control framework breakfast group agenda 9:00arrival, breakfast & networking 9:20 welcome and...
TRANSCRIPT
Control Framework
Breakfast Groupagenda
9:00 Arrival, Breakfast & networking
9:20 Welcome and The “gold star awards” - Ali Dove
9:25 Delegated authorities update - Sarah Thacker
9:45 Phase II: risk assessment, data flow - Jaana rouvariand next steps to launch
10:05 Broker engagement - John Hibbert
10:15 Q & A - All
10:30 Close
Lloyd’s market gold star awards…
MONTPELIER
MARKEL
NEWLINESPORTSCOVER
TRAVELERS
LIBERTY
ALTERRA
ASCOT
Control Framework
BRIT
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Should Lloyd’s Mandate the CH reporting standards?Sarah Thacker, Lloyd’s Delegated Authorities
21 May 2013
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The consultation
► Representatives from DUC, BACG, BOLT, DUM, Lloyd’s country managers and Xchanging were consulted
► Stakeholders were told that there had been a request to mandate the reporting standards in a response to the proposed roll-out of the control framework to coverholders
► Stakeholders were asked if they thought the reporting standards should be mandated on coverholders because of the control framework
► They were also asked for general comments around mandating the reporting standards on coverholders
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Issues with mandating, London
► Changes only typically take place annually at renewal
► Underwriters are largely not aware of the standards, their usefulness and importance
► Many London stakeholders still do not have systems to put this data into
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Issues with mandating, coverholders
► Domestic carriers typically collect this sort of data as a bi-product of processes, this is asking for something extra
► Customised versions of off-the-shelf systems mean charges for implementing standards
► Over time, as coverholders change systems so these issues are likely to be reduced
► Retail agents at the start of the chain need to collect the data
► Coverholders want to be asked for the same thing by all syndicates; but this is not what was proposed
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The reporting standards and the DATA control framework1. Information Requirements
The reporting standards ≠ the data items in the control framework
Control framework is what to capture and the controls, reporting standards is what to send into London
The red fields in the standards are not all in the control framework
The control framework includes Lloyd’s data which a coverholder would not know
Examples – risk codes, year of account
The control framework includes data which London already knows
Examples – Currency if always $; state if always Florida, Contract Type
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The reporting standards and the DATA control framework2. Risk model Will mandating help?
Risk 1 – requirements are not understood
The reporting standards ≠ control framework so may confuse
Risk 2 – data capture is inadequate Would help to explain, but see above may confuse and would not give the full picture
Risk 3 – data is processed incorrectly No
Risk 4 – data is corrupt No
Risk 5 – data is lost and cannot be recovered
No
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The reporting standards and the control frameworkControl Framework continued
Summary Will mandating help?
3. Apply risk model Each data item to be risk assessed and prioritised
No
4. Identify and document key controls
Identify and document the controls mitigating the risks
Might be an example of a control…
5. Gather evidence Gather evidence of controls No
6. Provide assurance This is about assuring Lloyd’s that controls are in place
No
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Lloyd’s should not mandate the coverholder reporting standards at this time
► Limited understanding of standards amongst London stakeholders, and insufficient current take-up for this to be accepted in London
► Costs for coverholders seen as prohibitive
► Information to be mandated is unclear – reporting standards ≠ data control framework
► Will not deliver the requirements of the Data Control Framework
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What next? ► The proposal to mandate the reporting standards on coverholders has been rejected.
► But
► There are still other activities separate to the Control Framework project which can be pursued.
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Audit Scope review
► Market project with reps from DUC, DUM, BACG, BOLT and Lloyd’s:- Charles Rowley, Steve Hart, Patricia Beaton, Dan Lott, Ian Whitehead and Sarah Thacker
► Scope is currently being reviewed
► Plan for draft in summer and final version in autumn
► This will be followed by training/education for auditors
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Audit Scope Review
Initial recommendation for questions RE control Framework
► How do you determine where the risk is located for entry onto your system?
► How would you risk locate for a policyholder in your country insuring a property in another country?
► How would you determine the location of risk for a policy holder outside your country but insuring property in your country?
► How do you determine what is the tax liability for the insured or insurer?
► Does this entry drive the bordereaux or is this entered manually onto a spreadsheet?
► Are you aware and use Crystal/Risk locator Tool?
► Note, these are draft only……
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Draft
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Data and technology
► BAU work with market promoting and educating on data and reporting standards
► Reporting standards are mandatory for new coverholders
► Brokers to be encouraged to provide all data to leads and followers via IMR or similar in a spread-sheet or other useable format
► Conversations with Xchanging around how they can help
► Working with market stakeholders to promote use of technology, automation and XML
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Education ► Application process could be amended, for example, coverholders could be asked to complete Crystal Assist
► Coverholder Toolkit includes information about data and reporting which can be enhanced when next updated
► Information can be put in Delegated Authorities Area on Lloyd’s web pages
► Promote use of Crystal and Risk Locator Tool at coverholder events
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Control Framework
phase ii Update
Coverholder risk assessmentData flow and controlsNext steps to launchFuture meetings
Control Framework
Coverholder risk assessment
Complexity of business written Nature of operations
Binding Authority- Single or multiple
territories
Principal Regional Complexity
Lines of Business Premium written
Coverholder Resources and
information provided
Historic Issues
Use of Lloyd’s Tools
Use of Lloyd’s coverholder
reporting standards
Control Framework
Dataflow and controls
Coverholder
TPA
Broker
XIS
XCS
Lloyd’s
Managing agent
Data is captured/ manipulated/ held
Premium
Claims
A/S
ECF
Premium
Claims
Premium
Claims
Information
Lloyd’s Coverholder
reporting standards
Lloyd’s Control
Framework ‘Green Book’
Control Framework
Purpose:To ensure required information is provided for premium and claims processing purposes
Purpose:To ensure tax and regulatory information at source meets the minimum requirements and is of good quality
Control Framework
Next steps to launch of phase ii
Lessons learnt
Phase II communications
approach
Delegated Authorities
engaged
Tool kit &
market group consultation
Control Framework
Next steps to launch of phase ii
Finalise Lloyd’s tool kit:
Phase II road map Coverholder risk assessment guidance notes Data items spreadsheet adapted for phase II Broker/ coverholder leaflet Control Framework Standard presentation for phase II ‘Board’ sign-off wording Phase II FAQs Guidance on what good looks like
Look for these @ lloyds.com/controlframework in July
Control Framework
Next step to launch of phase ii
Your contacts for phase II
Scheduled meetings for phase II Initial 1-2-1 meetings within the first 3 months Follow up meetings on request
Regular status reports from managing agents
The LAUNCH event
Control Framework
Future meetings
From July..
Project updateDelegated Authorities updateBroker engagement updateManaging agent/ broker/ other
presentation
Control Framework
Update on broker engagement
John Hibbert
Control Framework
Progress so farLIIBA endorsement of project frameworkIndividual broker meetings undertaken
• Millers• Towers Watson• Willis• Cooper Gay• Crispin Speers• Integro• Decus• THB• Bell and Clements
Control Framework
Next steps
Establish broker working group• LIIBA and BIBA members
Present to BOLT meeting 2nd JulyCommunicate to the wider broking
community through Phase II Launch in July
Individual Managing Agent/broker meetings