MI DIFS Bulletin 2024-07-INS
Group Capital Calculation Filing Exemption Criteria _____________________________
STATE OF MICHIGAN
DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES
Bulletin 2024-07-INS
In the matter of:
Group Capital Calculation Filing
Exemption Criteria
_____________________________/
Issued and entered
this 19th day of January 2024
by Anita G. Fox
Director
This bulletin sets forth criteria the Director of the Department of Insurance and Financial Services (Director)
may consider in determining a) whether to exempt an ultimate controlling person in an insurance holding
company system where Michigan is the lead state from filing an annual group capital calculation; or b)
whether to accept a limited group capital filing.
Where Michigan is the lead state for a company required to make a group capital calculation filing, MCL
500.1325b(5) allows the Director to exempt an ultimate controlling person from filing the annual group capital
calculation; or to accept a limited group capital filing based on criteria specified by the Director. MCL
500.1325b(3) sets forth criteria that automatically exempts insurance holding company systems from filing
the annual group capital calculations. The criteria described in this bulletin are additional criteria that the
Director may, in her discretion, consider in determining whether to exempt an ultimate controlling person from
filing the annual group capital calculation or to accept a limited group capital filing.
The Director will consider an exemption request or a request to accept a limited group capital filing when a
written request (i.e., a letter) is submitted under MCL 500.1325b(5) no later than February 28 of the year in
which the exemption is requested.
The Director may approve an exemption from filing the annual group capital calculation or accept a limited
filings based on the following:
• The insurance holding company system’s non-United States group-wide supervisor has filed an
application with the NAIC Mutual Recognition Jurisdiction Working Group (NAIC) to be approved as
a Recognize and Accept jurisdiction. In addition, the following apply:
o The director has an established, productive working relationship with any jurisdiction that
has filed a Recognize and Accept application with the NAIC including a Memorandum of
Understanding.
o The director has some understanding of the jurisdiction’s regulatory framework and is not
aware of any statutory provisions that would prevent the jurisdiction from being approved by
the NAIC as a jurisdiction under the Recognize and Accept program.
• Any other documentation requested by the Director.
Any questions regarding this bulletin should be directed to:
Department of Insurance and Financial Services
Office of Insurance Evaluation
DIFS-FinFilings@michigan.gov
530 W. Allegan Street – 7th Floor
P.O. Box 30220
Lansing, Michigan 48909-7720
Toll Free: (877) 999-6442
/s/
____________________________
Anita G. Fox
Director