How to Fill Out NAIC Form F (w/Examples) + FAQs

NAIC Form F is the Enterprise Risk Report that the ultimate controlling person of an insurance holding company system files each year with its lead state insurance commissioner to disclose risks that could threaten the whole group. It comes from the NAIC Insurance Holding Company System Model Regulation (#450) and is now adopted in nearly every state, so the layout you fill out looks the same whether you file in California, Florida, or Arizona.

The form exists to give regulators a group-wide view of danger that a single insurer’s annual statement would miss, and skipping it or filing it wrong can trigger fines, a regulatory exam, or loss of confidential treatment for sensitive business secrets. Form F is short, but it is deceptively hard, because most of the work is judgment about what counts as enterprise risk. State versions like Florida’s carry a revision stamp such as 69O-143.046 New 5/16, so always confirm you are using your state’s current copy before you start.

Here is what you will learn in this guide:

• 📋 What Form F is, who must file it, and the exact statute that forces the filing
• 🗂️ Every document and data point to gather before you open the form
• ✍️ A line-by-line walkthrough of the title page, Item 1, and Item 2 with sample entries
• 👥 Three full filled-out examples following real holding company groups
• ⚠️ The field-level mistakes that get filings rejected and how to dodge them

What Form F Is and Who Must File It

Form F is a once-a-year narrative report that names the risks living inside an insurance group rather than inside one licensed insurer. The filing duty sits with the ultimate controlling person (UCP) of the holding company system, which is the top entity that controls the insurers and answers to no one above it. Control is presumed when one entity holds 10% or more of another’s voting securities, a number drawn straight from the NAIC model and copied into state law like Section 628.801, Florida Statutes.

The report goes to the lead state commissioner, which is the single regulator chosen to coordinate oversight of a multi-state group under the procedures in the NAIC Financial Analysis Handbook. A group licensed in twelve states does not file twelve Form Fs; it files one, with the lead state. That lead state then shares the report with the other regulators through confidential channels and, for large groups, through a supervisory college.

Not every insurer files. Form F is required only when an insurer is part of a holding company system that must already file the Holding Company System Annual Registration Statement (Form B). A standalone insurer with no parent and no affiliates does not file Form F at all. The duty was added after the 2008 financial crisis exposed how risk at a non-insurance parent, such as a banking or investment arm, could sink the insurance subsidiaries beneath it.

Because the form captures sensitive strategy, most states grant Form F strong confidentiality protection by statute, meaning it is not a public record and is exempt from open-records requests. This protection is the reason groups feel safe writing candidly about rating-agency talks or litigation. Lose the confidential treatment through a careless public filing, and competitors could read your playbook.

Before You Start: Documents and Information You Need

Form F looks like a one-page narrative, but the answers behind it pull from across the whole enterprise. Gathering these items first keeps you from guessing and protects you from leaving out a reportable event. Missing any one of them is the top reason a filing comes back thin or incomplete.

• The current Form B (Annual Registration Statement). Item 1 lets you skip anything already disclosed on Form B, so you need it open to avoid repeating or contradicting yourself.
• A current organizational chart of the group. Without it, you cannot correctly identify which entities count as part of the holding company system or who the UCP is.
• Board and audit committee minutes for the past 12 months. These surface internal audit findings, compliance issues, and strategy shifts that Item 1 demands.
• Records of any acquisitions or dispositions. Buying or selling an insurer, or moving entities inside the group, is a named Item 1 trigger.
• The shareholder register or cap table. You must report any change in ownership crossing the 10% voting-securities threshold, and you cannot spot that without the records.
• Pending litigation and regulatory matter logs. Item 1 asks for investigations or lawsuits that could materially affect the group.
• The group’s 12-month business plan and capital plan. Item 1 requires a summary of forward strategy and of capital resources and distribution patterns.
• Rating-agency correspondence. Any negative movement or even a discussion with a rating agency about a possible downgrade must be disclosed, so pull the latest letters and call notes.

If your group files with the U.S. Securities and Exchange Commission, also pull your most recent SEC filing such as the Form 10-K, because the form lets you attach it instead of rewriting the answers. If the UCP sits outside the U.S., gather the most recent public audited financial statement from its home country, which the form accepts in place of an SEC document.

Where to Get the Form and How to Access It

Form F is a state form built on a national template, so you download it from your domiciliary state’s insurance department, not from a single federal site. The master language lives in the NAIC Model Regulation #450, and each state copies that text into its own version with a state revision stamp. Florida publishes its copy as form OIR-A1-2118, Arizona posts its Holding Company Form F, and Kentucky issues its version under 806 KAR 37:010.

Always pull the form from the state where your lead regulator sits. The body text is nearly identical state to state because it tracks the model, but the statute cite, the revision date, and the submission instructions differ. Using California’s form when your lead state is Florida can put the wrong statutory reference on your title page.

Most states distribute Form F as a fillable PDF or a Word document. You complete it as a typed narrative, not as a fill-in-the-blank grid, because Item 1 is a written discussion rather than a set of boxes. Save your working copy with a clear file name that includes the group name and the reporting year so version control stays clean during internal review.

Check the revision stamp in the footer before you type a single word. A stamp like New 5/16 tells you the form has not changed since 2016, while a newer date means your prior-year template may be stale. Filing on an outdated form is a quick way to draw a deficiency letter.

Step-by-Step: How to Fill Out NAIC Form F Line by Line

Form F has three parts: the title page, Item 1 (Enterprise Risk), and Item 2 (Obligation to Report). Work them in order, because the title page frames who is speaking and Item 2 only matters once you have finished Item 1. The field labels below are the exact labels printed on the form.

Title Page — “Filed with the Insurance Department of the State of ____”

This line asks which state’s insurance department is receiving the report. You type the full name of your lead state, the single regulator coordinating your group, on the blank. Write it out plainly, such as Florida or California, matching the state whose form you downloaded.

For example, the UCP of a group whose lead regulator is the California Department of Insurance writes California on this blank. If your group operates in many states but the lead state is Arizona, you still write only Arizona here, never a list. A common mistake is naming a state where you merely hold a license rather than the designated lead state, which routes the report to the wrong regulator and delays acceptance. Many filers wrongly believe this line means “state of domicile of the top insurer,” but it means the lead state assigned under the NAIC handbook, and the two are not always the same.

Title Page — “By: Name of Registrant/Applicant”

This field asks for the name of the entity actually filing the report, which must be the ultimate controlling person of the holding company system. Enter the full legal name of that top entity exactly as it appears in your organizational chart and on your Form B. Do not abbreviate or use a trade name.

For example, Summit Mutual Holdings, Inc. writes its full legal name here, not “Summit” or “Summit Holdings.” If the UCP is an individual person rather than a company, you enter that person’s full legal name instead. A frequent error is naming a mid-level insurance subsidiary as the registrant, which is wrong because only the UCP files Form F, and listing a subsidiary signals you have misidentified who controls the group. Some filers assume the largest insurer in the group is the registrant, but size does not decide it; control does.

Title Page — “On Behalf of/Related to Following Insurance Companies (Name and Address)”

Here the form asks you to list every licensed insurance company in the group that this report covers, with each one’s name and address. Enter the full legal name and principal business address of each insurer the UCP controls, one per line, and continue on an attached sheet if you run out of room.

For example, Summit lists Summit Life Insurance Company, 400 Harbor Blvd, Tampa, FL 33602 and Summit Casualty Insurance Company, 400 Harbor Blvd, Tampa, FL 33602 on separate lines. If an insurer was sold mid-year, note it and the disposal date so the regulator sees the change. The biggest mistake is leaving an affiliated insurer off the list, which makes the filing look incomplete and can suggest you are hiding an entity from group supervision. Filers sometimes think only in-state insurers belong here, but you list all insurers the UCP controls, regardless of their home state.

Title Page — “Date”

This field asks for the date the report is signed and filed. Enter the calendar date in your state’s accepted format, and write the year on the printed 20___ line so the stamp reads cleanly, such as June 1, 20__26__.

For example, a filer completing the form on the first of June writes June 1, 2026. If your internal review pushes the signing date back a week, update this field rather than leaving the draft date in place. A small but real mistake is dating the form for the period it covers instead of the day you actually file, which can make a timely filing look late. People often assume the date can be any day in the filing window, but it should be the true date of execution so it lines up with your proof of filing.

Title Page — “Name, Title, Address and Telephone Number of Individual to Whom Notices Should Be Addressed”

This block asks who the regulator should contact with questions about the report. Enter the full name, job title, mailing address, and direct phone number of the real person handling the filing, usually a general counsel, chief risk officer, or compliance head.

For example, Summit enters Dana Reyes, Chief Risk Officer, 400 Harbor Blvd, Tampa, FL 33602, (813) 555-0142. Add an email address if your state’s form provides a space, since most regulators now correspond electronically. The common error is naming an outside consultant who cannot answer for the company or who leaves the engagement, which strands the regulator’s questions. Many filers think this must be an executive officer, but it can be any knowledgeable contact who can speak to the report and reach decision-makers fast.

Item 1 — Enterprise Risk: The Ten Disclosure Areas

Item 1 is the heart of the form and asks the registrant, to the best of its knowledge and belief, to discuss any of ten named areas that could produce enterprise risk, unless that information already appears on the group’s annual registration statement. You answer it as a written narrative, addressing each of the ten bullets in turn and writing “No material developments to report” under any bullet that is genuinely empty. The ten areas, taken verbatim from the form, are below.

• Any material developments regarding strategy, internal audit findings, compliance, or risk management affecting the system
• Acquisition or disposal of insurance entities and reallocating of financial or insurance entities within the system
• Any changes of shareholders of the system exceeding ten percent (10%) or more of voting securities
• Developments in investigations, regulatory activities, or litigation that may significantly impact the system
• The business plan of the system and summarized strategies for the next 12 months
• Identification of material concerns raised by a supervisory college, if any, in the last year
• Identification of the system’s capital resources and material distribution patterns
• Any negative movement or discussions with rating agencies that may cause a downgrade in credit or financial-strength ratings, including both score and outlook
• Information on corporate or parental guarantees and the expected source of liquidity if a guarantee is called
• Any material activity or development that, in senior management’s opinion, could adversely affect the system

For example, under the rating-agency bullet, the UCP of Cardinal Insurance Group writes “In March 2026, A.M. Best placed Cardinal Casualty’s A- rating under review with negative implications following storm losses; management is in active discussions and expects a decision by Q3.” The key nuance is the SEC shortcut: the form lets you attach your most recent SEC filing instead of rewriting answers, but only if you add specific references pointing the regulator to where in that filing each Item 1 area is covered. Skip those cross-references and the attachment does not satisfy Item 1, leaving you exposed to a deficiency notice. The most damaging mistake is treating Item 1 as a checklist and under-disclosing a known risk, because the standard is “to the best of its knowledge and belief,” and burying a known downgrade discussion can be read as a material omission. A widespread misconception is that Item 1 wants only bad news; in truth it also wants the forward business plan and capital picture, which are not negative at all.

Item 2 — Obligation to Report

Item 2 asks what happens when there is nothing to disclose under Item 1. If the registrant has not disclosed any information under Item 1, it must include a clear statement affirming that, to the best of its knowledge and belief, it has not identified enterprise risk subject to disclosure. You satisfy this by typing that affirmation in plain language and having an authorized officer stand behind it.

For example, a small, stable group writes “Greenfield Mutual Holdings affirms that, to the best of its knowledge and belief, it has not identified enterprise risk subject to disclosure pursuant to Item 1 for the reporting period.” The nuance is that Item 2 is not a way to avoid Item 1; you use it only after you have honestly worked through all ten areas and found nothing material. The serious mistake here is filing the Item 2 “nothing to report” statement when a reportable event exists, which converts a paperwork issue into a false-certification problem. Filers often assume Item 2 makes Form F optional in a quiet year, but the filing itself is still required; you simply file it carrying the affirmation instead of a risk narrative.

Three Filled-Out Examples Using Real Scenarios

Below are three common fact patterns, each following one named group through the form. The examples show how the same Form F flexes from a risk-heavy multi-state giant to a small group with nothing to report.

Scenario 1: Large multi-state group with a non-insurance parent (Meridian Financial Group). Meridian is a public company with banking and asset-management arms sitting above its insurers, and its lead state is California.

Form Section	What Meridian Enters
Filed with the State of	California
By: Name of Registrant	Meridian Financial Group, Inc.
On Behalf of Insurers	Meridian Life Insurance Co. and Meridian P&C Insurance Co., with full addresses
Date	June 1, 2026
Notices Contact	Priya Shah, General Counsel, (415) 555-0190
Item 1 – Strategy/Audit	Restructuring of asset-management arm; internal audit flagged IT controls
Item 1 – Rating Agencies	S&P revised outlook to negative on the parent bank in April 2026
Item 1 – Guarantees	Parent guarantees $200M of subsidiary debt; liquidity from holding-company credit line
Item 1 – Business Plan	Exit two unprofitable P&C lines over next 12 months
Item 2	Not applicable; risks disclosed under Item 1

Scenario 2: Mid-size group with a recent acquisition and downgrade watch (Cardinal Insurance Group). Cardinal bought a competitor last year and is now under rating-agency review, with Florida as its lead state.

Form Section	What Cardinal Enters
Filed with the State of	Florida
By: Name of Registrant	Cardinal Insurance Group, LLC
On Behalf of Insurers	Cardinal Casualty Insurance Company, 900 Bayshore Dr, Miami, FL 33131
Date	June 1, 2026
Notices Contact	Marcus Bell, Chief Risk Officer, (305) 555-0177
Item 1 – Acquisition	Acquired Coastal Mutual in October 2025; integration ongoing
Item 1 – Rating Agencies	A.M. Best placed A- under review, negative implications, March 2026
Item 1 – Litigation	Class action over claims handling filed Q1 2026
Item 1 – Capital	Holding company suspended dividends to preserve capital
Item 2	Not applicable; risks disclosed under Item 1

Scenario 3: Small stable group with no enterprise risk to report (Greenfield Mutual Holdings). Greenfield is a single-state mutual group with no acquisitions, no rating changes, and no litigation, filing in Arizona.

Form Section	What Greenfield Enters
Filed with the State of	Arizona
By: Name of Registrant	Greenfield Mutual Holdings
On Behalf of Insurers	Greenfield Mutual Insurance Company, 22 Desert Rd, Phoenix, AZ 85004
Date	June 1, 2026
Notices Contact	Lena Ortiz, Compliance Director, (602) 555-0123
Item 1 – All Ten Areas	No material developments to report under any area
Item 1 – Business Plan	Continue current product lines; no strategic changes planned
Item 1 – Capital	Stable; routine surplus distributions consistent with prior years
Item 2	Affirms no enterprise risk subject to disclosure under Item 1

How to File the Completed Form

Form F is filed with your lead state commissioner, not with the NAIC itself, and the exact channel depends on your state. Always keep proof of whatever method you use, because the burden is on the filer to show the report arrived on time.

• Secure online portal. Many states now require electronic submission through a regulated-industry portal. For example, Florida filers use the Office of Insurance Regulation portal, there is no separate filing fee for Form F itself, and the portal issues a confirmation receipt you should download and save as proof of filing.
• By mail. Some states still accept a paper original mailed to the insurance department’s financial oversight unit at the address printed in the form instructions. Use certified mail with return receipt, keep the green card, and expect handling to take longer than electronic filing.
• By email. Several departments accept Form F at a dedicated financial-analysis email box because the report is confidential and not a public web posting. Save the sent message and any auto-reply as your proof, and confirm the department’s size limit before attaching large SEC documents.
• In person. A few departments allow hand delivery to the financial oversight division. Ask the clerk to date-stamp a copy for your records, since that stamp is your proof of timely filing.

There is generally no fee to file Form F because it is a supervisory report rather than an application. Processing is not an approval step; the regulator reviews the report as part of ongoing group analysis rather than sending back a stamped acceptance. Keep your filed copy, all attachments, and your proof of filing together for at least the period your state’s record-retention rules require.

What Happens After You File

Once your lead state receives Form F, it folds the report into the group’s ongoing financial analysis rather than issuing an approval. Analysts read it alongside your Form B, your financial statements, and, for larger groups, your ORSA Summary Report to build a full picture of group risk. The report stays confidential by statute and is shared only with other regulators through protected channels.

For a large multi-state group, the lead state may bring the report into a supervisory college, a meeting of all the regulators overseeing the group, to discuss the risks you disclosed. If your Form F flags a serious issue such as a looming downgrade or a parent-company liquidity strain, expect follow-up questions, a request for more detail, or a targeted exam. Silence is the usual outcome for a clean filing, but silence is not the same as approval.

If a regulator finds the form incomplete or believes you under-disclosed a known risk, it can issue a deficiency letter demanding a corrected filing. Repeated or willful failures can lead to fines and, in serious cases, enforcement action under the holding company act. The confidential treatment that protects your candor only holds if you file through the proper confidential channel, so a sloppy public submission can waive it.

Mistakes to Avoid When Filling Out the Form

• Naming the wrong filer. Listing a subsidiary instead of the ultimate controlling person tells the regulator you have misidentified who controls the group.
• Writing the wrong state on the title page. Naming a license state rather than the lead state routes the report to the wrong regulator and delays acceptance.
• Leaving an affiliated insurer off the list. An incomplete insurer list makes the filing look like it is hiding an entity from group supervision.
• Under-disclosing a known risk. Burying a downgrade discussion or pending litigation can be treated as a material omission.
• Filing the Item 2 “nothing to report” statement when a risk exists. This turns a paperwork problem into a false-certification problem.
• Attaching an SEC filing without cross-references. Without specific pointers to each Item 1 area, the attachment fails to satisfy Item 1.
• Skipping the forward business plan. Treating Item 1 as bad-news-only leaves out the required 12-month strategy and capital picture.
• Using an outdated form version. Filing on a stale template draws a deficiency letter for using the wrong revision.
• Filing publicly or through the wrong channel. This can waive the statutory confidentiality and expose sensitive strategy.
• Dating the form for the coverage period instead of the filing day. A mismatched date can make a timely filing look late.
• Missing the annual deadline. Late filing of a required group report can trigger penalties under the holding company act.

Do’s and Don’ts

Do:

• Do confirm you are the ultimate controlling person before you file, because only the UCP carries the Form F duty.
• Do walk through all ten Item 1 areas one by one, since the standard is your full knowledge and belief.
• Do cross-reference any attached SEC filing area by area, because that is the only way the shortcut is valid.
• Do file with your designated lead state, since that single regulator coordinates the group.
• Do save your confirmation or certified-mail receipt, because the burden of proving timely filing is on you.
• Do check the revision stamp, so you never file on a stale form.

Don’t:

• Don’t repeat information already on your Form B, because Item 1 only wants what is not already disclosed there.
• Don’t name an outside consultant as the notices contact, since the regulator needs someone who can answer for the company.
• Don’t file Item 2 as a shortcut to skip Item 1, because the affirmation must follow an honest review.
• Don’t post the report to a public site, since that can waive confidentiality.
• Don’t abbreviate legal entity names, because mismatches with your Form B raise questions.
• Don’t assume a quiet year means no filing, since the report is required even with nothing to report.

Pros and Cons of Filing on Your Own vs. With Help

Filing In-House (Pro Se)	Filing With Outside Counsel or Consultants
Lower cost, since you avoid professional fees	Higher cost from legal and consulting rates
Your team knows the group’s risks best, so disclosure is accurate	Outside experts may miss internal nuance unless briefed well
Faster for a simple, stable group with nothing to report	Slower due to engagement and review cycles, but safer for complex groups
Full control over confidential strategy stays inside the company	Sharing sensitive data with outsiders adds a confidentiality layer to manage
Builds internal compliance muscle for future years	Provides expert judgment on what counts as a material enterprise risk
Risk of under-disclosure if your team misreads the standard	Lowers the risk of a deficiency letter through experienced review

FAQs

Who actually signs and files Form F?

Yes, the ultimate controlling person of the holding company system files it, signed by an authorized officer such as a general counsel, chief risk officer, or compliance head.

Is Form F filed with the NAIC?

No, you file it with your lead state insurance commissioner, not the NAIC; the NAIC only publishes the model template that states adopt.

Do I have to file Form F if nothing changed this year?

Yes, the filing is still required; you simply include the Item 2 statement affirming you have identified no enterprise risk subject to disclosure.

Is there a fee to file Form F?

No, there is generally no filing fee because Form F is a supervisory report rather than an application or license request.

Is Form F a public record?

No, most states protect Form F as confidential by statute, so it is exempt from open-records requests when filed through the proper channel.

In Item 1, do I write the state where my biggest insurer is domiciled?

No, the title-page state line names your lead state, the regulator coordinating your group, which is not always the domicile of the largest insurer.

Do I list every insurer in the group on the title page, even out-of-state ones?

Yes, you list all insurers the ultimate controlling person controls, regardless of which state each insurer calls home.

Does a 9% shareholder change need to be reported in Item 1?

No, the form’s threshold is a change of ten percent (10%) or more of voting securities, so a 9% shift falls below the reporting line.

Can I attach my SEC 10-K instead of writing Item 1 answers?

Yes, but only if you add specific references pointing the regulator to where each Item 1 area is covered in that filing.

Do I have to repeat risks already on my Form B?

No, Item 1 expressly excludes information already disclosed on the Insurance Holding Company System Annual Registration Statement.

Does Form F require numbers and financial tables?

No, Form F is a written narrative; it asks for discussion of risk areas and strategy, not the financial schedules found in your annual statement.

What happens if I under-disclose a known risk?

No, that is not safe; a regulator can treat a buried known risk as a material omission and issue a deficiency letter or pursue enforcement.

Can a foreign (non-U.S.) parent file something other than an SEC document?

Yes, a non-U.S. ultimate controlling person may attach its most recent public audited financial statement from its home country, with specific references to each Item 1 area.

Is the Item 2 affirmation a way to avoid filling out Item 1?

No, you use Item 2 only after honestly working through all ten Item 1 areas and finding nothing material to disclose.