Financial Audit Checklist

Annual statutory and operational audit prep for an insurance carrier or MGA, run by the controller or internal audit lead. Covers financial statement review, regulatory compliance attestations (Model Audit Rule, Holding Company filings), and operational controls testing.

5 sections 23 steps Collects data
1

Audit Planning and Engagement

  1. Pull the prior-year audit report and management letter
    • Retrieve last year's signed audit opinion, the management letter, and any unresolved Model Audit Rule (MAR) deficiencies. Carry-forward findings drive this year's risk assessment and scoping decisions.

  2. Confirm external auditor independence under MAR
    • NAIC Model Audit Rule requires lead and concurring partner rotation every five years and prohibits specific non-audit services. Document the auditor's independence representation and any pre-approved tax or actuarial work.

    Collects file
  3. Set materiality and scoping thresholds
    • Establish overall materiality, performance materiality, and the clearly-trivial threshold. For carriers, loss reserves and reinsurance recoverables typically drive scoping regardless of size.

  4. Issue the PBC list to controllership
    • Send the prepared-by-client request list with deadlines tied to fieldwork start. Standard items: trial balance, GL detail, reinsurance treaty schedules, Schedule F detail, investment statements, actuarial reserve memo.

2

Financial Statement Audit

  1. Reconcile the trial balance to the Annual Statement
    • Tie the GAAP trial balance to the SAP Annual Statement blanks (Pages 2, 3, 4 and Schedule F). Document GAAP-to-SAP differences for nonadmitted assets, deferred acquisition costs, and reserve discounting.

  2. Test loss and LAE reserve adequacy
    • Reconcile case reserves and IBNR to the appointed actuary's Statement of Actuarial Opinion. Roll-forward case reserves on a sample of open claims; recompute ALAE/ULAE allocations. Reserve drift between cadence updates is a common market-conduct finding.

    Collects file
  3. Confirm reinsurance recoverables with cedants
    • Send confirmations to all reinsurers on Schedule F. Review treaty wording for any following-form mismatch — a treaty drafted to follow the cedant's fortunes may not align with the underlying form's coverage triggers, creating recovery gaps.

  4. Verify written and earned premium cutoff
    • Test bound policies against the AMS effective dates and the unearned premium reserve calculation. Watch for surplus-lines policies booked but with stamping-office filings outstanding past the state window.

  5. Test investment portfolio classification and valuation
    • Tie holdings to custodian statements; verify NAIC SVO designations on bonds and that impaired securities are properly admitted. Common error: a bond downgraded mid-year still carrying the prior NAIC class.

3

Regulatory Compliance Testing

  1. Review Holding Company filings (Form B, D, F)
    • Confirm the annual Form B registration, any Form D related-party transaction filings, and the Form F enterprise risk report are filed with the lead state. Form A is required only on a change of control.

  2. Test producer licensing and NPN appointments
    • Sample bound policies and verify each producer's NPN, state resident/non-resident license, and CE status via NIPR for the bind state — not just where they hold a resident license. Lapsed CE = lapsed authority = potentially unauthorized transactions.

  3. Verify OFAC screening at issuance and at claim payment
    • Many carriers screen at policy issuance but skip the claim-payment screen. Sample claim payments above a threshold and confirm the SDN check ran at payment date — claimants and assignees can be added to the list mid-policy.

  4. Determine whether NYDFS Part 500 applies
    • Part 500 applies to any Covered Entity doing insurance business in New York. Confirm whether the entity meets the Covered Entity definition or qualifies for a limited exemption under §500.19.

    Collects list
  5. Test Part 500 cybersecurity controls
    • Verify the CISO designation, biennial risk assessment, annual penetration test, MFA on remote access (including third-party VPN under §500.12(b)), and the §500.11 vendor risk program scope covers TPAs and document-handling vendors — not just IT vendors.

    Collects file
  6. Confirm Anti-Fraud Plan filings are current
    • NY, CA, FL, NJ, OH, NM, KY, LA, and MN require periodic Anti-Fraud Plan filings. Acquired carriers commonly inherit unfiled plans — verify the filing date in each required state.

4

Operational Controls Review

  1. Walk through the underwriting authority controls
    • Sample bound policies against current binding authority documents — limit, line of business, hazard grade. Authority breaches are common at agencies with multiple appointed carriers and create rescission and E&O exposure.

  2. Test claims handling timeliness
    • For Texas business, verify the Chapter 542 timeline: 15 business days to acknowledge FNOL, 15 business days to decision after all info received, 60 days max. Each missed deadline triggers 18% statutory interest plus attorney's fees.

    Collects list
  3. Review SOC 2 Type II reports for key vendors
    • Pull current SOC 2 Type II reports for the policy admin system, claims platform, and any TPA. Map complementary user entity controls (CUECs) to internal controls; gaps in CUEC coverage are common audit findings.

  4. Sample subrogation files for notice timing
    • Many states require putting the at-fault party on notice within roughly 6 months. Missing the window waives the carrier's recovery right and shows up as a market-conduct exam finding.

  5. Verify policy and claim file retention schedules
    • Most states require 5-7 years of P&C file retention; workers comp can require 10+ years given lifetime medical. Premature destruction creates discoverable spoliation risk.

5

Findings and Sign-Off

  1. Draft the audit findings and management letter
    • Categorize each finding as material weakness, significant deficiency, or control deficiency. Tie each to a specific control and a remediation owner with a target date.

  2. Hold the audit committee exit conference
    • Walk the audit committee through findings, management responses, and required communications under AU-C 260/265. Document independent discussions with the committee outside management's presence.

  3. Finalize the audit and issue the opinion
    • Capture the final opinion type, the controller sign-off, and the signed audit report for filing with the domestic state by the MAR June 1 deadline.

    Collects list Collects signature Collects file

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Sections 5
Steps 23
Category Insurance
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