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MGU structure allows for greater risk appetite – Thomas Keist

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By operating as a managing general underwriter, SRS Altitude can access a larger pool of capacity and risk appetite compared to competitors that only have access to the appetite of a single carrier, Thomas Keist, chief commercial officer at SRS Altitude, told Captive Intelligence.

SRS announced the launch of SRS Altitude in November, with the MGU focusing on alternative risk transfer solutions, led by Loredana Mazzoleni Neglén as global CEO.



Captive Intelligence understands SRS will confirm the A-rated carriers it will be partnering with imminently.

Altitude began operating in the first quarter of 2024 with structured (re)insurance and parametric products at the centre of its offering.

It is focused on tailoring underwriting solutions to match clients’ needs when they cannot be appropriately addressed with conventional insurance.

“What differentiates Altitude in the market is that as an MGU we have more independence from the risk appetite and capabilities of a single (re)insurance carrier by being able to partner with multiple strategic carriers to enable higher agility and variety of risk appetite,” he said.

Keist said an MGU can act like a platform where various (re)insurance carriers who do not have the organisational possibilities or willingness to set up specialised teams can still access this business and integrate it as part of their offering to clients.

He added the decision to launch an MGU rather than exploring going into broking was made because this would have potentially jeopardised one of SRS’ key value propositions, which is independence, “and therefore access to business from brokers who are not part of the big three”.

“This independence is a key piece,” he said. “SRS Altitude is a more complementary addition because it’s different to the core service, but at the same time, it adds an important offering to captive clients.”

Young previously told Captive Intelligence that there’s a ‘’vacuum of expertise’’ in the market, so it made sense to fill that vacuum for clients with the launch of Altitude.

“More and more of our clients are facing risks that the standard insurance market cannot solve and there’s certain things we can do with a captive and partnering with carriers that have an appetite for these highly structured programmes seems to make sense,” he said.

Keist noted that there has been structural growth in the alternative risk transfer market since the beginning of the hard market.

“It’s not like we have just had a hard market and now there’s alternative risk transfer,” he said.

“The whole change is more structural because many of the corporates who have come into the hard market have started to realise that a different retention management will be much more sustainable for the longer term, and forming a captive to manage a corporate’s retention is a prime option to go for.”

Indian government reconsiders captive legislation – reports

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The Indian government is preparing once again to introduce a captive framework to its insurance legislation, according to multiple reports in the country’s media.

Proposed captive regulations were anticipated in 2022 and 2023, but amendments to India’s Insurance Act, 1938 did not materialise or progress.



The Economic Times, and other Indian media outlets, are now reporting a bill amending the Act will be introduced as part of the government’s Budget session and will include the issuance of captive licences, as well as the introduction of a composite licence so insurers can write life and non-life risks in the same entity, and a change in capital and solvency regulations.

The broader amendments are designed to meet the governments target of ‘Insurance for All by 2047’, and will also include measures to support the development of micro insurance.

The introduction of domestic regulation is thought to be imperative for the Indian corporate community to embrace and utilise captive insurance structures, because it is currently difficult to pay premium to internationally-domiciled captives.

Considering some large captive managers and brokers already outsource some back office work to India, it may be fairly straightforward to build local expertise and leadership should an Indian captive domicile materialise.

GCP #107: Solvency II reform and Q2 investments update

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Charles Low, FERMA
Laurent Nihoul, FERMA
Shadrack Kwasa, London & Capital
Nicholas Denbow, London & Capital

In episode 107 of the Global Captive Podcast, supported by the ⁠EY Global Captive Network⁠, Richard brings insight from FERMA on the recent Solvency II reforms that should bring some regulatory relief to EU-domiciled captives from 2026.

He is also joined by the London & Capital team for the latest quarterly investments update and its relevance for captives.

02.10 – 32.56: Charles Low, Head of EU Affairs at the Federation of European Risk Management Associations (FERMA), and Laurent Nihoul, Head of FERMA’s Captive Committee, discuss the process and timeline behind the Solvency II reforms, what they mean for captives and some of the tangible benefits they could bring.

33.36 – 43.56: London & Capital’s Shadrack Kwasa, executive director, and investment director Nicholas Denbow, provide a quarterly investment update and what the current environment means for captives.

For those following GCP and Captive Intelligence on ⁠LinkedIn⁠ and subscribed to our ⁠twice-weekly newsletter⁠, you will have heard that Nick Morgan, will be joining us as Commercial Director.

While Richard will unfortunately miss the VCIA annual conference next month due to his upcoming nuptials, Nick and our Senior Reporter Luke Harrison will be in Burlington flying the flag for GCP and Captive Intelligence, so please do seek them out.

Association captive formed to reduce premiums for New York affordable rentals

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Leaders in affordable housing operators and government officials in New York have formed the Vermont-domiciled Milford Street Association Captive Insurance Company to help reduce premium spend.

Milford will be owned by its premium payers and will provide insurance only to New York affordable rental buildings that have a regulatory agreement limiting rents and receive public financing.

Premiums have been increasing at an annual rate of 21% over the last five years, according to the New York Housing Conference March 2024 report.

Milford said rising insurance costs are restricting the development of new affordable housing and forcing current operators to defer necessary maintenance to remain operational.

This is adversely impacting housing quality and threatening the economic viability of the market.

“Rising insurance costs are an insidious threat to New York City’s affordability housing stock at a time when we need to solve the city’s affordable housing crisis,” said New York City comptroller, Brad Lander.

“Exponential increases in insurance premiums are driving up operating costs for existing affordable housing and limiting the production of new units.

“The creation of a self-funded insurance collective for the affordable housing industry is exactly the type of innovative and creative solution we need to ensure New York City remains a place where middle- and working-class people can afford to live.”

Milford Street was licensed by Vermont in December 2023 and the captive is managed by Avid Solutions Insurance Management.

Concert appoints Rawlins as SVP for property underwriting and programme management

Charles Rawlins has joined fronting specialists Concert Group as senior vice president for property underwriting and programme management.

Concert was launched in 2021 to focus on captive and programme fronting and is backed by Brady Young, CEO of Strategic Risk Solutions, Wes Duesenberg, Jr., CEO of Southern Insurance Underwriters, and Christopher Collins, CEO/founder of Corinthian Re, in partnership with Century Equity Partners and WT Holdings, Inc.



Rawlins will report to chief underwriting officer Joe Alberti and be responsible for underwriting and programme oversight across various programmes, with a primary focus on growing a profitable book of property driven business.

“I’m delighted to welcome Charlie to the Concert team,” said Alberti. “His breadth and depth of experience in the insurance industry, both in the US market and at Lloyd’s, will be invaluable as we continue to develop a diversified portfolio at Concert.

“Having had responsibility for a wide variety of lines of business, both as a broker and as an underwriter, I have no doubt that Charlie will play an integral role in achieving our goal of establishing Concert as a best-in-class hybrid fronting carrier.”

Rawlins was previously co-founder and CEO at Lloyd’s underwriting consortia Brace and has almost 20 years of industry experience as a broker at Willis with responsibility for US property and in underwriting roles at ACE Global Markets (now Chubb).

Hope remains for progress on UK captive regime, despite Labour victory


  • UK framework must be competitive to attract captives amid stiff competition
  • LMG keeps pressure on Government with industry backed letter
  • PRA must appreciate nuances of captives and regulate accordingly
  • Increased NDF threshold for insurers under £25m premium not expected to be attractive to captives

While the Labour election victory on 4 July is expected to delay progress on the proposed United Kingdom captive legislation, local industry has not given hope of pushing the new framework through.

Prime Minister Sir Kier Starmer confirmed the appointment of new City Minister Tulip Siddiq MP on Tuesday and the London Market Group (LMG) is primed with a letter backed by UK brokers, captive managers, insurers and Airmic calling for the planned consultation to be published to gauge industry response and backing.

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DoL considers ERISA exemption for pension captive transaction

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The US Department of Labour (DoL) has tentatively authorised an Employee Retirement Income Security Act (ERISA) exemption for the New York-based Memorial Sloan Kettering Cancer Centre (MSKCC), concerning a pension risk transfer to its captive.

The DoL requires that a US-domiciled captive is used to reinsure ERISA-governed benefits such as life and accidental death and dismemberment.

MSKCC is a cancer centre that is committed to patient care, research, and educational programmes, and has approximately 21,000 employees.

If approved, MSKCC is expected to receive a financial benefit from the exemption that will equal approximately $126,444,000.

Captive Intelligence understands MSKCC has worked closely with Spring Consulting, an Alera Group Company, on the transaction design and execution and would be among the first of its kind in the US.

This exemption would require MSKCC to ensure that plan participants and beneficiaries will receive the majority of the derived benefit in the form of a percentage increase to the monthly retirement benefit of all participants and beneficiaries.

Currently, the Department expects that MSKCC would implement a 5.37% increase in each participant’s and beneficiary’s monthly annuity payment.

Under the proposed exemption, the MSKCC Pension Plan would enter into an insurance contract with a fronting carrier who would be selected by an independent fiduciary.

The Fronting Insurer would then enter into a reinsurance contract with MSKCC’s Vermont-domiciled captive, MSK Insurance US, which would reinsure 100% of the plan’s risks.

Captive Intelligence published a long read in February 2023 analysing the DoL’s approach to successful captive exemption applications, whether there was likely to be greater activity following successful submissions from Phillips 66 and Comcast in 2022.

Blackwell Captive Solutions appoints Scott Lydon as national vice president

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United States-based Blackwell Captive Solutions has appointed Scott Lydon as its new national vice president.

Headquartered in Chicago, Illinois, Blackwell Captive Solutions serves a portfolio of clients across various industries, offering services in captive formation, management and consulting. 

“As healthcare costs continue to rise, employers are increasingly looking to captive solutions for cost stability, programme flexibility, health risk management strategies, cost transparency, and the potential to be rewarded for great practices to improve employee health,” said Lydon.

“I am thrilled to join the Blackwell Captive Solutions team to help give health benefits stakeholders complete control over their employee benefits.”

In his recent role as regional sales leader at Centivo, Lydon led his team and forged strong relationships with both internal and external partners in the value-based care space.

“Captives turn emerging risks into opportunities and insulate clients from market volatility,” said Kari Niblack, president of Blackwell Captive Solutions.

“Scott has exceptional full-cycle business development experience and will play a dynamic and lead role in defining and executing our long-term strategic goals while continuing to deliver best-in-class solutions to our customers.”

AXA XL using technology to help captives mitigate risks

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AXA XL is utilising technologies such as telematics, water mitigation, and worker wellness to help captive clients mitigate their risks.

Speaking on a recent episode of the Global Captive Podcast, Steve Bauman, global programmes and captives director for the Americas at AXA XL, and his colleague Rose Hall, senior vice president and head of innovation for the Americas, discussed how new technologies can be deployed to mitigate risks and compliment captive programmes.

Providing examples in the worker wellness area, Hall said there were multiple solutions that are proving to be effective.

“Two are wearables that a worker will wear, and they will get a haptic response, like a buzz or a beep when they’re lifting improperly or when they might be coming in close contact with a forklift in a manufacturing facility,” said Hall.

She said AXA XL also has worker wellness technologies in its suite that use existing closed-circuit cameras to identify hazards.

“For example, you can note that there’s a puddle on aisle three or if something is piled too high and you can go and mitigate those things before they cause an injury,” she said.

Bauman said the exciting part for him is the marriage between these new technologies, loss control efforts and captive utilisation.

“It’s a powerful combination that captives are becoming more involved with now, and I think it’s really exciting for the future, especially with all the technologies that Rose’s group looks at,” Bauman said.

Hall said the aim is to help clients adopt technologies that are going to help them reduce their risk, be more profitable, sustainable and resilient.

She also said she recognises that risk management is not just about insurance.

“It’s a piece of it, but there’s a holistic version of risk that includes insurance and also includes managing their own risk,” she said.

“How do we supplement our insurance solutions with risk management that meets the holistic need of the client?”

Listen to the full 20 minute discussing between Steve Bauman and Rose Hall on the Global Captive Podcast here, or on any podcast platform or app. Just search for the ‘Global Captive Podcast’.

Vermont captive assets increase 8% in 2023, but premium down

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According to a new report by the Vermont Department of Financial Regulation, the overall assets under management (AuM) for Vermont-domiciled captives increased 8.1% to $230.5bn in 2023, up from $211.9bn in 2022.

Despite AuM increasing, there was a reduction in overall gross written premium (GWP) from $42.5bn in 2022 to $30.6bn in 2023.

Reinsurance ceded from Vermont captives saw a reduction to $5.6bn in 2023, down from $15.4bn in 2022, suggesting captives were retaining more of their own risk.

In 2023, 306 captives in Vermont were writing less than $5m in GWP, while 105 captives were writing more than $50m in GWP.

The total number of captives domiciled in Vermont at the end of 2023 was 659.

Companies in the manufacturing and real estate sector saw the greatest increase in the number of captives by industry.

Manufacturing industry captives increased from 102 in 2022 to 107 in 2023, while the number of real estate captives increased from 36 in 2022 to 41 in 2023.

The number of insurance industry-owned captives also saw a steady rise, increasing from 80 in 2022 to 83 in 2023.

The insurance sector also saw the greatest increase in cell utilisation in 2023 with 17 new cells formed in 2023.