market bulletin

Ref: Y4898

Title

Data Reporting Requirements for Delegated Underwriting Business

PurposeTo explain new data collection requirements from1 January 2016.
To explain how Lloyd’s will communicate with coverholders and TPAs.

FromPeter Montanaro, Head of Delegated Authorities
Performance Management Directorate
Tel: +44 (0)20 7327 5971 email: peter.montanaro@lloyds.com

Date

12 May 2015

Related links

Registration for Lloyd’s Coverholder Presentations

Managing agents will be required to collect additional data with effect from 1January 2016
from coverholders and TPAs. The purpose of this bulletin is-To explain what is required from 1 January 2016.
Set out the role of managing agents, coverholders and brokers in collecting thisdata.
Provide a communications plan to ensure all parties are aware of these changes.

This bulletin consolidates previous advice. It contains no new data collection requirements.
What are the new data collection requirements?
Solvency II - Pillar 3
Appendix 1 of this bulletin summarises the data fields required under Pillar 3 of Solvency II.
Data is required for all direct - business (lead and follow) for the 2016 underwriting year
onwards.
Conduct Minimum Standards
Appendix 2 of this bulletin sets out the minimum core data fields required by Lloyd’s bulletin
Y4847.
This data is required for all business that relates to –Page 1 of 9

Lloyd’s is authorised under the Financial Services and Markets Act 2000

MARKET BULLETIN•“High product risk” products;•Underwritten by a coverholder through a binding authority from 1.1.16 onwards; and•

Where the Lloyd’s customer is domiciled or registered in the UK or EEA.

High product risk products are those that have been assessed as such by the managingagent having regard to Lloyd’s Conduct Minimum Standards (MS11); CR 5 “assessing andrecording product risk.”
CR5.8 sets out a non-exhaustive list of products that will generally have a “high productrisk”. Lloyd’s will expect any binding authority covered by the list in CR5.8 to be treated as“high product risk” for the purposes of Y4847 unless the managing agent has first discussed
this with the Lloyd’s Conduct team (conduct@lloyds.com).
It should be remembered that these are Lloyd’s minimum data requirements. Managingagents may consider it appropriate to request data / additional data for business notcovered by the Lloyd’s minimum standards.
What do these requirements mean for managing agents?
You should –1. Review the data requirements for Solvency II and identify whether, for all your leadbinding authority agreements, you already receive all the data required to complete
the return. Lloyd’s is investigating possible solutions for providing following markets
with the required data. We will issue an update later this month.
2. Assess which of your lead binding authorities are in scope for the conduct minimum
data requirements. These will be “high product risk” binding authorities relating toLloyd’s customers domiciled or registered in the UK and EEA. Managing agentsshould already be undertaking such assessments as part of the implementation of
the Conduct Standards.
3. Review the data requirements for conduct and identify whether, for all your ‘in scope’binders, you already receive all the data required.
Where there are any gaps in data, you will need to liaise with the placing Lloyd’s broker(s).
Our initial appraisal suggests that data should be readily available at either yours or thebroker’s office, without the need to request anything further from coverholders.
What do these requirements mean for Lloyd’s brokers?
You should –1. Review those data requirements that are set out in Appendices 1 and 2.

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2. For those binding authorities that you place, review whether the data required isalready being provided to your underwriters.
3. Where the data is not being provided, review whether that data is available from thedata that you already collect from your coverholders.
4. Where the data is available, liaise with your underwriter to arrange a process for thesubmission of that data.
If there are any gaps in the data required, you will need to contact your coverholders toagree a process for collecting this data. If new data is not required from coverholders,
existing data may not be in the format you require. You may need to ask your coverholder
to present data to you differently.
What do these requirements mean for coverholders / TPAs?
You may be approached by your managing agents and/or brokers requesting additional
data to support the Lloyd’s conduct minimum standard for data. Data is required forbusiness that has been designated as “high product risk” by your managing agent. If you
have more than one binder or you deal with more than one managing agent, you may findthat their rating for product risk is different.
You will be invited to a Lloyd’s presentation on the data requirements for 2016 and beyond.
These presentations will also include updates on UK complaints reporting and future MI
expectations on claims performance. Presentation dates are at the end of this bulletin.
Market Liaison
How will the LMA and Lloyd’s facilitate data collection requirements?
It is the responsibility of managing agents to ensure the relevant data is collected and used.
However, the LMA and Lloyd’s have agreed to help and facilitate the process as far aspossible. Accordingly –The LMA, through its Delegated Authorities Operations Committee (DAOC), will be
releasing revised coverholder premium and claims data standards at the end of May.
Managing agents are encouraged to adopt these standards in order to help collect all datarequired. Brokers are also asked to support managing agents in their endeavours to use
these standards. This will enable coverholders to adopt consistent reporting for all their
Lloyd’s relationships.
Andrew Smith, Deputy Chair of the LMA Regulatory Committee, has been asked by Lloyd’s
to support the Market in understanding these data requirements and monitoring where datagaps exist. Please liaise with Andrew on your progress (andrew.smith2@lloyds.com). Thiswill help Lloyd’s to compose appropriate messages for the UK coverholder roadshow
planned in June and July.

Page 3 of 9MARKET BULLETIN

Lloyd’s will be organising a UK coverholder roadshow to explain the reasons behind theserequirements. If you think any of the requirements outlined above might pose a challenge tocoverholders, please advise the Delegated Authorities team ahead of the roadshow.
Coverholder Communication
A managing agents / brokers Town Hall event was held at Lloyd’s on May 1st. This outlined
all data requirements as well as updates on claims and complaints and data standards.
A number of regional events have also been set up for Coverholders and TPAs. The
purpose of each event is to:
1.
2.
3.
4.
5.
6.

Ensure that all coverholders and TPAs receive a consistent message.
Provide an explanation for the data requirements.
Introduce premium data standards.
Listen to any challenges and issues that these requirement may cause.
Provide an update on work done to date on UK complaints.
Outline requirements for claims MI.

Below is the coverholder roadshow calendar. As this is a coordinated Market initiative, we
ask that brokers and managing agents send representatives wherever possible. Please ask
your coverholders and TPAs to attend. We expect that any coverholders and TPAs locatedwithin reasonable traveling distance of one of these events will send a representative. Adraft invitation from managing agents to coverholders and TPAs can be found at Appendix
3.
The dates are as follows:
8 June-Malmaison Birmingham The Mailbox, 1 Wharfside Street, Birmingham B1 2JR
10 June- Marriott Leeds 4 Trevelyan Square, Boar Lane, Leeds, West Yorkshire LS1 6ET
15 June- Hilton Cardiff Kingsway, Cardiff CF10 3HH
25 June- The Bristol Hotel Bristol Prince Street, Bristol BS1 4QF
29 June- Marriott Manchester Water Street, Manchester M3 4JQ
All of the above events will run from 09.30-13.00
Presentations will also be held at the Lloyd’s Building, 1 Lime Street, London EC3H 1AN
28 July 09.00-12.30
28 July 14.00-17.00
29 July 14.00-17.00
30 July 14.00-17.00
Lloyd’s European country managers will be updated on data requirements during theforthcoming International Representative Conference.

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The Delegated Authorities team will work with the European country managers to ensure
local Coverholders are aware of the reporting requirements. Relevant brokers andmanaging agents will be included in all correspondence.
If you have any questions regarding and of the above information, please contact
peter.montanaro@lloyds.com

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Appendix 1
Data Requirements for Solvency II Pillar 3.
Form ASR249

Movement of reported but not settled claims.

Open claims during the year, by underwriting year and line of business, including thenumber of claims, also reporting those claims "reduced to 0".
Form ASR 250

Loss Distribution Profile.

Incurred claims by underwriting year and line of business, the total number of claims
and out of claims incurred.
Claims to be reported in £1 million bands starting from £0–1,000,000 up to£20,000,001+.
Form ASR

252 Underwriting Risks.

Risks bound by some insured. £1 million bands starting from £0 – £1,000,000 up toup to £20,000,001+.
Each band to show total number of risks, total sum insured and total annualpremium.

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Appendix 2
Minimum data requirement in respect of highproduct risk products underwritten
through a binding authority
Periodic return
EEA business_____________________
Important Note - Please note that these requirements were originally issued on
5 December 2015 by bulletin Y4847. That bulletin should be referred to forfurther information/guidance.

The following fields of data (or information which enables the fields of data to be
calculated or determined) must be obtained in respect of high product risk products 1
underwritten through a binding authority where the Lloyd’s Customer is domiciled orregistered within the EEA.

Core policy data – linked to a unique policy reference
1.
2.
3.
4.
5.
6.
7.
8.
9.

Name of policyholder
Policy type (e.g. by risk code / other type agreed with Underwriters)
Policy Renewal – yes / noPolicy period (inception date / expiry date)Unique policy reference
Total premium to be paid by Lloyd’s Customer
Total other fees to be paid by Lloyd’s Customer in connection with this ProductTotal IPT
Amount to be paid to insurer(s) (net of commissions/brokerage)

Cancellation data – dynamic data by reference to unique policy reference
10.
11.

Date of cancellation
Reason for cancellation (by reference to drop-down menu) [main reason or multiple
reasons if applicable]
a.
b.
c.
d.
e.
f.

1

Product unsuitable / misunderstood
Product too expensive
Alternative product purchased
Cover overlapped with pre-existing cover
Product cancelled within cooling off period
Product cancelled by underwriter

See CR5 in respect of assessing product risk

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g.
h.
i.
j.

Poor service/complaint
Cover no longer required
Other (administrative reason)
Not knownComplaints data – dynamic data by reference to unique policy reference
12.
13.

Date of complaint
Reason for complaint (by reference to drop-down menu) ) [main reason or multiple
reasons if applicable]
a.
b.
c.
d.
e.
f.
g.
h.

14.
15.

Claim – coverage / terms and conditions
Claim – delay
Claim – quantum
Claim – standard of/duration/delay of repair
Cancellation / refund
Customer service
Product suitability
Other

Complaint upheld / rejected by coverholder
Date complaint upheld / rejected
Claims data –dynamic data by reference to unique policy reference

16.
17.
18.
19.
20.
21.
22.
23.
24.
25.

Date claim madeClaim open / closed / reopened
Amount claimed (where known)
TPA remuneration
Date coverage agreed (in whole or in part)
Date claim amount agreed (in whole or in part)
Date claim paid
Settlement value
orDate claim denied
Reason for denial (by reference to drop-down menu) [main reason or multiple
reasons if applicable]
a.
b.
c.
d.
e.
f.
g.

Non-disclosure
Non-payment of premium
Claims process not followed
Claim excluded/not covered
Claim within excess
Fraud
OtherPage 8 of 9

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Appendix 3
DRAFT INVITATION FROM MANAGING AGENTS TO COVERHOLDERS
Dear (coverholder contact),
As you may know, from 01 January 2016, Lloyd’s managing agents will require additional data inorder to assess management of conduct risk.
To help explain the background to these, the practical implications for Coverholders and to provide
updates on other matters relating to coverholder business, Lloyd's and representatives from theLloyd's Market will be presenting at a series of regional events. Each event will cover:•••••An overview of conduct risk and the new regulatory environment
Lloyd’s data requirements to satisfy conduct minimum standards
An update on progress made in the collection of UK complaints data
An update on requirements for future claims management information
An explanation of available Lloyd’s data standards

The session is also an important opportunity for you to feedback any challenges, observations orrecommendations that you may have. We are keen that a representative from your office attends
at least one of these events.
Regional dates, times and locations are listed below and you can register to attend one of thesesessions here.
8 June Malmaison Birmingham The Mailbox, 1 Wharfside Street, Birmingham B1 2JR
10 June Marriott Leeds 4 Trevelyan Square, Boar Lane, Leeds, West Yorkshire LS1 6ET
15 June Hilton Cardiff Kingsway, Cardiff CF10 3HH
25 June The Bristol Hotel Bristol Prince Street, Bristol BS1 4QF
29 June Marriott Manchester Water Street, Manchester M3 4JQ(all the above 09.30-13.00)
There will also be sessions held at the Lloyd’s Building, 1 Lime Street, London EC3H 1AN which you
can attend instead:
28 July 09.00-12.30
28 July 14.00-17.00
29 July 14.00-17.00
30 July 14.00-17.00

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