All posts by Chris Finney

I'm a Partner at Cooley LLP. I advise on UK and European financial services regulatory issues of all kinds.

#Brexit & Solvency II: Cooley publishes evidence submitted to Treasury Committee’s Solvency II inquiry

#Brexit & Solvency II: Cooley publishes evidence submitted to Treasury Committee’s Solvency II inquiry | Financial Services – Regulation & Risk

#InsurTech, and the emergence of Peer-to-Peer insurance

Insurers and insurance distributors don’t usually think of themselves as emerging companies. These industries “emerged” more than 300 years ago; and they’ve been growing and developing ever since. So why is Cooley being asked about #InsurTech and Peer-to-Peer (P2P) insurance so often? Answer: because these things are real, they’re growing, and they’re coming to EC3. (In fact, they’re already here.)

Lloyd’s CRO urges insurers to contingency plan against the risk of Brexit. Was he right to do so?

Lloyd’s Chief Risk Officer, Sean McGovern, spoke to the Insurance Institute of London yesterday about the impact of a possible Brexit on insurers, reinsurers and brokers. The speech was delivered at a sensitive time, and with some urgency: most commentators expect UK / EU negotiations to finish next week; with […]

Part VII Transfers – when is the Independent Expert obliged to disclose the documents he relies on, as he prepares his report?

In Excess Insurance Company Limited & others, the Court was asked to sanction the transfer of an insurance business from three different insurers to a fourth. The Prudential Regulation Authority and Financial Conduct Authority had no objections; and the Independent Expert (IE) had concluded that, “…the security provided to policyholders would be equivalent or improved after […]

The Senior Insurance Managers Regime for Solvency II firms: A practical guide

Cooley and the Insurance & Reinsurance Legacy Association (IRLA) have published a practical guide to the UK PRA’s Senior Insurance Managers Regime. The guide is available here. A fully cross-referenced version is available on request from Cooley.

Insurance Distribution Directive approved by the Permanent Representatives Committee on behalf of the Council: next steps

Coreper has approved the trilogue agreement on the proposed Insurance Distribution Directive (the IDD), on behalf of the European Council. The IDD is expected to be “minimum harmonising”, so the European Member States will be entitled to require more of the insurance distributors registered in their respective jurisdictions than the IDD […]

Solvency II third-country equivalence – an unexpected fly in the ointment

The European Parliament has published an exchange of letters between the chair of its Economic and Monetary Affairs Committee (Roberto Gualtieri) and the European Commissioner for Financial Stability, Financial Services & the Capital Markets Union (Jonathan Hill).

FCA call to action: rule breaches in general insurers’ delegated authority & outsourcing arrangements

An FCA Thematic Review suggests that many more rule breaches are occurring in the general insurance market than we might have expected; and that insurers, intermediaries and outsourced-service providers should act quickly to identify and resolve them, if they want to avoid regulatory action. The FCA’s “Thematic Review TR15/7 – Delegated authority: Outsourcing in the general insurance market” takes a […]