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Federal Reinsurance Receivables - ACA
Glenn,
I spoke with Robin Marcotte and these receivables are nonadmitted 90 days after they are due from the federal governement, not from the accrual date. An excerpt from her email below. I think it's important to note: Hi Kerri You are correct that the transitional reinsurance program has a 90 day rule, but it does not go into effect until the receivables are scheduled to be disbursed which is the following year. Below is an excerpt from SSAP No. 107 which was adopted on Friday. It is essentially the same guidance that is in INT 13-04. 1. All receivables from the transitional reinsurance program are subject to the 90-day nonadmission rule beginning from when program receivables are due to be disbursed by the government or a government-sponsored entity. That is, the 90-day rule begins when governmental receivables are due, not from the date of initial accrual. The announced governmental or government-sponsored entity distribution date shall be the contractual due date similar to Appendix A-791, paragraph 2h, which requires that payments due from the reinsurer are made in cash within ninety (90) days of the settlement date. The receivable is also subject to impairment analysis. Robin Marcotte | NAIC | (: 816 783 8124 | |
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