Frequently Asked Questions – China

A: Lloyd's underwriters are permitted to write non-life business in China through Lloyd's Insurance Company (China) Ltd (LICCL) :

• all lines of general insurance business (i.e. property, casualty, construction, marine hull and cargo, credit, surety insurance etc.), excluding export credit insurance business and compulsory lines; and
• personal accident insurance and short-term health insurance;
• reinsurance and retrocession business of the above;

A: Lloyd’s syndicates may participate Lloyd’s China platform by establishing an Underwriting Division equipped with local underwriters. Participation is achieved by means of annual reinsurance/retrocession agreements between Lloyd’s China and each participating syndicate, ceding the entire book of risks underwritten by the corresponding Underwriting Division at Lloyd’s China.

A: Direct business cannot be written on a cross-border basis in China. Syndicates wishing to write direct business of risks located in China must be approved by Lloyd’s to participate on the LICCL platform, with the following exceptions:

• Under China’s World Trade Organisation (WTO) commitments, non-admitted insurers may write international MAT business. MAT refers to the international marine hull, aviation and cargo transportation.
• Risks that do not fall under the definition of a Chinese risk as set out in Article 7 of PRC Insurance Law - i.e. where the insured or policyholder is not a Chinese legal entity or the risk to be covered is not located in China.

A: No, Lloyd’s China’s capital is centrally funded by Corporation of Lloyd’s. The syndicates intend to participate on the platform are not required to place additional capital to Lloyd’s China.

A: Syndicates shall be treated as separate reinsurers.

A: Yes. The coverholder business model is not officially recognised under the current Chinese insurance intermediary regulatory regime and therefore falls under category of other business to be admitted by regulators. That said, from 2017, LICCL started the coverholder pilot scheme for reinsurance business (in Shanghai and Beijing) to promote the new business model in China with support by the regulator. Now Lloyd's China has two local coverholders with three binders in place involving terrorism, fine art and personal accident business. The coverholder model is one of the strategic priorities of Lloyd's China in the next five years.

Lloyd’s China Corproate teams may assist the participated syndicates (with UW divisions established) to develop new coverholders for piloting.

A: No, the coverholder model is a piloting scheme under close supervision by the local regulator. The purpose of such piloting is to encourage the intermediary innovation in local market. Lloyd’s China’s as the authorizer driving this scheme shall be responsible for business activities by these local coverholders with regular reporting to the regulator. Hence the syndicates not participating on China platform is not permitted to develop its local coverholders remotely or collaborate with the existing local coverholders.

A: All on-shore and off-shore reinsurers and reinsurance brokers conducting reinsurance businesses with a Chinese ceding company are required to be registered with the NFRA’s RI registration platform (NFRA stands for National Financial Regulatory Administration).

Coverholders and service companies that wish to transact Chinese reinsurance business will be able to rely upon a syndicate’s registration ID, as long as that syndicate has included the coverholder(s) on their list of authorised agents submitted to NFRA.

A: No, Lloyd’s China does not enter into the Terms of Business Agreement (TOBAs) with the overseas broker, as the brokers represent and act for the clients instead of (re)insurers under China legislation framework.

A: No, the overseas brokers are not permitted to offshore place direct business of China risks unless for the international MAT business. But overseas brokers may offshore place reinsurance business.