APRIL 2005 Insurance Coverage Issues Arising From the Recent Trend of Solvent London Insurers Proposing Schemes of Arrangement That Include Bar Dates INTRODUCTION BACKGROUND ON SOLVENT SCHEMES Two solvent London insurers—Sphere Drake Insurance Company Limited (“Sphere Drake”) and Mercantile & General Reinsurance Company Limited (“Mercantile”)—will hold Creditors’ Meetings in April 2005 for the purpose of voting on proposed Solvent Schemes of Arrangement (“Solvent Schemes”). Notwithstanding the fact that Sphere Drake and Mercantile are solvent, their proposed Solvent Schemes include bar dates by which policyholders must file all claims, including contingent and Incurred But Not Reported (“IBNR”) claims. Moreover, the insurers have announced that they will seek a permanent injunction from a bankruptcy court in the United States to prohibit policyholders from continuing or commencing any litigation against the insurers. A Scheme of Arrangement is essentially a contract that is binding on the insurer and all of its creditors that governs how the insurer will handle and resolve claims. Since the mid-1990s, numerous insolvent London insurers have adopted Schemes, including the KWELM companies, Andrew Weir, English & American, and Orion. In the past year or so, numerous solvent London insurers in run-off (generally, insurers that are solvent but who no longer issue new policies) have proposed or announced their intention to propose Solvent Schemes with bar dates. For example, Ludgate Insurance Company and Prudential Assurance Company Limited obtained creditor and court approval for so-called Solvent Schemes that included bar dates in 2004. While Scheme Administrators of insolvent London insurers pay some fraction of settled claims, the Solvent Scheme Administrators generally will pay 100% of settled claims. The proposed Solvent Schemes of Sphere Drake and Mercantile reflect a trend among solvent London insurers in run-off to move toward schemes with bar dates. This trend has sparked a considerable amount of controversy in the policyholder community. For example, it has been reported that a substantial number of policyholders recently voted against the proposed Scheme for British Aviation Insurance Company Limited (“British Aviation”) at a Creditors’ Meeting in March 2005. The fate of British Aviation’s proposed Scheme remains uncertain. In sum, policyholders should be aware of this trend and should carefully evaluate the Solvent Schemes in light of their unique claims history and coverage program. There are numerous other Solvent Schemes in the pipeline, including Sphere Drake and Mercantile. Sphere Drake is holding a Creditors’ Meeting to vote on its proposed Scheme on April 19, 2005. Policyholders who wish to vote on the Scheme must submit a Form of Proxy and Voting Form in advance of the meeting. An Explanatory Statement and the proposed Solvent Scheme are available at www.sdopoolssolventscheme.co.uk. If the Solvent Scheme is approved, it is expected that the bar date for filing claims will be September 5, 2005. Kirkpatrick & Lockhart Nicholson Graham LLP Mercantile is holding a Creditors’ Meeting on April 26, 2005. If approved, Mercantile anticipates a bar date for filing claims in October or November 2005. Copies of the Scheme and Explanatory Statement can be found at www.mgre.co.uk. As a general matter, in order to implement a Solvent Scheme, the relevant insurer must obtain approvals on three levels: (1) first, they must obtain the approval of a super-majority of all known creditors; (2) second, they must obtain the approval of an English court supervising the so-called Solvent Scheme; and (3) third, they must seek and obtain a permanent injunction from a bankruptcy court in the United States to prohibit any litigation against the insurer. For example, Sphere Drake has stated that “an application will be made in the United States of America pursuant to Section 304 of the United States Bankruptcy Code for a permanent injunction restraining Scheme Creditors in the United States from proceeding against the Company in relation to Scheme Liabilities in that jurisdiction and relying instead on the provisions of the Solvent Scheme for such liabilities to be met in full.” See Explanatory Statement Relating to a Proposed Solvent Scheme of Arrangement for Sphere Drake, at 17 (available at www.sdopools-solventscheme.co.uk). DISCUSSION It appears that there is a growing sense of unease among certain policyholders with respect to Solvent Schemes. For example, at the Creditors’ Meeting concerning the proposed British Aviation Solvent Scheme on March 15, 2005, a substantial group of policyholders sought to oppose the proposed Scheme. British Aviation has reported the following on its website: The votes cast at the meeting are now being reviewed. A number of votes (both for and against the Scheme) are not considered reasonable by the Company and will be reviewed by the Chairman in accordance with the English court order of 18 January 2005. The Chairman will determine a reasonable value to be put on disputed claims for voting purposes only. Once the Chairman has completed his review the result of the creditors’ vote on the Scheme will be reported to the Court and published on this website. 2 APRIL 2005 See www.baicsolventscheme.co.uk (posted as of April 5, 2005). As noted above, each policyholder should evaluate the so-called Solvent Schemes based on their unique facts and circumstances. Insurers have identified several purported advantages to the Solvent Schemes, including the following: ■ Early Payment (noting that Scheme Creditors may receive payments “sooner than if the run-off of the Scheme Business were to continue until all claims matured and were paid in the ordinary course”); and ■ Simplified Claims, Agreement Process (noting that disputes concerning the valuation of IBNR claims will “be referred to an independent Scheme Adjudicator for resolution in what is intended to be a fair and efficient manner”). See Explanatory Statement Relating to a Proposed Solvent Scheme of Arrangement for Sphere Drake, at 7. Based on such factors, certain policyholders may wish to support the Solvent Schemes, particularly if they are in a position to support substantial IBNR claims because they potentially may collect money now under the Schemes based on estimates of future claims that they otherwise would not collect for many years. On the other hand, policyholders also should consider the following factors: ■ Notwithstanding the fact that the occurrence-based policies at issue never expire, policyholders would not be able to file claims after the bar date, even if they were unaware of the claims before the bar date. ■ There is uncertainty concerning how the Scheme Administrators will value IBNR claims, particularly for policyholders that may have just recently become involved in asbestos-related lawsuits. More specifically, there is uncertainty whether the Scheme’s actuaries will limit their analysis to projections based on existing claims data or whether they will consider other factors. ■ There is uncertainty whether the pre-appointed Scheme Adjudicator will resolve disputes in a fair manner. KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP ■ There is uncertainty whether Scheme Administrators will otherwise handle claims in a fair manner, given that policyholders arguably lose the threat of suing the insurer if a settlement is not reached or the insurer acts in bad faith. Gregory S. Wright gwright@klng.com 202.778.9250 Julia Reynolds Johnson To the extent a policyholder decides to oppose a Scheme, it may mount its opposition at several stages in the process, including the creditor vote stage, the English court stage, and the United States bankruptcy court stage. jjohnson@klng.com 202.778.9227 Gregory S. Wright is a partner and Julia Reynolds Johnson is of counsel in the Washington, D.C. office of the law firm of Kirkpatrick & Lockhart Nicholson Graham LLP. They regularly counsel policyholders with respect to a wide variety of CONCLUSION insurance coverage claims, including claims against insolvent As noted above, the upcoming votes on proposed Solvent Schemes for Sphere Drake and Mercantile illustrate the issues presented by this developing trend of solvent London insurers proposing Solvent Schemes with bar dates. Battlelines are being drawn, and policyholders should carefully stake their positions on these issues. London insurers. The views expressed in this Alert are not 3 APRIL 2005 necessarily those of Kirkpatrick & Lockhart Nicholson Graham LLP or of its clients. KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP The Insurance Coverage practice group at Kirkpatrick & Lockhart Nicholson Graham LLP offers an international policyholder-oriented practice on behalf of Fortune 500 and numerous other policyholder clients. Its lawyers have authored Policyholder’s Guide to the Law of Insurance Coverage and edited the Journal of Insurance Coverage. 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