How to Fill Out the DC Captive Insurance Company Application + FAQs

The DC Captive Insurance Company Application is the form a business files with the District of Columbia Department of Insurance, Securities and Banking (DISB) to get a certificate of authority and legally run its own captive insurer in the District. A captive is an insurance company that a parent business owns to insure its own risks instead of buying coverage from an outside carrier. The form asks for the captive’s owners, its capital, its business plan, and the people who will manage it.

Filing this form right matters because DISB returns any application that is incomplete, and a returned application costs you weeks of delay while your risk sits uninsured. The District has built one of the largest captive markets in the country, with hundreds of licensed captives on its books and a published goal of acting within 30 days on a clean filing. That speed only works in your favor if every box is answered and every attachment is attached.

Here is what you will learn in this guide:

  • 📋 What the form is, who must file it, and the law that requires it
  • 🗂️ Every document and number you must gather before you start
  • ✍️ A line-by-line walkthrough of all 22 questions and the Business Plan Summary Form
  • 🧑‍💼 Three full filled-out examples that follow real captives from start to finish
  • 💵 How to file, what the fees are, and what happens after you send it in

What the Form Is and Who Must File It

The DC Captive Insurance Company Application is the single intake form DISB uses to decide whether to grant a certificate of authority to a proposed captive insurer. A certificate of authority is the license that lets the captive write insurance. Without it, the company cannot legally collect premium or pay claims in the District. The form lives inside the Risk Finance Bureau, the unit of DISB that runs the captive program.

The law behind the form is D.C. Code § 31–3931.09, the application requirements section of the District’s captive statute. This rule says every captive insurer must apply for a certificate of authority and must include organizing documents, a CPA-prepared pro forma financial statement, and a strategic business plan. The consequence of ignoring it is simple: no certificate, no captive. If you skip the business plan, for example, DISB cannot judge whether your plan is sound, so it will not issue the license.

You must file this form if you plan to form any type of captive in the District. That includes a single parent (pure) captive owned by one company, an association captive owned by a trade group, an agency captive, a branch captive, a risk retention group, a rental captive, or a protected cell. A common misconception is that small or single-owner captives are exempt. They are not. Every captive, no matter how small, files the same application and pays the same fees.

Before You Start: Documents and Information You Need

Captive applications fail more often from missing attachments than from wrong answers in the boxes. The form ends with a long list of enclosures at Question 22, and DISB returns the whole package if even one is missing. Gather everything below before you open the form so you are not chasing documents at the deadline.

  • Audited financial statements of the beneficial owners. Question 5 demands the most recent audited financials of the owners. Without them, DISB cannot test whether the owner can fund the captive.
  • Draft articles of incorporation, organization, or association, plus bylaws. Question 22(d) requires these. If the captive is a reciprocal, you need a certified power of attorney-in-fact and a subscribers’ agreement instead.
  • A CPA-prepared pro forma financial statement. The statute and Question 22(i)(6) both require five-year projections on the DISB Excel pro forma template. A pro forma your in-house bookkeeper builds will be rejected.
  • An actuarial feasibility study. Question 22(e) wants a study showing expected and adverse loss scenarios. Missing this signals that no one has tested whether the captive can pay claims.
  • Biographical affidavits for every officer, director, and MGA/MGU. Question 22(f) requires the official Biographical Affidavit for each leader. A missing affidavit stalls the background review.
  • Five years of loss experience and in-force declaration pages. Question 22(i)(4) and (5) require current carrier declaration pages and claims history. Describe every claim over $100,000.
  • Unexecuted service provider agreements showing fees. Question 22(h) requires draft contracts for the manager, lawyer, actuary, and accountant, with fees shown.
  • The fees themselves. You need a $500 non-refundable application review fee and a $300 certificate of authority fee, ready to pay by check, ACH, or wire.

A useful habit is to build a table of contents that mirrors the form’s question numbers. DISB asks for a detailed table of contents and clearly marked tabs, so matching your binder or PDF bookmarks to the box numbers helps the reviewer find each item fast.

Where to Get the Form and How to Access It

You download the official form straight from the agency. The current PDF is the Captive Insurance Company Application hosted on the DISB site, and the companion forms — the Biographical Affidavit, the Application for Approval as a Captive Manager, the Financial Pro Forma Template in Excel, and the Sample Letter of Credit Form — sit on the same About Captives page. Always pull the form from this page rather than from a third-party site so you know you have the version DISB will accept.

DISB does not print a numbered revision date on the face of the form, so you confirm you have the current version by checking the agency’s captive page for the linked PDF each time you file. The most important date to anchor is the electronic-filing rule that took effect on March 16, 2020, which changed how the form is submitted. Before that date, filers mailed paper binders; now the agency wants a single bookmarked PDF emailed in.

A smart first move is to call the Risk Finance Bureau before you fill anything in. DISB invites proposed captives to arrange a meeting or call with the Bureau Director to discuss the business plan and get early reactions. This pre-application call often surfaces problems — like a thin capital plan or an unapproved manager — while they are still cheap to fix.

Step-by-Step: How to Fill Out the DC Captive Insurance Company Application Line by Line

The application runs 22 numbered questions followed by a certification and a separate Business Plan Summary Form. Answer every question. The instructions say that if a question does not apply, you write “not applicable” rather than leaving it blank, because a blank box reads as an incomplete answer and triggers a return of the whole package.

Question 1: Name of Proposed Captive

This box asks for the exact legal name the captive will use. Write the full name as it appears, or will appear, on your draft articles of incorporation or organization, including the entity tag like “Inc.,” “LLC,” or “Reciprocal.” For example, Anacostia Health Assurance, Inc. goes on this line for a hospital system’s new captive. Match this name letter for letter to the name on the articles you attach under Question 22(d).

A common edge case is a name that is still pending a name-reservation check with the DC Department of Licensing and Consumer Protection. If the name is not yet cleared, note it as proposed and keep a backup name ready. The most common mistake here is using a trade name or “doing business as” name instead of the legal entity name, which creates a mismatch between the application and the articles and forces DISB to ask for a correction. People often think the captive’s name must include the word “captive” or “insurance,” but the statute sets no such rule.

Question 2: Parent or Beneficial Owner

This box asks who owns the captive at the top of the chain. Enter the legal name of the parent company or the ultimate beneficial owner that controls the captive. For a single parent captive, this is usually the operating business itself, such as Anacostia Health System, LLC. Use the parent’s full legal name, not a brand or division name.

If the captive is owned through a holding company, name the entity that holds the shares, and let Question 3 capture the chain below it. The most common mistake is naming the operating brand the public knows instead of the registered parent, which confuses the ownership review and delays the background check on the owner. Filers sometimes believe a captive can have no parent at all; in fact, every captive must trace back to a beneficial owner that DISB can vet.

Question 3: Names and Addresses of Beneficial Owners and Percentage of Ownership

This section asks you to list each beneficial owner, their address, and how much of the captive each one owns. Fill in lines (a) through the blank line with each owner’s name and mailing address, then write the ownership share as a percentage in the right-hand column. For example, Anacostia Health System, LLC — 100% on line (a) for a wholly owned pure captive. The percentages must add up to 100%.

For an association captive with many members, you may not be able to list every member here, so name the association as the owner and attach a member schedule. The most common mistake is percentages that do not total 100, which signals to the reviewer that the cap table is wrong and stops the review. A frequent misconception is that minority owners under some small threshold can be left off; DISB wants every beneficial owner who controls the captive listed.

Question 4: Explain Relationship Among Beneficial Owners

This box asks how the owners relate to each other and to the captive. Write a short, plain description of the ownership and control links, such as parent and subsidiary, sibling companies under one holding company, or independent members of a trade association. For example, “All beneficial owners are wholly owned subsidiaries of Anacostia Health System, LLC, which is the sole member of the captive.”

If the owners are unrelated businesses joining an association captive, explain the common industry or risk that ties them together, because that link is what makes an association captive legal. The most common mistake is a one-word answer like “affiliated,” which tells the reviewer nothing and prompts a follow-up question. Some filers think this box is a formality; in reality, DISB uses it to confirm the captive insures genuine related-party or member risk rather than unrelated third-party business.

Question 5: Audited Financial Statements of Beneficial Owners

This is an instruction, not a fill-in box: you must enclose the most recent audited financial statements of the beneficial owners. Attach the full audited statements, with the auditor’s opinion, behind the matching tab in your PDF. For example, Anacostia Health System, LLC encloses its 2025 audited consolidated financials.

If an owner is a brand-new entity with no audit yet, attach the most recent reviewed or compiled statements and a note explaining why no audit exists. The most common mistake is sending unaudited internal financials, which DISB will reject because it cannot rely on numbers no auditor has tested. Filers often assume a tax return will do; it will not, because a return is not an audited financial statement.

Question 6: Contact Individual for This Application

This box asks for the one person DISB should call with questions about the filing. Enter the name, address, phone number, and email of the contact, who is usually the captive manager or the insurance lawyer. For example, Maria Delgado, Capital Risk Managers, 810 First St NW, Suite 701, Washington, DC 20002, (202) 555-0143, mdelgado@capitalrisk.com.

Pick someone who knows the file and answers quickly, because DISB’s 30-day clock keeps running while it waits for replies. The most common mistake is listing a busy executive who never checks the inbox, which stalls the review when the agency has a quick question. People often think this must be an owner or officer; it can be any authorized representative who can speak to the application.

Question 7: Type of Proposed Captive

This box asks you to check the captive type. Mark exactly one of the choices: Pure, Agency, Association, Branch, Risk Retention, Rental, or Cell. A pure captive insures one parent and its affiliates, while an association captive insures members of a group. For example, a hospital system marks Pure.

The form adds a key rule: if cells are to be formed, you submit a separate application for each cell. The most common mistake is checking two boxes or the wrong box, which changes the capital rules and the review path and can void the analysis. Filers sometimes think the type can be changed later with a quick email; in fact, a change in type is a material change that needs prior written approval under the statute.

Question 8: Organization Form

This box asks for the legal structure of the captive. Check one: Stock, Mutual, Reciprocal, LLC, or Non-profit. The choice must match your draft organizing documents under Question 22(d). For example, a single parent captive often checks LLC and attaches articles of organization, while a reciprocal checks Reciprocal and attaches a power of attorney-in-fact.

If you check Reciprocal, remember the form requires a certified copy of the power of attorney-in-fact and the subscribers’ agreement rather than ordinary bylaws. The most common mistake is a structure here that conflicts with the attached articles, which forces DISB to ask which one is correct. A common misconception is that the structure has no tax effect; in fact, the form you pick shapes how the captive is taxed at the federal level, so coordinate with a tax adviser first.

Question 9: Jurisdictions Where Majority of Risks Will Be Located

This box asks where most of the insured risks sit. List the states or countries where the bulk of the parent’s exposures are located, such as District of Columbia, Maryland, and Virginia for a regional hospital system. Be specific and rank by where the largest share of risk lives.

If the parent operates nationwide, name the top jurisdictions and note that risk is spread across all states. The most common mistake is writing only “DC” when the real risk is mostly elsewhere, which misleads the actuary reviewing exposure and can undercut your pro forma. Filers sometimes think the captive must insure mainly DC risk to license here; it does not, since DC captives commonly cover risk located in other states.

Question 10: Location of Books and Records

This box asks where the captive’s books and records will physically live. Enter the address where the records will be kept, which is usually the captive manager’s office in the District. For example, Capital Risk Managers, 810 First St NW, Suite 701, Washington, DC 20002.

DC captives generally must keep records accessible to the Commissioner, so naming an in-District location through your manager is the clean path. The most common mistake is listing the parent’s out-of-state headquarters with no DC presence, which raises a question about whether the Commissioner can examine the records. People often assume records can sit anywhere because everything is digital; the agency still wants a defined custodian and a real address.

Question 11: Resident Registered Agent and Address

This box asks for the captive’s registered agent in the District and that agent’s address. Enter the name and DC street address of the agent who will accept legal service for the captive. For example, DC Corporate Agents, Inc., 1100 H St NW, Washington, DC 20005.

The agent must have a physical DC address, not a P.O. Box, because legal papers are hand-delivered there. The most common mistake is naming an agent who has not yet agreed to serve, which means the captive has no valid agent on record. Filers often confuse the registered agent with the captive manager; they can be different parties, and the agent’s only job is to receive legal notices.

Question 12: Capital and/or Surplus of Company

This box asks for the money standing behind the captive. In part (a), enter Initial Capital, Initial Surplus, and the Total of the two. In parts (b) and (c), split how much of that comes from policyholders versus other persons, and in part (d) identify those other persons and their relationship to the captive. Part (e) asks where the shares of stock are located. For example, a pure captive enters Initial Capital $250,000, Initial Surplus $250,000, Total $500,000.

The total must meet the minimum capital and surplus the statute requires for your captive type, since D.C. Code § 31–3931.09(b) makes you prove the assets match the risks assumed. The most common mistake is funding below the minimum, which gets the application denied outright because an underfunded captive cannot be trusted to pay claims. A common misconception is that promised future contributions count; DISB wants evidence the capital is real and available at licensing.

Question 13: Letters of Credit (If Used)

This box applies only if a letter of credit will back the captive’s capital. If so, enter the issuing bank’s name and address, the party in whose favor it is issued, and the dollar amount. For example, Potomac National Bank, 500 K St NW, Washington, DC — issued in favor of Anacostia Health Assurance, Inc. — $250,000.

The form notes a strict rule: the District of Columbia letter of credit form must be used, so download the Sample Letter of Credit Form and match it exactly. The most common mistake is using the bank’s own template instead of the DC form, which DISB will reject because the wording does not meet District requirements. Filers sometimes think a letter of credit fully replaces cash; in practice, only part of capital may be held this way, and the rest must be in admitted assets.

Question 14: Captive Manager

This box asks for the firm that will run the captive day to day. Enter the captive manager’s name, address, phone, and email. The manager must be approved by the Commissioner, so pick from the list of approved management firms. For example, Capital Risk Managers, 810 First St NW, Suite 701, Washington, DC, (202) 555-0143, manager@capitalrisk.com.

If your preferred manager is not yet approved, the firm must file the separate Application for Approval as a Captive Manager before your captive can rely on it. The most common mistake is naming an unapproved manager, which freezes the whole application until approval comes through. Filers sometimes think the parent can self-manage with no licensed firm; DC expects a Commissioner-approved manager in nearly every case.

Question 15: Lawyer

This box asks for the captive’s attorney. Enter the lawyer’s name, address, phone, and email. Most filers name insurance counsel experienced with DC captives, such as James Whitfield, Whitfield Insurance Law, 700 13th St NW, Washington, DC, (202) 555-0188, jwhitfield@wilaw.com.

If you used different counsel to draft the articles than the one who will advise the captive, list the lawyer who will serve the captive going forward. The most common mistake is leaving this blank because the parent’s general counsel is handling it; if so, name that lawyer rather than skipping the box. People often assume a lawyer is optional for a simple captive; while not strictly required, DISB strongly expects experienced insurance counsel on the file.

Question 16: Claims Handler and Underwriter

This box asks who will handle claims and who will underwrite the captive’s policies. Enter the name and address of each. For a small pure captive, the manager often handles both, so you might write Capital Risk Managers (claims and underwriting), 810 First St NW, Suite 701, Washington, DC.

If you use a third-party administrator for claims, name that TPA here and attach its service agreement under Question 22(h). The most common mistake is leaving claims handling vague, which makes DISB doubt the captive can actually pay and process claims. Filers sometimes think underwriting is unnecessary for a single-parent captive; even then, someone must set terms and price the coverage, so name that party.

Question 17: Certified Public Accountant

This box asks for the CPA who will audit and prepare the captive’s financials. Enter the firm’s name and address, such as Beltway Audit Partners, LLP, 1200 G St NW, Washington, DC. This is the same caliber of firm that must prepare the pro forma the statute requires.

Choose a CPA with captive experience, because DC captives must file annual audited statements, and a firm new to captives may stumble on the format. The most common mistake is naming a small local accountant who cannot perform a statutory insurance audit, which causes problems at the first annual filing. A misconception is that the parent’s regular accountant always qualifies; captive accounting differs, so confirm the firm does insurance work.

Question 18: Actuary

This box asks for the actuary who will sign the feasibility study and reserve opinions. Enter the actuary’s name and address, such as Tidewater Actuarial Group, 1500 Eye St NW, Washington, DC. This actuary usually prepares the feasibility study required at Question 22(e).

The actuary must be qualified to issue statements of actuarial opinion, since the captive will need reserve opinions every year. The most common mistake is listing a non-credentialed analyst, which weakens the feasibility study and invites extra scrutiny. Filers sometimes believe the actuary and the CPA can be the same person; they are separate roles with separate credentials, so name each one.

Question 19: Reinsurance Broker/Intermediary

This box asks who will place the captive’s reinsurance. Enter the broker or intermediary name and address, such as Eastern Re Brokers, 900 17th St NW, Washington, DC. If the captive will cede risk to reinsurers, this party arranges those treaties.

If the captive retains all risk and buys no reinsurance, write “not applicable” rather than leaving the box blank. The most common mistake here is a blank box when the pro forma clearly assumes reinsurance, which contradicts the financials and prompts a question. People often think reinsurance is only for large captives; even small captives often cede catastrophic layers, so confirm your program before answering.

Question 20: Service Providers and Compensation

This box asks you to list every service provider, how each is paid, and the estimated annual cost for Year 1 and Year 2. Fill the grid with the provider, the method of compensation (hourly, flat fee, or percentage of premium), the service performed, and the dollar estimates. For example, Capital Risk Managers — flat fee — captive management — Year 1 $60,000, Year 2 $62,000.

Match these entries to the unexecuted agreements you attach under Question 22(h), because DISB cross-checks the fees. The most common mistake is leaving cost estimates blank or rounding to vague figures, which makes the expense lines in the pro forma look unsupported. Filers sometimes think only the manager goes here; list the lawyer, actuary, CPA, TPA, and any other paid provider too.

Question 21: Biographical Information for Directors and Officers

This box asks you to list each director and officer with their position at the captive and their outside employer and position, and to attach a biographical affidavit for each. Fill the grid with each name, role, and day job. For example, Dr. Lena Park — Chair — Anacostia Health System, Chief Risk Officer. Then attach a signed Biographical Affidavit for every person listed.

If a director is a non-U.S. resident, the background check can take longer, so submit those affidavits early. The most common mistake is listing officers but forgetting an affidavit for one of them, which stalls the character review the statute requires under § 31-3931.09(b)(2). People often think only the parent’s executives need affidavits; every officer and director of the captive, plus any MGA or MGU, must file one.

Question 22: Required Enclosures

This is the master checklist of attachments, and it is where most applications fall short. You must include the $500 application fee, the $300 certificate fee, the Business Plan Summary Form, draft articles and bylaws, an actuarial feasibility study, biographical affidavits, association details if applicable, unexecuted service agreements, and a detailed Plan of Operation. The Plan of Operation alone has fourteen parts, from risks insured by line of business through reinsurance program, investment policy, organization chart, and proposed coverage forms. For example, Anacostia Health Assurance attaches a 14-tab Plan of Operation that opens with medical malpractice as the insured line.

Two parts deserve special care: subpart (i)(5) requires you to describe every claim over $100,000 from the past five years and the corrective action taken, and subpart (i)(6) requires five-year pro forma projections on the DISB template in both expected and worst-case scenarios. The most common mistake is submitting projections in your own spreadsheet instead of the required DISB Excel template, which gets the financials kicked back. Filers often underestimate the Plan of Operation, thinking a short summary is enough; DISB wants all fourteen elements with supporting data.

Certification and Signature Block

The form ends with a certification a director signs under penalty of being wrong. Print the signer’s name, write the date, and sign on the Director line. The certification states the information is true and correct and that the captive will notify the Commissioner within ten days of any material change. For example, Dr. Lena Park signs as Director and dates the form the day the package goes out.

Read this language before signing, because it binds you to a 10-day notice duty that continues after licensing. The most common mistake is signing with stale figures in the pro forma, since the certification covers all estimates as carefully considered. A misconception is that an unsigned electronic application is acceptable while details are finalized; the instructions require a signed application, and an unsigned one is incomplete.

Business Plan Summary Form (Attachment 22(c))

This separate one-page form distills the captive’s economics onto a single sheet. Enter the captive name, type, form of organization, owner, and manager at the top, then complete eight numbered items: risks directly insured with premium, limits, deductible, and rating; fronted policies; retention and reinsurance details for each risk; total written premium; paid-in capital surplus; estimated retained earnings; estimated loss reserves; and four operating ratios. For example, a pure captive lists medical malpractice — $1.2M premium — $1M limit — $250K deductible — G (guaranteed cost) on line 1.

The ratios in item 8 — such as net retained risk to net written premium plus capital and surplus — let DISB gauge solvency at a glance, so the numbers must tie to your full pro forma. The most common mistake is a summary that disagrees with the detailed pro forma, which signals careless math and invites a deeper review. Filers sometimes treat this form as optional because it duplicates the Plan of Operation; it is a required enclosure under Question 22(c), and omitting it returns the package.

Three Filled-Out Examples Using Real Scenarios

These three examples show how different captives complete the form. Each follows one named filer through the main sections so you can see what real answers look like.

Example 1: Dr. Lena Park forms a pure captive for a hospital system’s malpractice risk.

Form Section What Dr. Lena Park Enters
Q1 Name of Proposed Captive Anacostia Health Assurance, Inc.
Q2 Parent or Beneficial Owner Anacostia Health System, LLC
Q3 Beneficial Owners / % Anacostia Health System, LLC — 100%
Q7 Type of Captive Pure
Q8 Organization Form Stock
Q9 Jurisdictions of Risk District of Columbia, Maryland, Virginia
Q12 Capital and Surplus Initial Capital $250,000; Surplus $250,000; Total $500,000
Q14 Captive Manager Capital Risk Managers (Commissioner-approved)
Q21 Directors and Officers Dr. Lena Park, Chair; affidavits attached
Certification Signed by Dr. Lena Park, Director

Example 2: Marcus Bell forms an association captive for a contractors’ trade group.

Form Section What Marcus Bell Enters
Q1 Name of Proposed Captive Builders Mutual Assurance, Reciprocal
Q2 Parent or Beneficial Owner Capital Contractors Association
Q3 Beneficial Owners / % Association members per attached schedule — 100% collectively
Q4 Relationship Among Owners All owners are dues-paying members of the same contractors’ association
Q7 Type of Captive Association
Q8 Organization Form Reciprocal (power of attorney-in-fact attached)
Q12 Capital and Surplus Total $750,000
Q22(g) Association Details History, purpose, and 140-member size attached
Q22(e) Feasibility Study Actuarial study for general liability attached
Certification Signed by Marcus Bell, Director

Example 3: Priya Nair forms a protected cell within a sponsored cell captive.

Form Section What Priya Nair Enters
Q1 Name of Proposed Captive Tidewater Cell Series 3
Q2 Parent or Beneficial Owner Tidewater Logistics, Inc.
Q3 Beneficial Owners / % Tidewater Logistics, Inc. — 100% of the cell
Q7 Type of Captive Cell (separate application filed for this cell)
Q8 Organization Form LLC
Q9 Jurisdictions of Risk Nationwide, top exposure in Texas and Ohio
Q12 Capital and Surplus Total $300,000 ring-fenced to the cell
Q14 Captive Manager Capital Risk Managers
Q19 Reinsurance Intermediary Eastern Re Brokers
Certification Signed by Priya Nair, Director

How to File the Completed Form

Filing is now electronic, and you have one main channel plus payment options. Effective March 16, 2020, DISB asks filers to submit applications electronically and no longer requires hard-copy binders. You assemble the whole package as a single signed PDF with a detailed table of contents and bookmarks, attach the pro forma as a separate Excel file, and email both to the Risk Finance Bureau at the address DISB lists, with a copy to the second listed address.

For the fees, you pay the $500 non-refundable application review fee and the $300 certificate of authority fee. If you pay by check, include a copy of the check inside the PDF and mail the actual check to the DC Treasurer Insurance Bureau, PO Box 712180, Philadelphia, PA 19171-2180. DISB also accepts ACH and wire transfer; you request those instructions from the bureau’s payment contact before sending funds.

Keep proof of everything you send. Save the sent email with timestamps, the read receipt if you can get one, and the wire or ACH confirmation, because these prove the date you filed and the date the 30-day clock should start. The legacy paper process — one signed original and four copies in three-ring binders with tabbed sections delivered to the Risk Finance Bureau at 810 First Street, NW — still appears on the form face, but the electronic method is the current path, so follow the electronic instructions unless the bureau tells you otherwise.

What Happens After You File

Once DISB has a complete application, the statute gives it a clear deadline. Under D.C. Code § 31–3931.09(d), if the Commissioner finds the documents complete and satisfactory, the Commissioner issues the certificate of authority within 30 days. DISB’s own guidance echoes this, promising to process properly documented applications within 30 days.

During review, the agency may send your application to an independent actuary, and the statute lets the Commissioner require outside legal, financial, and examination services. You pay for that review, and the form warns you must pay the review firm within 30 days of its invoice. If you ignore that invoice, you slow your own licensing and risk a denial.

After the certificate issues, the captive enters an annual cycle. Each certificate renews every year, due no later than April 30 after issuance. The Commissioner may fine a captive that fails to renew before August 1 and may suspend or revoke the certificate of a captive that still has not renewed on or after that date, so calendar the renewal the moment you are licensed.

Mistakes to Avoid When Filling Out the Form

Captive applications are long, and each box is a chance to slip. These are the errors that most often delay or sink a filing.

  • Leaving a box blank instead of writing “not applicable.” DISB returns the entire incomplete application.
  • Using a trade name in Question 1 instead of the legal entity name. The mismatch with your articles forces a correction.
  • Listing ownership percentages that do not total 100% in Question 3. The reviewer cannot trust the cap table.
  • Funding capital below the statutory minimum in Question 12. The application is denied outright.
  • Naming an unapproved captive manager in Question 14. The file freezes until the manager is approved.
  • Submitting the pro forma in your own spreadsheet rather than the DISB Excel template. The financials get kicked back.
  • Forgetting a biographical affidavit for one officer in Question 21. The character review cannot finish.
  • Sending unaudited financials for the owners under Question 5. DISB will not rely on untested numbers.
  • Omitting the Business Plan Summary Form required by Question 22(c). The package is incomplete.
  • Skipping the description of claims over $100,000 in Question 22(i)(5). The loss history looks hidden.
  • Using the bank’s own letter of credit wording instead of the required DC form. The credit is rejected.
  • Signing the certification with stale pro forma numbers. You certify figures you did not carefully consider.

Do’s and Don’ts

These quick rules keep your application on the fast track.

Do’s

  • Do call the Risk Finance Bureau before filing, because early feedback fixes weak plans cheaply.
  • Do match your table of contents and bookmarks to the question numbers, so the reviewer finds each item fast.
  • Do use the DISB Excel pro forma template, since the statute requires CPA-prepared projections in that format.
  • Do pick a Commissioner-approved manager up front, because an unapproved one freezes the file.
  • Do save proof of filing and payment, so you can show when the 30-day clock started.
  • Do answer every box, writing “not applicable” where needed, because blanks trigger a return.

Don’ts

  • Don’t underfund capital, because the statute makes you prove assets match the risks you assume.
  • Don’t use a bank’s own letter of credit form, since only the DC form meets District wording rules.
  • Don’t list a busy executive as the contact, because slow replies stall the 30-day review.
  • Don’t submit unsigned, because the instructions require a signed application.
  • Don’t ignore the actuary’s invoice, since late payment delays your own licensing.
  • Don’t treat the Plan of Operation as a short summary, because DISB wants all fourteen parts with data.

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

Most DC captives file through a manager and counsel, but it helps to weigh the trade-offs.

Pros of filing with a captive manager and counsel

  • They know the DISB template and tabs, so the application is complete the first time.
  • They are already Commissioner-approved, which satisfies Question 14 without a separate approval step.
  • They coordinate the CPA, actuary, and lawyer, so the attachments tie together.
  • They speak DISB’s language, which often shortens the back-and-forth during review.
  • They handle the annual renewal and the 10-day material-change notices after licensing.

Cons of filing with a captive manager and counsel

  • Professional fees add real cost, often tens of thousands of dollars a year.
  • You depend on outside parties for timing, which can slow you if they are busy.
  • A manager unfamiliar with your industry may misjudge your risk profile.
  • You share confidential business data with several outside firms.
  • Switching managers later is a material change that needs notice and coordination.

Pure Captive vs. Association Captive at a Glance

This table contrasts the two most common types so you check the right box at Question 7.

Feature Pure Captive
Owners One parent and its affiliates
Risk insured The parent group’s own risk
Typical filer A single company’s risk manager
Question 4 answer Parent-subsidiary relationship
Extra enclosure None beyond standard 22 items
Feature Association Captive
Owners Members of a trade association
Risk insured The members’ shared industry risk
Typical filer An association on behalf of members
Question 4 answer Members of the same association
Extra enclosure Association history and size under 22(g)

FAQs

Do I have to use the official DISB pro forma Excel template?

Yes. The statute requires a CPA-prepared pro forma, and DISB requires its own Excel template; your own spreadsheet will be returned as incomplete.

Can I leave a question blank if it does not apply to my captive?

No. The instructions tell you to write “not applicable” instead, because any blank box reads as incomplete and triggers a return of the whole application.

Do I file the application by mail or electronically?

Yes, electronically. Since March 16, 2020, DISB wants a single signed, bookmarked PDF plus the Excel pro forma emailed to the Risk Finance Bureau.

Is the $500 application review fee refundable if I am denied?

No. The $500 application review fee is non-refundable, though the $300 certificate of authority fee is returned if the application is denied.

Do I check more than one box at Question 7 for the captive type?

No. Mark only the single type that fits, because the type sets your capital rules and review path, and multiple checks confuse the analysis.

In Question 3, must the ownership percentages add up to 100%?

Yes. The beneficial owners’ shares must total 100%, or the reviewer cannot trust the cap table and will ask you to fix it.

Do I need a biographical affidavit for every officer and director?

Yes. Question 22(f) and Question 21 require a signed affidavit for each officer, director, and any MGA or MGU, with no exceptions.

Can I name my own bank’s letter of credit form in Question 13?

No. The form states the District of Columbia letter of credit form must be used, so the bank’s own template will be rejected.

Will DISB really decide within 30 days?

Yes, if the application is complete. The Commissioner issues the certificate within 30 days of finding the documents complete and satisfactory.

Does my captive have to insure mostly DC-based risk to license here?

No. DC captives commonly cover risk located in other states, so Question 9 simply lists where the majority of risks sit.

Do I have to keep the captive’s books and records inside DC?

Yes, in practice. Question 10 expects an accessible location, usually the manager’s DC office, so the Commissioner can examine the records.

Is a captive manager legally required to file?

No, not in every case, but DC expects a Commissioner-approved manager, and naming an unapproved one at Question 14 freezes the application until approval.

Do I need to describe small claims in the loss history?

No. Question 22(i)(5) requires you to describe only claims over $100,000 from the past five years, along with the corrective action taken.

Must I notify DISB if my business plan changes after licensing?

Yes. The certification binds you to notify the Commissioner within ten days of any material change, and plan changes need prior written approval.