The United Kingdom (UK) formally left the European Union (EU) on 31 January 2020 and entered into a transition period as part of the Withdrawal Agreement between the UK and the EU. The transition period is due to end on 31 December 2020. During this transition period it has been “business as usual,” as this period was intended to provide the UK and the EU with time to negotiate the details of the future relationship, ready for implementation at the end of 2020.
We have set out below answers to the most common questions raised by our brokers and business partners.
Chubb’s primary underwriting operation in the UK and Europe is Chubb European Group SE (“CEG SE”). On 1 January 2019 CEG SE successfully redomiciled from the UK to France and now operates under the supervision of the French Prudential Supervision and Resolution Authority (“ACPR”) The UK branch of the Company continues to be subject to limited regulation by the Financial Conduct Authority (“FCA”). CEG SE has branch offices across Europe and holds cross border permissions throughout the EEA.
Our preferred location of France was clear and straightforward. Chubb has a long-established, vital presence in the French market, with several hundred employees serving businesses of all sizes, as well as a vibrant consumer market in which we offer a wide range of products. Paris is also the principal office for our Continental European operation, allowing us to capitalise on the management and staff already present in the city as we build our EU headquarters. Choosing France reflected our existing strong commitment both to the French market and the larger European market. In considering France as the future home of our legal entity, we worked closely with the ACPR.
CEG SE continues to have a substantial presence in London which remains its Regional European headquarters.
CEG SE is headquartered in France with its registered office at La Tour Carpe Diem, 31 Place des Corolles, Esplanade Nord, 92400 Courbevoie. It is entered into the Nanterre companies register under number 450 327 374. Since 1 January 2019, CEG SE has been authorised and supervised by the ACPR.
Until the end of the transition period, CEG SE will continue to operate in the UK through its cross-border passports. It remains based at Chubb’s Regional European headquarters at 100 Leadenhall Street, London EC3A 3BP, with additional offices throughout the UK. As a branch of an EEA company, CEG SE is subject to limited regulation by the Financial Conduct Authority (FS Register number 820988).
CEG SE’s UK company registration fell away when it redomiciled to France. You can now find CEG SE on the Nanterre companies register under number 450 327 374. As a Societas Europaea or European company, CEG SE is considered to be domiciled throughout the EEA and in the UK, until the end of the transition period. As such, there is no current requirement for CEG SE to separately register its UK branch with Companies House. When the transition period ends, CEG SE will register its UK branch with Companies House. In the meantime, CEG SE’s UK branch is recognised by both the Prudential Regulation Authority (“PRA”) and FCA and can be found on the Financial Services Register under reference number 820988.
At the end of December 2020, CEG SE will benefit from the UK Government’s Temporary Permissions Regime. This allows CEG SE to operate in the UK and continue to write business in the same way as it does now. The Temporary Permissions Regime will be in place for up to three years from the end of the Transition Period. During that time CEG SE will establish an international branch in the UK. The UK branch will be authorised by the Prudential Regulation Authority while also remaining part of the same legal entity CEG SE. This will enable CEG SE to continue to operate in the UK beyond the expiry of the Temporary Permissions Regime.
Yes, UK underwriters are able to issue one policy with one stamp covering UK and EEA risks. 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. Our two-page summary explains how we will operate post 31 December 2020.
No change. The Temporary Permissions Regime allows CEG SE to continue to service existing policies and pay claims.
Our Lloyd’s managing agency, Chubb Underwriting Agencies Ltd (CUAL), continues to be able to underwrite business in the EEA and elsewhere, through its arrangement with Lloyd’s Insurance Company SA (Lloyd’s Brussels) and its Lloyd’s Syndicate 2488, respectively.
Lloyd’s will transfer certain EEA insurance policies to Lloyd’s Brussels via a Part VII transfer, expected to be effective on 30 December 2020. The proposed transfer will not change the terms and conditions of any policy, except that Lloyd’s Brussels will become the insurer and Data Controller in respect of the transferred policies. Further information about the proposal (including whether it could affect your pre-transfer position), which policies are transferring, your rights and what you need to do can be found at www.lloyds.com/brexit-transfer
On 1 January 2019, ACE Europe Life SE (“AEL SE”) also successfully redomiciled from the UK to France. AEL SE is now headquartered in France with its registered office at La Tour Carpe Diem, 31 Place des Corolles, Esplanade Nord, 92400 Courbevoie. It is entered into the Nanterre companies register under number 497 825 539. Since 1 January 2019, AEL SE has been authorised and supervised by the ACPR.
The UK branch of the company is based at Chubb’s Regional European headquarters at 100 Leadenhall Street, London EC3A 3BP. As a branch of an EEA company, AEL SE is subject to limited regulation by the Financial Conduct Authority (FS Register number 820989). After the end of the transition period, AEL SE will also rely on the UK Government’s Temporary Permissions Regime.
Note: We are proposing to change the name of AEL SE to Chubb Life Europe SE with effect from 31 March 2021.
We continue to benefit from the S&P “AA” rating assigned to core operating companies within the Chubb Group.
If as a broker or partner you relied on passporting rights to intermediate EU business then those passporting rights will cease from the end of 2020 and EIOPA Recommendation 9, as interpreted by EU regulators, requires that all intermediaries in the chain are EU authorised where the policy has both an EU policyholder and risk location.
If brokers or partners do not intend to obtain necessary authorisations to continue servicing existing EU business and or new/renewal of EU business that fall within Recommendation 9 please contact Chubb.
When the passporting regime falls away at the end of December 2020 EEA firms may need to seek authorisation in the UK to continue to access the UK market. Further information can be found on the FCA’s website.