One exception to this rule is amounts recoverable from reinsurers. Instead of reclassifying reinsurance recoverables on paid losses over 90 days past due as non-admitted assets, statutory accounting imposes a liability against these recoverables (the provision for reinsurance). The provision, in effect, offsets the value of the amounts recoverable from reinsurers. A provision may be calculated for disputed recoverables, overdue recoverables or uncollateralized recoverables. The amount of the provision may be influenced by whether the recoverables emanate from an authorized, unauthorized or certified reinsurer. Below are the 9 Parts of Schedule F: Part 1: Assumed Reinsurance – Identifies all ceding companies from whom the reporting entity assumes business – Ceding companies with balances (paid and unpaid loss & loss adjustment expenses (LAE) less than $ 100,000 may be aggregated) Part 2: Portfolio Reinsurance – Lists any portfolio reinsurance effected or cancelled during the year (assumed or ceded) Part 3: Ceded Reinsurance – Identifies all cessions (ceded written premium) to reinsurers during the calendar year – Identifies all reinsurers with outstanding recoverables (paid and unpaid losses, loss adjustment expenses (LAE) and unearned premiums) and payables – Unaffiliated reinsurers may be aggregated if ceded written premiums and total reinsurance recoverables are less than $ 100,000 and no recoverables are more than 90 days past due Part 4: Aging of Ceded Reinsurance – Ages reinsurance recoverables on paid losses and LAE Part 5: Provision for Unauthorized Reinsurance – Calculates the provision for reinsurance for unauthorized reinsurers Part 6, Section 1: Provision for Reinsurance Ceded to Certified Reinsurers – Calculates a provision if the collateral is underfunded Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 75 Aon Benfield Analytics | Market Analysis Part 6, Section 2: Provision for Overdue Reinsurance Ceded to Certified Reinsurers – Section 2 potentially creates an additional provision based on whether the certified reinsurer has disputed and/or overdue recoverables; the provision may be lower for 1 certified reinsurers that are considered Non-Slow Payers and potentially higher for 2 certified reinsurers that are considered Slow Payers – Both sections reflect the one-year deferral on approved property catastrophe losses (or named hurricanes) 1 Part 7: Provision for Overdue Authorized Reinsurance (Non-Slow Payers ) – Calculates the provision for reinsurance for authorized reinsurers that have disputed and/or overdue balances and are NOT “slow payers” 2 Part 8: Provision for Overdue Reinsurance (Slow Payers ) – Calculates the provision for reinsurance for authorized reinsurers that are deemed “slow payers” Part 9: Restatement of Balance Sheet to Identify the Net Credit for Reinsurance – Provides a gross balance sheet which is intended to show the impact of ceded reinsurance on the balance sheet Notes: 1. Non-Slow Payers are certified or authorized reinsurers where less than 20% of the paid reinsurance recoverables are overdue. 2. Slow Payers are certified or authorized reinsurers where 20% or more of the paid reinsurance recoverables are overdue. Market Analysis Update: U.S. Collateral Reform – December 2016 Proprietary and Confidential 76
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