FAQs
Delegated Data Manager (DA SATS)
View all 'Delegated Data Manager (DA SATS)'
Delegated Data Manager (previously DA SATS) is a submission, access and transformation solution that enables consistent data and information exchange across the entire Delegated Authority market.
Delegated Authority data management in the London Market is often inefficient and inconsistent resulting in a large amount of duplicated effort and versioning issues amongst bordereaux sent via email between parties. A lack of a centralised platform for all parties on a contract creates barriers, making it difficult to transact Delegated Authority business effectively.
LIMOSS is the market services owner.
LIMOSS is a not-for-profit entity created by Lloyd’s, the LMA and the IUA to manage day-to-day management of market services.
Annual run costs are funded by carriers in the London Market.
Delegated Data Manager is currently mandatory for LBS binding authority contracts. From 1st January 2021 this will increase to LBS Bulking Lineslips. Lloyd’s recently launched the Conditions of Trade Market Bulletin Y5311, which outlines principles agreed with market associations that will take effect from Q3 2021, if pre-requisites have been met. Please see Conditions of Trade section on this FAQs page for further details.
Yes, it is designed for all Lloyd’s DA and Lineslip business.
Full implementation of these Conditions of Trade will ensure full market realisation of the benefits of DDM, including but not limited to:
• Reduced effort and improved quality:
Less manual transmission and processing of Coverholder reporting data, or further processing by Managing Agents or Brokers, leading to better data quality and usable extracts which can support firms CAT Modelling, pricing, and market insights.
• Improved data security:
Access controls which only allow members to see relevant sections will enhance data security. This will remove the process of emailing bordereau to every member on the binder thus leaving a more transparent and efficient data reporting process.
• Reduced Costs:
Less costs and delays during the processing and reporting of Coverholder Reporting data, allowing enhanced data-based performance management.
• Facilitation of reporting:
Facilitate the collection and distribution of bordereaux submissions for oversight, tax and regulatory purposes. This will remove the double keying process currently in place, where firms are required to separately submit data to regulators.
• Integrated DA Ecosystem:
Develop an integrated ecosystem of parties, via a common standard to transact digital placement through API’s. However, to support this roadmap we need to drive the adoption of DDM, as it is an important transition state that will improve the quality of Delegated Authority policy and claims data and act as the foundation that underpins the future model.
• Enhanced data quality:
A ‘step-change’ in data quality; RPAC API will not support transfer of file-based data, or transfer of non-compliant data, therefore Lloyd’s Conditions of Trade will allow the market to realise benefits sooner due to the time it will take to build planned RPAC API-based integrations.
We are currently in the process of designing the training and onboarding approach for Delegated Data Manager and more information will be available from Q1 2021.
This section contains answers that were provided to questions posed during the Consultation Sessions for Managing Agents and Brokers throughout the consultation period.
Broker Session: Thursday 19th November 2020
Q: At what point are you looking for these changes to come into effect for Phase 1? How much notice are you going to give Coverholders to make changes to their systems to meet the minimum requirements?
A: As a result of this consultation, we are expecting all feedback to be received by the 25th of November, after which we will look to finalise the changes and communicate as a market bulletin on the 1st of December.
Q: ‘Intermediary Commission amount’ - is this capturing local broker commission details or both local broker and London broker commission amounts?
A: This needs to be clarified. It is local as there are specific fields for London broker. All we’re changing here is the column name, not the data, and we will be following this up with detailed guidance.
Q: Are there going to be more changes to the standards in Phase 2? If so, is it not worth doing this as one rather than getting Coverholders to make changes and then 6 months later asking them to make more?
A: Based on the market feedback, the phased approach was more favourable. There is further work to be done on Phase 2 which is more aligned to the Future at Lloyd’s. If there’s feedback that we would like to extend this change, then we will take this on board. To add to this, it depends on the level of changes as we’ve had varying feedback that the longer-term Phase 2 changes could take some time to put together, specifically around an extended risk standard. This is why we split it into phase 2. If there is a larger scale change that could take place in a shorter period of time, then we welcome this feedback but rest assured that everything we do will be with Coverholders in mind.
Q: There was mention of Coverholders losing their Coverholder status if the data quality is not met. What is the time scale for Coverholders to conform to the new Standards when they are released?
A: We will have more to communicate on this once we have more detail on the data; however, what we're trying to do is get everyone aligned, interested and invested to make this work. Rather than putting in place a blanket deadline, we have chosen to work with all stakeholders, taking into account individual circumstances, to ensure everyone is prepared to comply with the updated Standards.
Q: Based on advice from Lloyd’s, we wrote import routines using the duplicated Solvency 2 fields. Since then, TPAs and managing agents have informed us that these are not required. Please can you clarify?
A: This is a governance-related question which is part of what we are looking to solve in the next phase. This involves making sure that guidance and advice is consistent and clear.
Q: Regarding property business, will there be the ability to add COPE information to the risk bordereau, flood zone, earthquake zone, roof age etc to avoid further work providing these separately?
A: Some of these fields are already present and are only required for flood related business. These fields are all covered in 3001 on the Market Business Glossary and there's risk standards that cover these, for example DDM will take car RLDs and capture all this information for you. We hope this will become clearer in Phase 2.
Q: Can we ensure certain fields, such as ‘Roof Age’, are not required unless absolutely necessary?
A: Yes. Mandatory Condition Management needs to be revisited so we are not demanding fields which we do not need.
Q: Are the mandatory fields lists going to be updated?
A: Yes, they will be updated and cleaned up as part of this process. When we reach Phase 2, they will be re-evaluated to identify if there are alternative reference tables we can use.
Q: The feedback deadline of 25th November is not long enough to gather the correct members of staff and complete the survey. Can we have an extra week?
A: We are trying to keep to a tight deadline; however, we encourage you to reach out to us with any queries and we will work with you on this.
Managing Agent Session: Tuesday 17th November 2020
Q: How will data validation within DDM work (considering any mandatory rules)? Will records be rejected (upfront validation), and/or will there be post processing validation reports that may require follow-up?
A: Initially, there may be some upfront warnings to say you have missing fields to give you a chance to reprocess the bordereau or to get improved data from your coverholders; however, this may change in the future. We are working with Lloyd’s tax and regulatory to create a more comprehensive roadmap for validations in the coming weeks, which we hope to communicate before the end of the year.
Q: How will you identify firms that do not adhere to the conditions of trade? How is it Will it be at a Coverholder vs MA level and what are the enforcement measures?
A: Each role and responsibility will be made much clearer in new contracts that come through from DDM. This will allow us to monitor Conditions of Trade compliance by assessing who is responsible for each role. We’re open to suggestions around the enforcement measures and we’re working with the LMA and LIIBA to make sure the Conditions of Trade adherence measures put in place are stringent and applied correctly to improve data quality.
Q: Has there been any progress regarding the MA meeting to discuss common data issues relating to the Coverholder Reporting Standards?
A: Yes, a session has been set up with about 9 MAs to discuss the common themes and how to enhance the Coverholder reporting standards. Luke Doyle from Atrium is leading this, so we would recommend that you reach out to Luke, but we are conscious that most of you might not know him, so feel free to get in touch with DAChangesupport@lloyds.com and we can forward your interest to Luke.
Q: Can modelling files such as EDM’s be loaded into DDM?
A: No, EDMs are specific to RMS so it’s their proprietary setups that can be broken out into proper risk bordereaux.
Q: Are MAs to be set up automatically as Trusted Sources as Y5311 doesn’t seem to mention that MAs can upload written bordereaux directly into DDM?
A: No one will be set up automatically as a Trusted Source as Trusted Source accreditation will have stringent criteria. The idea around Trusted Source is to allow MAs that want to use a different proprietary system to do so. If you’re uploading directly into DDM, you don’t need to apply for Trusted Source accreditation.
Q: Do the standards apply retroactivity for older Binding Authorities?
A: The Conditions of Trade will only apply to all Binders incepting from the dates that the Condition of Trade is active which currently is 31/7/21. We’re giving people the opportunity to upload retracted bordereaux if they wish to, but the standards that apply to them will only be the standards which apply at the that time so v5.1, v5.0 etc.
Q: What will be done to ensure standards are applied consistently between carriers?
A: Coverholder Reporting Standards v5.2 will initially serve as a base level, with the new Standards coming into effect in Phase 2. As we are very aware that is only the base level, a stringent set of validations and business controls will hopefully be applied that consistently allow us to monitor it.
Q: Will there be any cross-validation or class-specific validations to alert users that a particular code cannot apply to PI business?
A: The intention is to have the validations in DDM mirror the validations in the guidance, in addition to any further validations that DDM may require.
Q: How are Lloyd’s going to ensure the capture of key Risk data which is not currently mandatory?
A: We really need your feedback on this. Coverholder Reporting Standards v5.2 specifies what is required from a Tax and regulatory reporting standpoint; however, if market feedback calls for a bigger data set, then we are very happy to take this into account. We just need to know exactly what data items are required.
Q: What if we currently use our own Risk Bordereaux for our Coverholders? Will we be required to use the Lloyd’s risk bordereaux as well?
A: If you can meet the data requirements and validations in DDM, then using a Coverholder Reporting Standards v5.2 format isn’t necessarily required. As long as the data flowing into DDM is of an acceptable standard, then the use of the v5.2 format is not required.
Managing Agent Session: Tuesday 10th November 2020
Q: As well as adding and clarifying fields, is this an opportunity to work together to determine which fields cause issues across the market and potentially remove them?
A: Yes, this is partly what we are proposing too. We will also have time in the next several months to document best practice and release it to the market.
Q: What about all the other fields which we already ask for where Coverholders either don’t supply the information or supply it incorrectly? The CoT works on the assumption that they are supplying this data.
A: The overarching goal is better quality data, so working with the market we will be looking to capture this information now. As we go into phase 2, we have to identify the areas which are the most important and have the worst quality first.
Q: With the changes to 1294 and 1295, it may be an opportunity to make clear whether the Coverholder Commission should or should not include the intermediary commission.
A: Yes, we should define that for you. [Follow up TBC]
Q: How is this being communicated to Coverholders and TPAs?
A: We have a plan for Coverholder engagement kicking off later this month, which we will be expanding on in the coming weeks once we have feedback from the change leads and the associations. Due to the large amount of change, we have a lot to communicate to them, such as system onboarding and Conditions of Trade. We will initially be talking to a very small subset of Coverholders, those who are already dealing directly with BAR and we are very aware of engaging at the right time with the right level of information.
Q: Is the Market Glossary used correctly? What improvements are needed?
A: The Market Glossary is a very good tool; however, it needs to be easier to navigate. We also have to clear up some of the definitions and rules and do some ‘housekeeping’. We welcome any feedback on the Market Glossary, which will be fed back to LIMOSS.
Q: Are there inconsistencies between the Market Glossary and the reporting standards?
A: Yes. We will work to remove these inconsistencies and will be looking to market feedback during this Consultation Period to inform that work.
Q: When will DDM validations be aligned with Coverholder Reporting Standards v5.2 and will our Coverholders have notice of this?
A: This is work in progress and is currently being reviewed by Lloyd’s. There will be further updates on this in the coming weeks.
Q: If we have specific questions about classes of business and how they might fit into the standards, who can we ask directly?
A: Marc Bloom (marc.bloom@lloyds.com) is a good initial contact, but please feel free to reach out to Jamie Coughlan (Jamie.coughlan@lloyds.com) or Paniz Mojahedi (paniz.mojahedi@lloyds.com) who can coordinate to ensure your questions are answered quickly and in full.
Q: How are Lloyd’s going to ensure Lloyd’s is a favourable market despite further data changes?
A: This is always at the front of our minds. We have to strike the right balance as, whilst we are bringing in these data changes, we do not want to overcomplicate doing business at Lloyd’s. This is exactly why we want to work collaboratively with the market to try and simplify and remove fields, as well as enrich them.
Q: Will there be any changes for Lineage users?
A: If you are a current Lineage user, you will not have to do anything additional. Lineage will have the data moved to DDM and we are developing a plan to ensure there is no duplication of effort. If you go through another mechanism for non-Lineage or open-market business, those reporting channels will continue and they will follow the Conditions of Trade.
Q: Why are some fields essential for DXC but not mandatory for Premium or Risk?
A: The Coverholder Reporting Standards v5.2 are currently being reviewed by DXC and we are working to ensure there is alignment here. There will be further updates and clarification on this in the follow-up documentation.
Q: As Coverholders will only have 6 months for system changes, will they have a grace period for them to engineer their systems to accommodate the additional requirements?
A: There will be a transition period before go-live, during which individual circumstances will be taken into account. This means that there will not be a blanket deadline, instead we will work with stakeholders to ensure that they are sufficiently prepared to comply with the Coverholder Reporting Standards.
Q: What form do you intend this consultation feedback to take?
A: There will be a follow-up Consultation Survey to allow us to gather feedback on the proposed changes. There will also be free text fields to ensure all feedback can be captured. The feedback will be collated and communicated to the market following the Consultation Period.
Q: There used to be a data group which has appropriate governance around data changes - is this still active? If not, will it be with the appropriate volunteers (i.e. not just operations people).
A: Yes, we are looking to put in place effective governance moving forward.
Q: On the theme of data, it should be recognised that in the past some data was derived or calculated or obtained across 2 bordereaux or from an expiring year. Will this be rejected outright or will DDM have the capacity to cope with these scenarios?
A: This needs better clarity. You have calculated capability in DDM but will need to look at specifics to see where it has been derived from the expiring year. Please contact Chris Rees to discuss directly.
Q: What happens where we receive a Risk/Premium Bordereau as 1 Bordereau. Does this mean we would need to load these twice? One for Risk and One for Premium?
A: No. Whilst we are proposing the use of three separate bordereaux for Risk, Premium and Claims, we recognise that some entities are currently able to process a combined Risk Premium Bordereau in DDM with no issues. Therefore, this proposed change is optional.
Q: Should the MAs ‘encourage’ their Coverholders to submit correct, accurate data or is this the role of the broker?
A: To support the capture of consistent, high-quality data, a group has been established to allow Managing Agents from across the market to meet to review current data quality issues and discuss commonalities; the results of which will be fed back to Lloyd’s. If you would like to participate in these sessions, please reach out to Luke Doyle (luke.doyle@atrium-uw.com).
Broker Session: Thursday 12th November 2020
Q: What effect will these changes have on DDM?
A: Very little as, for the most part, these fields already exist.
Q: Are you planning on using one bordereau per class regardless of country? If so, will this mean there are large bordereaux with a lot of redundant columns depending on country?
A: Generally, yes, however not if it is not necessary. If it is more efficient for some to split, then we will accept this as we do not want to create extra work. Coverholder Reporting Standards V5.2 have various conditional mandatory fields and, regarding class, many have territory-specific mandatory fields. Using the Market Glossary, you can filter by territory to ascertain which conditional mandatory fields apply and this can help you streamline your bordereaux.
Q: When will the updated standard reporting templates for Risk, Premium and Claims be released on the Lloyd’s website, as it currently only shows Premium and Claims?
A: Following feedback gathered during these Consultation Sessions, we will be looking to confirm the standards on the 1st December 2020.
Q: What will happen to historical data previously uploaded into DDM? Is there any risk of creating duplicates because of the additional details?
A: No, historical data previously uploaded into DDM has already been confirmed and will therefore remain as-is.
Q: Will the communications still utilise the Market Business Glossary?
A: Yes, all updates will be included in the Market Business Glossary.
Q: If the Future at Lloyd’s is looking at implementing specific tax tools for market use, will this auto-feed DDM and are the DA team looking at how the tax tool could complement use of DDM?
A: In the long term, as part of Future at Lloyd’s and Middle & Back office work, we are looking at how specific tax tools can feed into and complement DDM. However, we are also aware that many Coverholders have their own tax tools and we would not want to ask them to switch.
Q: Can you confirm the driver for all changes are legal and regulatory?
A: Yes, the main driver is legal and regulatory, but this is not the only driver. A few of the changes have also been requested by stakeholders.
Q: Will ER3001 still be used for commercial property in the US?
A: Yes. We currently have no plans to change this.
Q: Will similar bordereaux be created for Bulking Lineslips?
A: The recent market bulletin contained guidance on this, with further communications from LBS and the LMA set to come out in the coming weeks.
Q: What happens if a claim is not in litigation and then later advised that it is once the bordereau has been submitted?
A: It would be put on the next bordereau, if possible.
Broker Session: Thursday 19th November 2020
Q: At what point are you looking for these changes to come into effect for Phase 1? How much notice are you going to give Coverholders to make changes to their systems to meet the minimum requirements?
A: As a result of this consultation, we are expecting all feedback to be received by the 25th of November, after which we will look to finalise the changes and communicate as a market bulletin on the 1st of December.
Q: ‘Intermediary Commission amount’ - is this capturing local broker commission details or both local broker and London broker commission amounts?
A: This needs to be clarified. It is local as there are specific fields for London broker. All we’re changing here is the column name, not the data, and we will be following this up with detailed guidance.
Q: Are there going to be more changes to the standards in Phase 2? If so, is it not worth doing this as one rather than getting Coverholders to make changes and then 6 months later asking them to make more?
A: Based on the market feedback, the phased approach was more favourable. There is further work to be done on Phase 2 which is more aligned to the Future at Lloyd’s. If there’s feedback that we would like to extend this change, then we will take this on board. To add to this, it depends on the level of changes as we’ve had varying feedback that the longer-term Phase 2 changes could take some time to put together, specifically around an extended risk standard. This is why we split it into phase 2. If there is a larger scale change that could take place in a shorter period of time, then we welcome this feedback but rest assured that everything we do will be with Coverholders in mind.
Q: There was mention of Coverholders losing their Coverholder status if the data quality is not met. What is the time scale for Coverholders to conform to the new Standards when they are released?
A: We will have more to communicate on this once we have more detail on the data; however, what we're trying to do is get everyone aligned, interested and invested to make this work. Rather than putting in place a blanket deadline, we have chosen to work with all stakeholders, taking into account individual circumstances, to ensure everyone is prepared to comply with the updated Standards.
Q: Based on advice from Lloyd’s, we wrote import routines using the duplicated Solvency 2 fields. Since then, TPAs and managing agents have informed us that these are not required. Please can you clarify?
A: This is a governance-related question which is part of what we are looking to solve in the next phase. This involves making sure that guidance and advice is consistent and clear.
Q: Regarding property business, will there be the ability to add COPE information to the risk bordereau, flood zone, earthquake zone, roof age etc to avoid further work providing these separately?
A: Some of these fields are already present and are only required for flood related business. These fields are all covered in 3001 on the Market Business Glossary and there's risk standards that cover these, for example DDM will take car RLDs and capture all this information for you. We hope this will become clearer in Phase 2.
Q: Can we ensure certain fields, such as ‘Roof Age’, are not required unless absolutely necessary?
A: Yes. Mandatory Condition Management needs to be revisited so we are not demanding fields which we do not need.
Q: Are the mandatory fields lists going to be updated?
A: Yes, they will be updated and cleaned up as part of this process. When we reach Phase 2, they will be re-evaluated to identify if there are alternative reference tables we can use.
Q: The feedback deadline of 25th November is not long enough to gather the correct members of staff and complete the survey. Can we have an extra week?
A: We are trying to keep to a tight deadline; however, we encourage you to reach out to us with any queries and we will work with you on this.
Managing Agent Session: Tuesday 17th November 2020
Q: How will data validation within DDM work (considering any mandatory rules)? Will records be rejected (upfront validation), and/or will there be post processing validation reports that may require follow-up?
A: Initially, there may be some upfront warnings to say you have missing fields to give you a chance to reprocess the bordereau or to get improved data from your coverholders; however, this may change in the future. We are working with Lloyd’s tax and regulatory to create a more comprehensive roadmap for validations in the coming weeks, which we hope to communicate before the end of the year.
Q: How will you identify firms that do not adhere to the conditions of trade? How is it Will it be at a Coverholder vs MA level and what are the enforcement measures?
A: Each role and responsibility will be made much clearer in new contracts that come through from DDM. This will allow us to monitor Conditions of Trade compliance by assessing who is responsible for each role. We’re open to suggestions around the enforcement measures and we’re working with the LMA and LIIBA to make sure the Conditions of Trade adherence measures put in place are stringent and applied correctly to improve data quality.
Q: Has there been any progress regarding the MA meeting to discuss common data issues relating to the Coverholder Reporting Standards?
A: Yes, a session has been set up with about 9 MAs to discuss the common themes and how to enhance the Coverholder reporting standards. Luke Doyle from Atrium is leading this, so we would recommend that you reach out to Luke, but we are conscious that most of you might not know him, so feel free to get in touch with DAChangesupport@lloyds.com and we can forward your interest to Luke.
Q: Can modelling files such as EDM’s be loaded into DDM?
A: No, EDMs are specific to RMS so it’s their proprietary setups that can be broken out into proper risk bordereaux.
Q: Are MAs to be set up automatically as Trusted Sources as Y5311 doesn’t seem to mention that MAs can upload written bordereaux directly into DDM?
A: No one will be set up automatically as a Trusted Source as Trusted Source accreditation will have stringent criteria. The idea around Trusted Source is to allow MAs that want to use a different proprietary system to do so. If you’re uploading directly into DDM, you don’t need to apply for Trusted Source accreditation.
Q: Do the standards apply retroactivity for older Binding Authorities?
A: The Conditions of Trade will only apply to all Binders incepting from the dates that the Condition of Trade is active which currently is 31/7/21. We’re giving people the opportunity to upload retracted bordereaux if they wish to, but the standards that apply to them will only be the standards which apply at the that time so v5.1, v5.0 etc.
Q: What will be done to ensure standards are applied consistently between carriers?
A: Coverholder Reporting Standards v5.2 will initially serve as a base level, with the new Standards coming into effect in Phase 2. As we are very aware that is only the base level, a stringent set of validations and business controls will hopefully be applied that consistently allow us to monitor it.
Q: Will there be any cross-validation or class-specific validations to alert users that a particular code cannot apply to PI business?
A: The intention is to have the validations in DDM mirror the validations in the guidance, in addition to any further validations that DDM may require.
Q: How are Lloyd’s going to ensure the capture of key Risk data which is not currently mandatory?
A: We really need your feedback on this. Coverholder Reporting Standards v5.2 specifies what is required from a Tax and regulatory reporting standpoint; however, if market feedback calls for a bigger data set, then we are very happy to take this into account. We just need to know exactly what data items are required.
Q: What if we currently use our own Risk Bordereaux for our Coverholders? Will we be required to use the Lloyd’s risk bordereaux as well?
A: If you can meet the data requirements and validations in DDM, then using a Coverholder Reporting Standards v5.2 format isn’t necessarily required. As long as the data flowing into DDM is of an acceptable standard, then the use of the v5.2 format is not required.
Q: As well as adding and clarifying fields, is this an opportunity to work together to determine which fields cause issues across the market and potentially remove them?
A: Yes, this is partly what we are proposing too. We will also have time in the next several months to document best practice and release it to the market.
Q: What about all the other fields which we already ask for where Coverholders either don’t supply the information or supply it incorrectly? The CoT works on the assumption that they are supplying this data.
A: The overarching goal is better quality data, so working with the market we will be looking to capture this information now. As we go into phase 2, we have to identify the areas which are the most important and have the worst quality first.
Q: With the changes to 1294 and 1295, it may be an opportunity to make clear whether the Coverholder Commission should or should not include the intermediary commission.
A: Yes, we should define that for you. [Follow up TBC]
Q: How is this being communicated to Coverholders and TPAs?
A: We have a plan for Coverholder engagement kicking off later this month, which we will be expanding on in the coming weeks once we have feedback from the change leads and the associations. Due to the large amount of change, we have a lot to communicate to them, such as system onboarding and Conditions of Trade. We will initially be talking to a very small subset of Coverholders, those who are already dealing directly with BAR and we are very aware of engaging at the right time with the right level of information.
Q: Is the Market Glossary used correctly? What improvements are needed?
A: The Market Glossary is a very good tool; however, it needs to be easier to navigate. We also have to clear up some of the definitions and rules and do some ‘housekeeping’. We welcome any feedback on the Market Glossary, which will be fed back to LIMOSS.
Q: Are there inconsistencies between the Market Glossary and the reporting standards?
A: Yes. We will work to remove these inconsistencies and will be looking to market feedback during this Consultation Period to inform that work.
Q: When will DDM validations be aligned with Coverholder Reporting Standards v5.2 and will our Coverholders have notice of this?
A: This is work in progress and is currently being reviewed by Lloyd’s. There will be further updates on this in the coming weeks.
Q: If we have specific questions about classes of business and how they might fit into the standards, who can we ask directly?
A: Marc Bloom (marc.bloom@lloyds.com) is a good initial contact, but please feel free to reach out to Jamie Coughlan (Jamie.coughlan@lloyds.com) or Paniz Mojahedi (paniz.mojahedi@lloyds.com) who can coordinate to ensure your questions are answered quickly and in full.
Q: How are Lloyd’s going to ensure Lloyd’s is a favourable market despite further data changes?
A: This is always at the front of our minds. We have to strike the right balance as, whilst we are bringing in these data changes, we do not want to overcomplicate doing business at Lloyd’s. This is exactly why we want to work collaboratively with the market to try and simplify and remove fields, as well as enrich them.
Q: Will there be any changes for Lineage users?
A: If you are a current Lineage user, you will not have to do anything additional. Lineage will have the data moved to DDM and we are developing a plan to ensure there is no duplication of effort. If you go through another mechanism for non-Lineage or open-market business, those reporting channels will continue and they will follow the Conditions of Trade.
Q: Why are some fields essential for DXC but not mandatory for Premium or Risk?
A: The Coverholder Reporting Standards v5.2 are currently being reviewed by DXC and we are working to ensure there is alignment here. There will be further updates and clarification on this in the follow-up documentation.
Q: As Coverholders will only have 6 months for system changes, will they have a grace period for them to engineer their systems to accommodate the additional requirements?
A: There will be a transition period before go-live, during which individual circumstances will be taken into account. This means that there will not be a blanket deadline, instead we will work with stakeholders to ensure that they are sufficiently prepared to comply with the Coverholder Reporting Standards.
Q: What form do you intend this consultation feedback to take?
A: There will be a follow-up Consultation Survey to allow us to gather feedback on the proposed changes. There will also be free text fields to ensure all feedback can be captured. The feedback will be collated and communicated to the market following the Consultation Period.
Q: There used to be a data group which has appropriate governance around data changes - is this still active? If not, will it be with the appropriate volunteers (i.e. not just operations people).
A: Yes, we are looking to put in place effective governance moving forward.
Q: On the theme of data, it should be recognised that in the past some data was derived or calculated or obtained across 2 bordereaux or from an expiring year. Will this be rejected outright or will DDM have the capacity to cope with these scenarios?
A: This needs better clarity. You have calculated capability in DDM but will need to look at specifics to see where it has been derived from the expiring year. Please contact Chris Rees to discuss directly.
Q: What happens where we receive a Risk/Premium Bordereau as 1 Bordereau. Does this mean we would need to load these twice? One for Risk and One for Premium?
A: No. Whilst we are proposing the use of three separate bordereaux for Risk, Premium and Claims, we recognise that some entities are currently able to process a combined Risk Premium Bordereau in DDM with no issues. Therefore, this proposed change is optional.
Q: Should the MAs ‘encourage’ their Coverholders to submit correct, accurate data or is this the role of the broker?
A: To support the capture of consistent, high-quality data, a group has been established to allow Managing Agents from across the market to meet to review current data quality issues and discuss commonalities; the results of which will be fed back to Lloyd’s. If you would like to participate in these sessions, please reach out to Luke Doyle (luke.doyle@atrium-uw.com).
Broker Session: Thursday 12th November 2020
Q: What effect will these changes have on DDM?
A: Very little as, for the most part, these fields already exist.
Q: Are you planning on using one bordereau per class regardless of country? If so, will this mean there are large bordereaux with a lot of redundant columns depending on country?
A: Generally, yes, however not if it is not necessary. If it is more efficient for some to split, then we will accept this as we do not want to create extra work. Coverholder Reporting Standards V5.2 have various conditional mandatory fields and, regarding class, many have territory-specific mandatory fields. Using the Market Glossary, you can filter by territory to ascertain which conditional mandatory fields apply and this can help you streamline your bordereaux.
Q: When will the updated standard reporting templates for Risk, Premium and Claims be released on the Lloyd’s website, as it currently only shows Premium and Claims?
A: Following feedback gathered during these Consultation Sessions, we will be looking to confirm the standards on the 1st December 2020.
Q: What will happen to historical data previously uploaded into DDM? Is there any risk of creating duplicates because of the additional details?
A: No, historical data previously uploaded into DDM has already been confirmed and will therefore remain as-is.
Q: Will the communications still utilise the Market Business Glossary?
A: Yes, all updates will be included in the Market Business Glossary.
Q: If the Future at Lloyd’s is looking at implementing specific tax tools for market use, will this auto-feed DDM and are the DA team looking at how the tax tool could complement use of DDM?
A: In the long term, as part of Future at Lloyd’s and Middle & Back office work, we are looking at how specific tax tools can feed into and complement DDM. However, we are also aware that many Coverholders have their own tax tools and we would not want to ask them to switch.
Q: Can you confirm the driver for all changes are legal and regulatory?
A: Yes, the main driver is legal and regulatory, but this is not the only driver. A few of the changes have also been requested by stakeholders.
Q: Will ER3001 still be used for commercial property in the US?
A: Yes. We currently have no plans to change this.
Q: Will similar bordereaux be created for Bulking Lineslips?
A: The recent market bulletin contained guidance on this, with further communications from LBS and the LMA set to come out in the coming weeks.
Q: What happens if a claim is not in litigation and then later advised that it is once the bordereau has been submitted?
A: It would be put on the next bordereau, if possible.
Q: What are the benefits of using DDM?
A: Full implementation of these Conditions of Trade will ensure full market realisation of the benefits of DDM, including but not limited to:
• Reduced effort and improved quality:
Less manual transmission and processing of Coverholder reporting data, or further processing by Managing Agents or Brokers, leading to better data quality and usable extracts which can support firms CAT Modelling, pricing, and market insights.
• Improved data security:
Access controls which only allow members to see relevant sections will enhance data security. This will remove the process of emailing bordereau to every member on the binder thus leaving a more transparent and efficient data reporting process.
• Reduced Costs:
Less costs and delays during the processing and reporting of Coverholder Reporting data, allowing enhanced data-based performance management.
• Facilitation of reporting:
Facilitate the collection and distribution of bordereaux submissions for oversight, tax and regulatory purposes. This will remove the double keying process currently in place, where firms are required to separately submit data to regulators.
• Integrated DA Ecosystem:
Develop an integrated ecosystem of parties, via a common standard to transact digital placement through API’s. However, to support this roadmap we need to drive the adoption of DDM, as it is an important transition state that will improve the quality of Delegated Authority policy and claims data and act as the foundation that underpins the future model.
• Enhanced data quality:
A ‘step-change’ in data quality; RPAC API will not support transfer of file-based data, or transfer of non-compliant data, therefore Lloyd’s Conditions of Trade will allow the market to realise benefits sooner due to the time it will take to build planned RPAC API-based integrations.
Coverholder Reporting Standards – Phase 1
Q: Lloyd’s suggest that the first phase of the “minimal changes” to the current V5.2 standards will be effective from July 2021. Do we know when these changes will be signed off by ‘Lloyds Tax, Regulatory and Finance functions’ and shared with Managing Agents, Brokers and Coverholders/TPA’s? If to be effective from July 2021, this in most cases will require Coverholders to provide the new standards in the May 2021 bordereaux. Or is it that the Coverholders will start capturing the revised data in July 2021, which will be reportable in September 2021? And will there be a required change from Lloyd’s in terms of reporting timelines? Currently, in most cases it is 30 days from the end of the month. Will this reduce to 15 days to be aligned with LBS?
A: Yes, these are working through sign-off procedures at present and the consultation period will be launched from Monday 2nd November with the full data set. The changes are being consulted on so if the market feels they are not appropriate, they will not be introduced. The Conditions of Trade will be live for all binders incepting from July 2021 so the data would be reported according to this.
Q: The phase 1 model very much seems to play to advantage of Lloyd’s rather than the MAs – by focussing on transactional details of money movements we aren’t gaining much – we find the risk attributes/claims decision making data (e.g. for conduct reporting) far more useful – and its looks like the Conditions of Trade do not really help us with those – what do MAs gain here in phase 1?
A: Costs are reduced for all by streamlining the transaction processes. The whole market will benefit from the increase in data quality. By introducing a phased approach MA’s will still have access to their current levels of Risk and Claims decision making data. A concurrent phase 2 project to ensure the correct levels of risk and claims data is collated will start in Q4 2020 but due to the complexity of market needs will take some time to finalise. Putting in place a phase 1 whereby all Coverholder data is entering a central repository whereby we can control the levels of quality will add benefits for the whole market.
Q: I note there is a new addition to this version that Risk and Premium Bordereaux can no longer be combined – this is new. Is this because of the split in the data tables in DDM?
A: We feel that the premium bordereaux should not be held up by adding other fields not necessary for processing. But this will be consulted on during the consultation period starting Monday 3rd November.
Q: What is the target date for implementation of COT and the related data standards, validations, and accreditations? And how will stakeholders be supported to comply?
A: Lloyd’s aim to implement the Conditions of Trade from July 2021 upon meeting the pre-requisites set out by both the LMA and LIIBA. Consultations are beginning W/C 26th October for Data standards and will last for 3 weeks; we therefore expect to have a final version ready for market distribution by the end of November. Validations and accreditations will follow on from this and be ready as soon as is possible.
Lloyd’s will provide support for all stakeholders through a variety of change and adoption mechanisms. Firstly, training will be developed to support all users of the Tide system alongside detailed user guidance. Secondly, we will be hosting twice monthly support sessions from November to support the market in adopting the conditions of trade. Thirdly we will continue to offer business readiness support workshops over the coming months to prepare firms for the upcoming change. Finally, additional support is always available if any stakeholder needs it to prepare for the adoption of the conditions of trade.
Q: Minimal change being referred to within the phase 1 data standards is misleading, it may be minimal to V5.2 but will not be seen minimal to those that need to comply with the changes. Appreciate some of the changes may have been requested by the market, but can Lloyd’s demonstrate the value by the additions so that we can assess if it is right to make any change now or hold it over for the bigger piece of work in phase 2?
A: This is the reason we are consulting on the data fields and its clear what has been added and why.
Stakeholder Compliance
Q: We have experienced challenges in getting Coverholders to be V5.2 compliant. Even if these changes are minimal, we suspect there will be Coverholders that are unable to update their systems in time to report from May next year. What is Lloyd’s implementation approach to Data standards?
A: The reporting standards have been mandatory for years however it was never enforced by Lloyd’s. These Conditions of trade will change this. We are working out the challenges in full before communicating with the market via consultation starting on 3rd November. If we want to enhance data quality then Coverholders will have to become compliant, by introducing a market-wide approach to Coverholder Reporting, there will be a level playing field. In addition to this Lloyd’s will support market firms by working with Coverholders to ensure reporting is complete.
Q: What happens if Coverholders are not in a position to provide the new data requests but have a plan to be able to report as required post July 2021? Is there any leniency in this regard?
A: We would like to be made aware of which data fields are an issue so we can factor that in. In individual cases Lloyd’s will look at ways to support Coverholders and understand said plans.
Q: What happens if stakeholders (Brokers/Coverholders/TPAs) do not comply? Who is sanctioned and how? What is the direct impact to the market?
A: Lloyd’s have a range of sanctions at our disposal, but the main sanction will be that premium will be held up at DXC to be processes if not correctly loaded into DDM. If this continues then we may need to review the suitability of the Coverholder to remain at Lloyd’s.
Q: How will Lloyd’s implement a COT target date bearing in mind some stakeholders will not be ready to comply? Will it be a soft or firm implementation? How does this impact data quality and the planned implementation of validations? Phased or half-baked?
A: The COT is for contracts incepting after the go live date. So its not a big bang and we remain confident that there is enough time to become compliant and if not we would like to know why as soon as possible, as if its data fields and this is a theme we may look to remove those from the mandate.
Governance & Oversight
Q: Can we get oversight of the proposed “rigorous data validation” and “business controls” that will be applied? What are they?
A: The data validations will be designed once the data standards are approved so are still some time away and will be discussed with all the appropriate governance forums upon completion. This is also true for business controls where we look to the market for steer on what is appropriate.
Q: Will there be any grace for Coverholders experiencing issues or will the “potential consequences” strictly apply from day one?
A: Please see question above for answer.
Q: Will you really have validations that kick out anything that’s not fully 5.2 compliant (that’s what page 1 suggests)?
A: Yes, these will be developed once the consultation on Data standards is complete.
Q: How does the guidance planned on data fields facilitate the Conditions of Trade?, and what is the plan to achieve a successful implementation and source adherence?
A: They don’t - The standards, compliance, rules, controls, and validations working in coordination facilitate the Conditions of Trade.
Roles & Responsibilities
Q: Will mapping be required of the bordereaux? If so, who will be responsible for the mapping of bordereaux into DDM? How will training be provided and by whom? Managing Agents for Risk, Brokers for Premium and Managing Agents/TPA’s for Claims?
A: Yes, mapping is required of bordereaux within DDM. That will be decided within each binding authority and a feature of DCM. Training and support will be provided on system use to all firms by Lloyd’s/LIMOSS. For premium/claims we are stating that it should be the partner responsible for submitting to DXC that is responsible for loading into DDM which in most cases may be the broker. Risk data can be submitted via a ‘trusted source’ if the MA would prefer.
Q: Is it to be assumed that in most cases, the ‘submission partner’ will be the broker or will this be for Premium Bordereaux only? If so, what is the feedback on this from the brokers? Have LIIBA been consulted?
A: Yes, the submission partner can be the broker in most cases. However, we want to add some level of flexibility for circumstances such as 100% MA contract and Coverholders who may want to directly load. These roles can be determined in the contract creation within DCM. LIIBA are supportive of these principles and are putting together some additional pre-requisites in the coming weeks.
Q: How are we going to decide this who is the submission partner? What is the feedback received from Brokers?
A: This will be negotiated during the contract creation process and Lloyd’s feels this should be completed between relevant parties not Lloyd’s. Brokers are supportive of these principles.
Q: Why not make the Premium Paid bordereaux at least mandatory for Brokers? Who else can process through DXC? The principle talks about sharing of responsibilities across the market, but this could have an impact on workload for the BDX team for example.
A: There is some instances such as 100% MA contract where there is no Broker but we are essentially making it a Condition of Trade that the broker do this. Some of these questions need to be discussed in person to add clarity and we are happy to discuss further.
Q: What is not specified in the Conditions of Trade?
A: All roles will be set in DCM and therefore in the binder. We feel that conversations should be taking place during the negotiation stage to ensure this is put in place correctly.
“Trusted Sources”
Q: When will ‘trusted sources’ work be completed, and will it be in place for July 2021?
A: This a new concept put together following feedback at the last LMAOC in September when the demand was put forward to continue using other systems. This is currently being investigated and will take some time to finalise. It is our intention for it to be in place by July 2021 as this is a pre-requisite of the Conditions of Trade.
Q: Managing Agents will be tested on the configuration of their bordereaux systems in order to become a ‘trusted source’. How will Lloyd’s enforce this? Could a templated feed/report be developed by Watertrace, VIPR, DXC, etc. for Managing Agents to deploy into their environments? Namely, a Lloyd’s DDM Report which is spec’d out to capture all the required reporting fields from the Bordereaux Processing tool and loaded into DDM?
A: Lloyd’s will accredit ‘trusted sources’ and enforcement will take place through strong validations at the front of DDM which will reject any bordereau that fails validations. The data that enters DDM should not be heavily remediated, transformed, or adapted in any way other than by the Coverholder/Broker.
Q: Will accreditation only be for supplier systems or can in house systems get accredited status?
A: Accreditation will not be based on systems but on individual firms so is open to any system that can meet the criteria.
Central Customer Service (BPO)
Q: A BPO service will have to go back to Managing Agents or Coverholders/Brokers to clear the queries, so it is not an easy and straightforward process, especially if reporting timelines are reduced from 30 days to 15. How are we going to implement this?
A: Data quality must be driven from source, the BPO will not be about remediating data as this does not fix the issue. It will purely be for chasing and submitting/mapping. Any errors should be sent back to source for correction. We are listening to feedback on the 15-day timeline for the risk bordereaux. The premium will be driven by terms in the binder.
Q: My concern is that as the Conditions of Trade are currently stated, Brokers who don’t wish to engage can just step back, state it’s not possible for them to load and therefore it falls back on the Managing Agent, meaning we don’t make as much progress as we’d like in getting close to the source of the data. I believe the document needs to clearly state that Condition 2 takes precedence and for Lloyd’s to clarify that the BPO service only applies to Risk Bordereaux and Claim Decision Bordereaux, all bordereaux where no broker is in place and/or sets out acceptable reasons for a broker not being able to load.
A: We will layout the terms of use for the BPO in more detail to ensure that Principle 2 takes precedence. Once the RFI is complete we will communicate specifically around any BPO offering.
Pre-requisites/Critical Path
Q: There is nothing in here around getting data out of DDM – support and adoption will be far easier if TIDE has a meaningful reporting capability where MAs can self-serve and write reports to use their own data. An API to flow data into MA own systems also increases value to us – again what’s in it for us if we can’t get anything out of the system – we don’t want canned reports we want to be able to write our own.
A: This document is just focused on the Conditions of Trade. We will be coming out with updates regarding the pre-requisites, one of which is a functioning data extract. Work on this is ongoing with a working group set up through the DDM Market User group. Further work on the Bordereaux distribution service will allow for automated transmission into other market systems.
Q: What broker engagement and comments have there been and what are their prerequisites? How and will Coverholders and TPAs be engaged?
A: LIIBA and the LMA have been consulted on the COT and we plan to engage directly with Coverholders and DCA’s/TPA’s once more detail has been finalised.
Q: What is the plan and approach for the activity to support COT, particularly the items on the critical path, including trusted source accreditation criteria; data standards P1 / P2 (risk, premium, claims); business rules; data validations; APIs; broker engagement & compliance; DA vendor systems engagement & compliance; MA engagement & compliance?
A: more detail to follow on this once we have finalised the consultation.
A: Full implementation of these Conditions of Trade will ensure full market realisation of the benefits of DDM, including but not limited to:
• Reduced effort and improved quality:
Less manual transmission and processing of Coverholder reporting data, or further processing by Managing Agents or Brokers, leading to better data quality and usable extracts which can support firms CAT Modelling, pricing, and market insights.
• Improved data security:
Access controls which only allow members to see relevant sections will enhance data security. This will remove the process of emailing bordereau to every member on the binder thus leaving a more transparent and efficient data reporting process.
• Reduced Costs:
Less costs and delays during the processing and reporting of Coverholder Reporting data, allowing enhanced data-based performance management.
• Facilitation of reporting:
Facilitate the collection and distribution of bordereaux submissions for oversight, tax and regulatory purposes. This will remove the double keying process currently in place, where firms are required to separately submit data to regulators.
• Integrated DA Ecosystem:
Develop an integrated ecosystem of parties, via a common standard to transact digital placement through API’s. However, to support this roadmap we need to drive the adoption of DDM, as it is an important transition state that will improve the quality of Delegated Authority policy and claims data and act as the foundation that underpins the future model.
• Enhanced data quality:
A ‘step-change’ in data quality; RPAC API will not support transfer of file-based data, or transfer of non-compliant data, therefore Lloyd’s Conditions of Trade will allow the market to realise benefits sooner due to the time it will take to build planned RPAC API-based integrations.
Coverholder Reporting Standards – Phase 1
Q: Lloyd’s suggest that the first phase of the “minimal changes” to the current V5.2 standards will be effective from July 2021. Do we know when these changes will be signed off by ‘Lloyds Tax, Regulatory and Finance functions’ and shared with Managing Agents, Brokers and Coverholders/TPA’s? If to be effective from July 2021, this in most cases will require Coverholders to provide the new standards in the May 2021 bordereaux. Or is it that the Coverholders will start capturing the revised data in July 2021, which will be reportable in September 2021? And will there be a required change from Lloyd’s in terms of reporting timelines? Currently, in most cases it is 30 days from the end of the month. Will this reduce to 15 days to be aligned with LBS?
A: Yes, these are working through sign-off procedures at present and the consultation period will be launched from Monday 2nd November with the full data set. The changes are being consulted on so if the market feels they are not appropriate, they will not be introduced. The Conditions of Trade will be live for all binders incepting from July 2021 so the data would be reported according to this.
Q: The phase 1 model very much seems to play to advantage of Lloyd’s rather than the MAs – by focussing on transactional details of money movements we aren’t gaining much – we find the risk attributes/claims decision making data (e.g. for conduct reporting) far more useful – and its looks like the Conditions of Trade do not really help us with those – what do MAs gain here in phase 1?
A: Costs are reduced for all by streamlining the transaction processes. The whole market will benefit from the increase in data quality. By introducing a phased approach MA’s will still have access to their current levels of Risk and Claims decision making data. A concurrent phase 2 project to ensure the correct levels of risk and claims data is collated will start in Q4 2020 but due to the complexity of market needs will take some time to finalise. Putting in place a phase 1 whereby all Coverholder data is entering a central repository whereby we can control the levels of quality will add benefits for the whole market.
Q: I note there is a new addition to this version that Risk and Premium Bordereaux can no longer be combined – this is new. Is this because of the split in the data tables in DDM?
A: We feel that the premium bordereaux should not be held up by adding other fields not necessary for processing. But this will be consulted on during the consultation period starting Monday 3rd November.
Q: What is the target date for implementation of COT and the related data standards, validations, and accreditations? And how will stakeholders be supported to comply?
A: Lloyd’s aim to implement the Conditions of Trade from July 2021 upon meeting the pre-requisites set out by both the LMA and LIIBA. Consultations are beginning W/C 26th October for Data standards and will last for 3 weeks; we therefore expect to have a final version ready for market distribution by the end of November. Validations and accreditations will follow on from this and be ready as soon as is possible.
Lloyd’s will provide support for all stakeholders through a variety of change and adoption mechanisms. Firstly, training will be developed to support all users of the Tide system alongside detailed user guidance. Secondly, we will be hosting twice monthly support sessions from November to support the market in adopting the conditions of trade. Thirdly we will continue to offer business readiness support workshops over the coming months to prepare firms for the upcoming change. Finally, additional support is always available if any stakeholder needs it to prepare for the adoption of the conditions of trade.
Q: Minimal change being referred to within the phase 1 data standards is misleading, it may be minimal to V5.2 but will not be seen minimal to those that need to comply with the changes. Appreciate some of the changes may have been requested by the market, but can Lloyd’s demonstrate the value by the additions so that we can assess if it is right to make any change now or hold it over for the bigger piece of work in phase 2?
A: This is the reason we are consulting on the data fields and its clear what has been added and why.
Stakeholder Compliance
Q: We have experienced challenges in getting Coverholders to be V5.2 compliant. Even if these changes are minimal, we suspect there will be Coverholders that are unable to update their systems in time to report from May next year. What is Lloyd’s implementation approach to Data standards?
A: The reporting standards have been mandatory for years however it was never enforced by Lloyd’s. These Conditions of trade will change this. We are working out the challenges in full before communicating with the market via consultation starting on 3rd November. If we want to enhance data quality then Coverholders will have to become compliant, by introducing a market-wide approach to Coverholder Reporting, there will be a level playing field. In addition to this Lloyd’s will support market firms by working with Coverholders to ensure reporting is complete.
Q: What happens if Coverholders are not in a position to provide the new data requests but have a plan to be able to report as required post July 2021? Is there any leniency in this regard?
A: We would like to be made aware of which data fields are an issue so we can factor that in. In individual cases Lloyd’s will look at ways to support Coverholders and understand said plans.
Q: What happens if stakeholders (Brokers/Coverholders/TPAs) do not comply? Who is sanctioned and how? What is the direct impact to the market?
A: Lloyd’s have a range of sanctions at our disposal, but the main sanction will be that premium will be held up at DXC to be processes if not correctly loaded into DDM. If this continues then we may need to review the suitability of the Coverholder to remain at Lloyd’s.
Q: How will Lloyd’s implement a COT target date bearing in mind some stakeholders will not be ready to comply? Will it be a soft or firm implementation? How does this impact data quality and the planned implementation of validations? Phased or half-baked?
A: The COT is for contracts incepting after the go live date. So its not a big bang and we remain confident that there is enough time to become compliant and if not we would like to know why as soon as possible, as if its data fields and this is a theme we may look to remove those from the mandate.
Governance & Oversight
Q: Can we get oversight of the proposed “rigorous data validation” and “business controls” that will be applied? What are they?
A: The data validations will be designed once the data standards are approved so are still some time away and will be discussed with all the appropriate governance forums upon completion. This is also true for business controls where we look to the market for steer on what is appropriate.
Q: Will there be any grace for Coverholders experiencing issues or will the “potential consequences” strictly apply from day one?
A: Please see question above for answer.
Q: Will you really have validations that kick out anything that’s not fully 5.2 compliant (that’s what page 1 suggests)?
A: Yes, these will be developed once the consultation on Data standards is complete.
Q: How does the guidance planned on data fields facilitate the Conditions of Trade?, and what is the plan to achieve a successful implementation and source adherence?
A: They don’t - The standards, compliance, rules, controls, and validations working in coordination facilitate the Conditions of Trade.
Roles & Responsibilities
Q: Will mapping be required of the bordereaux? If so, who will be responsible for the mapping of bordereaux into DDM? How will training be provided and by whom? Managing Agents for Risk, Brokers for Premium and Managing Agents/TPA’s for Claims?
A: Yes, mapping is required of bordereaux within DDM. That will be decided within each binding authority and a feature of DCM. Training and support will be provided on system use to all firms by Lloyd’s/LIMOSS. For premium/claims we are stating that it should be the partner responsible for submitting to DXC that is responsible for loading into DDM which in most cases may be the broker. Risk data can be submitted via a ‘trusted source’ if the MA would prefer.
Q: Is it to be assumed that in most cases, the ‘submission partner’ will be the broker or will this be for Premium Bordereaux only? If so, what is the feedback on this from the brokers? Have LIIBA been consulted?
A: Yes, the submission partner can be the broker in most cases. However, we want to add some level of flexibility for circumstances such as 100% MA contract and Coverholders who may want to directly load. These roles can be determined in the contract creation within DCM. LIIBA are supportive of these principles and are putting together some additional pre-requisites in the coming weeks.
Q: How are we going to decide this who is the submission partner? What is the feedback received from Brokers?
A: This will be negotiated during the contract creation process and Lloyd’s feels this should be completed between relevant parties not Lloyd’s. Brokers are supportive of these principles.
Q: Why not make the Premium Paid bordereaux at least mandatory for Brokers? Who else can process through DXC? The principle talks about sharing of responsibilities across the market, but this could have an impact on workload for the BDX team for example.
A: There is some instances such as 100% MA contract where there is no Broker but we are essentially making it a Condition of Trade that the broker do this. Some of these questions need to be discussed in person to add clarity and we are happy to discuss further.
Q: What is not specified in the Conditions of Trade?
A: All roles will be set in DCM and therefore in the binder. We feel that conversations should be taking place during the negotiation stage to ensure this is put in place correctly.
“Trusted Sources”
Q: When will ‘trusted sources’ work be completed, and will it be in place for July 2021?
A: This a new concept put together following feedback at the last LMAOC in September when the demand was put forward to continue using other systems. This is currently being investigated and will take some time to finalise. It is our intention for it to be in place by July 2021 as this is a pre-requisite of the Conditions of Trade.
Q: Managing Agents will be tested on the configuration of their bordereaux systems in order to become a ‘trusted source’. How will Lloyd’s enforce this? Could a templated feed/report be developed by Watertrace, VIPR, DXC, etc. for Managing Agents to deploy into their environments? Namely, a Lloyd’s DDM Report which is spec’d out to capture all the required reporting fields from the Bordereaux Processing tool and loaded into DDM?
A: Lloyd’s will accredit ‘trusted sources’ and enforcement will take place through strong validations at the front of DDM which will reject any bordereau that fails validations. The data that enters DDM should not be heavily remediated, transformed, or adapted in any way other than by the Coverholder/Broker.
Q: Will accreditation only be for supplier systems or can in house systems get accredited status?
A: Accreditation will not be based on systems but on individual firms so is open to any system that can meet the criteria.
Central Customer Service (BPO)
Q: A BPO service will have to go back to Managing Agents or Coverholders/Brokers to clear the queries, so it is not an easy and straightforward process, especially if reporting timelines are reduced from 30 days to 15. How are we going to implement this?
A: Data quality must be driven from source, the BPO will not be about remediating data as this does not fix the issue. It will purely be for chasing and submitting/mapping. Any errors should be sent back to source for correction. We are listening to feedback on the 15-day timeline for the risk bordereaux. The premium will be driven by terms in the binder.
Q: My concern is that as the Conditions of Trade are currently stated, Brokers who don’t wish to engage can just step back, state it’s not possible for them to load and therefore it falls back on the Managing Agent, meaning we don’t make as much progress as we’d like in getting close to the source of the data. I believe the document needs to clearly state that Condition 2 takes precedence and for Lloyd’s to clarify that the BPO service only applies to Risk Bordereaux and Claim Decision Bordereaux, all bordereaux where no broker is in place and/or sets out acceptable reasons for a broker not being able to load.
A: We will layout the terms of use for the BPO in more detail to ensure that Principle 2 takes precedence. Once the RFI is complete we will communicate specifically around any BPO offering.
Pre-requisites/Critical Path
Q: There is nothing in here around getting data out of DDM – support and adoption will be far easier if TIDE has a meaningful reporting capability where MAs can self-serve and write reports to use their own data. An API to flow data into MA own systems also increases value to us – again what’s in it for us if we can’t get anything out of the system – we don’t want canned reports we want to be able to write our own.
A: This document is just focused on the Conditions of Trade. We will be coming out with updates regarding the pre-requisites, one of which is a functioning data extract. Work on this is ongoing with a working group set up through the DDM Market User group. Further work on the Bordereaux distribution service will allow for automated transmission into other market systems.
Q: What broker engagement and comments have there been and what are their prerequisites? How and will Coverholders and TPAs be engaged?
A: LIIBA and the LMA have been consulted on the COT and we plan to engage directly with Coverholders and DCA’s/TPA’s once more detail has been finalised.
Q: What is the plan and approach for the activity to support COT, particularly the items on the critical path, including trusted source accreditation criteria; data standards P1 / P2 (risk, premium, claims); business rules; data validations; APIs; broker engagement & compliance; DA vendor systems engagement & compliance; MA engagement & compliance?
A: more detail to follow on this once we have finalised the consultation.