The NAIC has released a COVID-19 Information Request Template (the “Template).  The Template preamble explains, “it was developed for purposes of state insurance department use in collecting information from U.S. insurance groups and legal entities (hereafter “companies”) on their preparation for and exposure to the novel coronavirus known as COVID-19.  Companies are asked to provide complete and accurate responses to the relevant sections of the request to facilitate effective regulatory review and to reduce the need for additional requests.”

Additionally, the Template was prepared such that it can be submitted on a group basis to the Lead State regulator (if applicable), although certain requests are required to take legal entity impacts into consideration.  The information provided by companies through use of Template will be treated as confidential and will be shared with other state insurance departments through the NAIC’s Master Information Sharing and Confidentiality Agreement.  The Template was developed to reduce the need for duplicative and overlapping information requests.

The Template consists of two sections; Operational Impact of COVID-19 and Financial Impact of COVID-19.  The Operational Impact section contains seven questions, and relates to the operational impact of COVID-19 and steps taken by ‎companies to implement an effective Business Continuity Plan (“BCP”) and/or COVID-19 response plan to ‎support ongoing operations.  The Financial Impact section contains eight questions, and relates to the financial impact of COVID-19 on company solvency and steps taken by companies to both assess ‎their exposures and address any concerns identified.

As of now there has been no guidance released from the NAIC on the Template.  If you have any questions on the Template please contact us for assistance.

We will continue to monitor the situation and provide updates.

Visit our COVID-19 Resource Center often for up-to-date information to help you stay informed of the legal issues related to COVID-19.