NAIC Form D is the Prior Notice of a Transaction that a domestic insurer files with its state insurance department before entering into a material transaction with an affiliate inside its holding company system. You file it under the Insurance Holding Company System Model Regulation (Model #450), and the rule is simple but strict: you must give notice at least 30 days before the transaction, and you cannot close the deal if the commissioner disapproves it inside that window.
Most filers are insurance company compliance staff, in-house counsel, or outside regulatory attorneys acting for the insurer. The stakes are real because, across the country, holding company filings number in the thousands each year, and regulators routinely send back Form D filings that skip the SSAP No. 25 due-date language or the “fair and reasonable” statement in Item 2(c). A missed notice can force you to unwind a signed agreement and can expose your officers to fines, so getting the form right the first time saves both money and credibility.
Here is what you will learn in this guide:
- 📋 What each of the seven Items on Form D asks and how to answer it in plain language
- 💵 The exact dollar thresholds that decide whether you even need to file at all
- ✍️ Three fully filled-out examples for the most common affiliate transactions
- 📨 Every way to file the completed form, with portals, fees, and proof to keep
- ⚠️ The mistakes that get filings rejected and how to dodge each one
What NAIC Form D Is and Who Must File It
NAIC Form D is the standardized notice an insurer uses to tell its regulator about a planned transaction with a member of its holding company system before that transaction happens. The form lives inside NAIC Model #450, the Insurance Holding Company System Model Regulation with Reporting Forms and Instructions, which nearly every state has adopted in some form. The version most states use carries a 2013 revision date and appears on form pages 450-22 through 450-26, so check that your copy matches your state’s current adoption before you start.
The form is filed by the registrant, which is the insurer or the person controlling the insurer, on behalf of one or more named insurance companies. It goes to the insurance department of the state where the insurer is domiciled, not to the NAIC itself. The NAIC writes the model; the states enforce it through their own statutes, such as California Insurance Code Section 1215 or Nebraska Revised Statute 44-2133.
You must file when a transaction crosses a materiality threshold set in Section 5 of the Act. Covered transactions include affiliate sales, purchases, loans, guarantees, investments, reinsurance agreements, and all management, service, tax-allocation, and cost-sharing arrangements. The consequence of ignoring this duty is steep: the commissioner can deem the agreement void, order it unwound, and impose monetary penalties on the insurer and its officers. A common misconception is that Form D asks for approval; in truth it is a notice filing, and the transaction is cleared if the commissioner does not disapprove it within 30 days.
Before You Start: Documents and Information You Need
Form D moves faster when you gather every supporting item before you open the document. The regulator reviews for completeness first, so a missing attachment is the most common reason a filing stalls. Pull these items together first:
- The signed or near-final transaction agreement. Regulators read the contract alongside the form, and a vague summary without the agreement triggers a request for more information.
- The most recent December 31 annual statement. Every threshold test keys off admitted assets and policyholder surplus as of the prior December 31, so you need those exact figures.
- Identity details for every party. You need each party’s legal name, home office address, principal executive office, and entity type for Item 1.
- An organizational chart with ownership percentages. This shows the relationship between the parties and supports Item 1(f).
- The cost or expense allocation method. Item 6 asks whether charges are based on “cost or market,” so settle this before filing.
- An actuarial or pricing analysis for reinsurance. For Item 5 cessions, regulators want the projected premium or liability change upfront.
- A surplus-impact statement. Several Items ask for the effect on the insurer’s surplus, and leaving it out invites a follow-up request.
- The name and title of the authorized officer. Item 7 requires a signature and certification from someone authorized to bind the company.
If any item is missing, the practical result is delay: the 30-day clock often does not start until the department considers the filing complete, so an incomplete package quietly pushes back your closing date.
Where to Get the Form and How to Access It
The official template lives inside the NAIC Model #450 regulation PDF, on the pages labeled 450-22 through 450-26. Most state insurance departments also post their own adopted copy; for example, South Dakota publishes a clean fillable Insurance Holding Company Form D that mirrors the NAIC text. Always pull the version from your domiciliary state when one exists, because state-specific section numbers may differ slightly from the model.
You can complete the form in Word or as a PDF, but it is filed electronically in most states. California accepts holding company filings through its OASIS electronic system, while Nebraska uses a secure SFTP portal where each domestic company has its own upload folder. A few states still accept email or paper, so confirm the channel before you submit.
A frequent misconception is that one “national” Form D filing covers every state where the insurer does business. It does not. Form D is filed only with the domiciliary regulator of each insurer named in the notice, so a transaction touching insurers domiciled in two states usually means two separate filings. Getting the destination wrong sends your notice to the wrong desk and burns days off your timeline.
Step-by-Step: How to Fill Out NAIC Form D Line by Line
The form opens with a caption block and then moves through seven numbered Items. Complete them in order, use the exact field labels printed on the form, and italicize nothing on the actual filing — the italics below only show you sample entries.
Caption Block: Registrant, Insurers, Date, and Contact
The top of Form D asks you to name the State, the Name of Registrant, the insurance companies the notice is filed on behalf of, the Date, and the individual to whom notices and correspondence should be addressed. Fill in the domiciliary state on the “Insurance Department of the State of” line, then type the registrant’s full legal name. List each insurer with its name and address, then add the contact’s name, title, full address, city, state, ZIP, and phone.
For example, Pioneer Mutual Holdings, Inc. writes its name as the registrant, lists Pioneer Life Insurance Company, 100 Main Street, Pierre, SD 57501 as the insurer, and names Dana Reyes, VP & Associate General Counsel as the contact with a direct phone line.
A common edge case is multiple insurers in one filing. If the same transaction involves two affiliated insurers domiciled in the same state, you may list both in the caption block, but confirm your department allows a combined notice. The most common mistake here is naming a holding company as the “insurer” rather than the licensed insurance entity, which confuses the department about whose surplus is at risk. Many filers wrongly believe the contact person must be an officer; in fact it can be outside counsel or a compliance manager, as long as that person can answer questions about the filing.
Item 1: Identity of Parties to the Transaction
Item 1 asks you to describe every party to the transaction so the regulator can see who is dealing with whom. For each party you furnish: (a) name, (b) home office address, (c) principal executive office address, (d) the organizational structure such as corporation, partnership, individual, or trust, (e) a description of the nature of the party’s business operations, (f) the relationship of the other parties to the insurer filing the notice, including any ownership or debtor/creditor interest, and (g) where the transaction is with a non-affiliate, the name of the affiliate that will receive the proceeds.
Answer each subpart in a short labeled paragraph that tracks (a) through (g) exactly. For (f), spell out the ownership chain in plain terms, such as “Parent owns 100% of the insurer’s voting stock.”
For example, Carlos Mendez, compliance director for an insurer, writes for party (d): “ABC Insurance Company is a stock insurer organized as a corporation under Delaware law,” and for party (e): “ABC underwrites personal auto and homeowners coverage in 12 states.”
A frequent edge case is an individual party, such as an officer receiving a loan; there you enter a residential or business address and “individual” for structure. The most common mistake is leaving subpart (f) vague, which forces the department to request an ownership chart and delays the review. A widespread misconception is that affiliates are “obvious” and need little description; regulators want the relationship stated in writing even when the parties share a parent.
Item 2: Description of the Transaction
Item 2 is the heart of the form and asks four things for each transaction: (a) a statement of whether notice is given under Section 5A(2)(a), (b), (c), (d), or (e) of the Act; (b) a statement of the nature of the transaction; (c) a statement of how the transaction meets the “fair and reasonable” standard of Section 5A(1)(a) of the Act; and (d) the proposed effective date.
To answer, first cite the correct subsection. Sales, loans, and investments fall under 5A(2)(a); reinsurance under 5A(2)(c); and management, service, and cost-sharing arrangements under 5A(2)(d). Then describe the deal in one or two sentences, explain why the pricing and terms are fair to the insurer, and give the date you plan to close, written as 07/01/2026.
For example, Janet Cole, treasurer of a life insurer, writes for 2(a): “Notice is given under Section 5A(2)(d),” and for 2(c): “Fees are charged at cost with no markup, consistent with arm’s-length terms, so the arrangement is fair and reasonable to the insurer.”
A tricky edge case is a transaction that fits two categories, such as a service agreement with an embedded loan; cite both subsections and describe each piece. The most common mistake is citing the wrong subsection in 2(a), which signals to the reviewer that the rest of the form may use the wrong materiality test. Many filers think the “fair and reasonable” statement in 2(c) is boilerplate; regulators read it closely and reject filings that simply repeat the standard without explaining how the terms meet it.
Item 3: Sales, Purchases, Exchanges, Loans, Extensions of Credit, Guarantees, or Investments
Item 3 applies when the transaction is a sale, purchase, exchange, loan, extension of credit, guarantee, or investment. You furnish a brief description of the amount and source of funds, securities, property, or other consideration, plus the terms of any securities received and any related service or consulting agreements. If the deal involves something other than cash, you describe the consideration, its cost, its fair market value, and the basis for that valuation. You must also include a brief statement of the effect of the transaction upon the insurer’s surplus.
For loans, guarantees, or extensions of credit, add the maximum amount the insurer may be obligated to provide, the termination date, and any interest accrual or deferral terms. For investments and guarantees, state how long the arrangement stays in effect and any renewal provisions.
For example, Marcus Bell, CFO of a property insurer, writes: “The insurer will purchase a $5,000,000 surplus note from its parent; funds come from the insurer’s general account; the purchase reduces surplus by $5,000,000 until repaid.”
A key threshold edge case: no notice is needed if the maximum outstanding amount is less than, for non-life insurers, the lesser of 3% of admitted assets or 25% of policyholder surplus, or, for life insurers, 3% of admitted assets, each measured as of the prior December 31. The most common mistake is omitting the surplus-impact statement, which the regulator will then request as a best practice and which restarts your timing. A common misconception is that book value equals fair market value for non-cash consideration; you must support the fair value with a stated basis, or the filing reads as incomplete.
Item 4: Loans or Extensions of Credit to a Non-Affiliate
Item 4 captures the indirect deal: a loan or extension of credit to a person who is not an affiliate, where the proceeds will in whole or substantial part be used to loan to, purchase assets of, or invest in an affiliate. You describe the arrangement, specify how the proceeds flow to the affiliate, and describe the amount and source of funds or other consideration. As in Item 3, non-cash consideration needs its cost, fair market value, and valuation basis, and you furnish a brief statement of the effect on the insurer’s surplus.
For example, Aisha Rahman, deputy general counsel, writes: “The insurer will lend $3,000,000 to an unaffiliated bank under an understanding that the bank will on-lend the funds to the insurer’s parent; the loan reduces liquid surplus by $3,000,000 during its term.”
This Item exists to stop insurers from routing money to affiliates through a friendly middleman to dodge the affiliate rules. The same threshold exemption applies as in Item 3, so no notice is needed below the lesser of 3% of admitted assets or 25% of surplus for non-life insurers, or 3% of admitted assets for life insurers. The most common mistake is treating a back-to-back loan as a simple non-affiliate transaction and skipping Item 4 entirely, which regulators view as an attempt to evade review. A widespread misconception is that an informal “understanding” with no written contract escapes Item 4; the rule reaches any arrangement, written or not.
Item 5: Reinsurance
Item 5 applies to a reinsurance agreement or modification under Section 5A(2)(c)(ii), or a reinsurance pooling agreement or modification under Section 5A(2)(c)(i). You furnish the known or estimated amount of liability to be ceded or assumed in each calendar year, the period the agreement runs, and a statement of whether any understanding exists to transfer part of the consideration to one of the insurer’s affiliates. You also give a brief description of the consideration and a brief statement of the effect on the insurer’s surplus.
For example, Pioneer Life Insurance Company writes: “Pioneer will cede 50% of its term life block to affiliate Pioneer Re; estimated ceded premium is $8,000,000 per year for five years; the cession increases surplus by $4,000,000 at inception.”
A central threshold edge case: no notice is needed for a reinsurance agreement or modification if the reinsurance premium or change in liabilities, actual or projected in any of the next three years, is less than 5% of policyholder surplus as of the prior December 31 — but all pooling agreements require notice regardless of size. The most common mistake is forgetting to project across three years; a deal that looks small in year one can cross 5% in year three and require filing. A common misconception is that an internal pooling reshuffle among affiliates is too routine to report; pooling agreements and their modifications always require a Form D.
Item 6: Management Agreements, Service Agreements, and Cost-Sharing Arrangements
Item 6 covers the agreements regulators see most. For management and service agreements, you furnish: (a) a brief description of the managerial responsibilities or services to be performed, and (b) a brief description of the agreement including its duration and the basis for and terms of compensation. For cost-sharing arrangements, you furnish seven subparts: (a) the purpose, (b) the period of time in effect, (c) each party’s expenses or costs covered, (d) the accounting basis used to calculate each party’s costs, (e) the effect on policyholder surplus, (f) a statement of the cost allocation method specifying whether charges are based on “cost or market,” with a rationale if market-based, and (g) a statement regarding compliance with the NAIC Accounting Practices and Procedures Manual on expense allocation.
For example, Dana Reyes writes for a service agreement: “The parent provides IT, HR, and accounting services for a five-year term; the insurer pays actual cost with no markup, billed monthly,” and adds for cost-sharing (g): “Allocations comply with SSAP No. 25 and the NAIC Accounting Practices and Procedures Manual.”
A practical edge case stressed by regulators is the due date: SSAP No. 25, paragraph 9 requires the agreement to state a specified settlement due date, and filings that omit it get bounced. The most common mistake is skipping subpart (g) or (f), since reviewers check directly for the “cost or market” language and the Manual compliance statement. A frequent misconception is that a “cost only” arrangement needs no allocation method described; you must still state the accounting basis under subpart (d), even when there is no markup.
Item 7: Signature and Certification
Item 7 closes the form with two parts: the Signature block and the Certification. The signature block recites that, under Section 5 of the Act, the applicant has caused the application to be signed in a named city and state on a given date, and it is signed by an officer with name and title, then attested by another officer. The certification is a sworn statement that the signer executed the form for the applicant, holds the stated office, is authorized to file it, is familiar with the contents, and believes the facts are true.
For example, Marcus Bell, Chief Financial Officer, signs the signature block for ABC Insurance Company in Sacramento, California, dated 06/15/2026, and the corporate secretary attests below.
A common edge case is a registrant that is a non-insurer parent; there the parent is the “applicant,” but the officer signing must still have authority to bind it. The most common mistake is having an unauthorized person sign, which voids the certification and forces a re-file. A widespread misconception is that an electronic or scanned signature is never acceptable; most states that use portals accept a signed and scanned PDF, so check your department’s rule rather than assuming wet ink is required.
Three Filled-Out Examples Using Real Scenarios
These three scenarios show how named filers carry a transaction through Form D from caption to certification. Each uses common facts that regulators review every week.
Scenario 1 — Management/Service Agreement (Dana Reyes for Pioneer Life): The parent will provide back-office services to the insurer.
| Form Section | What Dana Reyes Enters |
|---|---|
| State / Registrant | South Dakota / Pioneer Mutual Holdings, Inc. |
| Insurer named | Pioneer Life Insurance Company, Pierre, SD |
| Item 1 parties | Parent (corporation) owns 100% of insurer’s voting stock |
| Item 2(a) subsection | Section 5A(2)(d) |
| Item 2(b) nature | Five-year management and service agreement for IT, HR, accounting |
| Item 2(c) fair/reasonable | Services billed at actual cost, no markup, settled monthly |
| Item 6 type | Management/service: duration 5 years, compensation at cost |
| Item 2(d) effective date | 07/01/2026 |
| Item 7 signer | Dana Reyes, VP & Associate General Counsel, attested by secretary |
Scenario 2 — Cost-Sharing Arrangement (Carlos Mendez for ABC Insurance): Affiliates share the cost of a joint data center.
| Form Section | What Carlos Mendez Enters |
|---|---|
| State / Registrant | California / ABC Holdings, Inc. |
| Insurer named | ABC Insurance Company, Sacramento, CA |
| Item 2(a) subsection | Section 5A(2)(d) |
| Item 6(a) purpose | Share cost of shared data center and software |
| Item 6(c) costs covered | Hosting, licensing, and IT staff salaries |
| Item 6(d) accounting basis | Allocated by headcount and usage |
| Item 6(f) cost or market | Cost-based; no market markup applied |
| Item 6(g) compliance | Complies with SSAP No. 25 and the NAIC manual |
| Item 6(e) surplus effect | Estimated $400,000 annual expense, immaterial to surplus |
| Item 7 signer | Carlos Mendez, Compliance Director, attested by treasurer |
Scenario 3 — Affiliated Reinsurance Cession (Marcus Bell for a property insurer): The insurer cedes part of its book to an affiliated reinsurer.
| Form Section | What Marcus Bell Enters |
|---|---|
| State / Registrant | Nebraska / Summit Group, Inc. |
| Insurer named | Summit Property Insurance Company, Omaha, NE |
| Item 2(a) subsection | Section 5A(2)(c)(ii) |
| Item 5 liability ceded | 50% quota share, est. $8,000,000 premium/year |
| Item 5 period | Five years, with annual renewal |
| Item 5 affiliate transfer | No side understanding to transfer consideration |
| Item 5 surplus effect | Increases surplus by $4,000,000 at inception |
| Item 2(c) fair/reasonable | Ceding commission set at market terms per actuarial study |
| Item 2(d) effective date | 09/01/2026 |
| Item 7 signer | Marcus Bell, CFO, attested by corporate secretary |
How to File the Completed Form D
Form D is filed only with the domiciliary insurance department of each named insurer, and the available channels depend on the state. Below are the main channels and what to expect for each.
- State electronic portal (most common). California uses the OASIS system and Nebraska uses a secure SFTP portal where each domestic company uploads to its own folder. There is usually no filing fee for a Form D notice, though many states charge a separate annual holding company registration fee. The portal often gives no automatic confirmation, so save a screenshot and the upload timestamp as your proof.
- Email. Some departments accept a signed PDF by email to the financial or holding company unit. Keep the sent message and any acknowledgment reply as proof of filing.
- Mail or in person. Where paper is still allowed, send the signed original to the department’s financial regulation division at the address on the state’s holding company page, and use certified mail so you keep the postmark and return receipt as proof.
To get portal access, you typically request a login from the department’s financial examination staff and name the companies you file for. Expected processing time is governed by the 30-day waiting period: the transaction is cleared once the commissioner has not disapproved it within 30 days of a complete filing. Keep your proof of filing, because that date starts the clock that lets you close.
What Happens After You File Form D
After you submit, the department first checks the filing for completeness, and an incomplete package may not start the 30-day clock until the missing items arrive. A reviewer then reads the form against the agreement, the org chart, and the prior December 31 financials to confirm the transaction is fair and reasonable and will not harm policyholders. For complex deals, the department may set up a call or request a pricing or actuarial analysis before clearing the notice.
If the commissioner takes no action within 30 days, the transaction may proceed. The commissioner can also affirmatively approve it sooner, or disapprove it if the terms appear unfair, threaten surplus, or harm policyholders. A disapproval means you cannot close as proposed; you must revise the terms and re-file.
A common misconception is that silence is risky and you must wait for written approval. In a notice regime, the absence of disapproval within the window is itself the green light, though many filers ask the department to confirm clearance in writing for their files. Keep every piece of correspondence, because examiners revisit Form D filings during periodic financial exams.
Mistakes to Avoid When Filling Out Form D
- Filing late. Submitting fewer than 30 days before closing means you cannot legally complete the transaction on your target date.
- Citing the wrong Section 5A subsection in Item 2(a). It signals the wrong materiality test and undermines the whole filing.
- Skipping the Item 2(c) fair-and-reasonable explanation. A bare restatement of the standard gets the filing rejected.
- Omitting the surplus-impact statement. The department will request it and your review stalls.
- Leaving out the SSAP No. 25 due date in a cost-sharing agreement. Reviewers check for a specified settlement date and bounce filings without it.
- Dropping Item 6(f) “cost or market” language. Without it the cost allocation statement is incomplete.
- Forgetting Item 6(g) NAIC manual compliance statement. This is a required line, not optional boilerplate.
- Not projecting reinsurance across three years. A small year-one cession can cross 5% of surplus later and require notice.
- Treating all pooling agreements as exempt. Every pooling agreement and modification requires a Form D regardless of size.
- Filing with the wrong state. Sending the notice to a non-domiciliary regulator wastes days and the clock never starts.
- Having an unauthorized person sign Item 7. It voids the certification and forces a re-file.
- Using book value as fair market value. Non-cash consideration needs a stated valuation basis or the filing reads as incomplete.
Do’s and Don’ts
Do’s
- Do file at least 30 days early, because the waiting period protects your closing date.
- Do attach the underlying agreement, since regulators read the contract next to the form.
- Do use the exact Item and subsection numbers from your state’s Act, so the reviewer can follow your logic.
- Do include a surplus-impact statement on every applicable Item, because the department will ask for it anyway.
- Do state a specified due date in cost-sharing deals, since SSAP No. 25 requires it.
- Do save your portal timestamp or certified-mail receipt, because it proves when the clock started.
Don’ts
- Don’t assume Form D is an approval form, because it is a prior-notice filing cleared by non-disapproval.
- Don’t combine insurers from different states in one notice, since each domiciliary regulator needs its own filing.
- Don’t leave Item 1(f) relationships vague, because that draws an immediate request for an org chart.
- Don’t skip Item 5’s three-year projection, since future-year premium can trigger the filing duty.
- Don’t route money to an affiliate through a non-affiliate to dodge review, because Item 4 captures it.
- Don’t sign without authority, because an invalid certification kills the filing.
Filing on Your Own vs. With Professional Help
Pros of filing in-house
- Lower cost, since you avoid outside counsel fees on routine, low-dollar agreements.
- Speed, because your compliance team already knows the company’s structure and financials.
- Institutional knowledge, as in-house staff understand prior filings and recurring affiliate deals.
- Direct regulator relationships, which help on routine notices the department has seen before.
- Control, because you keep the full file and timeline inside the company.
Cons of filing in-house / pros of professional help
- Complex deals carry real risk, and outside counsel knows how to frame novel reinsurance or financing structures.
- Subsection citation is technical, and an expert avoids the Item 2(a) errors that derail filings.
- Multi-state transactions multiply work, where counsel coordinates parallel filings efficiently.
- Regulators expect polish on large transactions, and seasoned advisors anticipate the department’s questions.
- A rejected filing costs time, so professional review can be cheaper than a missed closing date.
Form D vs. Form A and Form B at a Glance
| Feature | Form D and Related Forms |
|---|---|
| Form A | Application for approval to acquire control of a domestic insurer; full prior approval required |
| Form B | Annual registration statement for the holding company system, due on a set annual date |
| Form C | Summary of changes to the Form B registration statement |
| Form D | Prior notice of a material transaction between the insurer and an affiliate, cleared by non-disapproval |
| Form F | Enterprise risk report describing risks across the holding company system |
FAQs
Do I have to file Form D before the transaction happens?
Yes. You must file at least 30 days before entering into the transaction, and you cannot close if the commissioner disapproves it within that 30-day window.
Is there a filing fee for Form D?
No. Most states charge no fee for the Form D notice itself, though many require a separate annual holding company registration fee under Form B.
Do I file Form D with the NAIC?
No. You file it with the insurance department of the state where the insurer is domiciled; the NAIC only writes the model regulation that the states adopt.
Does Form D mean the regulator must approve the deal?
No. It is a notice filing, and the transaction is cleared if the commissioner does not disapprove it within 30 days, though some departments confirm clearance in writing.
Do small affiliate transactions still need a Form D?
No. Transactions below the threshold are exempt, generally the lesser of 3% of admitted assets or 25% of surplus for non-life insurers, or 3% of admitted assets for life insurers.
Do I cite the subsection in Item 2(a) even for a service agreement?
Yes. Management, service, and cost-sharing arrangements are filed under Section 5A(2)(d), and citing the wrong subsection signals a wrong materiality test to the reviewer.
Do I write the effective date or the signing date in Item 2(d)?
Yes, write the proposed effective date of the transaction, formatted like 07/01/2026; the signing date goes only in the Item 7 signature and certification block.
Do all reinsurance pooling agreements require a Form D?
Yes. Every pooling agreement and any modification requires notice regardless of dollar size, even though ordinary cessions are exempt below 5% of policyholder surplus.
Do I need the SSAP No. 25 due date in a cost-sharing filing?
Yes. SSAP No. 25 paragraph 9 requires a specified settlement due date, and cost-sharing filings without it are commonly sent back as incomplete.
Do I list the holding company or the insurer as the named insurer?
No, do not list the holding company as the insurer; the caption block names the licensed insurance entity whose surplus is affected, while the parent may appear as registrant.
Can outside counsel sign the Item 7 certification?
No, the certification must be signed by an officer of the applicant who is authorized to file it; outside counsel may, however, be the contact person for correspondence.
Do I need a separate Form D for insurers domiciled in different states?
Yes. Each domiciliary regulator receives its own filing, so a transaction involving insurers in two states usually means two separate Form D notices.
Do I have to include a surplus-impact statement on every Item?
Yes for Items 3, 4, 5, and 6, because each calls for a brief statement of the effect on the insurer’s surplus, and omitting it triggers a follow-up request.
Does an electronic signature work on Form D?
Yes in most states that use portals, which accept a signed and scanned PDF, but confirm your department’s rule because a few still require a wet-ink original.
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