Statutory Issue Paper No. 3 Accounting Changes

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Statutory Issue Paper No. 3Accounting ChangesSTATUSFinalized March 16, 1998Original SSAP and Current Authoritative Guidance: SSAP No. 3Type of Issue:Common AreaSUMMARY OF ISSUE1.Statutory accounting and GAAP differ in accounting for corrections of errors and certain changesin accounting. Statutory accounting and GAAP are similar in their treatment of mergers and changes inreporting entities. The purpose of this issue paper is to codify statutory guidance and to expand disclosurerequirements for changes in accounting, which include changes in accounting principle, estimate, andreporting entity, and for correction of an error in previously issued financial statements in order to achievethe concept of consistency/comparability as defined in the Statutory Accounting Principles Statement ofConcepts and Statutory Hierarchy (Statement of Concepts).SUMMARY CONCLUSION2.The term accounting change means a change in an accounting principle, an accounting estimateor the reporting entity. The correction of an error in previously issued financial statements is not deemedto be an accounting change.Accounting Principle3.A change in accounting principle results from the adoption of an accepted accounting principledifferent from the one previously used for reporting purposes. An accounting principle includes not onlyaccounting principles and practices but also the methods of applying them.4.A characteristic of a change in accounting principle is that it concerns a choice from among twoor more accounting principles. However, neither (a) initial adoption of an accounting principle inrecognition of events or transactions occurring for the first time or that previously were immaterial intheir effect nor (b) adoption or modification of an accounting principle necessitated by transactions orevents that are clearly different in substance from those previously occurring is a change in accountingprinciple.Accounting Estimate5.Changes in estimates used in accounting are necessary consequences of periodic presentations offinancial statements which require estimating the effects of future events. Examples of items for whichestimates are necessary include service lives of depreciable assets and uncollectible receivables.Accounting estimates change as new events occur, as more experience is acquired, or as additionalinformation is obtained.Correction of an Error6.Errors in financial statements result from mathematical mistakes, mistakes in the application ofaccounting principles or oversight or misuse of facts that existed at the time the financial statements wereprepared. In contrast, a change in accounting estimate results from new information or subsequentdevelopments and accordingly from better insight or improved judgment. Thus an error is distinguishedfrom a change in estimate. 1999-2015 National Association of Insurance CommissionersIP 3–1

IP No. 37.Issue PaperCurrent statutory treatment shall be retained as follows:-Changes in accounting principles and corrections of errors in previously reportedfinancial statements shall be reported as adjustments to surplus in the period of thechange in accounting principle or the period an error is detected.A change in the method of applying an accounting principle shall be considered as achange in accounting principle for purposes of applying the accounting principles setforth in this paper.A change in accounting estimate shall be included in the statement of income in theperiod when the change becomes known.8.If the effect of a change in accounting principle is inseparable from the effect of a change inaccounting estimate, then the change shall be considered as a change in accounting estimate for purposesof applying the accounting principles set forth in this paper. The treatment of a change resulting from aninsurance department examination will depend on whether the change resulted from a correction of anerror, a change in accounting principle or a change in estimate.9.Material changes which do not affect assets, liabilities, revenues, expenses or surplus but whichdo affect historical information in the financial statement supplemental schedules (e.g., Schedule P) shallbe reflected in the current years’ schedules with appropriate notations made directly to the affectedschedules and in the notes to the financial statement.10.For mergers, restatement of prior years’ amounts in the Annual Statement shall be required.Additionally, restatement shall be required for the two most recent years’ included in the Five YearHistorical Summary. The Five Year Historical Summary shall include a footnote that the other three yearshave not been restated. A company that merges with an entity which effectively is a shell company (i.e.,the other entity has no outstanding underwriting liabilities), shall be exempt from the above requirements.Disclosures11.Disclosure of material changes in accounting and correction of errors shall include:-a brief description of the change, encompassing a general disclosure of the reason andjustification for change or correction.the impact of the change or correction on net income, surplus, total assets and totalliabilities for the two years presented in the financial statements (i.e., the balance sheetand statement of income and operations).the effect on net income of the current period shall be disclosed for a change in estimatethat affects several future periods, such as a change in the service lives of depreciableassets or actuarial assumptions affecting pension costs. Disclosure of the effect on thoseincome statement amounts is not necessary for estimates made each period in theordinary course of accounting for items such as uncollectible accounts; however,disclosure is recommended if the effect of a change in the estimate is material.DISCUSSION12.Accounting Principles Board Opinion No. 9, Reporting the Results of Operations (APB 9) andAccounting Principles Board Opinion No. 20, Accounting Changes (APB 20) address GAAP accountingand reporting for accounting changes. Portions of these pronouncements are not applicable to statutoryaccounting and some of the guidance is not consistent with statutory objectives. Therefore, rejection ofAPB 20 in its entirety and the portions of APB 9 that address the treatment of extraordinary items andprior period adjustments is recommended.13.The consistency concept within the Statement of Concepts is concerned with the regulator’s needfor meaningful, comparable financial information to determine an entity’s financial condition through 1999-2015 National Association of Insurance CommissionersIP 3–2

Accounting ChangesIP No. 3consistency in the development and application of statutory accounting principles. In keeping with theStatement of Concepts, comparability of financial information would be best served by the restatement ofprior year financial information for certain changes in accounting principle as well as the correction of anerror in the previous year. However, existing statutory accounting guidance and practice requires such anitem to be shown as an adjustment to surplus. In order to bridge the gap between current statutoryaccounting guidance and the achievement of comparability sought by the Statement of Concepts,additional disclosure as to the general description and the effect of such changes on income and surplusfor all periods presented would provide the financial statement reader enough information to understandthe effect of such change on consistency between periods.14.The modification of existing statutory accounting for additional disclosure relating to changesbetween years and correction of prior errors bridges the gap between GAAP accounting as required byAPB 20 and APB 9. More importantly, the added disclosure bridges the gap between current statutoryprocedures and the concept of consistency/ comparability required by the Statement of Concepts.Drafting Notes/CommentsAccounting for Consolidations of Majority-owned Subsidiaries is addressed in a separate issuepaper (see Issue Paper No. 1).Accounting for mergers is addressed in a separate issue paper. This may include an expansion ofthe traditional definition of a merger to include all combinations or assumptions which, insubstance, are mergers.Extraordinary items are discussed in a separate issue paper.Specific discussion regarding reserve changes including a change in valuation basis is addressedin a separate paper.RELEVANT STATUTORY ACCOUNTING AND GAAP GUIDANCEStatutory Accounting15.Statutory accounting is specific as to the treatment of accounting changes. The primary statutoryaccounting guidance is the NAIC Annual Statement Instructions (Annual Statement Instructions).Summarized, the Annual Statement Instructions specify that a change in accounting principle or thecorrection of an error is to be reported as an adjustment to surplus. Changes in accounting estimates are tobe included in the statement of income for the current period. The treatment for a merger requires thatprior year’s amounts be restated and reported on a merged basis consistent with the current year’s postmerger reporting basis.16.The issues of changes in accounting principles and estimates are not specifically addressed in theAccounting Practices and Procedures Manuals for Life and Accident and Health and for Property andCasualty Insurance Companies.17.Chapter 10 of the Accounting Practices and Procedures Manual for Property and CasualtyInsurance Companies, in a discussion on recoveries from salvage and subrogation, states that:Companies which have previously reported reserves gross of salvage and subrogation shouldreport the change to the net method as a change in accounting principle. The cumulative effecton prior years of this change should be reported as a write-in item in the surplus section of theannual statement. The change in the reserve calculated using the net method should be includedin net income for the year of the change and all future years.18.The Annual Statement Instructions (which documents the conclusions reached by the EmergingAccounting Issues Working Group of the Accounting Practices and Procedures (EX4) Task Force inmeeting 92-1) addresses accounting changes. The instructions state that: 1999-2015 National Association of Insurance CommissionersIP 3–3

IP No. 3Issue PaperAmounts reported in prior years may need to be adjusted in the current year as a result of thefollowing:Changes in accounting principles or practices or changes in the methods of applying accountingprinciples or practices.Changes in accounting estimates as a result of new events or new information.Corrections of errors in previously filed information.A merger.If changes are required for amounts reported in prior years, such changes should be included inthe amounts reported for the current year and the effects of such changes should be reported asfollows, unless these Instructions or the NAIC Accounting Practices and Procedures manualspecifically provide for a different treatment:(1)The cumulative effect of a change in accounting principles or practices or a change in themethod of applying accounting principles or practices should be reported with anappropriate identifying title as a write-in item for gains and losses in surplus. Thecumulative effect of changing to a new accounting principle is the difference between theamount of capital and surplus at the beginning of the year and the amount of capital andsurplus that would have been reported at that date if the new accounting principle hadbeen applied retroactively for all prior periods. An example of a change in accountingprinciples would be a change in the method of accounting for pensions or other postemployment benefits.(2)The effects of changes in accounting estimates are included in income and expenses inthe Statement of Income for the current year. For example, a change in the estimate ofloss reserves for losses related to prior years should be included in the Statement ofIncome in losses incurred for the current year.(3)The effects of changes resulting from corrections of errors in previously filed information(for example, mathematical mistakes, misapplication of accounting principles, oroversight or misuse of facts) should be reported as an adjustment to surplus in thecurrent year. Such adjustments to surplus should be reported with an appropriateidentifying title as a write-in item for gains and losses in surplus.(4)In the case of a merger, prior years’ amounts reported for assets, liabilities, surplus,revenues and expenses, as well as those amounts reflected in supporting AnnualStatement schedules, should be reported on a merged basis consistent with the currentyear’s post-merger reporting basis. A footnote should be inserted on each page of theAnnual Statement which contains such merged amounts clearly detailing thecircumstances.If one of the above described adjustments is required that does not affect assets, liabilities,revenues or expenses but which does adjust historical information, such as that found inSchedule P, the change may be made in the currently filed annual statements; however,appropriate notations of such adjustments should be made directly on the schedules affected andin the notes to the Financial Statements. 1999-2015 National Association of Insurance CommissionersIP 3–4

Accounting ChangesIP No. 3Generally Accepted Accounting Principles19.Statutory accounting treatment is similar to GAAP except for the following:-when reporting changes in accounting principles, GAAP accounting requires that thecumulative effect of a change be reported in the statement of income as a separate lineitem. Statutory accounting requires this to be shown as a separate component of surplus.GAAP accounting requires that corrections of errors be reported as prior periodadjustments with adjustment to the prior year income and surplus.accounting for changes in a reporting entity includes several circumstances in which theremay be a change in reporting entity. The only relevant area as it applies to StatutoryAccounting is that of a merger. As such, this is the only area which Statutory Accountingspecifically addresses.20.The primary GAAP accounting guidance with respect to accounting changes comes fromAPB 20, paragraph 19, which states that changes in accounting principles are to be reported as follows:21.a.Financial statements for prior periods included for comparative purposes should bepresented as previously reported.b.The cumulative effect of changing to a new accounting principle on the amount ofretained earnings at the beginning of the period in which the change is made should beincluded in net income of the period of the change.c.The effect of adopting the new accounting principle on income before extraordinary itemsand on net income of the period of the change should be disclosed.d.Income before extraordinary items and net income computed on a pro forma basisshould be shown on the face of the income statements for all periods presented as if thenewly adopted accounting principle had been applied during all periods affected.APB 20 also states that changes in accounting estimates are to be accounted for as follows:.the effect of a change in accounting estimate should be accounted for ina.the period of change if the change affects that period only orb.the period of change and future periods if the change affects both.A change in an estimate should not be accounted for by restating amounts reported in financialstatements of prior periods or by reporting pro forma amounts for prior periods.22.For changes in the reporting entity (e.g., a merger), APB 20 states the following:.accounting changes which result in financial statements that are in effect the statements of adifferent reporting entity should be reported by restating the financial statements of all priorperiods presented in order to show financial information for the new reporting entity for allperiods.23.For changes in accounting principles inseparable from changes in accounting estimates, APB 20states:Changes of this type are often related to the continuing process of obtaining additionalinformation and revising estimates and are therefore considered as changes in estimates forpurposes of applying this Opinion.24.Lastly, according to APB 20, corrections of errors are to be accounted for as follows:Correction of an error in the financial statements of a prior period discovered subsequent to theirissuance should be reported as a prior period adjustment. 1999-2015 National Association of Insurance CommissionersIP 3–5

IP No. 3Issue Paper25.GAAP accounting provides guidance with respect to the accounting for prior period adjustmentsin APB 9, paragraph 18. APB 9 states that “When comparative statements are presented correspondingadjustments should be made of the amounts of net income (and the components thereof) and retainedearnings balances (as well as of other affected balances) for all of the periods reported therein, to reflectthe retroactive application of the prior period adjustments.” Additionally, APB 9 requires footnotedisclosures regarding such changes.RELEVANT LITERATUREStatutory AccountingStatutory Accounting Principles Statement of Concepts and Statutory HierarchyAccounting Practices and Procedures Manual for Property and Casualty Insurance Companies,Chapter 10, LossesEmerging Accounting Issues Working Group of the Accounting Practices and Procedures (EX4)Task Force Minutes, 92-1, 91-4NAIC Annual Statement InstructionsGenerally Accepted Accounting PrinciplesAccounting Principles Board Opinion No. 9, Reporting the Results of OperationsAccounting Principles Board Opinion No. 20, Accounting ChangesFASB Statement No. 16, Prior Period AdjustmentsState RegulationsNo additional guidance obtained from state statutes or regulations.Other Sources of InformationDraft discussion materials from previous Property/Casualty codification projects, Prior PeriodAdjustments/Corrections of Errors 1999-2015 National Association of Insurance CommissionersIP 3–6

IP 3–1 Statutory Issue Paper No. 3 Accounting Changes STATUS Finalized March 16, 1998 Original SSAP and Current Authoritative Guidance: SSAP No. 3 Type of Issue: Common Area SUMMARY OF ISSUE 1. Statutory accounting and GAAP differ in accounting for correct

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