Do I need to reissue the 2019 Statement of Actuarial Opinion if the impact of COVID-19 could be material to the loss and LAE reserves as of December 31, 2019, my conclusion with respect to RMAD, my opinion on any other reserve balance, or considerations c
Based on a strict reading of the NAIC Instructions for P&C Statements of Actuarial Opinion, the answer seems to be “no.” Amendments to the Actuarial Opinion generally occur when the opinion was in error as a result of reliance on data or other information (other than assumptions) that, as of the balance sheet date, was factually incorrect and the opinion would not have been issued or would have been materially altered had correct data/information been used. The NAIC Instructions to the P&C Statement of Actuarial Opinion state, “The Actuarial Opinion shall not be considered to be in error if it would have been materially altered or not issued solely because of data or information concerned events subsequent to the balance sheet date or because actual results differ from those projected.”
However, if the appointed actuary deems the event to have a material impact on the 2019 Statement of Actuarial Opinion, the appointed actuary will likely hold discussions with company management to determine communication and disclosure to the company’s board of directors and regulator.