Segregated Accounts Guidance Note: Key Regulatory Updates For Segregated Account Insurers

In July 2024, the Bermuda Monetary Authority (BMA) released its long-awaited guidance note entitled "General Business Insurers with Segregated Accounts and Separate Accounts" (the "SAC Guidance Note") which provides the industry with clarity on the regulatory regime and requirements for Bermuda insurers using segregated accounts and separate accounts ("SAC Insurers"). Effective 1 January 2025 the SAC Guidance Note applies only to general business insurers including Commercial Insurers (Classes 3A, 3B and 4), Limited Purpose Insurers (Classes 1, 2 and 3), Special Purpose Insurers, Collateralised Insurers and IIGB (innovative insurers).

Driven by the increasing complexity in this space, the SAC Guidance Note first and foremost is intended to provide clarity on the governance of SAC Insurers in light of the unique segregated account structure. This includes requiring that an SAC Insurer's governance and risk management framework clearly addresses the organisational