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. Source: SL 1966, ch 111 , ch 5, § 8 (2); SL 1995, ch 284 , § 45.