Conditions for the optional and mandatory registrations of open supplementary pension operations with risk coverage in the Operations Registration System (“SRO”).
On March 17, 2022, SUSEP Circular No. 655/2022 was published, establishing conditions for optional and mandatory registration of open supplementary pension operations with risk coverage in registration systems approved and managed by registration entities accredited by the Superintendency of Private Insurance (‘’SUSEP’’).
SUSEP chose to organize the Circular into attachments, divided according to the financial system adopted for the operations.
The Circular has the purpose of furthering the SRO and lays out, in its Attachment I, the basic core information for pension operations with risk coverage, and, in its Attachment II, about supplementary information for pension operations with risk coverage structured in the simple sharing financial system.
In Attachment I, the Circular presents as its basic core information the following:
- Information regarding the contract, in the case of collective contracting, participant certificate and endorsement;
- Information regarding the person;
- Information regarding collective contract;
- Technical information regarding contracted guarantees;
- Information regarding the movement of contributions and deferred acquisition costs;
- Information regarding the financial settlement of contributions;
- Information regarding the movement of optional/proportional reinsurance premiums;
- Information regarding the financial settlement of reinsurance premiums;
- Information regarding intermediation;
- Information regarding the movement of benefits;
- Information regarding the reinsurance contract;
- Information regarding the movement of premiums – reinsurance (automatic non-proportional contracts); and
- Information regarding the reinsurance accounting.
Regarding Attachment II, the Circular sets forth:
- Establishing the date of October 1, 2022 as the effective date for mandatory registration for pension operations with risk coverage structured in the simple sharing financial system whose coverage period commenced as of such date (new contracts);
- Granting of an additional term, after October 1, 2022, for collective contracts and participant certificates to be registered with the registration entities, of (i) 30 business days, if issued previously and still in force on the required registration date, (ii) 10 business days after the first financial transaction, if the validity period ended prior to the required registration date and (ii) 20 business days in the case that events were reported and not yet paid or contributions not paid on October 1, 2022;
- As a result of any difficulty that the supervised entities may have recovering the history of transactions relating to older contracts, open pension entities (EAPCs) may omit some of the information required, as regards collective contracts and participant certificates with a coverage period ending before January 1, 2019, provided that they are justified and are not related to financial transactions.
SUSEP Circular No. 655/2022 come into force on April 1, 2022, and can be accessed here.
Demarest’s Insurance and Reinsurance team is available to provide any additional clarifications that may be necessary.
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