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How is Chubb changing under Brexit?

Chubb European Group SE and ACE Europe Life SE re-domiciled to France on 1 January 2019.

An SE is a public company registered under EU corporate law and formed in accordance with the law of the Member State in which it has its registered office. SE status enables Chubb European Group and ACE Europe Life to redomicile to another EU jurisdiction – France – and continue to undertake business both around the EU and into the UK.

From 1 January, 2019, the new registered address for Chubb European Group SE and ACE Europe Life SE is La Tour Carpe Diem, 31 Place des Corolles, Esplanade Nord, 92400 Courbevoie, France. 

Also from 1 January, 2019, Chubb European Group SE and ACE Europe Life SE are now supervised by the ACPR, 4 Place de Budapest, CS 92459, 75436 PARIS CEDEX 09 and operate in the UK – initially at least – as an EEA branch.

The company registered number for CEG has changed to 450 327 374 RCS Nanterre.

The company registered number for AEL has changed to 497 825 539 RCS Nanterre.

As a company headquartered in France, AEL is supervised by the French Prudential Supervision and Resolution Authority, 4, Place de Budapest, CS 92459, 75436 PARIS CEDEX 09. CEG and AEL are subject to limited regulation by the Financial Conduct Authority in the UK.

Customers will benefit from continuing to receive insurance cover from the same legal entity with the same level of capital. In addition there will be no change to the level of customer service.

Specifically, for UK customers this means contract certainty and certainty of insurance cover. The French companies will operate in the UK under passporting rules until Brexit or expiry of any transition period. After that time and if required, Chubb intends to seek authorisation of the branches of its French companies in the UK. In the event of a ‘Hard Brexit’ where no transition period is agreed between the UK and EU, Chubb’s UK branches will benefit from the UK government’s temporary permissions regime. This regime will enable firms like Chubb to undertake new business within the scope of their permission, enable them to continue performing their contractual rights and obligations, manage existing business and mitigate risks associated with a sudden loss of permission.

For customers based in the EU there will also be no disruption as the French authorised business for Chubb European Group SE and ACE Europe Life SE will be able to passport across the EU. This means there will be no complicated portfolio transfers or changes in insurers which might otherwise be experienced.

We anticipate that these changes will allow us to continue to benefit from the S&P “AA” rating assigned to core operating companies within the Chubb Group.

The Chubb Group of companies, of which CEG and AEL are part, continues to be based at 100 Leadenhall Street, London EC3A 3BP in the UK and to maintain a substantial presence in the UK.

From the outset, our primary aim has been to ensure a seamless transition and to offer certainty and continuity of service for all our customers and our business partners, regardless of location or the final outcome of the Brexit negotiations.

Specifically, for UK customers this means contract certainty and certainty of insurance cover. The French companies will operate in the UK under passporting rules until Brexit or expiry of any transition period. After that time and if required, Chubb intends to seek authorisation of the branches of its French companies in the UK. In the event of a ‘Hard Brexit’ where no transition period is agreed between the UK and EU, Chubb’s UK branches will benefit from the UK government’s temporary permissions regime. This regime will enable firms like Chubb to undertake new business within the scope of their permission, enable them to continue performing their contractual rights and obligations, manage existing business and mitigate risks associated with a sudden loss of permission.

For customers based in the EU there will also be no disruption as the French authorised business for Chubb European Group SE and ACE Europe Life SE will be able to passport across the EU. This means there will be no complicated portfolio transfers or changes in insurers which might otherwise be experienced.

The UK Government served a notice under Article 50 in March 2017 which kick-started a minimum two-year period for negotiations and Brexit is due to take place on 29 March 2019. Recently the UK and the EU have agreed transitional arrangements that will allow UK insurers to operate in EU countries, and for EU insurers to continue to operate in the UK until the end of 2020. Without such transitional arrangements, like many insurers and financial services firms, Chubb European Group (CEG) and ACE Europe Life (AEL) would no longer be able to undertake regulated activities in the EEA without obtaining EEA permissions.

CEG and AEL are currently authorised in the UK. Chubb’s Brexit plans are designed to ensure it can continue to provide its products and services to its UK and EU customers.

Chubb’s Brexit plan will ensure that Chubb can continue to carry out business in all the countries we operate in now.

If you are an eligible UK customer, you are currently able to bring complaints to the FOS and will continue to be able to do so after the transfer of Chubb European Group (CEG) and ACE European Life (AEL) to France.

What will change after the companies move to France but before Brexit?

No change
Eligible customers of CEG and AEL continue to be able to bring complaints to the FOS after CEG and AEL transfer to France.

  • Financial services firms in any European Economic Area (EEA) member state can use the existing passporting regime to carry out regulated activities in any other member state. 
  • After the transfer to France, CEG and AEL have permission under these existing rules to do business in the UK, through branches, known as EEA-incoming branches ("EEA In-coming branch").
  • UK customers of the EEA In-coming Branches are able to bring complaints to the FOS.

What will change after Brexit?

No change
After Brexit, eligible UK customers of CEG and AEL will continue to have access to the FOS.

  • If a Transitional Period is agreed between the UK and EU after Brexit, we expect existing EU rules to apply during this period and eligible UK customers will still be able to bring complaints to the FOS.
  • If no Transitional Period is agreed, the UK government has proposed a Temporary Permissions Regime. Existing EU rules will continue to apply for EEA-Incoming Branches and eligible UK customers will continue to have access to the FOS.
  • After Brexit, we expect eligible UK customers to continue to have access to the FOS for the following reasons:

(a) When the UK withdraws from the EU the UK will become a ‘third-country’ in relation to the EU and EEA firms will no longer be able to passport into the UK. 
(b) CEG and AEL will therefore seek authorisation from the UK regulators to open Third Country Branches.
(c) UK customers of the Third Country Branch will have access to the FOS, either because that will be agreed between the UK and EU or, if not, because, CEG and AEL will submit voluntarily to the FOS to enable all UK customers to benefit from the regime.

If you are an eligible UK customer you are currently protected by the FSCS and will continue to benefit from this protection after the transfer of Chubb European Group (CEG) and ACE Europe Life (AEL) to France.

 

UK customers of CEG

UK customers of AEL

What will change after CEG and AEL move to France but before Brexit?

No change
Eligible UK customers of CEG will have access to the FSCS.

  • Financial services firms in any European Economic Area (EEA) member state can use the passporting regime to carry out regulated activities in any other member state. 
  • After the transfer to France has permission under these existing rules to do business in the UK, through branches, known as EEA-incoming branches ("EEA In-coming branch"). Eligible UK customers of the EEA In-coming branch have access to the FSCS.

After the transfer,

No change
Eligible UK customers of CEG will have access to the FSCS.

  • Financial services firms in any European Economic Area (EEA) member state can use the passporting regime to carry out regulated activities in any other member state. 
  • After the transfer to France CEG has permission under these existing rules to do business in the UK, through branches, known as EEA-incoming branches ("EEA In-coming branch"). Eligible UK customers of the EEA In-coming branch have access to the FSCS.

After the transfer, the FGAO may also be available to UK customers who have taken out policies in relation to risks which are located in France (e.g. in relation to vehicle insurance where the vehicle is registered in France, or in relation to building insurance, where the property is located in France).

No change
Eligible UK customers of AEL have access to the FSCS.

  • Financial services firms in any European Economic Area (EEA) member state can use the passporting regime to carry out regulated activities in any other member state. 
  • After the transfer to France, AEL has permission under these existing rules to do business in the UK through branches, known as EEA-incoming branches ("EEA In-coming branch"). Eligible UK customers of the EEA In-coming branch have access to the FSCS.

After the transfer CEG will be a participant firm in the FGAP which may then also be available to UK policyholders of AEL.  

What will change after Brexit?

No change
We expect eligible UK customers to continue to have access to the FSCS after Brexit.

After Brexit, CEG intends to operate in the UK through a fully licenced Third Country Branch. The FSCS regime will be applicable to eligible UK customers of this branch.
Eligible UK customers will continue to have access to the FSCS until the CEG Third Country Branch is licenced:

  • If there is a Transitional Period agreed between the EU and UK, CEG will operate in the UK through a branch under existing rules while it applies to open its third country branch and the FSCS will continue to apply to eligible UK customers.
  • If there is a Hard Brexit the UK regulators have proposed a temporary permissions regime for EEA firms that want to continue to do business in the UK after Brexit, while the firms apply for authorisation in the UK.  Because CEG will already have a branch in the UK, the FSCS will remain available to UK customers of CEG until expiry of that temporary permissions regime.

As a participant firm in the FGAO, it is expected that the FGAO will be available to UK customers of CEG who have taken out policies in relation to risks which are situated in France (for example compulsory motor insurance for a vehicle registered in France or in relation to building insurance where the property is located in France).

No change
We expect eligible UK customers to continue to have access to the FSCS after Brexit.

After Brexit, AEL intends to operate in the UK through a fully licenced Third Country Branch. The FSCS regime will be applicable to eligible UK customers of this branch.
Eligible UK customers will continue to have access to the FSCS until the AEL Third Country Branch is licenced:

  • If there is a Transitional Period agreed between the EU and UK, AEL will operate in the UK through a branch under existing rules while it applies to open its third country branch and the FSCS will continue to apply to eligible UK customers.
  • If there is a Hard Brexit the UK regulators have proposed a temporary permissions regime for EEA firms that want to continue to do business in the UK after Brexit, while the firms apply for authorisation in the UK.  Because AEL will already have a branch in the UK, the FSCS will remain available to UK customers of AEL until expiry of that temporary permissions regime.

As AEL intends to join the FGAP as a participant firm, it is expected that the FGAP will be available to eligible UK customers of AEL who were habitually resident in France at the time of taking out the policy. It is unclear, however if the FGAP would only be available to policyholders who took out a policy prior to the redomicile to France. As a result, it may be that policyholders who took out a policy prior to the redomicle will not be covered by FGAP.

Difference between the FSCS and FGAO and FGAP

The scope of cover of the FGAO is significantly less extensive than the FSCS as the FGAO only covers certain French compulsory general insurance policies. The FGAO only covers motor vehicle liability insurance and building damage insurance, in each case only the where the risk is located in France. 

The FGAO will compensate outstanding claims within the limits of the terms and conditions of the insurance policy. However, the FGAO compensates only 90% of the claim, but will compensate 100% if damages to persons or property are caused by a motor land vehicle. In addition, there is an overall compensation limit that caps the FGAO's protection to 700 million Euros in respect of all claimants of all participant firms.

Claims must also be brought within a specified time limit under the FGAO unlike under the FSCS, where a claim can be brought at any time subject to expiry of the right to claim by operation of law.

The scope of cover of the FGAP is similar the FSCS and covers most classes of life insurance policies.

There are, however, upper limits on the monetary amounts that can be claimed under the FGAP unlike the FSCS.

Under the FGAP, for life/health policies, there is a limit of:

  • 70,000 Euros for contractual benefits (which are not payable or due at the time when the scheme is triggered).

  • If you are an eligible EU customer (excluding UK customers) and your policy has been administered and/or issued from the UK, you are able to bring complaints to the FOS for acts or omissions by Chubb European Group (CEG) or ACE Europe Life (AEL) which occurred before the companies transfer to France.  
  • After the transfer to France, as an EU customer you now have access to the French ombudsman complaints regime instead of the FOS.
  • If you are an EU customer whose business was written and/or administered outside the UK, you are not eligible to make complaints to the FOS and instead have access to a local complaints regime. That access has not change after CEG and AEL redomicile to France.

 

Customers of CEG (French and non-French customers) with policies covering French risks e.g. French property or a car registered in France

Customers of AEL that were habitually resident in France at the time of taking out the policy

What will change after the move to France before Brexit? 

Change
EU customers no longer have access to the FSCS.


The FGAO is be available to EU policyholders of CEG (French or non-French policyholders) for insurance policies where the risk under the insurance policy is situated in France and is covered by the scheme (e.g. in relation to vehicle insurance where the vehicle is registered in France).

The FGAO scheme is significantly less extensive than the FSCS.

Change
EU customers no longer have access to the FSCS.

Instead, AEL has joined the FGAP and it is expected that the FGAP will therefore be available to eligible EU customers of AEL.

What will change after Brexit?

Change
EU customers will no longer have access to the FSCS.

After Brexit, as CEG will join the FGAO. It is expected that the FGAO will be available in relation to insurance policies where the risks under the policies are situated in France  and is covered by the scheme(e.g. vehicle insurance where the vehicle is registered in France).

The FGAO scheme is significantly less extensive than the FSCS.

Change
EU customers will no longer have access to the FSCS.

After Brexit, as AEL will join the FGAP it is expected that the FGAP will be available to eligible EU customers.

Difference between the FSCS and FGAO

The scope of cover of the FGAO is significantly less extensive than the FSCS as the FGAO only covers certain French compulsory general insurance policies, where the risk is situated in France. For risks written prior to 1 July 2018, the FGAO is limited to motor vehicle liability insurance only. After 1 July 2018, building damage insureance is also covered.
 
The FGAO will compensate outstanding claims within the limits of the terms and conditions of the insurance policy. However, the FGAO compensates only 90% of the claim, but will compensate 100% if damages to persons or property are caused by a motor land vehicle. In addition, there is an overall compensation limit that caps the FGAO's protection to 700 million Euros in respect of all claimants of all participant firms.

Claims must also be brought within a specified time limit under the FGAO unlike under the FSCS, where a claim can be brought at any time subject to expiry of the right to claim by operation of law.

The scope of cover of the FGAP is similar to the FSCS and covers most classes of life insurance policies.
There are however upper limits on the monetary amounts that can be claimed under the FGAP unlike the UK FSCS.

Under the FGAP, for life/health policies, there is a limit of:

  • 70,000 Euros for contractual benefits (which are not payable or due at the time when the scheme is triggered).

  • If you are an EU customer (excluding UK customers) whose policy has been administered and/or issued from within the UK, you will have access to the FOS regime in respect of any complaints you may have against CEG and AEL where the act or omission occurred before the companies transfer to France.
  • Now the companies have transferred to France, as an EU customer you have access to the French complaints regime instead of the FOS.
  • If you are an EU customer whose business was written and/or administered outside the UK you have access to a local complaints regime.

  Customers of CEG with policies covering risks that are not in France or the UK e.g. a policy covering a property in Spain or a car registered in Germany

Customers of AEL that were habitually resident in an EEA State other than France (or the UK) at the time of taking out the policy

What will change after the move to France but before Brexit?

Change
The FSCS is no longer be available.

Depending on which EU jurisdiction the insured risk is located, there may or may not be a local scheme that applies instead. For example, a policyholder of a home insurance policy covering a house situated in Italy will not be eligible to claim under the French scheme and there is no equivalent compensation scheme in Italy.

Where a scheme is available in an EEA member state it typically covers very limited types of insurance (e.g. motor vehicle, worker incident) but some jurisdictions have wider industry schemes.

You can find out more information on the availability of national insurance guarantee schemes in the paper prepared by the European Insurance and Occupational Pensions Authorityfrom the 30th July 2018. 

Change
The FSCS is no longer be available.

AEL has joined the FGAP as a participant firm and it is expected that the FGAP is therefore be available to eligible EU customers of AEL.

What will change after Brexit?

The FSCS will no longer be available. Depending on which EU jurisdiction the insured risk is located, there may or may not be a local scheme that applies instead. For example, a customer of a home insurance policy covering a house situated in Italy will not be eligible to claim under the French scheme and there is no equivalent compensation scheme in Italy.

Please refer to the EIOPA paperfor more information

As AEL has joined the FGAP as a participant firm, it is expected that the FGAP will be available to eligible EU customers of AEL.

Difference between the FSCS and FGAO

The scope of cover available to customers of CEG will depend on which EU jurisdiction the insured risk is located. Please refer to the following paper by the EU Commission at the following link:
https://eiopa.europa.eu/Publications/Consultations/EIOPA-CP-18-003_Discussion_paper_on_resolution_funding%20and.pdf

 

The scope of cover of the FGAP is wide like the FSCS and covers most classes of life insurance policies.

There are however upper limits on the monetary amounts that can be claimed under the FGAP unlike the UK FSCS.
Under the FGAP, for life/health policies, there is a limit of:

  • 70,000 Euros for accrued contractual benefits (which are not payable or due at the time when the scheme is triggered).

  • In March 2018, the UK and EU announced their agreement in principle to a draft Withdrawal Agreement ("WA") containing a transitional period that would have the effect of delaying the UK's departure from the EU from 29 March 2019 to 31 December 2020 ("Transitional Period"). If the Withdrawal Agreement is ratified before 29 March 2019, this will allow CEG and AEL to operate in the UK through branches, under existing EU "passporting" rules, until the end of the Transitional Period. Once the Transitional Period ends, Chubb European Group (CEG) and ACE Europe Life (AEL) will need to have authorisation from the UK regulators to operate in the UK through what is known as a "third country branch" ("Third Country Branch").
  • During the Transitional Period, CEG and AEL will therefore both apply to the UK insurance regulators to open Third Country Branches to allow them to continue to operate their businesses in the UK.

  • If the Withdrawal Agreement is not ratified before 29 March 2019, there will be what is referred to as a "Hard Brexit" and it is expected that Chubb European Group (CEG) and ACE Europe Life (AEL) would both lose the right to conduct their businesses under current passporting rules in the UK from 29 March 2019.
  • In preparation for the possibility of a Hard Brexit, the UK Government and insurance regulators are working together to implement a temporary permissions regime that will allow EU insurance companies (like CEG and AEL) to continue to do business in the UK ("Temporary Permissions Regime"). Simply put, the temporary permissions regime is a back-stop should the EU and UK not finalise the Withdrawal Agreement.
  • The Temporary Permissions Regime will give firms like CEG and AEL the time to apply for permanent authorisation from the UK regulators to operate their insurance businesses in the UK. During the Temporary Permissions Regime, CEG and AEL would apply to the UK insurance regulators to open Third Country Branches.
  • During the Temporary Permissions Regime, the FSCS will apply to firms with a branch in the UK. CEG and AEL will apply to have a UK branch using the existing passporting rules and eligible UK custom will be covered by the FSCS.

How will I be affected by Chubb's Brexit planning?

You may have received an Important Notice from Chubb, one of our partners, or your broker. The Important Notice was to advise you that we are planning for Brexit and consequently there are likely to be some changes to the corporate structures of our companies. This website is the best place to find up to date information about our Brexit planning.

You may have insurance cover provided by Chubb through a broker or an organisation that have chosen to place their business with us. If you are unsure about your cover please contact your broker. We are required to make you aware of any changes taking place.

You don’t need to do anything. Our Brexit changes will have no effect on the duration of your policy or policies.

To find out the details of your policy you will need to speak to the appropriate team – please refer to your policy and then call the telephone number included, or use the contact us telephone numbers included on Chubb.com.

There will be no change to the cover afforded to our policyholders under their existing policies or any changes in their rights, premiums or benefits under the policy. Our creditors will benefit from continuing to receive insurance cover from the same legal entity with the same level of capital. There will be no change to the level of customer service or existing point of contact.

Our Brexit changes will have no effect on the amount of your premium(s).

You will not incur any costs as a result of the Brexit changes.

No. Our Brexit changes will have no effect on your terms and conditions.

There is no change to your current contact name or contact numbers. Please continue to contact us in the usual way. There may be changes to some numbers in due course, but we will advise you if this is the case in good time.

Our conversion to SE will have no effect on any claims which have been made or may be made under your policy.

Our Brexit changes will have no effect on any claims which have been made or may be made under your policy.