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Page 1: CONTENTS · 3 CONTENTS MANAGING INSURABLE RISK IN THE FINANCIAL SERVICES INDUSTRY n ALIGNMENT WITH OPERATIONAL RISKS..... 4 The financial crisis meant that there has been a greater
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CONTENTS

MANAGING INSURABLE RISK IN THE

FINANCIAL SERVICES INDUSTRY

n ALIGNMENT WITH OPERATIONAL RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 The financial crisis meant that there has been a greater focus on insurable risk among larger financial institutions.

As a result, the insurable risk management function is becoming more central among larger financial institutions,

and has become more aligned with operational risk and other risk functions

n RISK SOLUTIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Financial institutions are increasingly demanding solutions rather than just insurance products.

Products are too generic, too focused on the broad market. What risk managers want are bespoke

solutions, which fit their risk profile and risk landscape

n RISING INVESTIGATION COSTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 The economic crisis and its fallout, and headline-grabbing issues such as PPI, LIBOR, and FX, have all resulted in

financial institutions facing increasingly aggressive regulators, and a barrage of new legislation and regulation.

As a result, more financial institutions have experienced cross-border investigations and rising investigation costs

n IMPORTANCE OF MULTINATIONAL PROGRAMMES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Risk managers of financial institutions are demanding far more from their insurer and broker particularly in relation

to multinational exposures. The larger financial institutions want to ensure that their organisation has the right policies

in the various jurisdictions to comply with the local regulatory requirements for insurance

n LONG-TERM PARTNERSHIPS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Financial institutions’ risk managers are looking for innovation from the insurance industry and a response to

their evolving risk profile. Long-term partnerships with insurers and brokers are crucial because of the need to work

together to identify risks and to examine specific operational risk scenarios—data analysis is increasingly key

n THE VIEW FROM AIG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Analysis from Mark Fellows and Jeremy Sharpe

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‘‘If it could be said that any profession has had a ‘good’ recession, risk managers in the financial services industry might be worth a nomination.” So stated a survey by Marsh more than two years ago, which highlighted the fact

that two-thirds of financial institutions’ risk managers had benefited from a much higher or increased status since 2008.

Risk management has been growing in stature and relevance in organisations for some time, but in the financial services industry it has become much more central and higher in profile in recent times. As risk in its wider sense has taken centre stage, chief risk officers on the boards of financial institutions are not only more common, but the role itself has taken on a much greater importance.

And as a result of all this, the insurable risk management function is also becoming more central among larger financial institutions, as it has become more aligned with operational risk and other risk functions. Insurable risk managers in large financial institutions now tend to belong in operational risk or as part of a wider risk function, reporting to the chief risk officer, rather than part of legal or finance as in the past.

The response to the financial crisis included what one insurable risk manager at a leading UK bank called “the tsunami of regulations” that have come from the US, the UK and Europe. According to many risk managers, board members and non-executives are showing more interest in insurable risk, because of the growing regulatory focus on them as individuals.

The sector is facing a number of compliance challenges such as the senior managers’ regime, and regulators requiring attestations, all of which put the focus squarely on directors and their role. Add to that the number and quantum of fines being imposed on financial institutions, and it is not surprising that risk management as a discipline has a much higher profile in organisations than ever before.

FOCUS ON INSURABLE RISK

Siobhan O’Brien, Managing Director, FINPRO Practice, Marsh, says she believes that in addition to the financial crisis, it is the internal operational risk scenario analyses and reviews that large banks are carrying out that have probably focused attention on the insurable risk element and the purchase of insurance. “The alignment of the insurable risk function and the operational risk function is becoming more prevalent. Instead of seeing risk managers reporting into treasury or legal or procurement, what you are beginning to see is more of an alignment between operational risk and insurable risk,” she explains.

The global insurable risk manager of a leading global bank says that recently he has been having conversations with senior individuals within the group, something that had not really happened in previous years. He says he has a

direct line into the chief risk officer, and every year his team prepares several papers for the management board.

According to brokers, there has been a switch from clients simply wanting their claims to be paid, towards large financial institutions trying to align their insurances with their strategic operational risks. This means a much greater emphasis on the responsiveness of policies, the sustainability of capacity and the longevity of product offerings. Larger financial institutions increasingly seek meaningful capacity, something the insurance industry has perhaps struggled with in the past. This is particularly noticeable in newer areas of insurance, such as cyber risk, where Tier 1 banks face considerable insurance capacity issues.

Smaller and medium-sized financial institutions will continue to buy insurance for protection, to smooth losses, remove volatility and to comply with regulations, brokers believe. But they will also look for insurers to provide more than just an indemnity solution and demand additional services as part of a more integrated response.

ALIGNMENT WITH OPERATIONAL RISKS

“Our interaction with the top level of management has been far greater, and they have taken much more interest in not only what insurance products we buy, but how we see the world and what the potential for insurance is in offsetting our various risks around the world.”

Global insurable risk manager, leading global bank

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While insurance is still a crucial area for smaller and medium-sized financial institutions, some risk managers think that insurance could be having less impact within large financial institutions,

partly because of the issue of capacity. Aldo Cappelletti, Executive Director, Group Insurance Management, UBS AG, says he does not think that insurance is becoming more central, at least not in large financial institutions. “The insurance market has limited capacity compared to the size of the major risks surrounding large financial institutions, and therefore cannot structurally play a central role in risk management,” he explains.

Philippe Viénot, Group Risk Manager, BNP Paribas, says that for small to medium-sized financial institutions, insurable risk management can be a matter of survival to a crisis or a claim. “But for very large multinational institutions, available insurance solutions, both in terms of capacity and scope of coverage, are one to two orders of magnitude smaller than what would be required to effectively protect the balance sheet of the HQ in case of a very large threat materialising, such as unauthorised trading, mis-selling, or securities claims,” he says.

There is an even more fundamental problem than capacity as one bank risk manager explains: “Capacity is an issue, but the problem is that everybody wants to sell me a product. I don’t want a product, I want a solution. The problem is trying to have a constructive conversation with an insurer that doesn’t just offer a product but actually asks what the issue is.”

SOLUTIONS AND SERVICES

Insurers are too often seen as pushing product after product, while the financial institutions themselves demand solutions. This is not simply a question of semantics. Products are too generic, too focused on the broad market. What risk managers want are bespoke solutions, which fit their risk profile and risk landscape.

Marsh’s Siobhan O’Brien says that banks want to cover specific elements of their activity. For example, a risk might be identified through the bank’s operational risk scenario analyses that could lead to a multi-million dollar loss or impairment to capital. Here the bank will look to buy cover explicitly for that exposure.

The risk manager of a leading global bank agrees: “If the insurance market can get rid of the idea of product and look at specific risks for specific industries or organisations, then that would be very helpful. I think it will take time for the market to do that, but I think the market will have to do that, because otherwise the products that they offer will become more irrelevant as

time goes on. The market is moving slowly towards that.”Another concern is that where products are focused

on indemnity, solutions can offer much more around risk mitigation. Take cyber insurance, for example. Financial institutions require an integrated approach involving help in prevention as well as PR consultants and computer specialists to put things right in the event of a problem, as well as a product to pay an indemnity. This is particularly true for smaller and medium-sized financial institutions where they do not have any sort of in-house capability, and where the provision of these services may be the real reason that they are buying cyber insurance.

SOPHISTICATED BUYERS

Brokers believe that financial institutions are becoming more sophisticated in their insurance buying. “Generally, financial institutions are being a lot more selective as to how they

spend their risk transfer dollar,” says Kevin St Clair Alcock, Executive Director, FINEX Global, Willis. “But what underpins all of this is that they are being a lot more savvy in how they deploy their insurance—they are looking at their operational risk models, and they are looking at what the regulator is saying.”

Financial institutions, as well as being more sophisticated with their insurance buying, are also becoming much more demanding than in the past. According to Tracy-Lee Kus, Managing Director, Financial & Professional Services Group, Aon: “The bar continues to get higher—insurers are expected to contribute

intellectual property, and brokers are now expected to drive innovation—this has become a big part of discussions that we are having: innovations across the board related to products, service and combining issues into one programme. Clients are expecting a lot more thought leadership from the industry.”

As part of the requirement for the insurance industry to be more innovative, there is a growing desire for insurance to play a more strategic role in creating and delivering value, and enabling opportunities for growth. This role encompasses credit and investment risks, such as trade credit and political risk, through to transaction liability insurance in merger and acquisition deals and capital relief under Basel II. This is where financial institutions that have Advanced Measurement Approach (AMA) status use operational risk programmes to get capital relief based on their insurance programme, offsetting some of the capital that they need to hold.

The answer in many of these cases may be to look at non-traditional risk financing, in order to find inno- vative solutions that provide the required capacity and scope of cover.

RISK SOLUTIONS NOT PRODUCTS

Tracy-Lee Kus

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The economic crisis and its fallout and headline-grabbing issues such as interest rate swaps, PPI, LIBOR and FX, have all resulted in financial institutions facing increasingly aggressive regulators, a barrage of new legislation

and regulation and more active and informed consumers who know their rights (and who are not afraid to exercise them).

As a result, more financial institutions have experienced cross-border investigations and, as a result, rising investigation costs.

Financial institutions are under more pressure to self-investigate and voluntarily produce documents and information required by the regulator. In the UK, legislation such as Section 165A of the Financial Services and Markets Act 2000 (FSMA) puts the responsibility for investigations onto financial institutions, creating a major cost burden for the sector.

Fines on financial institutions, while not generally insurable, are also increasing, as can be seen in the US by the fact the US Department of Justice tripled its income from fines and charges for the financial year ending 30 September, 2014 to a record $24bn.

An example of increasing investigations can be seen in the Swiss banking sector, which has faced a number of investigations by US tax authorities into whether Swiss banks have been involved in tax avoidance for US citizens.

In recent years there has also been a progressive increase in the frequency and severity of claims against financial institutions. The most affected line of insurance has been professional indemnity, and there is a strong feeling in the financial institutions market, from brokers and risk managers, for tier 1 risks in the UK Market, that the product needs realigning before it materially diminishes in value.

RISE OF D&O

The risk focus appears to have shifted from professional indemnity to directors’ & officers’ liability (D&O), according to brokers, largely because board members are increasingly under scrutiny, facing investigations and the threat of litigation.

According to Marsh’s Siobhan O’Brien, D&O has moved to the top of the agenda in the last decade: “In the US a bank will start with a D&O policy—that is the first thing they want to talk about. Ten years ago in the UK, crime and professional indemnity were the big products purchased by banks, and D&O was another product that you purchased. Now, with the amount of regulatory scrutiny and

investigations, the D&O policy has become infinitely more important than any other product that they are buying.”

Take-up of D&O insurance was held up in the past by the lack of claims, particularly outside of the US. But since the credit crisis, the number of claims in the D&O market has grown, and, in general, the size of claims has increased. Such activity has heightened interest in D&O and the perception of the risks faced by directors and officers.

RISING INVESTIGATION COSTS

“There is a genuine fear that if you run a bank, and you are responsible for the direction and management of a bank or large financial institution, then you are a target now both from the plaintiff bar and from the regulatory side. They have to do so much more about signing off on regulatory compliance matters, that I think it is very much something they focus on. And there is a fear as to what the future may hold.”

Kevin St Clair Alcock, Executive Director, FINEX Global, Willis

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One area where risk managers of financial institutions demand far more from their insurer and broker is multinational exposures. The larger financial institutions want to ensure that their organisation has

the right policies in the various jurisdictions to comply with the local regulatory requirements for insurance. This is a complex issue, and one that is becoming more difficult for all companies to manage, not only financial institutions.

International insurance regulation has tightened up considerably in recent years, and non-compliance is no longer an option. The days of largely non-admitted programmes are long gone, and companies have to focus on compliance as never before. At the same time, there is a growing need for organisations to pull together their global insurance programmes to ensure that there is consistency of cover around all the operations, with a growing trend towards centralisation of programmes.

“The biggest risk that concerns our financial services industry clients is the reach of regulatory oversight from multi-jurisdictional regulation,” says Marsh’s Siobhan O’Brien. “In the past you were regulated by the national regulator. Now, however, as our clients’ operations become more multinational, regulation is becoming more multijurisdictional in its reach. When you look at some of the recent settlements against some big French and UK banks with the US regulator, international regulatory risk is becoming more serious and more costly. And an international investigation is always going to be more costly.”

RISK OF NON-COMPLIANCE

BNP Paribas’ Philippe Viénot explains: “Due to our size, we have learned to live with a large portion of our operational risks being uninsurable. What is more of a concern for me now—for the part that we can, and have decided to, insure—relates to compliance and the effectiveness of multinational programmes. Firstly, brokers and insurers are protected with their so-called financial interest clause provisions, leaving the insured with the risk of non-compliance, double taxation, poor quality of local wordings, and so on. And secondly, local wordings are usually poor local standard, very far away from the finely tuned master policies, and I cannot blame insurers for it, because we want to pay the minimum fee for a reasonably compliant programme.”

Financial institutions often have subsidiaries abroad, some of them small in size and not as resilient to risk as their HQ. Philippe Viénot feels that these small subsidiaries more than ever need to protect their P&L, and hence have to look carefully at their insurable risks.

One global bank, in common with many

multinationals, in the past generally had its various operations around the world handling their own insurance buying: responding to their local market conditions and centralising insurance purchasing proved difficult. “We saw the need many years ago to centralise and have a global insurable risk operation, which proved difficult in the early years, but we have been pushing on an open door in the last few years, and this is what we have been able to do,” says the bank’s insurable risk manager.

He explains: “There was, perhaps, a watershed with the financial crisis, where we found that having global standards around how we approach the financial services market, and having a single, high standard for everything, was much easier to push through, as everyone within the group had been going through a similar change.”

IMPORTANCE OF MULTINATIONAL PROGRAMMES

“I believe that we will have to be clear: if our main insurable risk is now the P&L of the subsidiaries, then we should focus on the quality of the local wordings much more than we currently do. In a sense, for large financial institutions nowadays, coordinated programmes would make more sense than integrated ones, but will we be able to convince our bosses to put the required amount of money on the table?”

Philippe Viénot, Group Risk Manager, BNP Paribas

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Financial institutions’ risk transfer requirements are changing, because the world in which they operate is changing—their customers, the regulators, technology. In the world of financial institutions, if insurance is to stay relevant it needs to

acknowledge and move with those requirements. The message from financial institutions’ risk managers

is that if they do not get innovation and a response to their evolving risk profile, then insurance will become less and less relevant.

But there is also an acknowledgment that some insurers are waking up to the challenges confronting financial institutions, and the more astute among them recognise that the big organisations especially need something different.

Risk managers at financial institutions want to have dialogue with a receptive insurer who understands their risk concept and their specific challenges. But they want insurers with the appropriate internal management structures, the resources and commitment, as well as capacity from a net line perspective.

In terms of operational risk-type policies, there is a growing willingness from insurers and brokers to have discussions, but sometimes their offerings are not practical, according to the global insurable risk manager of a leading global bank. “The reality is that the market would have to spend a great deal of time, especially with an organisation of our size, working with us to fully understand what the risks are and what the exposure is. Going forward, you would probably have the selection of a partner, and that would be the hard work, and then a two- to three-year lead-in time of collecting information and understanding the risk, and only at that point, at the end of that period, look to put something in place,” he adds.

DEEPER DATA ANALYSIS

Long-term partnerships with insurers and brokers are crucial because of the need to work together to identify risks and to examine specific operational risk scenarios. Data analysis is increasingly key because insurable risk is so closely integrated with operational risk—where most decisions are made on the basis of analysis of underlying data.

“We need to look at losses and how they would manifest themselves in insurance contracts, and map issues to what coverage is around, and look at the specific operational risk scenarios that a bank may have. We have to show them what it means for them, not just relying on the past and what others would do. We have to be more analytical and more savvy with the use of data. And you have to keep data current otherwise it is useless,” says Willis’s Kevin St Clair Alcock.

One bank risk manager explains that they spend as much time focused on using the insights that they can get from insurers and brokers to inform and help improve the risk internally, as they would buying and managing insurance policies. “Insurers and brokers have a phenomenal amount of information and insight—we are starting to have conversations, particularly with brokers, that you wouldn’t have thought possible three or four years ago, in terms of them starting to see their role differently,” he says. “Actually using the information that they have access to, and mining it and analysing it in such a way that can provide some very valuable insights to ourselves and to others, and then using that to improve the underlying risk.”

All of this requires an approach and a partnership that goes beyond the traditional annual insurance contract.

In effect, what financial institutions want from the insurance market is cost effective, long-term, stable partnerships with carriers that are innovative, have the risk appetite and the financial strength to offer meaningful capacity, and above all that will commit fully to helping the financial services industry manage its increasingly complex risk profile.

LONG-TERM PARTNERSHIPS

“We are being asked to do more limits’ analysis by clients, who will provide us with the information around operational risk and data that they hold. And clients are very focused on what the wording means. There is more involvement of their legal teams looking at the wording, and more time deciding where they want to place their insurance and looking at deductibles.”

Tracy-Lee Kus, Managing Director, Financial & Professional Services Group, Aon

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THE VIEW FROM AIG

Commercial Risk Europe talked to Mark Fellows, Financial Institutions Manager, and Jeremy Sharpe, Head of UK Broker Engagement & Regions, AIG, about the key themes in the report, highlighting the need for a closer dialogue with clients, concerns over cross-border investigations, and the need for long-term partnerships

commercial risk europe: Do you see a greater alignment between insurable risk and operational risks?

mark fellows [mf]: Yes. In the last couple of years, financial institutions have started to move this alignment a lot further forward internally, but I think the insurance industry still lags behind in its response. That said, there are a few insurance carriers and brokers who have been looking for client solutions in a far more positive manner. A barrier to more positive activity is simply that insurance markets and clients have not yet fully engaged in direct and transparent dialogue with all internal stakeholders around risk exposures and drivers. The three different parts of the jigsaw being client, broker and insurer are, to an extent, acting independently.

As for the clients, in most cases the operational risk departments are slightly removed from the insurance market, so it is has proven challenging for all parties to create open, constructive dialogue. The risk manager’s role is moving from managing the insurance needs of the client to fully engaging with internal operational risk stakeholders to ensure the two disciplines are fully aligned. This goal can be fully realised if and when all parties are fully engaged in creating a holistic solution, closely mapped to a client’s risk profile. At this time, although some success has been achieved, the general approach is still very disjointed and there is no common direction.

cre: What does this mean in practice for insurers and the solutions they offer?

jeremy sharpe [js]: With the larger banks, for the amount of capacity they need, the insurance market has to come together, in a similar way to how the banking industry itself comes together to offer solutions to its clients (such as syndicated loans or IPOs), with banks working alongside each other on major deals. One or two insurers alone cannot provide capacity that is meaningful to larger banks. We need to collaborate with brokers and clients to deliver something meaningful. It needs everybody working together.

mf: But to date, there has been almost no collaboration between carriers. With the current client engagement and negotiation processes in place full collaboration is difficult, and for a catastrophe insurance solution to work the amount of transparency between all parties needs to be much, much greater. Traditionally competition within the market place has meant disclosure between client and insurer is kept to a minimum. But for large long-term contracts transparency is a key ingredient to contract certainty and so a more inclusive

approach must be adopted. The very last thing you need when it comes to making a claim is any lack of transparency at the underwriting stage—that is where a claim negotiation can become more of a drawn out process than necessary. This will become even more apparent in the UK when the new Insurance Act comes into force in August 2016. The Act requires insureds to make a “reasonable search” and to disclose at least “sufficient information” to put the prudent insurer on notice that further enquiries are needed. Further, the Act introduces proportionate remedies for failing to fairly present the risk, which insurers may in

fact be less reluctant to exercise than the “nuclear option” of avoidance.

But from the client’s point of view, with transparency comes resource. To be transparent a client will need to invest time and manpower into providing documentation and staff input as part of the due diligence process. The aim is not to overburden the process, so collaboration between all parties, including between carriers, is essential to minimise resource drain.

js: Insurers recognise this, but are often trying to come up with their own solution for the market. Carriers want it to be their solution rather than a market one, as these larger organisations have differing needs. There have been attempts to do this but momentum has been lost in recent times.

cre: Do you see more cross-border investigations affecting financial institutions and as a result, rising investigation costs? Is this one of the factors behind the growing

demand for D&O?

mf: For multinationals, there is no question that cross-border regulation is a major risk. When one regulator announces they are investigating an institution, we find all other regulators affected by that entity join the investigation. Banks operate across borders, so regulators clearly need to also operate cross-border. That doesn’t mean

Mark Fellows

Jeremy Sharpe

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THE VIEW FROM AIG

the exposure is higher—the volume and size of transactions has not materially changed—but from a cost point of view, during an investigation banks now have to deal with multiple regulators across multiple jurisdictions, where in the past these tended to be more limited in scope.

D&O insurance policies work on the basis that directors are always making the best decisions for their stakeholders—the policy is there to protect them in the unlikely event that the decision has an unforeseen adverse effect. This protection gives directors full confidence in their decision- making, made on behalf of the bank or shareholders without worrying about how that could adversely affect them personally. Without it, directors will more likely lean on a safe decision that may not necessarily be the best decision.

Directors are also now being exposed much earlier in the investigation process, where regulators have appeared to focus on specific individuals from the start of any procedure. Our aim is to keep insurance relevant and up-to-date with regulatory changes to ensure D&O policies are fit for purpose.

cre: When it comes to multinational programmes, is compliance the main issue for financial institutions?

mf: It is a very difficult area to manage—the rules are changing constantly, wordings are changing constantly—and we need to ensure that we are on top of that. AIG has spent a lot of time and resources striving to improve multinational programmes.

It is not just compliance—from a D&O point of view, for example, local directors just want a wording that works. If a locally-filed policy does not provide a similar level of cover as the master then the local director has every

right to express concern. Within the confines of local regulation, we are striving to make sure directors get the best available wording. In addition to this, there are also tax and compliance issues that need to be taken into account, and so we need to make local policies as broad and applicable as regulation allows in order to maximise the benefit to the client.

cre: Is part of the answer that there needs to be a long-term partnership between insurer, broker and buyer?

mf: Annual renewals may over time become inefficient. As clients and insurers look to find ways of streamlining the whole processes, multi-year deals may be a good source of reducing unnecessary resource use. The current market place is highly sensitive to a softer or harder market, with premiums floating at the current market price. At times the client benefits, and at other times it is the insurers who benefit. But over time the process can become repetitive and over burdensome and often leads to frustrations for either side of the deal depending on where the market cycle is at the time of placement. We feel for longer-term, stable contracts it is desirable to move away from the laissez-faire movements of contract language and premium and look to provide certainty around price with a contract linked to a client’s risk profile. So with certain clients we see the need to step out of that cycle, and set a price and a wording that is specific and predictable over time for the client. I believe when talking to clients, they too are focusing on this issue and want this to happen. They want certainty around their risk and they want certainty around price. These are things that come with a long-term partnership.

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RUBICON MEDIA

While every care has been taken in publishing this report neither the publisher nor any of the contributors accept responsibility for any errors it may contain or for any losses howsoever arising from or in reliance upon its contents.

Editor: Adrian Ladbury • www.commercialriskeurope.com • Published by Rubicon Media Ltd © 2015

REPORTERS: [email protected] GENERAL EDITORIAL: [email protected] UK / IRELAND: Stuart Collins, Tony Dowding, Nicholas Pratt, Garry BoothFRANCE / SPAIN: Rodrigo Amaral GERMANY: Anne-Christin Groeger, Friederike Krieger, Herbert Fromme

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REPORT AUTHORTony Dowding

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RUBICON MEDIA LTD. © 2015All rights reserved. Reproduction or transmission

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Commercial Risk Europe is published monthly, except August and December, by Rubicon Media Ltd.—Registered office 7 Granard Business Centre, Bunns Lane, Mill Hill, London NW7 2DQ

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Insurance solutions for fi nancial institutions from AIG.Today’s fi nancial institutions face more risk than ever, due to a growing breadth of regulations and heightened enforcement. Having the right coverage is critical. At AIG, we offer cutting-edge insurance solutions built to meet the challenges of risk today—and will keep innovating to meet the challenges of tomorrow. Learn more at www.aig.com

Insurance and services provided by member companies of American International Group, Inc. Coverage may not be available in all jurisdictions and is subject to actual policy language. For additional information, please visit our website at www.aig.com. AIG Europe Limited is registered in England: company number 1486260. Registered address: The AIG Building, 58 Fenchurch Street, London, EC3M 4AB

Confi dence is on the agenda.

AIG13069 D&O_Confdnce Ad_A3_CommRiskEurope NOV 15.indd 1 04/11/15 6:17 pm