Part VII Insurance Business Transfer Expertise

We manage all aspects of the Part VII FSMA 2000 (Financial Services & Markets Act 2000) process including the subsequent capital reduction of transferors and holding companies. Typical roles have encompassed :

 

  • Consultancy on project design, structure, planning, corporate governance and quality assurance
  • Programme and project management of the design, structure, planning and delivery of the entire programme as well as individual workstreams (including all legal, regulatory, technical, communications and operational requirements)
  • Part VII feasibility studies - especially regarding Brexit 

Technical and functional areas we manage include:

  • Actuarial - Scheme structure / report production / Independent Expert liaison / policyholder response & objection management / reassurance
  • Legal - Scheme development / regulatory compliance / court process / witness statement production / 3rd party contracts
  • Tax - Corporate & policyholder aspects (e.g. tax clearances as well as operational impact)
  • Regulatory - PRA, FCA, EEA, Channel Islands, Isle of Man, Overseas regulator requirements & liaison
  • Policyholder & Customer Services - policyholder mailing / response management / press & website notices
  • Company Secretarial - Board meetings / capital reductions / name change / liquidation
  • Finance - Operational change / reporting / capital reductions / liquidation
  • Investments - asset movements / operational change (e.g. custodian / stamp duty / Capital Gains Tax impact)
  • IT systems - operational impact

 

In addition to the above areas, Annuity portfolio transfers have also covered:

  • Implementation of Portfolio Sale & Reassurance Agreement - reassurance accounting, investment transfers, operational & management reporting changes required
  • Data migration following Part VII transfer

In each case, close liaison and management of both internal resources and external suppliers has been required. The key relationships we manage cover all of the following:

  • Board Directors & Senior Management
  • Regulators - PRA / FCA / EEA / Channel Islands / Isle of Man / Overseas
  • Professional Advisors - Lawyers / Independent Expert / Actuaries / Tax Advisors / Accountants / Auditors
  • Project Team Resources
  • Service Providers - Outsourcers / Print Broker & Mailing Houses / Press & Advertising Agencies

 

Business types cover both insurance & reinsurance run-off, with-profit / non-profit and life / pensions portfolios. We have implemented Schemes with Effective Dates at various dates as well as at the financial year-end.