South Dakota Code § 58-26-34

Reserve for liability policies written during three years preceding
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For all liability policies written during the three years immediately preceding the date as of which the statement is made, the reserve required by §
58-26-31
shall be calculated in accordance with the Annual Statement Instructions Manual prescribed by the National Association of Insurance Commissioners as adopted by rule by the director pursuant to chapter
1-26
. But in any event, the reserve may not be less than the determined and estimated unpaid claims under policies written during the three
-
year period. For all liability policies written more than three years prior to the date as of which the statement is made, the reserves required by §
58-26-31
shall be determined and estimated unpaid claims.

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