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New FERMA president keen to expand advocacy capabilities

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Charlotte Hedemark has been appointed president of the Federation of European Risk Management Associations (FERMA).

Hedemark, who is a senior risk manager at SAP, took on the role at an official handover ceremony which took place at a FERMA seminar in Antwerp on 16 October.

“We want to expand our advocacy capabilities,” she said. “By developing partnerships with other EU professional or sectorial associations, and inside EU institutions.”

“We want to tap into even more expertise and knowledge and increase the involvement of the national risk associations in our advocacy work.”

FERMA has made some progress in recent years on lobbying for greater proportionality applied to captive regulation under Solvency II.

Hedenmark replaces Dirk Wegener, who concluded his four-year term as president with a speech during the FERMA seminar.

“FERMA has become much more impactful and effective in its advocacy work,” he said. “I would like to thank our members for their active engagement in our committees and working groups.

“This strengthens our expertise and the value we provide, both of which are recognised by the European institutions.”

He also highlighted the “tense but increasingly collaborative” relationship FERMA has with the insurance sector.

“We have cooperated with the insurance industry on regulatory issues and crucially ways to support risk transfer and I am sure FERMA will continue to increase dialogue and take concrete action on key issues for the insurance and risk management communities,” he added.

“I leave my role as President with FERMA in a strong position, and I am passing the baton on to Charlotte, knowing that the future of FERMA is in extremely capable hands.”

TDI re-hires Robert Rudnai as Texas’ first dedicated captive specialist

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The Texas Department of Insurance (TDI) has re-hired Robert Rudnai as a captive specialist, where he will be responsible for licensing and monitoring Texas-domiciled captives.

Rudnai started in his new position on 2 October and is the result of State lawmakers directing the TDI to employ a specialist to support captive insurance oversight after lobbying from the Texas Captive Insurance Association (TxCIA).



“There’s an opportunity now to use the experience and operational knowledge gained over the last decade to evaluate and refine processes and procedures,” Rudnai said.

“This starts by my listening to our stakeholders and considering their perspectives.”

Rudnai previously worked at the TDI as a financial analyst, where he provided oversight to captives, and evaluated captive applications as part of his role.

Members of the captive industry operating in Texas had previously expressed concern over the length of time it was taking to establish a captive in Texas compared to other domiciles.

“The issue in Texas right now is staffing,” Andrew Marson, managing director at Strategic Risk Solutions and a TxCIA board member, told Captive Intelligence for our Texas long read published in January.

“They’re really struggling to employ people at the TDI. So, the speed of which you can form a captive in Texas is significantly slower than other domiciles.

“Therefore, it’s not attractive from that perspective, because it does take quite a bit of time.”

At the end of 2022, Texas had 73 captives licenced in the state, of which 72 were pure captives.

ZGEBS adds Bupa as Turkey partner to offer private medical cover

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Zurich Global Employee Benefits Solutions (ZGEBS) has partnered with Bupa Acıbadem Sigorta (Bupa) to offer private medical cover for its customers in Turkey.

ZGEBS provides risk management, data and financing solutions for the international employee benefit plans of multinationals companies, including pooling and fronting for captive EB programmes.

Bupa has more than 7,000 organisations in its medical network and is one of the only providers in Turkey specialised solely on private health insurance.

“At the heart of our collaboration lies a shared focus on innovation and efficiency,” said Patricio Delacroix, head of network partner management operations at ZGEBS.

“Bupa’s cutting-edge automatic provision systems, developed internally with a stringent emphasis on claims analysis and sustainable pricing, optimises provision times and elevates the customer experience.”

Zurich offers health insurance solutions in more than 100 markets and covers more than one million employees.

“We both share the ambition of creating value for our customers,” said Işıl Kücük, chief sales officer at Bupa.

“Bupa’s strategy aligns perfectly with ZGEBS’ vision of transparency, measurability, and a win-win framework.

“By joining forces, we aim to optimize the pace and quality of insurance services and to reach a broader range of multinational customers.”

Lowering premiums, “winning hearts and minds” key to captive EB success

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Risk managers are in a strong position when they implement a captive employee benefits programme because they have the power to lower premiums and engage the whole group, according to Marc Bentley, InterContinental Hotels Group director of risk finance, and Matthias Helmbold, vice president of global risk benefits, health and wellbeing at DHL.

Helmbold and Bentley were speaking on a panel at a London event organised by MAXIS Global Benefits Network and Captive Intelligence, that was also recorded for the Global Captive Podcast. Listen to the episode here, below or on any podcast app.

Bentley discussed how IHG had started reinsuring some employee benefits through the captive in 2017, while Helmbold reflected on DHL’s long journey, beginning in 1996, as the first company to take this approach.

Helmbold said the DHL programme had been successful because they were able to use premium pricing as a tool to encourage participation across the business.

“This is a muscle that I think is underutilised by a lot of EB captives. The risk managers are in a very, very strong position here,” added.

“The DHL programme did not grow because of a global mandate to place all EB covers into the captive. It was on the basis of actually being the best offer out there and business units actually saving money.”

Bentley agreed with this approach and said when IHG began captive participation, he did not to put a global mandate in place.

“It is absolutely a partnership so I purposely did not want the mandate coming down from  up above,” he explained. “We’ll engage and we’ll win hearts and minds to make sure that this is a long-term solution for the company.”



Helmbold said employee benefits can be seen as a “tame animal” compared to some other risks that captive owners grapple with.

He said: “You need a bit of knowledge, you need to understand your medical trends, your long tail business, but compared with the exposures that you may be dealing with in your property programmes, or your D&O, and not even mentioning cyber risk, it’s high frequency, lower impact in many cases compared to many other risks that captives are writing.”

Helmbold added that collaboration with different parts of the business is key to creating understanding and support for the captive approach to financing employee benefits through a captive.

“Procurement is one example where people need to know what’s going on,” he said. “HR is key as they are the owners of policies locally and they are in charge of the benefit design, but not of the financing necessarily.

“Likewise, the sponsorship and the support from senior management. It is equally important that your CFO, CEO do know and understand and what’s going on and you don’t have any surprises.”

Concerning the quantitative and qualitative benefits resulting from the captive EB approach, both said it had been a success with further initiatives planned in the future.

Bentley said the multinational’s focus had initially been on improving its benefits offering, but it had since realised other benefits too.

“Our original goal with the captive programme was to enhance the benefits we were offering to our people – that was our original aim and we were successful,” he explained.

“As much as it wasn’t intended to be a cost saving, we’ve also achieved brilliant savings. We’ve probably saved about 30% on premium that was going out of the business, which is obviously positive, but not necessarily one of the key drivers or goals.”

Since 2015, DHL’s Health & Wellbeing programme has helped the company to mitigate medical trend, he said.

“At the moment we’re looking at savings north of €10 million on €80 million premium. Those are impressive numbers.”

GCP Short: DHL & IHG – journey to an EB captive

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Aaron Brown, MAXIS GBN
Matthias Helmbold, DHL
Marc Bentley, IHG

In this GCP Short, produced in partnership with MAXIS Global Benefits Network, Richard shares a live discussion recorded with two experienced EB captive users:

Marc Bentley, Director of Risk Finance at IHG, and Matthias Helmbold, Vice President of Global Risk Benefits, Health and Wellbeing at DHL.

Marc and Matthias explain when, why and how their respective companies started reinsuring international employee benefits in their captive, lessons learned along the way, how their programmes have evolved over time and what they want to achieve in the future.

The episode is introduced by Richard and Aaron Brown, Regional Manager for Business Development in the UK & Ireland at MAXIS.

For more information on MAXIS and its captive services, visit its Friend of the Podcast page.

Stay up to date with all major developments in the captive market by signing up to the twice-weekly Captive Intelligence Newsletter.

Jeff Carr joins Liberty Specialty Markets

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Liberty Specialty Markets has appointed Jeff Carr as global client executive after spending three and a half years in a similar role at Crawford & Company.

Carr will be responsible for growing and developing client relationships and delivering solutions that meet current and future needs.

Laura Burns, head of client management at Liberty, said: “ I am delighted that Jeff has joined our growing Client Management team. As well as a wealth of experience, Jeff brings a consultative style and a proven track record of delivering solutions, and I am very confident that our partners will love working with him.”

Captive Intelligence understands Liberty is keen to build out its captive capabilities and plans to make further hires with experience in this area.

Carr has extensive experienced with multinational clients and captive programmes, particularly with global programmes.

Prior to joining Crawford in 2020, he held several roles at QBE Europe, Chubb and AIG.

Shipping and mining captives among new Vermont formations

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Vermont has licensed five new captives in the third quarter of 2023, taking the state’s total number of new licences for the year to 27.

The five new captives for Q3 include: Corrugate Country Insurance Corporation, Blue Canary Inc, 1920 Risk Assurance Inc, Steelshield Insurance Company, and RVC RE, LLC.

Captive Intelligence understands Corrugate Country Insurance Corporation is owned by Wisconsin-based shipping and packing supplies company Uline, while Blue Canary is owned by Alabama-based coal mining company, Warrior Met Coal.

Corrugate Country Insurance Corporation is managed by Strategic Risk Solutions (SRS), 1920 Risk Assurance is managed by Marsh, and RVC RE, LLC is manged by Artex.

Blue Canary and Steelshield Insurance Company are both managed by Aon.

Of Vermont’s 27 new captives registered in 2023 to date, 20 are pure captives, five are sponsored structures, one is an association captive, and one is a risk retention group (RRG).

According to Captive Intelligence’s data on the number of captives in each major domicile, at the end of 2022 Vermont had reached number one with 639 active captives at year-end.

In August, Captive Intelligence published a long-lead highlighting that the state is notresting on its laurels after taking top spot, with a focus on “quality over quantity” and a continued recruitment drive both within the regulator and across the local industry.

EIOPA publishes opinion on cash pooling, outsourcing and governance

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The European Insurance and Occupational Pensions Authority (EIOPA) has published a draft opinion concerning the supervision of captive (re)insurance undertakings, with a focus on intra-group transactions, the prudent person principle and governance.

EIOPA said the published opinion is seeking to facilitate “a risk-based and proportionate supervision of captive (re)insurance undertakings and further support the convergence of supervisory expectations in the context of creating a level playing field within the EU”.



Stakeholders are invited to provide comments by responding to questions in an online survey by 5 January, 2024.

The consultation arises in the context of planned alterations to Solvency II which should benefit a select number of captives, while new domiciles within the European Union, such as France, with a desire to regulate captive business. Similar efforts are also underway in Italy and Spain.

Concerning the use of cash pooling by captive-owning corporates, EIOPOA said regulators should “ensure that (re)insurance captive undertakings recognise and classify in the

Solvency II Balance Sheet the asset and liability descriptions according to the economic substance of the cash pooling arrangement and also apply the proper calculation of the Solvency Capital Requirement (SCR)”.

In its opinion, EIOPA sets out the different treatment of a cash pooling arrangement depending on whether it is classed as a loan or cash at the bank.

“In addition to the SCR calculation, NCAs should ensure that the captive (re)insurance undertakings assess all risks and benefits brought by intra-group transactions, for example assessing the impact on liquidity and concentration risks linked to a material reliance on these types of transactions,” it explained.

“In cases of material reliance on these types of transactions such assessment should be reflected in the Own Risk and Solvency Assessment. Furthermore, the risk exposure relating to the availability of the funds in a cash pooling needs to be evaluated in a stress scenario and depends on the role of the cash pool leader managing the cash pooling.

“Regarding cash pooling agreements, limits should be set by the group in particular concerning assets held to cover liabilities towards policyholders.”

The opinion also turns the spotlight on governance in the context of Administrative, Management, Supervisory Board (AMSB) composition and outsourcing of key functions.

EIOPA said regulators should ensure that the governance and management structure “possesses the necessary seniority, competency, skills and professional experience” and reinforced that there is no exception for captives.

“Key function tasks can be outsourced, however the captive undertaking should designate a person within the undertaking with the overall responsibility for the outsourced key function who is fit and proper and possesses sufficient knowledge and experience regarding the outsourced key function to be able to challenge the performance and results of the service provider,” it stated.

EIOPA believes regulators should ensure the person designated as responsible for outsourced key functions should have an employment contract with the captive, be a person under supervision of the regulator regardless of their employee status with the captive, or employed by the captive owner in a role that is “properly documented within the outsourcing arrangements and fitness and propriety process”.

“NCAs (national competent authorities) should ensure that, in case of multiple services provided by the same service provider or captive manager from captive undertakings, the segregation of duties is clearly agreed and documented,” EIOPA added.

“Given the high degree of outsourcing operated by captive (re)insurance undertakings, NCAs should ensure that the initial and ongoing due-diligence on the service provider operated by the captive on the service provider is embedded in strong processes and procedures which shoud be made available to the NCA upon request.”

UPDATE: Gibraltar elects Feetham, GSLP Liberal Alliance with captives on horizon

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Experienced insurance lawyer Nigel Feetham has been elected to the Gibraltar parliament and is expected to be appointed the country’s next Minister of Financial Services by Chief Minister Fabian Picardo.

Captive Intelligence reported in September that Feetham was running for election as a member of the GSLP and wanted to reinvigorate Gibraltar’s captive sector with renewed legislation suitable for its role outside of the European Union, post Brexit.

Prior to Brexit, Gibraltar had a unique captive and insurance offering, being able to passport across Europe and into the United Kingdom. It was, however, restricted by the EU’s Solvency II regime.

Feetham, in the GSLP Liberal manifesto, has proposed new legislation that would update Gibraltar’s regime and make it more attractive.

“Post-Brexit, an opportunity has arisen for Gibraltar to establish a captive regime for international business, an initiative which was unattainable within the EU,” it states.

“If elected, the GSLP Liberals commit to passing legislation enabling a captive regime for international (non-UK and non-EU passported) business. This significant move would enhance Gibraltar’s insurance sector, offering unprecedented opportunities.”

Feetham has also proposed the formation of a Gibraltar government-owned captive insurance company to “obtain the most competitively priced insurance for the Government and addressing any public interest insurance needs linked to the Government not available locally, such as travel insurance for our elderly citizens”.

Authentic “overwhelmed” by interest in Captive in a Box concept

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The genesis behind the formation of Authentic was the realisation that embedded players were only offering “very small” commission splits to their distribution partners.

New-York and Ohio-based Authentic announced in September that it had raised $5.5m in a seed round.

The company is touting a ‘Captive in a Box’ platform it says allows any vertical software as a service (SaaS) company, franchise or association to launch captive programmes in a matter of weeks.

Authentic offers business owner’s policy (BOP) coverage and is also targeting businesses in food and beverage, salon and spa, retail, fitness, and professional services.

It is utilising Montana as a captive domicile and its series business unit (SBU) regulation.

Cole Ricarrdi, founder and CEO at Authentic, told Captive Intelligence that he had questioned why companies with distribution capabilities had not formed their own programme, or their own captive.

“When I went through the process of mapping that out, I realised that is incredibly challenging,” he said.

He said no one had ever previously packaged underwriting, legal work, reinsurance and capital together as a product before.

Ricarrdi noted that the current trend in the software industry is the attempt to bundle in more financial services, “so it’s a very natural fit”.

“If a client is a software company, their entire goal is to sell more products and services into their gyms, or their restaurants or salons,” he said.

He said the client is essentially the operating system from a technology standpoint.

“Because the owners are logging in every day, they realise that they have incredible shelf space to add other financial products, and we want to be that insurance offering on the shelf for SaaS companies,” he said.

Since Authentic’s New launch, Ricarrdi said the company has been “overwhelmed”.

“We had strong interest before we launched in our software channel, but what’s neat is all the interest we’ve had from other channels, including brokers or agency captives,” he said.

“Some brokers have reached out for a more tech enabled solution or a more turnkey solution to a captive for their client.”

Ricarrdi said at first the expectation was to mostly go direct to software companies, agencies, or credit unions but “we’re actually being contacted by brokers to use our services to stand up a captive for a client”.