BankServe Insurance Services Limited
Latham House, 16 Minories, London, EC3N 1AX
Tel: 020 7480 0288
Fax:
020 7374 5909
9th May 2002
AN OPINION ON THE FEASIBILITY OF
THE PROSPECTIVE PROTOCOL TO
THE ATHENS CONVENTION BEING MET
Guarantees for Liabilities to Passengers for injury and death, except when caused by
terrorism
Possible Solutions
There appears to be just two alternative solutions for owners and operators of passenger
vessels, predominantly cruise ships and ferries, to meet the prospective protocol to the Athens
Convention. These alternatives can be categorised as the ‘Expensive Solution’ and the
‘Cheaper Solution’.

The Expensive Solution entails establishing a third party liability insurance covering just
the risks laid down under the protocol, accepting direct action from claimants to the
statutory limit. This insurance would not be reliant upon P&I club cover and would
automatically absolve the P&I clubs from covering passenger liabilities under their double
insurance rule.
Establishing a new insurance to take just one of the liability risks, otherwise covered by the
Protection & Indemnity (P&I) clubs, will be very expensive. The reason centres on the
handling and processing the many attrition claims from the ground up involving serious
administrative and claims handling costs, as well as the legal costs. This and the
exceedingly high levels of specific reinsurance required to meet a catastrophic loss may
require the setting up of a new dedicated insurance company that could run foul of US anti
trust laws and EU commissioners at DG COMP, formerly DGIV.
Any reduction in P&I club calls from the exclusion of passenger liabilities will be
insignificant when compared to the cost of such insurance.

The Cheaper Solution, and more sensible solution, is to make full use of the existing first
party indemnity cover for passenger liabilities provided by the P&I clubs and top it with a
Difference in Conditions insurance. The Difference in Conditions insurance could be
designed to enhance the P&I clubs’ cover to the required third party liability cover,
accepting direct action and able to guarantee payment of claims to the limits insured.
This solution emulates the precedent set by the guarantors specially established to enable
shipowners to obtain Certificates of Financial Responsibility (COFRs) from the “US Coast
Guard” (USCG) under the “US Oil Pollution Act 1990” (OPA’90).
As under the COFR precedent, this solution requires a degree of co-operation by the P&I
clubs. Such co-operation must include prior advice of cancellation and any reservations, or
qualifications, of P&I club cover in sufficient time for the Difference in Conditions cover
to be cancelled and guarantees withdrawn.
The Precedent
The precedent in using a Difference in Conditions insurance to upgrade the P&I clubs' first
party indemnity terms of cover to that required arose from the introduction of OPA'90.
Regulated by the USCG, OPA’90 requires all ships trading within the US Exclusive Economic
Group Member
Zone to have a COFR that guarantees payment of oil pollution liabilities up to the statutory
limits.
Despite the strongest objections from the “International Group of P&I clubs” (IG) against
COFRs, the USCG began enforcing the COFR requirement from December 1994. The
amounts having to be guaranteed were, and remain, the OPA'90 statutory limits for pollution
liabilities, being $900 per gross ton for a non-tanker and $1500 per gross ton for a tanker.
Under this formula the highest guarantee issued by an OPA Guarantor is $396,000,000 on M/T
Jahre Viking.
In issuing COFRs, the USCG accept letters of credit, bank guarantees, surety bonds and
insurance solutions in the form of a 'Difference in Conditions Insurance furnished as Other
Evidence of Financial Responsibility'. (See Appendix 1 COFR DIC form attached)
Some tanker fleets got their ship mortgagees to issue LOCs or bank guarantees on their behalf,
fleets owned by the oil majors provided their own guarantees either through their captive
insurers or by other means acceptable to the USCG. The majority of shipowners used the
insurance solution obtainable from the specially established OPA Guarantors of which the first
was First Line, followed by Shoreline.
First Line, renamed in 1996 the Shipowners’ Insurance Guarantee Company (SIGCo) when the
UK P&I Club, Gard Club and The Steamship Mutual P&I Club became indirect shareholders
through trustees, and Shoreline are wholly secured by reinsurers at Lloyds, London and the
Bermuda markets. In 1996 First Line, always the bigger of the two, generated $40 million of
income and to my knowledge has only had one loss of $400,000. The premiums of both SIGCo
(First Line) and Shoreline have subsequently reduced to the extent that the combined income
in 2001 was $32million in guaranteeing 78% of all COFRs issued by the USCG. (see
Appendix 2 OPA Guarantors attached)
The Inadequacy of the current IG Reinsurance Programme
The difficulty is not so much the guaranty requirement but the statutory amount at risk per
passenger to give a possible maximum loss (PML). This will be calculated as the total loss of
life resulting from a collision between two large passenger ships, say 7,000 passengers. A
protocol requirement of SDRs350,000 to SDRs500,000 per passenger results in a PML of
$3.5billion to $4.9billion from a single incident.
PMLs of these magnitudes not only breach the P&I clubs absolute limits of cover, any one
accident, but will exceed the IG pool reinsurance limit of US$2.03 billion for all liabilities.
Other liabilities include crew, collision in excess of amounts covered under the Hull &
Machinery insurance, removal of wreck. Pollution liabilities have a separate limit under IG
pool reinsurance programme to $1billion. (see IG pool R/I programme on IMO website)
The current IG pool reinsurance programme is clearly inadequate to meet the statutory
passenger liability limits now being contemplated under the prospective protocol to the Athens
Convention. Indeed, the pool reinsurance programme is already inadequate in protecting IG
club members against risks of Catastrophe Calls resulting from an Overspill Claim for
passenger liabilities that could arise in a jurisdiction that is not a signatory to the existing
Athens Convention. This particularly applies to the United States of America from where the
majority of cruise vessels operate.
Prerequisite for the Cheaper Solution
The limits under the IG pool reinsurance programme will have to be more than doubled.
Preferably passenger liabilities might be removed from the general IG liability programme and
be reinsured separately to US$4.03billion, in the same way that pollution liabilities are
separately reinsured to US$1billion.
Group Member
A separate reinsurance programme for passenger liabilities will benefit the majority of club
members who do not operate passenger ships (95% according to the IG) three ways:

Firstly, their club calls will no longer incorporate the reinsurance costs for passenger
liabilities and, as a result, their P&I premiums (or Estimated Total Calls) should reduce,
and

Secondly, their risk of having to pay Catastrophe Calls, to meet an Overspill Claim, will
become insignificant and consequently their capital bases will cease to be exposed, through
mutuality, to the vicissitudes of a sector in which they do not operate, nor are compatible
with.

Finally, some clubs have bought insurance against Overspill Claims, where the
predominant risk is passenger liabilities in the USA. Reinsuring passenger liabilities
separately to the PML, under the IG pool reinsurance programme, will dispense with the
need for this insurance, eliminating this cost and, coincidentally, release capacity for the
separate passenger liability reinsurance.
The cost of the passenger liability reinsurance programme, when separated out from the
general liability reinsurance will have to be met by members operating passenger vessels,
essentially cruise ships and ferries.
What will the Cheaper Solution cost?
This is a very difficult question best answered by P&I club managers, or the International
Group, and even they will have to test the market. For anyone outside the inner P&I club circle
the answer can only be a calculated guess derived from the following:
1. The premium cost under the IG’s general pool reinsurance programme covering all
liabilities, in excess of the club and pool retentions.
2. From which, estimate the premium on the passenger liability risk and add an estimated cost
of insuring the first $30 million of club and pool retentions.
3. Next, estimate the additional premium for extending passenger liability reinsurance from
$2.03 billion to the PML ($3.5 billion to $4.9 billion).
4. Add the cost of the Difference in Conditions insurance and the guaranty costs of the
guarantee entities, as per SIGCo and Shoreline for OPA’90 COFRs, (from zero up to the
PML).
5. This will give a crude estimate of the additional cost to be paid for by all passenger vessel
operators. This estimate takes no account of P&I deductibles and the need for reinstatement
provisions required on an extended IG pool R/I programme.
To put this crude estimate into perspective and in recognition of operators passing this cost
onto passengers through ticket pricing, the estimated cost of providing insurance to meet the
proposed protocol should be divided by the number of ferry and cruise tickets sold per annum
by operators, who:

Are recognised by guarantors as being responsible first class operators of ferries or cruise
ships, and

Are insured on terms, conditions and underwriting security acceptable to guarantors, and

Have to comply with IMO’s proposed protocol. This particularly depends upon whether the
US finds a way of becoming a signatory.
Group Member
Crude estimates
I would use the following guesstimates for the items listed 1 to 5 above:
1. $176 million, excludes US voyage additional premiums and the premium for the excess
War P&I cover.
2. I would estimate $70 million for passenger liabilities plus $30 million assuming sizeable
secured deductibles.
3. Assuming a rate on line of 2.5%, I estimate this premium at $50 million.
4. On the basis of the SIGCo and Shoreline’s combined annual premium income being $32
million for guaranteeing 78% of all COFRs, I estimate $150 million.
5. $300 million is my crude estimate of the total cost to operators of passenger ships. The
initial cost in the first year might be higher.
Available statistics show that almost 10 million cruise tickets are sold per annum. This number
is probably incorporated within the statistics produced by ShipPax which show that
675,385,106 passengers boarded passenger ships world wide during the year 2000. (see ferry
statistics on IMO website <http://folk.uio.no/erikro/WWW/corrgr/index.html#ins>).
Assuming 400 million passengers embarked on ferries and cruise ships that meet the
guarantors’ essential criteria; the average additional cost per ticket should only be $0.75.
Obviously the cost to be born by a passenger taking a 7 day cruise should be higher than for a
ferry passenger. Say $0.75 per day on a cruise ship and $0.65 for a ferry trip.
If the total acceptable passenger figure is only 300 million, because the US declines to ratify
the protocol, the average additional cost per ticket goes up to $1 per ticket.
Conclusions
Although the above calculations are made on very crude estimates, the projected cost per
passenger ticket under the Cheaper Solution is relatively modest. The Expensive Solution is
equally viable but would cost considerably more, perhaps double.
P&I club managers’ instinctive inclination to resist this proposed protocol is based on their fear
of what further elements of P&I cover will have to be guaranteed next, further undermining the
concepts of mutuality and protection and indemnity.
However, any amendment to the IG pool reinsurance programme that separates out passenger
liabilities will clearly benefit 95% of all P&I club members. The remaining 5% of passenger
vessel operators might hope procrastination tests the resolve of the IMO and defers
implementation. The risk is of an extended public debate making bankers more concerned
about the maritime lien and tort action risks associated with a cruise ship catastrophe and
reduce their commitment to passenger ships; also the 95% majority of club members may
conclude that they are subsidising the American cruise business.
The IMO will need to ratify the protocol before expecting any pragmatic response from the
International Group. Only when faced with the inevitable will, I suspect, the P&I club Boards
of Directors instruct club managers to assist with the implementation of the Cheaper Solution. I
do not see those clubs that accept cruise ships readily abandon these operator members nor the
substantial call, or premium, income they generate.
Yours sincerely
Graham Barnes
Group Member
Postscript
Bankers’ Interests
Shipping banks have current loans outstanding on cruise ships and large ferries of around
$12billion and are committed to lending a further $10billion on cruise vessels either ordered or
under construction.
The market for cruise ships is predominantly in North America with 71% of the total. Most
cruise ships operating in the North American market use US ports to embark and disembark
passengers, or transport American passengers to offshore embarkation points. Either way
American law applies.
The United States of America is not a signatory to the current Athens Convention, indeed it has
not ratified any shipowners’ limitation of liability convention, on the basis of why should
shipowners’ have the benefit of limited liability? However, in taking this decision the US has
forfeited certainty of any payment from the P&I clubs.
In the event of a catastrophe involving a cruise ship, the US courts will be unconstrained in
determining a cruise line’s liabilities to passengers. Should large numbers of passengers be
involved, liabilities awarded against the cruise line will certainly exceed the current Athens
Convention limit and probably exceed the passenger limit being proposed in this new protocol.
Consequently, total liabilities could so easily exceed the $2.03billion limit reinsured under the
current IG pool reinsurance programme, causing an Overspill Claim to be met by all IG club
members.
A threatened Overspill Claim involving cruise ship passengers will force the clubs to consider
the interests of the majority of their members and, in my opinion, the respective club is likely
to decline use of the Omnibus rule to waive the paramount “pay to be paid” rule. This means
the cruise line found responsible must pay the full liabilities first before seeking recovery from
their P&I club. This raises the following questions:
1. Would the banks fund it? Our BankServe advice would be no. Not without a guarantee of
repayment from the club, which the club almost certainly will not give.
2. What cruise lines could pay without funding?
3. What if the cruise line found responsible and liable cannot pay?
Clearly, the current limits of liability under the Athens Convention are now wholly
unacceptable which is why this new protocol is being tabled. The concern is that the US
appears to be adopting the stance of an observer, rather than an active participant, in the
discussions on these new proposals.
If a cruise line cannot pay it’s full liabilities, it will not just be bad for the cruise line.
The ship mortgage banks will have non performing loans and face serious bad debts caused by
a plaintiffs’ tort action against the responsible ship to prime the mortgage. Current P&I club
cover will cease to be acceptable by the US authorities.
It seems that neither the IG nor the US authorities are willing to confront this issue in the hope
of it not happening. As Express Samina, Estonia, Herald of Free Enterprise, Exxon Valdez that
brought about OPA’90 and September 11th have proved, there is an accident waiting to happen
with a lot of money at stake.
Graham Barnes
Group Member
Appendix 1
DEPARTMENT OF TRANSPORTATION
U.S. COAST GUARD
GUARANTY BASED ON DIFFERENCE IN CONDITIONS INSURANCE, FURNISHED
AS OTHER EVIDENCE OF FINANCIAL RESPONSIBILITY UNDER THE OIL
POLLUTION ACT OF 1990 AND THE COMPREHENSIVE ENVIRONMENTAL
RESPONSE COMPENSATION, AND LIABILITY ACT, AS AMENDED
I.
DEFINITIONS
“Acts” means OPA and CERCLA
“Amount of Financial Responsibility” means with respect to a Covered Vessel for each separate Incident
an amount which in the aggregate for all owners, operators and demise charterers of a Covered Vessel,
individually and in combination, shall not exceed –
(i)
for Covered Liability under OPA, the amount determined under Part I of the Applicable
Amount Table below, or
(ii)
for Covered Liability under CERCLA the amount determined under Part II of the Applicable
amount Table below, or
(iii)
for Covered Liability under OPA and CERCLA the sum of the amounts determined under Part I
and Part II of the Applicable Amount Table below.
Provided, however that if Guarantor knew or should have know that the official, applicable tonnage
certificate used to determine the amounts under the Applicable Amount Table below was incorrect, then
the amount of Financial Responsibility shall be calculated using the correct tonnage.
“Center” means the Coast Guard National Pollution Funds Center.
“CERCLA” means Title I of the Comprehensive Environmental Response, Compensation and Liability
Act, as amended (42 U.S.C. “9601-9626).
“Claim” means a request, made in writing by a Claimant for a sum certain for compensation for a
Covered Liability.
“Claimant” has the meaning as defined in section 1001(4) of OPA or section 101(5) of CERCLA,
“Covered Liability” means only the liability of the Covered Party to a Claimant for removal costs and damages under section 1002 of OPA, but limited by section 1004(a) of OPA
Costs and damages under section 107(a)(I) of CERCLA but limited by sections 107(c) (I)(A) and (b), or
costs and damages under both (i) and (ii) above
Group Member
and such costs and damages are caused by a discharge or threatened discharge from any Covered Vessel; or
result from an Incident involving a Covered Vessel in which the discharge or threatened discharge of oil
is not from a Covered Vessel if, and only if, the responsible party for a vessel or facility from which oil is
discharged or threatened discharge and the resulting removal costs and damages were caused solely by
an act or omission of the Covered Party acting as a third party as described in OPA section 1003(a) (3) or
were caused solely by such an act or omission in combination with an act of God or an act of War of a
Covered Party acting as a third party as described in OPA section 1003(a)(3).
“Covered Party” means the vessel owners, operators and demise charterers of a Covered Vessel:
“Covered Vessel” means each vessel named in or added to the schedules below.
“Effective Date” means, for each Covered Vessel, the date the vessel is named in or added to the
schedules below.
“Incident” means any occurrence or series of occurrences having the same origin, involving a Covered
Vessel, resulting in the discharge or substantial threat of discharge of oil (as defined by section 1001(23)
of OPA) into or upon the navigable waters or adjoining shorelines of the United Stated or the exclusive
economic zone of the United States and means any occurrence or series of occurrences having the same
origin involving a Covered Vessel resulting in the release or threatened release of a hazardous substance
(as defined by section 101(14) of CERCLA) into or upon the navigable waters of the United States, the
adjoining shorelines, or into or upon the waters of the Exclusive Economic Zone of the United States.
One or more events or causes resulting in a discharge or substantial threat of a discharge of oil or a
release of threatened release of a hazardous substance, from a Covered Vessel, constitutes one Incident.
“Limit Guaranteed” means the Amount of Financial Responsibility less all amounts paid to Claimants for
Covered Liabilities (including liabilities to contractors conducting removal operations) by or on behalf of
the Covered Party, including payments by a Covered Party’s marine insurer, if any (the combination) and
less all amounts paid towards such costs and damages by, or on behalf of, any third party treated as the
responsible party pursuant to OPA section 1002(d)(1)
“OPA” means Title 1 of the Oil Pollution act of 1990 (33 U.S.C. “270-2719).
“Termination Date” means, for each Covered Vessel, the earlier of (I) the date 30 days after the date of
receipt by the Center of written notice that Guarantor has elected to terminate this Guaranty with respect
to such Covered Vessel and
has so far notified the vessel operator identified on the schedule below or (ii) the date of receipt by the
Centre if written notice that such covered Vessel is the subject of a guaranty other than this guaranty.
II.
GUARANTY BASED ON DIFFERENCE IN CONDITIONS
INSURANCE
This Guaranty, subject to the provisions herein is provided to the Coast Guard on the basis of a
difference in conditions insurance contract with the Covered Party.
The undersigned guarantor (“Guarantor”) hereby certifies to the United States Coast Guard that the
Covered Liabilities are guaranteed by Guarantor up to, but not exceeding the Limit Guaranteed.
Group Member
THE AMOUNT AND SCOPE OF THE GUARANTY HEREBY PROVIDED BY GUARANTOR IS
NOT CONDITIONED OR DEPENDENT IN ANY WAY UPON THE EXISTENCE OF ANY
CONTRACT, AGREEMENT, OR UNDERSTANDING BETWEEN THE COVERED PARTY AND
GUARANTOR, OR BETWEEN THE COVERED PARTY AND A MARINE INSURER, IF ANY.
Guarantor consents to be sued directly with respect to any claim, including any Claim by right of
subrogation against the Covered Party. In any direct action, Guarantor’s maximum liability per Covered
Vessel per Incident shall not exceed the Limit Guaranteed in respect of such Incident.
This Guaranty shall be applicable only to Incidents occurring on or after the effective Date and before the
Termination Date of this Guaranty and shall be applicable only to Claims under section 1002 of OPA or
section 107(a)(1) of CERCLA, or both involving a Covered Vessel. Termination of this Guaranty as to
any Covered Vessel shall not affect the liability of the Guarantor in connection with an Incident
occurring prior to the Termination Date.
Guarantor’s obligations hereunder with respect to any one Incident shall be reduced by all payments of
succession of payments to one or more Claimants (including contractors responding to or conducting
removal and/or clean up operations on behalf of the Covered Party), made by or on behalf of(a)
the Covered Party (the total of all amounts paid by or on behalf of owners, operators and demise
charters of the Covered Vessel, individually and in combination), including payments by the
Covered Party’s marine insurer, if any.
(b)
The Guarantor; and
(c)
Any third party established as the responsible party pursuant to OPA section 1002(d)(I)
Guarantor’s obligation hereunder with respect to any one Incident shall be satisfied in full and the
Guarantor shall have no further obligation hereunder with respect to such Incident when the total
amounts paid to all Claimants (including contractors responding to or conducting removal operations on
behalf of the Covered Party) by or on behalf of the Covered Party (including payments by a Covered
Party’s marine insurer, if any) by or on behalf of the Guarantor and by or on behalf of any third party
established as the responsible party pursuant to OPA section 1002 (d)(I) equal or exceed the Amount of
Financial Responsibility.
This Guaranty is for the purpose of evidencing financial responsibility under the acts, separately at the
levels in effect at the time of the Incident(s) giving rise to Claims. This Guaranty shall be null and void
with respect to any claims for liability brought or initiated under the law statute other than section 1002
of OPA or section 107(a)(I) or CERCLA. Nothing in this Guaranty shall impose liability on the
Guarantor with respect of an Incident for damages or costs which exceed, in the aggregate, the lesser of
(I) the Limit Guarantied, or (ii) the Covered Liability.
III.
DEFENSES
Guarantor may invoke the following rights and defenses in any direct action:
(1)
A defense that the Incident was caused by the wilful misconduct of the owners, operators or
demise charterers of a Covered Vessel.
(2)
Any defense that the owners, operators or demise charterers of a Covered Vessel may raise
under the Acts
(3)
A defense that the amount of a Claim or Claims, filed in any action on any court or other
proceeding that, in the aggregate, exceeds the Limit Guaranteed with respect to an Incident.
(4)
A defence that the Claim is not one made under either of the Acts
Group Member
Additional defenses not enumerated above that may be available to the Guarantor against the Covered
Party arising from a contract, if any, pursuant to which the Guaranty is provided may not be invoked by
Guarantor against a Claimant in any direct action by a Claimant.
IV.
AGENT FOR SERVICE OF PROCESS
CT Corporation
With offices at
1025 Vermont Avenue NW
Washington, DC 20005
Is designated as Guarantor’s agent in the United States only: (I) for service of process for a Claim or suit
brought or maintained pursuant to the acts, and (2) for receipt of notices of designation and presentation
of Claims under the Act. If the designated agent cannot be served due to death, disability, or
unavailability, the Director, Coast Guard National Pollution Funds Centre, is the agent of Guarantor only
for these purposes. Agent is not authorised to accept or receive service of process on behalf of Guarantor
with respect to any claim or suit brought or initiated pursuant to any law or statute other than the Acts.
V.
ADDITION OF VESSELS
If, during the currency of this Guaranty, a covered Party requests that an additional vessel be made
subject to this Guaranty and if Guarantor accedes to that request and so notifies the Center, then that
vessel is considered included in the schedules below as a Covered Vessel.
VI.
GUARANTORS
No more than one Guarantor (including lead underwriters) may execute this Guaranty
This Guaranty is established, maintained in accordance with and governed by 33 CFR part 138
Effective date of coverage for vessels named in this guaranty:
28 December 1996
(day/month/year)
The Shipowners Insurance & Guaranty Company Ltd.
55 Par-la-Ville Road, Hamilton, HMLX, Bermuda
(Name of Guarantor)
Group Member
APPLICABLE AMOUNT TABLE
Part I. Applicable Amount Under the Oil Pollution Act of 1990
VESSEL TYPE
Tank Vessel ¹
VESSEL’S GROSS TONS
APPLICABLE AMOUNT
Over 300 gross tons ² but not to
exceed 3,000 gross tons
The greater f $2,000,000 or $1,200
per gross ton
Over 3,000 gross tons
The greater of $10,000,000 or
$12,00 per gross ton
Over 300 gross tons²
The greater of $500,000 or $600 per
gross ton
Tank Vessel ¹
Vessel other than a Tank Vessel
This minimum gross ton limit does not apply to any vessel using the waters of the US Exclusive economic zone to
tranship or lighter oil destined for a place subject to the jurisdiction of the United states (as specified in 33 CFR
138.12(a)(I))
Part II. Applicable Amount Under the Comprehensive Environmental Response,
Compensation and Liability act as amended.
VESSEL TYPE
APPLICABLE AMOUNT
Vessel over 300 gross tons carrying hazardous
substance as cargo
The greater of $5,000,000 or $200 per gross ton
Any other vessel over 300 gross tons
The greater of $500,000 or $300 per gross ton
Part III.
Total Applicable Amount = Maximum applicable amount calculated under Part I of this Table
plus maximum applicable amount calculated under Part II of this Table.
¹
Except a tank vessel on which no liquid hazardous material in bulk is being carried as cargo or cargo residue, and on
which the only oil carried as cargo or cargo residue is animal fat or a vegetable oil, as those terms are used in section
2 of the Edible Oil regulatory Reforms Act (P.L. 104-55)
²
Except a tank vessel on which no liquid hazardous material in bulk is being carried as cargo or as cargo
residue and on which the only oil carried as cargo or cargo residue is animal fat or a vegetable oil as
those terms are used in section 2 of the Edible Oil regulatory Reforms Act (P.L. 104-55)
Group Member
Appendix 2
OPA GUARANTORS
Statistics as at 31st March 2001
Method of Guaranty:
Insurance
78%
Financial Guaranty
12%
Self-Insurance
9%
Surety Bond
1%
Based on number of Guaranties issued:
Insurers providing C.O.F.R. Guaranty (All vessels):
SIGCo
64%
Shoreline
25%
All others
11 %
Insurers providing C.O.F.R. Guaranty (Dry Cargo vessels):
SIGCo
65%
Shoreline
23%
All others
12%
Insurers providing C.O.F.R. Guaranty (Tank vessels):
SIGCo
62%
Shoreline
32%
All others
6%
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