2025 SRA—Appendix II 07-01-24 

APPENDIX II 

PLAN OF OPERATIONS 

The Plan of Operations (Plan) filed by the Company shall contain the information stated herein 

and the Company shall certify the accuracy and completeness of the Plan. Information, 

documents, or forms, are to be identified in the Plan as Exhibits to correspond with each section 

and paragraph. The Company shall file all Exhibits required herein annually, and, as necessary, 

file any addition or revision to specific Exhibits during the reinsurance year. Any Exhibit not 

filed when required may delay approval of the Plan. The Company may be required to provide 

additional information as may be necessary to clarify or provide further detail in support of the 

Company’s or MGA’s financial or operational capacity. 

SECTION I. INSURANCE COMPANY GENERAL 

(a) The name, address, phone number, web site address, and tax identification 

number of the Company. (Note: If the Company’s Plan is approved, information 

from this Exhibit other than tax identification number will be released on RMA’s 

public web site.) 

(b) The names, address, and tax identification numbers of all PICs and, upon request, 

a copy of agreements between the Company, or its MGA, and PICs. 

(c) If the Company elects to use an MGA: 

(1) The name, phone number, address, web site address, and tax identification 

number of the MGA; (Note: If the Company’s Plan is approved, 

information from this Exhibit other than tax identification number will be 

released on RMA’s public web site.) 

(2) A copy of all agreements between the MGA and the Company that relates 

to eligible crop insurance contracts reinsured under this Agreement; and 

(3) A letter from an officer of the Company that empowers the entity 

identified in subparagraph (c)(1) to act as the MGA for the Company for 

the reinsurance year. The officer must be listed in the Company’s Annual 

Statement filed with the State in which the Company is domiciled and 

have the authority to act on behalf of the Company. 

SECTION II. CERTIFICATIONS 

The Company shall provide a certification statement referencing each item in this section, signed 

by the person authorized to sign the Agreement on behalf of the Company, unless otherwise 

specified. 

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2025 SRA—Appendix II 07-01-24 

(a) In accordance with section I of Appendix I, the Company shall submit its 

certification regarding procurement integrity. 

(b) In accordance with section II of Appendix I, the Company shall submit its 

certification regarding a drug free workplace. 

(c) In accordance with section III of Appendix I, the Company shall complete and 

submit OMB Form LLL, Disclosure of Lobbying Activities, and specify the 

period of time to which such completed form applies. 

(d) In accordance with section IV(p) of the Agreement, the Company shall submit its 

certification regarding compliance with discrimination laws. 

(e) The Company shall submit its certification that the Company, its MGA as 

applicable, its affiliates, and its PICs are properly licensed under the insurance 

laws or regulations of all States in which the Company sells and services eligible 

crop insurance contracts reinsured under this Agreement. 

(f) The Company shall submit its certification regarding the Company’s ability to 

meet its obligations under the current and any prior Agreement, as applicable. 

(g) The Company shall submit its certification regarding non-disclosure, as specified 

in section XV(a)(9) of Appendix I. 

(h) The Company shall submit its certification that the information required by US 

Federal Contractor Registration (www.sam.gov) has been provided. This 

information will be used to process payments. 

(i) The Company shall submit its certification that any agent cancellation 

notifications will provide the affected agent/agency 60 days written notice, or the 

period of notice required by state law, whichever is greater, prior to the first sales 

closing date of the agent/agencies book of business. AIPs shall provide RMA 

written notice 30 days prior to sending the agent/agency written notice. 

SECTION III. FINANCIAL INFORMATION 

(a) Upon specific request by FCIC, the Company shall provide the following: 

(1) The Statutory Annual Statement for the most recent reporting year. 

(2) The Statutory Quarterly Statements for the most recent quarter and 

throughout the reinsurance year, within 10 days after such statements are 

filed with the State. 

(3) The Statutory Management Discussion and Analysis, within 10 days of 

making the filings in subparagraph (c). 

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2025 SRA—Appendix II 07-01-24 

(4) Actuarial Opinion of Reserves for the most recent reporting year, by June 

1 preceding the start of the reinsurance year. 

(5) Insurance Regulatory Information System (IRIS) Ratios. 

(6) The Statutory Insurance Expense Exhibit. 

(b) The Company shall provide the following: 

(1) If prepared in the normal course of business, annual audited GAAP 

financial statements for the previous reporting year, by June 1 preceding 

the start of the reinsurance year. 

(2) If prepared in the normal course of business, Quarterly GAAP financial 

statements throughout the reinsurance year, within 45 days of the end of 

each quarter. 

(3) If prepared in the normal course of business, annual Securities and 

Exchange Commission filings (i.e. 10K), if applicable, within 30 days of 

making such filings. 

(4) If prepared in the normal course of business, quarterly Securities and 

Exchange Commission filings (i.e. 10Q) within the reinsurance year, if 

applicable, within 30 days of making such filings. 

(5) Controls or management recommendations received from an independent 

auditor regarding the Company, by June 1 preceding the start of the 

reinsurance year. 

(6) The most recent State Insurance Department Examination Report, within 

30 days of receipt by the Company of such report. 

(c) If an MGA is designated, the MGA shall provide the following: 

(1) Annual audited GAAP financial statements for the previous calendar or 

fiscal year, as applicable, by June 1 preceding the start of the reinsurance 

year. 

(2) Quarterly GAAP financial statements throughout the reinsurance year, 

within 45 days of the end of each quarter. 

(3) If prepared in the normal course of business, annual Securities and 

Exchange Commission filings (i.e. 10K), within 30 days of making such 

filings. 

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2025 SRA—Appendix II 07-01-24 

(4) If prepared in the normal course of business, Quarterly Securities and 

Exchange Commission filings (i.e. 10Q) within the reinsurance year, 

within 30 days of making such filings. 

(5) Internal controls or management recommendations received from an 

independent auditor regarding the MGA, by June 1 preceding the start of 

the reinsurance year. 

(d) The Company shall provide an explanation for any ratio falling outside the 

requirements of 7 C.F.R. §§ 400.162. 

(e) Upon request the Company shall provide a description of all financial 

relationships that pertain to crop insurance business reinsured under this 

Agreement. 

(f) The Company shall provide Agent Compensation Reports, itemizing agent 

commissions and other agent compensation only for business under the SRA. 

Reports shall itemize eligible insurance contracts reinsured by FCIC as 

specified in the Agent Compensation Template, and completed for the: 

(1) Previous reinsurance year’s actual data certified by a financial officer, 

authorized by the Company, as being in compliance with FCIC 

procedures; 

(2) Current reinsurance year’s estimated data; and 

(3) Upcoming reinsurance year’s projected data. 

(g) The Company shall provide Loss Adjustment Expense Reports, itemizing loss 

adjuster expenses only for business under the SRA. Reports shall itemize 

eligible insurance contracts reinsured by FCIC as specified in the Loss 

Adjustment Expense Template, and completed for the: 

(1) Previous reinsurance year’s actual data certified by a financial officer, 

authorized by the Company, as being in compliance with FCIC 

procedures; 

(2) Current reinsurance year’s estimated data; and 

(3) Upcoming reinsurance year’s projected data. 

(h) The Company shall submit Total Expense Reports only for business under the 

SRA. Reports shall itemize total expenses for all eligible crop insurance contracts 

reinsured by FCIC, be prepared according to the National Association of 

Insurance Commissioners Annual Statement Instructions as specified in the Total 

Expense Template, and be completed for the: 

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2025 SRA—Appendix II 07-01-24 

(1) Previous reinsurance year’s actual data certified by a financial officer, 

authorized by the Company, as being in compliance with FCIC 

procedures; 

(2) Current reinsurance year’s estimated data; and 

(3) Upcoming reinsurance year’s projected data. 

(i) Posted reserves for which estimated liability exceeds five percent of policyholder 

surplus for: 

(1) All open contingent liabilities; and 

(2) All pending arbitration, mediation, or litigation. 

(j) Upon request, the Company, and MGA if applicable, shall provide one or more of 

the following: 

(1) Actual and estimated cash flow documentation; 

(2) Copies of all line of credit agreements with financial institutions used to 

fund any expenses, including amounts due FCIC; or 

(3) Any other financial information related to the Company or the MGA that 

would assist FCIC in determining the financial capacity to perform under 

the terms of this Agreement. 

SECTION IV. INSURANCE OPERATIONS 

The Company’s Plan shall include: 

(a) The name, title, mailing address, e-mail address, office telephone numbers, and 

fax telephone numbers of the officer or employee authorized by the Company to 

sign and certify the Monthly Settlement Report. Any changes regarding the 

officer or employee shall be provided to FCIC in writing prior to the submission 

of the next Monthly Settlement Report. 

(b) The names, titles, mailing addresses, e-mail addresses, office telephone numbers, 

and fax telephone numbers of at least two officers or employees authorized by the 

Company, and two officers or employees authorized by the MGA, if an MGA is 

designated by the Company, as managers of the eligible crop insurance contracts 

reinsured under the Agreement. Each person will act as liaison or contact between 

the Company and FCIC regarding this Agreement. 

(c) The names, mailing addresses, e-mail addresses, office telephone numbers, and 

fax telephone numbers of the office of the Company, or any entity, that qualifies 

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2025 SRA—Appendix II 07-01-24 

as a service provider and a description of the services it provides. 

(d) The names, mailing addresses, e-mail addresses, office telephone numbers, 

and fax telephone numbers of all regional offices and service centers operated 

by the Company or its MGA that provides a service related to eligible crop insurance 

contracts reinsured under this Agreement and a description of the services they 

provide. 

(e) An organizational chart showing the names and positions of individuals 

performing the following functions with respect to Federal crop insurance 

operations: chief executive officer, chief operations officer, chief financial officer, 

and the highest ranking individuals responsible for information technology, 

underwriting, claims, quality control, training and development, sales and 

marketing, compliance, and reinsurance. If an individual performs more than one 

of the foregoing functions, the chart shall so indicate. Any changes to the 

information contained in this chart shall be reported within 30 days to FCIC in 

writing. 

(f) The name and address of the Company or MGA, if applicable, and the bank that 

will make Electronic Funds Transfer payments to FCIC for the Company. 

(g) The name, street address, city, county, state, country, city code, county code, state 

code, country code, (codes can be obtained from http://www.itl.nist.gov and 

http://www.itl.nist.gov/itl) and Congressional District for the organization to 

whom payments from FCIC should be remitted for amounts due on Monthly and 

Annual Settlement reports. 

(h) A declaration as to the Company’s intention to use the Escrow Agreement and 

associated procedures, for reimbursement by FCIC to cover losses paid by the 

Company. If the Company elects to use the Escrow Agreement, the Company 

shall provide the following, even if the required documents were provided in a 

prior reinsurance year and no changes have been made: 

(1) An executed copy of the agreement regarding the Reinsurance Escrow 

Arrangement between the Company and FCIC; and 

(A) For the Standard Reinsurance Agreement only; 

(B) For both the Standard Reinsurance Agreement and Livestock 

Price Reinsurance Agreement. 

(2) An executed copy of the Escrow Agreement between the Bank and FCIC. 

(A) For the Standard Reinsurance Agreement only; 

(B) For both the Standard Reinsurance Agreement and Livestock 

Price Reinsurance Agreement. 

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(i) The Training and Performance Evaluation Plan (TPEP) and the Training and 

Performance Evaluation Report (TPER) required in section II of Appendix IV. 

The TPEP will be approved if all elements identified in Appendix IV are 

contained therein. Approval of the TPEP in the Plan of Operations is not a 

determination of the sufficiency of the Company’s training and evaluation 

program. 

(j) The Company’s quality control information required in section I(a) of Appendix 

IV. The quality control information provided by the Company will be approved if 

all elements identified in section I(a) of Appendix IV are contained therein and 

such approval with the Plan of Operations is not a determination of the 

sufficiency of the Company’s quality controls. 

(k) With respect to section II(a)(5) of the Agreement: 

(1) The Company shall review its contract arrangements with any affiliate 

that is also a cooperative or trade association (or any affiliate that, in turn, 

has a contractual arrangement with a cooperative or trade association) to 

determine whether the cooperative or trade association seeks to qualify 

for payments to producers under section 508(b)(5)(B) of the Act (7 

U.S.C. § 1508 (b)(5)(B)). If a cooperative or trade association seeks to 

qualify under section 508(b)(5)(B) of the Act, the Company shall submit 

the items listed below and receive written FCIC approval before the 

cooperative or trade association will be deemed to qualify under section 

508(b)(5)(B) of the Act. 

(A) The names, addresses, and telephone numbers of each cooperative 

association or trade association with which the Company or its 

affiliates intends to enter into a licensing or other financial 

agreement or contract authorized by sections 508(b)(5)(B), or has 

entered into such agreements; 

(B) A copy of the agreement or contract with the cooperative 

association or trade association and a list of the states where the 

cooperative association or trade association will return all or part 

of the CAT administrative fee received from the Company to its 

producers; and 

(C) For each State listed in subparagraph (B), a letter from the State 

Insurance Department stating whether the payment of all or a 

portion of the CAT administrative fees on behalf of producers is in 

compliance with the rebating laws of such State. 

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(2) For those cooperative or trade associations previously determined by 

FCIC to have qualified under section 508(a)(9)(B)(iii) of the Act, the 

Company shall provide a current certification from an officer of the 

cooperative or trade association that it will make any payments to its 

producers during the reinsurance year under the same terms and conditions 

under which it received original approval from FCIC. 

(l) E-Business Implementation Plan: The Company shall include the following 

information to demonstrate compliance with the Freedom to E-File Act and 

section 508 of the Rehabilitation Act (29 U.S.C. § 794(d)). 

(1) The process the Company will use to provide and receive electronically all 

required forms and other information concerning the Federal crop 

insurance program. The Company shall provide a description of: 

(A) The process the Company will use to allow producers to file 

electronically all paperwork required for participation in the 

program. 

(B) The type of electronic signature that will be used by producers. 

(C) The name, address and e-mail address for one contact person with 

the vendor being used to provide electronic signatures. 

(D) The security measures the Company will use to protect the 

confidential nature of the data and information submitted by 

producers from being reviewed, revised or otherwise used by 

unauthorized persons. A third-party certification of security 

measures shall be obtained from a recognized security certification 

firm and shall be provided. 

(E) The process the Company will use to document revisions to data 

and information submitted by producers. 

(F) The storage, backup and retention procedures being used by the 

Company for electronically filed documents. Provide the name, 

address, and phone number for one contact person for the 

Company who manages the storage and backup procedures for the 

Company. 

(2) The names, URL's, facsimile numbers, and mailing addresses of each 

location where producers may electronically access and file the paperwork 

required for participation in the program. 

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(3) Describe the directions being provided with respect to how to access the 

information and forms, properly completing and submitting them; meeting 

filing deadlines; obtaining user ID and password, etc. 

(4) The online responsibilities of the crop insurance agent to each producer 

who files or retrieves required paperwork electronically with the 

Company. 

(5) The process for obtaining consent from the producer to electronically 

conduct crop insurance business on a partial or complete basis with the 

Company. 

(6) Provide the procedures a producer must use to withdraw consent to 

electronically conduct crop insurance business on a partial or complete 

basis with the Company. 

(7) Provide the procedures that a producer must use to request a paper copy of 

an electronic record. 

(8) The statement of the required hardware and software needed by a producer 

to access, obtain, and retain electronic documents from the Company. 

(m) A general description of the Company’s Information Technology architecture and 

operating environment (e.g., hardware and software) to establish operating 

capacity and compatibility with RMA systems, including whether these systems 

are managed in-house or through service providers, and the names of any such 

service providers. The description should, at a minimum, include the types and 

major version numbers of operating systems and databases; major programming 

languages and software products; and the name and major version number, if 

applicable, of any Company developed system that interacts with RMA systems, 

including a general description of the network architecture and security 

capabilities of such systems and industry standards or methodologies used for 

data exchange and software development. 

(n) A complete description of the process the Company will use to retain all records 

relative to eligible crop insurance contracts reinsured under this Agreement (e.g. 

applications, acreage reports, summaries of coverage, claims of loss, etc.). 

(1) The description shall include the office addresses and telephone numbers 

of the locations where such records are retained. 

(2) If records are retained by sales agencies or sales agents, the Company 

shall report those records’ location(s) in accordance with Appendix III. 

(3) The description shall include a certification that the Company has in place 

the security measures sufficient to ensure the confidentiality, integrity, and 

availability of any records in a manner consistent with FISMA. 

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(4) If records are kept electronically, the description shall include the 

processes and procedures for electronic storage and retrieval of such 

records, including locations of the principal and backup server locations. 

(o) If requested by FCIC, any information related to the Company or MGA that 

would assist FCIC in determining the operational capacity to perform under the 

terms of this Agreement. 

(p) The following information regarding intended business decreases, agent/agency 

contract terminations, and agent/agency compensation reductions. 

(1) A summary of your intensions to decrease business for the 2025 reinsurance year, 

including location, crop, and plan of insurance. 

(2) A list of agent/agencies whose contract has been or will be terminated for the 2025 

reinsurance year, including location. 

(3) A list of agent/agencies whose compensation has been or will be decreased for the 

2025 reinsurance year, including location and revised compensation terms. 

SECTION V. FCIC REINSURANCE BUSINESS PLAN 

The Plan shall include: 

(a) The maximum reinsurable net book premium volume for which the Company 

requests reinsurance. (This may be more than the total provided for item (V)(b)). 

(b) A designation as to the States in which the Company seeks to be authorized to sell 

and service eligible crop insurance contracts and estimates of the net book 

premium assigned to each fund within each designated State as specified in the 

Estimated Premium Template. 

(c) A declaration of the percent of the net book premiums and associated liability for 

ultimate net losses the Company will retain in the Commercial Fund for each 

State designated in accordance with section V(b), as specified in the Commercial 

Fund Template. 

(1) Selling and servicing eligible crop insurance contracts in a State for which 

no declaration has been made by the Company under this subsection will 

result in the automatic designated of a retention of 100 percent net book 

premium and associated liability for ultimate net losses for such State. 

(2) In the case of the Company acquiring another AIP, the Company merging 

with another AIP, or the Company being acquired by another AIP, and the 

percentage declarations for any State made under section V(c) are 

different between the Company and the other AIP, the Commercial Fund 

retention percentage for the combined net book premiums and associated 

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liability in such States will be deemed by FCIC to be the higher 

percentage. 

(d) The Company’s intention to reinsure a portion of its net liability (after FCIC 

reinsurance) in accordance with section II(b)(11) of the Agreement. The 

Company shall submit, within 10 days of its receipt of the executed reinsurance 

documentation, a copy of the reinsurance documentation (agreements or cover 

notes) related to eligible crop insurance contracts reinsured under this Agreement. 

The reinsurance documentation shall be executed by all parties and include: 

(1) The percent subscribed by each reinsurer to each arrangement, treaty, or 

binder, and the names of each reinsurer, intermediary, or broker; and 

(2) A description of the type of reinsurance, retentions, attachment points and 

limits, aggregate limits, minimum deposit, premium rates, and all other 

applicable terms. 

SECTION VI. RISK ASSESSMENT AND CONTINGENCY PLAN 

The risk assessment shall consist of, at a minimum, the following: 

(a) A copy of the latest maximum probable loss risk assessment, whether prepared by 

or on behalf of the Company. The assessment shall detail the magnitude and 

frequencies of the risks assessed and include a description of the methodology 

used. 

(b) For each of the risks listed in subsection (c): 

(1) An estimate of the probability of occurrence; 

(2) A rationale for the estimate; 

(3) An assessment of the impact on the Company; and 

(4) A contingency plan for how the Company will be able to meet the 

obligations under the Agreement should the event described by such risk 

occur. The plan shall describe: 

(A) How the Company will ensure that sufficient resources will be 

available to continue operations and service eligible crop insurance 

contracts for current and any previous reinsurance years, as 

applicable; 

(B) How the Company would meet its obligations for continuity of 

indemnity payments to producers, to accurately calculate premium 

and indemnities, to bill premium timely, and to prevent data 

corruption; 

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(C) If the Company uses an MGA identify how the Company will 

obtain or retain sufficient financial and operational capacity to 

manage a delivery system through resources other than those 

currently provided by the MGA; 

(D) How the Company will ensure that sufficient cash resources will 

be retained to continue servicing operations and meet all 

requirements of the Agreement; 

(E) How the Company will ensure that it retains sufficient expertise in 

crop insurance sales, underwriting, loss adjustment, quality 

control, data processing, and all other facets of crop insurance sales 

and service to continue operations until all requirements of the 

Agreement have been met; and 

(F) The physical security of current and backup systems; how 

backup systems will be deployed in the event they are needed; 

an estimate as to how long before normal operations may be 

expected to resume in the event the backup system is needed as 

the primary operational system; and how personally identifiable 

information will be protected in a transition from primary to backup 

systems. 

(c) Risks: 

(1) Crop insurance expenses exceed the A&O subsidy provided by FCIC. 

(2) Underwriting gains are insufficient to offset any expense deficit identified 

in paragraph (1). 

(3) Policyholder surplus decreases more than ten percent in any calendar year. 

(4) A significant interruption occurs in computer hardware or software that 

affects operations or data transfer capabilities (such as due to a computer 

virus, security breach, communications failure, etc.). 

(5) A rating agency determines the Company’s ability to meet its current 

obligations is marginal and that its financial condition is vulnerable. 

(6) Lines of credit or other financial arrangements become unavailable or is 

inadequate to meet cash flow needs. 

(7) Commercial reinsurance becomes unavailable or its cost rises (or ceding 

commissions received decline) significantly. 

(8) If the Company uses an MGA or service providers, the MGA or service 

provider: 

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(A) Is no longer able to perform the requirements of its agreement with 

the Company; 

(B) No longer has the financial or operational capacity to enable the 

Company to comply with the requirements of the Agreement; or 

(C) Becomes ineligible to participate in the Federal crop insurance 

program. 

(9) Any other material threat or risk that the Company may be aware of or 

have prior knowledge of that should be considered in the selling and 

servicing of eligible crop insurance contracts reinsured under the 

Agreement. 

(d) If requested by FCIC, the Company shall submit information that would assist 

FCIC in determining the capacity of the Company or MGA, if applicable, to 

continue operations under the terms of this Agreement during and following a 

pandemic, terrorist, or other catastrophic event. 

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