JUN 8 – 10, 2015
Title Slide
Intro to Captives
www.bermudacaptive.bm
Intro to Captives
Speakers:
Dale Fenwick, President, Sovereign Insurance Services,
LLC
Adam Rekerdres, Vice President, Rekerdres & Sons
Insurance Agency Inc
Chiara Nannini, Associate, Conyers Dill & Pearman
Limited
Moderator:
Peter Willitts , President, Liberty Mutual Management
Bermuda Ltd
Intro to Captives
1.Mid 1980s: Excess Liability market – ACE, XL
2.1960s: Frederic Reiss – Birth of captives in Bermuda
3.1990s: Reinsurance market – Hurricane Andrew
4.New waves of capital
•
2001 response to September 11, 2001
•
2005 response to hurricanes
•
Innovation in Policy Forms, Cell Companies,
Captive Pooling and other specialized
commercial vehicles, such as SPIs and Sidecars
Intro to Captives
A Few Facts from 2013:
Bermuda Captives wrote $48 Billion in premium
They had $59 Billion in capital.
Impressive ?????
Bermuda Insurers had $448 billion in Assets !!!
32 Bermuda re/insurers write captive business
Bermuda is vibrant
Largest Captive Market in the world
Last year there were also:
28 New SPIs
16 Commercial Insurers
10 Long term license
12 agents
7 Managers
5 Brokers
Intro to Captives
An Introduction to Captives
Dale Fenwick CRM, ARM, MBA, CIC
President,
Sovereign Insurance Services, LLC
Intro to Captives
1. Captive Insurance Overview
2. Fronting
3. Risk Transfer and Risk Distribution
4. Captive Feasibility Study
5. Loss Projections
6. Captive Taxes
7. Domicile Selection
8. Advantages & Disadvantages
Intro to Captives
1. What is a Captive
a. A captive insurance company is a legal
entity created for the purpose of
insuring the loss exposures of its
owner(s).
b. A closely held insurance company
whose insurance business is supplied
by and controlled by its owners, and in
which the insured are the beneficiaries.
c. Any insurance company that is owned
and controlled by its policyholders(s).
Why are they called “captives?”
• Fred Reiss
• Ohio – 1950s
• Youngstown Sheet & Tube Company
• Mining operations called “captive” mines
• The insurance subsidiary became another form
of “captive” operation.
• “The policyholder owns the insurance
company; therefore, the insurer is captive to
the policyholder.”
-Fred Reiss
Captive Categories
1. Ownership – Who Owns the Captive?
2. Structure – How is the Captive Owned?
3. Policy – How are the Policies Issued?
Captive Ownership – Who?
1. Who Owns the Captive?
a. Single Owner
1) Single Parent/Pure Captive
2) Economic Family Captive
“Pure” Captive (Single Owner)
Insured
Premiums
Policies
Underwriting
& Investments
Profits
Captive
12
“Economic Family” Captive
Parent
Sub 1
Sub 2
Sub3
Sub 4
Sub 5
Premiums
Sub 6
Sub 7
Captive
Captive Ownership – Who?
b. Multiple Owners
1) Group Captive
2) Association Captive
3) Risk Retention Group
c. “Related” Owners (3rd Party Risk)
1) Agency Captive
2) “Franchisor” Captive
Captive Ownership – How?
2. Ownership Structures
1) Owned Captive
2) Rent-a-Captive
a) Protected Cell Company (Guernsey)
b) Segregated Account Company (BDA)
c) Segregated Portfolio Company (KY)
d) Sponsored Captives (VT)
Rent-A-Captive
CORE
(Owned by Sponsor)
Cell
A
Cell
B
Cell
C
Cell
D
Cell
E
Claims
Premiums
Cell A
Owner
Cell B
Owner
Cell C
Owner
Cell D
Owner
Cell E
Owner
Cell Captive Fees
1. Fixed Annual Fee
2. Variable Fees
a. Percentage of Premium
b. Percentage of Invested Assets
c. Exposure-Based
1. Percentage of Payroll
2. Per Location / Unit
3. Combination (Fixed + Variable)
Captive Policies
3. Policy Structures
1) Direct-Write Captive
2) Fronted Captive
Direct-Write Captive Program
Insured
Captive
Reinsurer
Issues Policy
Example: $1 Million Limit
Retains Primary Layer
Example: First $250,000 of each claim
Provides Excess Reinsurance
Example: 750,000 x 250,000
19
Fronted Captive Program
Insured
Commercial
Insurer (aka Front)
(No Risk)
Captive
Reinsurer
(First 250K)
Commercial
Reinsurer
(750x250)
20
Fronting
Fronting – using one insurance company,
usually a domestic, admitted carrier, to issue
policies that will meet the regulatory and
contractual needs of the captive.
• Captive reinsures the fronting carrier
• Policyholder pays premium to the front
• Front cedes premium designated to
pay “retained” losses to the captive and
purchases “excess” reinsurance from a
commercial reinsurer
Fronting
• Front issues policies and pays losses.
• Front recovers claim payments from the
captive via a reinsurance contract.
• Front provides the use of its license,
name, balance sheet, and services in
exchange for a fronting fee.
• Fronting carrier generally requires
security from the captive to insure
reimbursement for claim payments.
• The front assumes no underwriting risk.
Fronting
When to use a front
•
Licensed (Authorized) Policy
•
Workers Compensation
•
Auto Liability
•
CGL (if required for permits, etc…)
• Rated Paper (AM Best)
What is an Insurance Company?
Court rulings require the “commonly accepted
notion of insurance,” which include, but are not
limited to:
• Sufficiently capitalized (5:1 Surplus Ratio Max)
• Formed for non-tax business reasons
• Premiums are charged at an arms-length rate
• The activities of the company should be
typical of commercial insurance enterprises
• Risk Transfer and Risk Distribution
Risk Transfer
1. Is the Present Value of the Benefit (limit)
greater than the Premium?
Example:
$1 Million Premium for $1 Million Limit
2. Whose Balance Sheet suffers the impact
of a claim?
Risk Transfer
Business Owner(s)
Premiums
Operating
Company
Policies & Claim Payments
Captive
Insurance
Company
Risk Distribution – Pre-2015
Revenue Ruling 2005-40
• 12 Subsidiaries – 12 Policies
• No One Policy > 15% of Premium
Risk Distribution – Pre-2015
Business Owner(s)
OC 2
OC 1
OC 4
OC 3
OC 6
OC 5
OC 7
OC 8
OC 10
OC 9
OC 12
OC 11
Captive
Insurance
Company
Risk Distribution – Post 2014?
Rent-A-Center
• Bermuda captive
• 15 brother-sister companies
• 66% of premium in one of the companies
• Tax Court focused on exposure units not
the number of entities
o 3,000 stores
o 15,000 employees
o 8,000 vehicles
Risk Distribution – Post 2014?
Securitas
•
•
•
•
•
•
Vermont captive
11 brother-sister companies in 2003
4 brother-sister companies in 2004
90% of premium in 4 companies in 2003
90% of premium in one company in 2004
“It is the pooling of exposures that brings about
the risk distribution--who owns the exposures is
not crucial.” - Dr. Neil Doherty
• The captive “was exposed to.” a large pool of
statistically independent risk exposures.”
Step 1:
Feasibility Study
Step 2:
Select Domicile
Step 3:
Form Company
Step 4:
Obtain License
1. Cost of Risk Analysis
a. Analysis of Historic Loss and Exposure Data
b. Retention Selection (Stratification Analysis)
c. Projected Losses
Number of Percent in Cummulative
Loss Interval
Losses
Interval
Percentage
$0 to $25,000
2,372
94.7%
94.7%
$25,000 to $100,000
126
5.0%
99.7%
$100,000 to $250,000
5
0.2%
99.9%
$250,000 to $500,000
2
0.1%
100.0%
$500,000 to $1,000,000
0
0.0%
100.0%
> $1,000,000
0
0.0%
100.0%
Totals
2,505
100.0%
Loss Interval
$0 to $25,000
$25,000 to $100,000
$100,000 to $250,000
$250,000 to $500,000
$500,000 to $1,000,000
> $1,000,000
Losses Percent in Cummulative
($)
Interval
Percentage
4,810,000
45.2%
45.2%
4,200,000
39.4%
84.6%
875,000
8.2%
92.8%
762,000
7.2%
100.0%
0
0.0%
100.0%
0
0.0%
100.0%
Total
Severity
Ultimate
Inflation
Year Incurred Development
Total
Index
($)
Factor
Losses ($)
2010
2011
2012
2013
2014
125,986
469,091
386,550
291,555
357,171
1.00
1.11
1.30
1.57
2.51
125,986
520,691
502,515
457,741
896,449
1.76
1.57
1.41
1.25
1.12
Inflation
Indexed
Losses
221,987
819,568
706,034
574,007
1,004,023
Year
Developed
Employees
& Indexed
(Exposure)
Losses
Loss
Rate
2010
2011
2012
2013
2014
221,987
819,568
706,034
574,007
1,004,023
449
1,532
1,300
1,040
1,777
494
535
543
552
565
Average Loss Rate = $1,220 per Employee
2015 Projected Employees = 589
Projected Losses = 589 x 1,220 = $718,000
1. Cost of Risk Analysis
a. Analysis of Historic Loss and Exposure Data
b. Retention Selection (Stratification Analysis)
c. Projected Losses
2. Administrative (non-Loss) Expenses
a. Domicile Fees (Fixed Costs)
b. Policy-Related Fees (Variable Costs)
c. Taxes
Captive Administrative Costs
Annual Domicile Fees (Fixed Costs)
Captive Management
$10,000 to $50,000
Audit Fees
$10,000 to $50,000
Actuarial Fees
$5,000 to $50,000
Government Fees
$5,000 to $15,000
Legal Fees
$1,000 to $10,000
Meeting Costs
$1,000 to $100,000
Misc.
$5,000 to $20,000
Total
$50,000 to $150,000
Captive Administrative Costs
Policy-Related Fees (Variable Costs)
Fronting
5% to 15%
TPA
2% to 8%
Premium Taxes
2% to 5%
Commissions
2% to 10%
Consulting
2% to 5%
Misc.
1% to 3%
Total
14% to 46%
1. U.S. Federal Income Tax
• 831(a) Tax on underwriting income (>1.2 M)
• 831(b) Tax only on Investment Income (<1.2M)
Note: To be eligible to make the 831(b) election the
entity must be an Insurance Company in the eyes of
the IRS…
Federal Income Tax Comparison
Extreme Example – Zero Losses
Premium
Administrative Expenses
Losses
Underwrting Profit
Investment Income
Net Income
831(a)
1,100,000
100,000
1,000,000
100,000
1,100,000
831(b)
1,100,000
100,000
1,000,000
100,000
1,100,000
Taxable Income
Taxes
After Tax Income
1,100,000
(374,000)
726,000
100,000
(34,000)
1,066,000
1. Federal Income Tax
• 831(a) Tax on underwriting income (>1.2 M)
• 831(b) Tax only on Investment Income (<1.2M)
2. Federal Excise Tax – Offshore Captives
• Direct Premiums (4%)
• Assumed Insurance (1%)
3. Premium Taxes
• Onshore Domiciles = 0% to 0.5%
• Offshore Domiciles = 0%
4. Direct Procurement Taxes
• 5.0% in many states
Captive Premium Tax Rates
Domicile
Arizona
Utah
Oklahoma
Delaware
District of Columbia
Hawaii
Missouri
Vermont
Montana
South Carolina
Tennessee
Nevada
Kentucky
Texas
Direct
Procurement
3.00%
4.25%
6.00%
2.00%
0.00%
4.68%
5.00%
3.00%
2.75%
0.00%
0.00%
3.50%
2.00%
4.85%
Captive
Premium
0.00%
0.00%
0.20%
0.20%
0.25%
0.25%
0.38%
0.38%
0.40%
0.40%
0.40%
0.40%
0.40%
0.50%
Minimum
$5,000
$5,000
$5,000
$5,000
$7,500
$7,500
$7,500
$5,000
$5,000
$5,000
$5,000
$5,000
$7,500 43
1. 5-Year Pro Forma Financial Statement
2. Risk Transfer Analysis
3. Risk Distribution Analysis
4. Non-Tax Business Purpose
5. Captive Ownership Structure
6. Capital Structure
7. Reinsurance Structure
8. Domicile Recommendations
Captive Domicile Selection
1. Domicile – The jurisdiction that issues a
license and is responsible for regulating
the captive insurance company.
Established Domiciles
2014 Captive Activity
Domicile
Bermuda
Cayman
Vermont
Utah
Delaware
Hawaii
Montana
Nevada
South Carolina
Kentucky
DC
Arizona
Jan
841
758
588
343
298
184
150
148
145
128
126
106
New
16
22
16
106
87
15
34
26
20
5
13
Closed
16
21
17
25
52
5
7
9
5
6
6
5
Dec
841
759
587
424
333
194
177
165
160
122
125
114
Growth
0%
0%
0%
24%
12%
5%
18%
11%
10%
-5%
-1%
8%
47
Emerging Domiciles
2014 Captive Activity
Domicile
Jan
New
Closed
Dec
Growth
North Carolina
4
49
0
53
1,225%
Tennessee
29
43
0
72
148%
Oklahoma
10
37
0
47
370%
Missouri
35
12
0
47
34%
Texas
0
12
0
12
NM
Connecticut
4
3
0
7
75%
New Jersey
14
3
0
17
21%
Total
96
159
0
255
166%
1. Capitalization required
2. Surplus required
3. Premium Taxes
4. Ownership structure
5. Reserving requirements
6. Regulatory environment
7. Meeting requirements
8. Investment regulations
9. Geographic convenience
10. Offshore v. onshore
Step 1: Feasibility Study - 30 to 90 Days
$20,000 to $30,000
Step 2: Select Domicile - 0 to 10 Days
Step 3: Form Company – 10 to 30 Days
$5,000 to $10,000
Step 4: Obtain License - 30 to 60 Days
$10,000 to $20,000
Use a Rent-a-Captive facility.
Still need a Feasibility Study.
10 to 30 days from post-Feasibility Study decision
1. Reduced Long-term Total Cost of Risk
2. Stabilize Premium & Availability
3. Greater Control Over Claims
4. Tailored / Increased Coverage
5. Investment Income
6. Direct Access to Reinsurance Markets
1. Risk of Loss
2. Initial Capital Investment
3. Formation Time
4. Runoff Time
5. Long-term Commitment
1. >$1 Million Premium
2. “Good” Loss Ratios
3. “Good” Risk Management Programs
4. Risk Tolerance
5. Predictable Losses
6. Limited Choices for Coverage
7. Funds for Capitalization
8. Long-Term Outlook
Working Example
Mr. Adam Rekerdres, MBA, CIC, ACI
Captive Benefits
Cost
Coverage
Capacity
Control
• Benefit of positive loss experience
• Reinsurance
• Cost Allocation
• Reduced volatility
• Tailored
• Uninsured Risks
• DIC
• Access to Reinsurance Market
• Good faith to primary insurers
• Claims
• Service Provider
• Focused Risk Management
• Enhanced Loss Control & Prevention
Captive Considerations
Claims
Costs
Regulatory
Fronting
• Impact of adverse claims
experience
• Start up costs
• Operating costs
• Capitalization costs
• Some countries don’t allow
non-admitted insurance
• Special non-admitted taxes
• An additional cost
• Collateral requirement
• Financial information
Real World Examples
1. Corporate Visibility
2. Management Attention
3. Market Flexibility
Real World Examples
Before…
• Global properties “insured” internally
Assets = $75mil
After
• Global properties insured by captive
Assets = $125mil
Real World Examples
Other Benefits…
• formalized claim history
• formalized history of risk improvements
• quick notifications from local mangers
Real World Examples
Management Attention to Claims
“Turn on the lights and the cockroaches run”
• How quickly can you get the director’s attention when the
captive insurance company is running a loss?
Real World Examples
Market Flexibility
Have the flexibility to assume more risk when the
market is hard and less risk when the market is soft.
Real World Examples
Ocean Marine Cargo
($35mil Building, $30mil Vessel,
no limit #)
Global Liability Excess
Property Program $60,000,000
Global Liability
Various Deductibles
Various Deductibles
Real World Examples
Ocean Marine Cargo
($35mil Building, $30mil Vessel,
no limit #)
Global Liability Excess
Property Program $60,000,000
Captive Insures US$2mil
Deductible
Captive Self Insures
Captive Insures $1mil
Deductible
Real World Examples
Ocean Marine Cargo
Captive takes $5mil x of $10mil
($35mil Building, $30mil Vessel,
no limit #)
Global Liability Excess
Property Program $60,000,000
Captive Insures US$2mil
Deductible
Captive Self Insures
Captive Insures $1mil
Deductible
Real World Examples
Before
After
Place Title Here
Overview Legal & Governance Issues
Chiara T. Nannini
Conyers Dill & Pearman Limited
Key Governing Statutes
1. Companies Act 1981
2. Insurance Act 1978
- Insurance Accounts Regulations 1980
- Insurance Returns & Solvency Regulations
1980 (together, the “Regulations”)
3. Segregated Accounts Companies Act 2000
(for segregated account companies)
Insurance Act – License Classifications
1. General Business
a. Classes 1, 2 & 3 – Captives
b. Classes 3A, 3B, 4 – Commercial
2. Long Term Business (annuity, life accident & health)
a. Classes A&B – Captives
b. Classes C, D, E – Commercial
3. SPIs (insurer fully funds liabilities through a debt
issuance or some other approved financing mechanism)
Segregated Accounts
Any general business or long-term insurer wishing
to operate segregated accounts may apply to be
registered under the Segregated Accounts
Companies Act 2000 (the “SAC Act”).
Process to Establish a Company in Bermuda
1. Application to incorporation / amalgamate / merge/ continue into
Bermuda / register under the SAC Act is made to the Registrar of
Companies.
2. Beneficial owners (10%+ beneficial owners) are vetted by the
lawyers and approved by the Bermuda Monetary Authority (in
accordance with the Exchange Control Act 1972).
3. Application to incorporate can be made separately from the
insurance license application (before or after), but is often made in
tandem.
4. For amalgamations / mergers / continuances / SAC registrations,
completion of the transfer may not occur until the BMA provides its
no-objection to the Registrar of Companies.
Registration under the Insurance Act
Pre-Licensing Considerations
1. Decisions made to form captive / re-domicile
into Bermuda
2. Consideration given to class of captive
3. Selection of service providers:
a. Insurance managers
b. Lawyers
c.
Auditors
d. Banker
e. Actuary / Loss Reserve Specialist
Registration under the Insurance Act
Pre-Licensing Documentation
Consists of:
1.
Business Plan
2.
5 year pro-forma financials (Balance Sheet and
Income Statement)
3.
Pre-Incorporation Form (for registration as an insurer)
4.
Parent company financial statements
5.
Resumes (senior management / directors)
6.
Acceptance letters for service providers
7.
SAC Form 1 (if applying for SAC registration)
Registration under the Insurance Act
Pre-Licensing Application
1. Application filed with BMA by 5:00 p.m. on Monday prior
to Assessment and Licensing Committee consideration
at their weekly meeting the following Friday.
2. Four possible outcomes:
a. Approved
b. Approved, but subject to [x]
c.
Deferred
d. Declined
Organising the Company
(A) Meetings to be held:
a. Provisional Meeting
b. Statutory Meeting
c. First Board Meeting
(B) Items to be approved:
a. Approval of service providers (auditors, insurance manager,
principal representative, resident representative, approved
actuary / loss reserve specialist etc.)
b. Bank account opening
c.
Bye-laws
Formal Insurance License Application
•
Once required capital is paid into the company,
Form 1B (registration application) may be
submitted to the BMA.
•
Insurance license may be issued in three days if
application complete.
•
Captive can start writing business once certificate
of registration has been issued.
Insurance Act – Main Provisions
1. Minimum Paid – Up Share Capital
a. $120,000 for Classes 1, 2 & 3
b. $120,000 for Class A
c. $250,000 for Class B
2. Principal Representative and Principal Office / SAC
Representative
a. All Bermuda insurers are required to
maintain a principal office and appoint a
principal representative resident in Bermuda
(usually the insurance manager).
b. SACs must appoint a SAC representative
resident in Bermuda.
Insurance Act – Main Provisions
3.
Independent Approved Auditor
All Bermuda Insurers are required to appoint an independent
approved auditor who will audit and report on the insurer’s statutory
financial
statements
and
statutory
financial
returns.
4.
Actuary / Loss Reserve Specialist (LRS)
• Class A& B insurers must appoint an approved actuary – must
be an individual – responsible for preparing the actuary’s
certificate filed with the annual statutory return.
• Class 2 and 3 insurers (and Class 1s if required by the BMA)
must appoint an approved loss reserve specialist – must be an
individual- responsible for preparing the LRS opinion in respect
of company’s loss and loss expense provisions in its annual
statutory return.
Insurance Act – Main Provisions
5.
Statutory Financial Statements and Returns
a.
Every insurer must prepare annual audited statutory financial statements
and submit to the BMA with its statutory financial return.
b.
Rules and guidance for preparation are set out in the Regulations.
c.
Statutory financial statements not prepared in accordance with GAAP.
d.
The statutory financial statements and statutory return are not public
documents.
An insurer is also required to submit, at the same time as it files its statutory
financial statements, a declaration of compliance declaring whether or not that
insurer has, with respect to the preceding financial year, (i) complied with the
minimum criteria applicable to it, and (ii) compiled with its minimum solvency
margin and enhanced capital requirement (if applicable) as at its financial yearend.
Insurance Act – Main Provisions
6.
Minimum Solvency Margin
An insurer’s statutory assets must exceed its statutory
liabilities by an amount greater than its prescribed minimum
solvency margin.
7.
Minimum Liquidity Ratio (MLR)
Every general business insurer must maintain the value of
its relevant assets at not less than 75% of the amount of its
relevant liabilities.
Insurance Act – Main Provisions
8.
9.
Restrictions on Dividends and Distributions
a.
A company may not declare or pay a dividend or
distribution if it is in breach of its MSM (or MLR for
general business) of if declaration or payment would
cause such as breach.
b.
Any company that fails to meet its MSM (or MLR for
general business) on the last day of any financial year
is prohibited from declaring or paying any dividends
during the next financial year without BMA consent.
Restrictions on Reduction of Capital
a.
No Bermuda insurer may reduce its total statutory
capital (as per previous year’s financial statements) by
15% or more without prior BMA approval.
Insurance Act – Main Provisions
10. Insurance Code of Conduct
All Bermuda insurers must comply with the Insurance Code
of Conduct.
-
Designed
to
ensure
sound
corporate
governance, risk management and internal
controls are implemented.
-
Captive insurers should be mindful of the
proportionality principle in establishing a sound
corporate governance, risk management and
internal controls framework.
Captive Governance
What is Corporate Governance?
• A system of rules, practices and processes by which a company is
directed and controlled.
• Per the Insurance Code of Conduct, every insurer must establish and
maintain a sound corporate governance framework. The framework
should have regard for international best practice on effective corporate
governance. Corporate governance includes principles on corporate
discipline, accountability, responsibility, compliance and oversight.
• Every insurer is required to implement such corporate governance
policies and processes as the BMA deems appropriate given the nature,
size, complexity and risk profile of the company in question. The insurer
is also required to appoint such number of non-executive directors as it
considers appropriate having regard to its circumstances and the nature
and scale of its operations.
The Role of the Directors
•
Directors manage the affairs of the company – “mind and
will”.
•
Appointed by the shareholder(s) on an annual basis.
•
Powers generally derive from the constitutional documents of
a company e.g. bye-laws.
•
Cannot act outside powers – a company may be able to
recover from its directors any loss to the company arising
from acts of the directors which constitute a breach of their
duties to the company.
•
Duties are generally owed to the company, not individual
shareholders.
Board Meetings
•
Notice – generally, any director may call a Board meeting at any time
on reasonable notice.
•
Quorum – usually 2.
•
Voting - one man/one vote.
- resolutions are passed by simple majority.
- if allowed in the bye-laws, the chairman may cast a tie-breaker vote.
•
Personal Interests – whenever a director has a personal interest in
the business of the Company, he must declare it to his co-directors at
the first board meeting where the matter is discussed.
•
Written Consents – anything done at a Board meeting can be done
by the unanimous written consent of the directors (often called a
UWR).
Directors Duties
Fiduciary Duties
• A duty to act in good faith in the best interests of the company (and
not for any collateral purpose).
• A duty to exercise powers for a proper purpose.
• A director must not put himself in a position where there is an
actual or potential conflict between his personal interest and his
duty to the company.
• A director must not take a personal profit from opportunities that
result from his directorship.
Directors Duties
Duty of Skill and Care
• A director must exercise the care, diligence and skill that a
reasonably prudent person would exercise in comparable
circumstances.
• A director must diligently attend to the affairs of the company,
but he is not bound to give continuous attention to the affairs.
• A director is entitled to rely on a subordinate put in a position
of charge for the express purpose of attending the detail of
management. However, directors cannot absolve themselves
entirely of their responsibility by delegation to others.
Questions?
DaleFenwick@Sovereign.ky
Chiara.Nannini@conyersdill.com
adam@reksons.com
Peter.willitts@libertybermuda.com