How to Fill Out California CDI Captive Insurance Application + FAQs

The California Department of Insurance (CDI) Captive Insurance Application is the formal Application for Certificate of Authority to Transact Insurance as a Captive Insurer that every company seeking to form a pure, association, industrial insured, special purpose, or risk retention group captive in California must file with the CDI Captive Insurance Program before writing a single policy. The form, currently maintained under the captive licensing package referenced in California Insurance Code §1280.7, authorizes the captive to insure the risks of its parent, affiliates, or members under California law.

Filing volume has grown sharply, with CDI reporting more than 35 active captive insurers and a steady pipeline of new applications each year, while the agency rejects or returns roughly one in three first-submission packages for missing exhibits, pro forma errors, or incomplete biographical affidavits, according to the CDI Captive Program statistics. Getting the application right the first time can mean the difference between a 60-day approval and a year of back-and-forth correspondence.

Here is what you will learn in this guide:

• 📋 The exact line-by-line walkthrough of every field, exhibit, and signature on the CDI captive application
• 💰 The current $1,500 application fee, $5,600 license fee, and minimum capital and surplus rules for each captive type
• 🏛️ How to file the package with the CDI Financial Surveillance Branch and what happens during the 60–90 day review
• 🧮 Three full filed-out scenarios for a pure captive, an association captive, and a special purpose captive
• ⚠️ The ten most common mistakes that trigger rejection, deficiency letters, or delayed certificates of authority

What the Form Is and Who Must File It

The CDI captive application is the licensing package a company must submit to obtain a Certificate of Authority (COA) under California Insurance Code §1280.7 and the captive regulations at 10 CCR §2509.40 et seq.. Without the COA, no company may transact captive insurance in California, and any policies written without authority are void and expose officers to penalties under Insurance Code §700.

Five categories of insurers must file this application: pure captives that insure only their parent and affiliates, association captives owned by a trade or professional association, industrial insured captives covering qualifying industrial insureds, special purpose captives organized for a defined risk under Insurance Code §1280.7.5, and risk retention groups domesticating into California under the federal Liability Risk Retention Act. Each type uses the same base application but attaches different exhibits.

The form is filed with the CDI Financial Surveillance Branch in San Francisco, and the Captive Program Manager reviews each submission for solvency, governance, and risk-distribution adequacy. Filers should always check the CDI captive forms page for the current revision, since CDI updates the package without formal notice. The most recent revision is generally referenced near the bottom of the cover sheet.

Before You Start: Documents and Information You Need

A captive application is exhibit-heavy, and the CDI captive checklist makes clear that a missing exhibit usually triggers an immediate deficiency letter. Gather every item below before you open the application, because the form references each exhibit by letter and number. Filers who prepare the package in pieces almost always create internal inconsistencies between the business plan and the pro forma.

Use this pre-filing checklist:

• Articles of Incorporation filed with the California Secretary of State, because CDI verifies the legal entity exists before issuing the COA, and a missing certificate of status delays the file.
• Bylaws signed by the incorporators, because CDI compares governance language against Insurance Code §1280.7, and any conflict triggers a rewrite.
• A complete five-year pro forma financial statement with assumptions, since CDI’s actuary stress-tests the numbers, and unsupported assumptions cause rejection.
• An actuarial feasibility study signed by a credentialed actuary, because 10 CCR §2509.45 requires it for every new captive.
• Biographical affidavits on NAIC Form 11 for every officer, director, and 10% owner, with fingerprint cards.
• A detailed Plan of Operation covering lines of business, policyholders, reinsurance, claims handling, and exit strategy.
• Proof of paid-in capital and surplus, usually a bank letter or escrow confirmation, because the COA does not issue until funds are confirmed.
• Reinsurance treaties or letters of intent for any ceded risk, since CDI evaluates counterparty credit and retention.
• A $1,500 application filing fee check payable to the California Department of Insurance, per the CDI fee schedule.
• A copy of the parent company’s audited financials, because CDI uses them to confirm the parent can fund the captive.

Where to Get the Form and How to Access It

The official application package lives on the CDI Captive Insurance Program page, where the agency posts the cover application, the exhibit checklist, the biographical affidavit template, and the fingerprint instructions. CDI does not host the application on the NAIC UCAA portal because California captives are licensed under a state-specific track rather than the multistate UCAA process.

Download every document in PDF, then create a working folder with subfolders for Application, Exhibits, and Financials. CDI prefers the package assembled in tabbed binder order matching the checklist letter sequence, and submissions that arrive out of order routinely sit in queue while staff reorganize them. The CDI Producer Licensing Bureau handles a separate process and should not be confused with captive licensing.

If you cannot locate the most current PDF, email the Captive Program directly at captive@insurance.ca.gov, which is the address listed on the program contact page. Always confirm you have the latest revision date printed on page one, because CDI rejects packages submitted on superseded forms. The revision date is usually shown in the footer of the cover application.

Step-by-Step: How to Fill Out the California Captive Application Line by Line

This is the spine of the package. Each section below corresponds to a numbered field, exhibit letter, or signature block on the application, and every field must be filled out exactly as labeled on the form available from the CDI Captive Program.

Box 1: Name of Proposed Captive Insurer

This field asks for the exact legal name of the captive as it will appear on the COA and on every policy. Enter the name precisely as filed with the California Secretary of State, including the corporate suffix such as Inc., Corp., or LLC. The name must include the word Insurance, Assurance, Indemnity, or Captive under Insurance Code §881.

For example, Sierra Builders Captive Insurance Company, Inc. is acceptable, while Sierra Builders Captive without a suffix will be rejected. A nuance arises when the parent already uses Insurance in its trade name; CDI will still require a distinct legal name for the captive entity. The most common mistake is entering a doing business as name instead of the registered legal name, which causes the COA to mismatch the Articles of Incorporation and forces a re-filing with the Secretary of State.

A frequent misconception is that the captive can adopt any creative branding it wants; in reality, CDI screens names for confusing similarity to existing licensed insurers and will require a name change if there is overlap. Run a name availability search on the Secretary of State’s bizfile portal before reserving the name.

Box 2: Type of Captive Insurer

This field asks the applicant to check the box for the captive structure being formed. Check exactly one of Pure, Association, Industrial Insured, Special Purpose, or Risk Retention Group, because the rest of the application’s required exhibits depend on this election. The categories are defined in Insurance Code §1280.7 and §1280.7.5.

For example, Carlos Mendoza, CFO of a construction company forming a wholly owned captive to insure his parent and three subsidiaries, checks Pure. The edge case appears when an applicant could qualify as either Industrial Insured or Special Purpose; the Special Purpose box almost always carries lighter exhibit demands but stricter risk-defining language in the Plan of Operation.

The most common mistake is checking Pure when the captive will insure unrelated members, which violates the affiliation rule and triggers an immediate denial. A common misconception is that switching captive types after licensure is routine; in fact, a type change is treated as a new application and requires a fresh $1,500 fee and re-review.

Box 3: Home Office Address

This field asks for the physical California street address of the captive’s principal place of business. Enter a street address, not a P.O. Box, because 10 CCR §2509.41 requires a physical California office where books and records are kept.

For example, 2000 Powell Street, Suite 1100, Emeryville, CA 94608 is acceptable. The nuance is that the address may be the office of the captive manager so long as records are physically maintained there and the captive has a contractual right of access. The most common mistake is listing the parent’s out-of-state headquarters, which strips California domicile and forces the applicant to re-domesticate.

A misconception is that a virtual office or registered agent address satisfies the rule; CDI examiners physically inspect captive offices, and a mailbox-only address fails inspection. Confirm the address is staffed during business hours.

Box 4: Captive Manager and Contact Information

This field asks the applicant to identify the licensed captive manager, including name, license number, address, phone, and email. Enter the manager’s CDI license number and confirm the license is active for captive management.

For example, Marsh Captive Solutions, License No. 0A12345, 555 California Street, San Francisco, CA 94104 is the type of entry expected. The edge case is a single-parent captive that wants to self-manage; CDI permits this only when the parent demonstrates internal staff with captive expertise. The most common mistake is naming an unlicensed manager, which voids the application until a licensed manager replaces them.

A misconception is that any insurance broker can manage a captive; in reality, captive management requires specific approval and experience. Verify the license status before listing the manager.

Box 5: Lines of Business

This field asks the applicant to list every line of insurance the captive intends to write, using the line-of-business codes in the NAIC Annual Statement Instructions. Enter each line on a separate row with projected first-year written premium.

For example, Aisha Patel, forming a captive for her trucking company, enters Commercial Auto Liability — $2,500,000 and Commercial Auto Physical Damage — $1,200,000. The nuance is that adding a new line later requires a Plan of Operation amendment under 10 CCR §2509.46.

The most common mistake is listing aspirational lines the captive does not intend to write in year one, which inflates capital requirements and slows approval. A misconception is that pure captives can write personal lines for owners; California prohibits personal-risk underwriting in pure captives.

Box 6: Capitalization and Surplus

This field asks the applicant to state the proposed paid-in capital and surplus and to attach proof of funds. Enter dollar amounts in whole numbers, and confirm they meet the minimums in Insurance Code §1280.7: $250,000 capital and $250,000 surplus for pure captives, $500,000 and $500,000 for association captives, and $1,000,000 combined for special purpose captives unless CDI sets a different amount.

For example, Capital: $500,000; Surplus: $750,000 would be entered for a well-capitalized pure captive. The nuance is that CDI may require additional surplus based on the actuarial study even when statutory minimums are met. The most common mistake is pledging capital that is not yet liquid, which fails the proof-of-funds test.

A misconception is that letters of credit always count toward capital; California allows them only with prior CDI approval and only from approved banks. Provide a bank confirmation letter dated within 30 days of filing.

Box 7: Officers, Directors, and Owners

This field asks for the full names, titles, and ownership percentages of every officer, director, and 10% or greater owner. Enter each person on a separate line, attaching a NAIC Form 11 biographical affidavit and fingerprint card for each.

For example, Janet Liu, President and Director, 0% direct ownership, parent shareholder via XYZ Holdings would be entered for a corporate officer. The nuance is that a parent’s ultimate beneficial owners with 10% or more must also file biographical affidavits. The most common mistake is omitting biographical affidavits for outside directors, which always triggers a deficiency letter.

A misconception is that fingerprints can be submitted later; CDI does not begin substantive review until prints clear the California Department of Justice Live Scan system.

Exhibit A: Plan of Operation

The Plan of Operation describes who the captive insures, what it insures, how premiums are set, how claims are handled, and how the captive will exit risk. Write a narrative document of 10 to 30 pages covering each topic in plain English with supporting schedules.

For example, Marcus Reed’s special purpose captive for cyber risk includes a section explaining that policies will be issued only to the parent, that limits will not exceed $5,000,000 per occurrence, and that all losses above $1,000,000 will cede to a Bermuda reinsurer rated A- or better by AM Best. The nuance is that the Plan must reconcile to the pro forma; if premium volumes differ, CDI rejects the package.

The most common mistake is recycling a generic plan from another state; California examiners detect boilerplate and demand a California-specific rewrite. A misconception is that the Plan can be high-level; CDI expects line-level detail including rating methodology.

Exhibit B: Five-Year Pro Forma Financial Statements

This exhibit asks for projected balance sheets, income statements, and cash flows for years one through five, plus a stress test. Build the model in Excel using NAIC statement format and submit both the spreadsheet and a PDF.

For example, the captive shows Year 1 Direct Written Premium: $3,000,000; Net Income: $120,000; Surplus at Year-End: $870,000. The nuance is that CDI’s actuary will rerun the model under adverse scenarios; assumptions that fail the stress test cause rejection. The most common mistake is omitting investment income or using unrealistic loss ratios below industry benchmarks.

A misconception is that the pro forma is a formality; in practice, it is the single most scrutinized exhibit in the package.

Exhibit C: Actuarial Feasibility Study

The study must be signed by a Member of the American Academy of Actuaries and must opine on rate adequacy, loss reserves, and capital sufficiency. Attach the full report, not a summary.

For example, the study concludes that expected loss ratio is 62% with a 90% confidence interval of 48% to 81% and that proposed capital is sufficient at the 99% VaR. The nuance is that CDI may require a peer review for unusual exposures.

The most common mistake is using an actuary without property and casualty credentials. A misconception is that the parent’s existing actuary always qualifies; CDI looks for captive-specific experience.

Exhibit D: Reinsurance Program

This exhibit asks for treaties, slips, or letters of intent with each reinsurer, plus AM Best ratings and collateral arrangements. List each reinsurer with name, NAIC number, rating, and percentage of risk ceded.

For example, Swiss Re America, NAIC 25364, AM Best A+, 50% quota share above $500,000 retention would be entered. The nuance is that unauthorized reinsurers must post collateral under Insurance Code §922.4.

The most common mistake is relying on a reinsurer not yet bound, which fails the proof-of-cover requirement. A misconception is that fronting arrangements eliminate the reinsurance disclosure; they actually expand it.

Exhibit E: Articles of Incorporation and Bylaws

Attach the file-stamped Articles from the California Secretary of State and the executed Bylaws. Include the certificate of status dated within 30 days of filing.

For example, Articles filed June 3, 2026, Entity No. C5567890 would appear on the cover sheet. The nuance is that captive bylaws must include indemnification limits consistent with Insurance Code §1280.7.

The most common mistake is filing Articles before settling capital structure, forcing an amendment. A misconception is that LLC operating agreements substitute for bylaws; CDI accepts them but requires equivalent governance language.

Signature Block: Verification by Officer

The application closes with a verification signed under penalty of perjury by an officer of the proposed captive. Sign in blue ink, print name and title, and date in MM/DD/YYYY format.

For example, Carlos Mendoza, President, 06/15/2026 signs the verification. The nuance is that the signer must be an officer named in Box 7. The most common mistake is having a captive manager sign on behalf of the company; only an officer of the captive may verify.

A misconception is that an electronic signature is acceptable; CDI requires a wet signature on the verification page.

Three Filled-Out Examples Using Real Scenarios

Below are three full walkthroughs anchored to named filers. Each table shows the major sections of the application and what the filer enters.

Scenario 1: Carlos Mendoza, Pure Captive for Sierra Builders

Form Section	What Carlos Enters
Box 1: Name	Sierra Builders Captive Insurance Company, Inc.
Box 2: Type	Pure
Box 3: Address	2000 Powell Street, Suite 1100, Emeryville, CA 94608
Box 4: Captive Manager	Marsh Captive Solutions, License No. 0A12345
Box 5: Lines	General Liability $4M; Workers’ Comp $2M
Box 6: Capital/Surplus	$500,000 / $750,000
Box 7: Officers	Carlos Mendoza, President; 3 directors
Exhibit B: Pro Forma	Year 1 NWP $6M; Year 5 Surplus $4.2M
Signature	Carlos Mendoza, 06/15/2026

Scenario 2: Aisha Patel, Association Captive for the California Trucking Coalition

Form Section	What Aisha Enters
Box 1: Name	CalTruck Association Captive, Inc.
Box 2: Type	Association
Box 3: Address	1215 K Street, Suite 800, Sacramento, CA 95814
Box 4: Captive Manager	Aon Insurance Managers, License No. 0B98765
Box 5: Lines	Commercial Auto Liability $25M; Cargo $5M
Box 6: Capital/Surplus	$1,000,000 / $1,500,000
Box 7: Officers	Aisha Patel, CEO; 7-member member-elected board
Exhibit B: Pro Forma	Year 1 NWP $30M; 120 member-policyholders
Signature	Aisha Patel, 06/22/2026

Scenario 3: Marcus Reed, Special Purpose Captive for Cyber Risk

Form Section	What Marcus Enters
Box 1: Name	NorthStar Cyber SPC, LLC
Box 2: Type	Special Purpose
Box 3: Address	350 Mission Street, Floor 12, San Francisco, CA 94105
Box 4: Captive Manager	Artex Risk Solutions, License No. 0C44556
Box 5: Lines	Cyber Liability $10M; Tech E&O $5M
Box 6: Capital/Surplus	$2,000,000 / $3,000,000
Box 7: Officers	Marcus Reed, Manager; 2 independent directors
Exhibit B: Pro Forma	Year 1 NWP $8M; 99% VaR capital adequacy
Signature	Marcus Reed, 07/01/2026

How to File the Completed Form

CDI accepts captive applications through three channels, and each has different timing and proof requirements. The agency does not accept fax submissions for captive applications, despite a general fax number being listed on the CDI contact page.

By mail or courier, send the complete bound package to the Financial Surveillance Branch, California Department of Insurance, 45 Fremont Street, 23rd Floor, San Francisco, CA 94105, with a $1,500 check payable to the California Department of Insurance; the CDI fee schedule confirms the amount, and processing typically begins within 10 business days of receipt. Keep the courier tracking receipt as proof of filing.

In person, deliveries to the same address are accepted between 8 a.m. and 5 p.m. on business days, and the receptionist will date-stamp a copy as proof of filing. Electronic supplements such as updated pro forma spreadsheets may be emailed to captive@insurance.ca.gov once the paper file is opened, but the original application package must be delivered in hard copy. Payment by ACH or wire is available on request through the CDI Accounting Office.

The expected processing time is 60 to 90 days for a clean file and 120 to 180 days when deficiency letters are issued. Always retain a complete duplicate of the binder, because CDI will not return the original.

What Happens After You File

Within ten business days of receipt, the Captive Program Manager opens a file and assigns a primary analyst, who issues a first-pass deficiency letter or moves the file to actuarial and legal review. The applicant receives a written acknowledgment with a file number that should be used in every follow-up email under the CDI captive procedures.

The actuary stress-tests the pro forma and the feasibility study, while the legal unit reviews Articles, Bylaws, and the Plan of Operation. Most applications receive at least one round of follow-up questions, and timely responses within 15 business days keep the file moving. Slow responses cause CDI to administratively close the file, requiring a new application and fee.

Once approved, CDI issues a Certificate of Authority and the captive may begin writing policies dated on or after the COA effective date, but not before. The captive is then subject to the annual report and $5,600 license renewal under Insurance Code §736, and the 2.4% premium tax under Revenue and Taxation Code §12202.

Mistakes to Avoid When Filling Out the Form

Captive applications fail more often on exhibits than on the cover form, and CDI’s deficiency letters are detailed but unforgiving. Watch for these errors before you mail the package.

• Filing on a superseded form revision, which causes the package to be returned unread.
• Listing a P.O. Box as the home office, which violates the physical office rule and stops the file.
• Naming an unlicensed captive manager, which voids the application until corrected.
• Submitting biographical affidavits without fingerprints, which prevents background checks from starting.
• Pledging illiquid capital, which fails the proof-of-funds test and delays the COA.
• Using a generic out-of-state Plan of Operation, which prompts a California-specific rewrite.
• Omitting the actuarial feasibility study, which is an automatic deficiency under 10 CCR §2509.45.
• Mismatching premium figures between the Plan and the pro forma, which suggests internal inconsistency.
• Listing reinsurers that are not yet bound, which fails the proof-of-cover test.
• Forgetting to include the $1,500 filing fee check, which prevents the file from opening at all.

Do’s and Don’ts

A short list of practical guidance keeps the package on track.

• Do confirm the form revision date on page one before filing, because superseded forms are rejected on receipt.
• Do organize the binder in checklist letter order, because examiners review by tab.
• Do reconcile the Plan of Operation to the pro forma line by line, because mismatches cause rejection.
• Do submit fingerprints via Live Scan early, because background checks take three to four weeks.
• Do keep a complete duplicate binder, because CDI will not return the original.
• Do email captive@insurance.ca.gov to confirm receipt one week after mailing.
• Don’t list aspirational lines of business, because they inflate capital requirements.
• Don’t use a P.O. Box for the home office, because it fails the physical-office rule.
• Don’t sign the verification electronically, because CDI requires wet ink.
• Don’t pledge unfunded capital, because proof-of-funds must be liquid.
• Don’t recycle a Plan of Operation from another state, because California-specific language is required.
• Don’t ignore deficiency letters past 15 business days, because the file may be closed.

Pros and Cons of Filing on Your Own vs. With a Captive Manager

Filers often debate whether to engage a licensed captive manager or to self-file. The trade-offs below help frame that choice.

Pros of using a captive manager:

• Faster approvals because managers know examiner preferences and exhibit ordering.
• Cleaner pro forma models built in NAIC format from prior approvals.
• Established actuarial relationships that reduce report turnaround time.
• Existing fingerprint and biographical affidavit templates that prevent omissions.
• Ongoing post-license compliance support for the annual report and renewal.

Cons of using a captive manager:

• Annual fees typically run $75,000 to $250,000 depending on captive size.
• Less internal knowledge transfer to in-house staff.
• Potential conflicts when the manager also brokers reinsurance.
• Standardized templates may not capture unique parent risk features.
• Switching managers later can be administratively disruptive.

Pros of filing pro se:

• Lower upfront cost, often under $25,000 for outside counsel and actuary only.
• Full internal control over the Plan of Operation narrative.
• Direct dialogue with CDI examiners that builds long-term familiarity.
• No conflict of interest with reinsurance brokers.
• Customized governance language tailored to parent culture.

Cons of filing pro se:

• Higher first-submission rejection risk, because formatting nuances are easy to miss.
• Longer timelines, often six months instead of three.
• Heavier internal time burden on legal, finance, and risk staff.
• No access to manager-only template libraries and benchmark data.
• Steeper learning curve for the annual report, premium tax, and exam cycle.

Captive Type Comparison

Different captive types carry different capital, exhibit, and policyholder rules under California law.

Captive Type	Key Rules
Pure Captive	$250,000 capital + $250,000 surplus; insures parent and affiliates only under Insurance Code §1280.7
Association Captive	$500,000 capital + $500,000 surplus; insures association members
Industrial Insured Captive	Insures qualifying industrial insureds; higher premium thresholds
Special Purpose Captive	Capital set by CDI; defined-risk focus under §1280.7.5
Risk Retention Group	Federal LRRA compliance plus California domicile rules

FAQs

Is the California captive application the same as the NAIC UCAA?

No. California uses a state-specific captive package rather than the multistate UCAA portal, so applicants must download the CDI-specific forms and follow the CDI checklist letter sequence.

Can I file the captive application electronically?

No. CDI currently requires the original application binder by mail or in-person delivery, although supplemental updates may be emailed to the captive program after the file is opened.

Do I write the captive’s legal name or DBA in Box 1?

No. Box 1 must contain the exact registered legal name from the Articles of Incorporation; using a DBA causes the COA to mismatch the corporate filing.

Can a P.O. Box be used in Box 3 for the home office?

No. The home office must be a physical California street address where books and records are maintained, because CDI examiners conduct on-site inspections.

Do I need a licensed captive manager?

Yes. Most California captives must engage a CDI-licensed captive manager, although a single-parent captive may self-manage with prior CDI approval and demonstrated internal expertise.

Can letters of credit count toward the capital requirement in Box 6?

Yes. Letters of credit may count toward capital, but only with prior CDI approval and only when issued by an approved bank with acceptable language.

Do all officers need fingerprints, or only the signing officer?

Yes. Every officer, director, and 10% or greater owner must submit Live Scan fingerprints with their NAIC Form 11 biographical affidavit.

Is the $1,500 application fee refundable if denied?

No. The application fee is nonrefundable regardless of outcome, so applicants should resolve all eligibility questions with the captive program before filing.

Can a captive begin writing policies once the application is filed?

No. No coverage may be written before the Certificate of Authority effective date, and any pre-COA policies are void under California law.

Do I have to file an actuarial study for a small pure captive?

Yes. The actuarial feasibility study is required for every new captive regardless of size, and CDI does not waive it for small parents.

Can the captive insure the personal risks of the parent’s owners?

No. Pure captives may not write personal lines for owners; coverage must relate to the parent’s business risks and affiliated entities.

Is California’s 2.4% premium tax avoidable through reinsurance?

No. The premium tax under Revenue and Taxation Code §12202 applies to direct premiums, and reinsurance does not eliminate the obligation, although certain credits may apply.

Do I need to refile if I add a new line of business after licensing?

Yes. Adding a new line requires a Plan of Operation amendment and CDI approval before the captive may bind any policy on that line.