FHLB prepayment obligations

[VeronikaK-BCSIC]

Hello,

We have been disclosing None within Note 11B 4(c) FHLB Prepayment obligations in the past because our company never incurred any prepayment expenses for the reporting period. However, if we do prepay, the contract states conditions where we need to pay a prepayment fee.

Can you please confirm the interpretation of the disclosure?


11B 4(c) FHLB Prepayments Obligations



c. FHLB Prepayment Obligations Does the company have prepayment obligations under the following arrangements


1. Debt No
2. Funding Agreements No
3. Other No

[Kent]

Note below that it says ?subject ? to prepayment penalties. It doesn?t say if you paid a prepayment penalty or not. Given the facts in the post, the response should change from none to yes (and apply whether Debt, Funding Agreement, or Other).


Please see the NAIC instructions excerpt below: Note part B.(4)c. (because this is exactly what Note 11B4c requires)



Note 11B4 parts a and c:

B. For FHLB (Federal Home Loan Bank) agreements, the following information shall be disclosed for the general account, separate account and the total of the general and separate accounts for the current year and prior year-end. (The information in the disclosures shall be presented gross even if a right to offset per SSAP No. 64?Offsetting and Netting of Assets and Liabilities exists.)


(1) General description with information on the nature of the agreement, type of borrowing (advances, lines of credit, borrowed money, etc.) and use of the funding.


(2) FHLB Capital Stock


a. Amount of FHLB capital stock held, in aggregate, and classified as follows:

? Membership stock (separated by Class A and Class B)
? Activity Stock
? Excess Stock
? The actual or estimated maximum borrowing capacity as determined by the insurer

Also provide a description of how the borrowing capacity was determined.


b. For membership stock (Class A and Class B), report the amount of FHLB capital stock eligible and not eligible for redemption (for FHLB membership stock to be eligible for redemption, written notification must have been provided to the FHLB prior to the reporting date) and the anticipated time frame for redemption showing:

? Total Current Year
? Not Eligible for Redemption
? Less than 6 months
? 6 months to 1 year
? 1 year to 3 years
? 3 years to 5 years


(3) Collateral Pledged to FHLB

a. Amount (fair value and carrying value) of collateral pledged to the FHLB as of the reporting date and total aggregate borrowing.

b. Maximum amount of collateral (fair value and carrying amount) pledged to the FHLB at any time during the current reporting period and amount borrowed at time of maximum collateral. (Maximum shall be determined on the basis of carrying value, but with fair amount also reported.)



(4) Borrowing from FHLB

a. Aggregate amount of borrowings from the FHLB, reflecting compilation of all advances, loans, funding agreements, repurchase agreements, securities lending, etc., outstanding with the FHLB, and classify whether the borrowing is in substance:

? Debt (SSAP No. 15?Debt and Holding Company Obligations)
? A funding agreement (SSAP No. 52?Deposit-Type Contracts)
? Other
? Aggregate Total

For funding agreements, report the total reserves established.

b. Report the maximum amount of aggregate borrowings from an FHLB at any time during the current reporting period for:

? Debt (SSAP No. 15?Debt and Holding Company Obligations)
? A funding agreement (SSAP No. 52?Deposit-Type Contracts),
? Other
? Aggregate Total

c. Disclose whether current borrowings are subject to prepayment penalties for:

? Debt (SSAP No. 15?Debt and Holding Company Obligations)
? A funding agreement (SSAP No. 52?Deposit-Type Contracts)
Other