Lloyds of London The Curious Case of Equitas Re

Lloyds of London The Curious Case of Equitas Re

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Editor's Note: Editor's Note: This article is a follow-up to the author's article "Meltdown at Lloyd's: A Few Topical Issues," which appeared in the September 2004 issue. The author's own technical terms (including references to the RRC series of "Reconstruction and Renewal" documents) are defined in the Master Glossary downloadable from http://www.astorlaw.com. The reader should note the considerable legal complexity of the Lloyd's enterprise and the "Equitas" construct, of which the present article conveys only an indication.1

Equitas Re: An Insolvency Diversion?

By 1996, the insurance enterprise colloquially known as "Lloyd's of London" was insolvent, having sold an indeterminate number of unlimited general liability policies—in effect, live and subsisting blank checks for asbestos, pollution and health hazard risks—to U.S. corporate EquitasRe-assured-at-Lloyd's in the 1950s through the early 1990s. Many of those checks remain valid and current. Some remain yet to be physically found. After a reserving exercise at Lloyd's costing millions of pounds,2 a number was finally arrived at purporting to be a fair quantification of the Lloyd's enterprise's previously allegedly unquantifiable3 exposure to those extant policies. Having been quantified, why those liabilities could not then simply remain at Lloyd's is a question that has not been answered satisfactorily.

The Lloyd's enterprise then needed a device that would give the false impression to the policyholders concerned that it had extricated itself from those liabilities and had validly transferred them—by means legally binding on relevant policyholders—out of the enterprise to an entity of less ample means than itself. This entity could then plausibly bargain with policyholders to pay them materially less than 100 percent of their true value, thus sparing its own and the Lloyd's enterprise's assets. International insurance practitioners around in 1996 will well remember the crisis. Equitas Reinsurance Limited4—apparently the world's largest reinsurance company—was the device set up by the Council of Lloyd's, in close cooperation with insurance regulators in a number of jurisdictions.

The Council of Lloyd's then collected the necessary reserve from various sources—principally from such members of Lloyd's as were then left holding5 the liabilities (some of whom persist in refusing to pay their so-called "Equitas premium")—capitalised Equitas Re6 accordingly, and procured Equitas Re to sell 100 percent whole-account reinsurance compulsorily to those members.7

Settling at Equitas Re appears and can easily be made to seem—falsely —a "win-win" outcome for both sides.

Old-year Liabilities Then Vanish...

Though it had and has no fresh money of its own—so is no more than a mere adjunct of the already closed and insolvent Lloyd's financial system8—Equitas Re and its now self-averredly unstable security are the pretext on which U.K. and some U.S. state insurance regulators then allowed, and continue to allow,9 the Lloyd's enterprise to take 100 percent credit on its balance sheet for all those ceded liabilities.10 In various adroit regulatorily approved moves concluded on or around Sept. 3, 1996, the Lloyd's enterprise and its closed financial system thus went from being (unquantifiably or quantifiably) insolvent one minute to having no relevant balance-sheet liabilities at all the next. From that date, the Lloyd's enterprise was magically rendered solvent. Ed Muhl, then New York superintendant of insurance, summarised the insurance regulator's dilemma by frankly admitting that regulatory obstruction of the Equitas construct would have been commercially unwise.11

...But Cedant Still Personally Liable

In erecting and effecting this back-office engineering between relevant members of Lloyd's and Equitas Re, no one bothered to involve the EquitasRe-assured-at-Lloyd's. No EquitasRe-assured-at-Lloyd's was personally privy to any of the legal instruments setting up Equitas Re or empowering it to sell reinsurance or manage relevant claims. As with any conventional outward reinsurance, the EquitasRe-reinsured member of Lloyd's still remains contractually liable to the policyholder for the entirety of the ceded business,12 regardless of enterprise-level balance sheet accounting ruses. No relevant instrument novates any ceded liability away from any relevant member of Lloyd's and into Equitas Re personally. The EquitasRe-assured-at-Lloyd's is still insured at Lloyd's, with the extensive enterprise-level securitisation entailed and regardless of the particular individual member's personal financial condition.

Over to Equitas Re

Over then to Equitas Re to handle13 and front claims on the spirited-away pre-1993 Lloyd's non-life liabilities. In its current operations, one minute the company claims imminent insolvency (in settlement negotiations), the next it avers solvency (to insurance regulators). One minute it claims it is completely independent of the Lloyd's enterprise; not so on examining the constitution of Equitas Holdings Ltd., which stipulates a preferred share owned by Lloyd's and a "Lloyd's director" appointed by Lloyd's. One minute it claims to be the EquitasRe-assured's-at-Lloyd's sole recourse; not so when sued personally as assumption reinsurer in U.S. federal or state court, which proceedings it defends by averring that it is a mere reinsurer and run-off agent. No wonder the EquitasRe-assured-at-Lloyd's is confused.

In addition to this day-to-day smoke and mirrors, Equitas Re's principal agenda, in which it also succeeds admirably, is to give EquitasRe-assureds-at-Lloyd's the overriding false impression that the Lloyd's enterprise is no longer liable to pay their claims. The more it can thus manage to distract and materially shortchange EquitasRe-assureds-at-Lloyd's, the more it will spare the Lloyd's enterprise and current Lloyd's enterprise assets. The Lloyd's enterprise hopes that a day of reckoning will never come.

Alternatively, if and when remaining EquitasRe-reinsured liabilities do return to the enterprise's balance sheet—whether by regulatory diktat or through Equitas Re becoming insolvent—the enterprise hopes that they will then not be on a scale, or of an order, sufficient to threaten enterprise-level insolvency, and or that the enterprise itself will by then be in a financial condition less parlous than in 1996 and more able to withstand them.

Foreground Summarised

Averring that it—rather than the Lloyd's enterprise with its famous "chain of security"—is now the EquitasRe-assured-at-Lloyd's' sole recourse, Equitas Re's standard message comprises four principal points: (1) We are impecunious; accept our offer of materially less than 100 percent of your entitlement—ideally no more than 37 percent—while we still have the money;14 (2) we are about to go insolvent, at which point you will have to prove our insolvency; (3) you have no recourse to the Lloyd's enterprise, or it is wholly impracticable to invoke it; (4) as a last resort, you will have to collect against each individual relevant member of Lloyd's for his insignificant discrete participation on your insurance contract.

This contrived message perplexes the EquitasRe-assured-at-Lloyd's, not yet admitted to the mystery of precisely how the supposedly superior securitisation blandished by the famous "Lloyd's of London" came to just disappear in the first place, and laboring under the misapprehension that he has, by some due process yet to be revealed, been validly dispossessed of his recourse rights to the Lloyd's enterprise.

He looks to insurance regulators, his own lawyers and his Lloyd's broker to protect him from such nonsense, but is badly served by each. No insurance regulator gainsays Equitas Re's sales pitch, or even appears interested in Equitas Re's persistent predictions of its own imminent insolvency.

Every relevant Lloyd's broker brokes claims on EquitasRe-reinsured insurance contracts at Equitas Re15 rather than at Lloyd's, further shielding the Lloyd's enterprise from its own liabilities. Some Lloyd's brokers are on record as endorsing Equitas Re's sales pitch, urging their clients—many of whom mean nothing commercially to the broker—to take what they can reasonably get from Equitas Re while Equitas Re still has some money available. Bolstered by this multiplied and mutually reinforced misinformation from a variety of apparently independent and disparate sources, Equitas Re has thus acquired, and retains, a significance among EquitasRe-assureds-at-Lloyd's wholly disproportionate to its actual importance. Its St. Mary Axe office is aptly located indeed.16

Settlements under a Misapprehension

Often unaware that he is still, and (paradoxically) always has been, fully securitised at Lloyd's, and that a variety of specific dedicated and not-dedicated trust and other funds—protected by Equitas Re's misrepresentations—remain available to pay his valid claim 100 percent, the EquitasRe-assured-at-Lloyd's instructs his lawyer to negotiate an acceptable settlement at Equitas Re—with no thought given to applying to some appropriate claims-handling office at Lloyd's. The settlement document contains a comprehensive release of all relevant members of Lloyd's, by which technique Equitas Re protects, spares and insulates the Lloyd's enterprise, as well as relevant claims payment securitisation trust funds,17 from all further liability (assuming the settlement agreement is not subsequently voided for fraud).

Settling at Equitas Re appears and can easily be made to seem—falsely—a "win-win" outcome for both sides. Equitas Re emerges looking munificent—which it then uses self-congratulatorily for public relations purposes—while the EquitasRe-assured-at-Lloyd's and his lawyer emerge looking pragmatic and "commercial."18 Of the often well-publicised settlements made at and with Equitas Re, it is presently believed that many inadvertently fall materially short of the 100 percent pay-out to which the valid-claimant EquitasRe-assured-at-Lloyd's is and always has been entitled. Shareholder funds have been compromised. CFOs and boards have been misled. Some short-changed corporate EquitasRe-assureds-at-Lloyd's may have or will become insolvent. The most extraordinary feature of all is the erroneous belief that the EquitasRe-assured-at-Lloyd's has lost his recourse to the Lloyd's enterprise.19

Now What?

The Lloyd's enterprise's ingenious shortchanging of corporate America—fronted by Equitas Re, abetted by insurance regulators, assisted by Lloyd's brokers and consummated by the EquitasRe-assured's-at-Lloyd's own specialist lawyers giving erroneous information and misconceived advice—may unravel when Equitas Re does finally go into a formal English-law insolvency process.20 At that juncture:

1. Insolvency at Lloyd's: Equitas Re is the only thing standing between the Lloyd's enterprise and its extant pre-1993 non-life liabilities, which are still of an order of magnitude capable of rendering the enterprise insolvent as soon as they return to its balance sheet. When EquitasRe-reinsured liabilities do bounce back to the Lloyd's enterprise—if the Council of Lloyd's through Equitas Holdings' "Lloyd's Director" can no longer stop Equitas Re's self-prophesied insolvency—the latter will overnight lose the protection afforded by the Equitas construct and revert to the overt insolvency that mysteriously vanished from its balance sheet in 1996, a financial condition then remediable principally not by the insurance industry or government rescue but by then-current members of Lloyd's contributing sufficiently to a sufficient Central Fund.21 U.K. and U.S.-state insurance regulators likely having no appetite for further regulatory sleights of hand, meltdown of the entire Lloyd's enterprise will follow those members' failure to make those contributions.

2. Unravelling of Equitas Re settlements: The EquitasRe-assured-at-Lloyd's who has already settled22 a valid claim on the cheap at Equitas Re under a mistake of fact or law will attempt to recover the difference between the settlement and the 100 percent he was entitled to all along by suing his lawyer and/or his Lloyd's broker for malpractice.

While elementary Recourse Due Diligence™ would have instantly established the existence of relevant expressly available claims-payment securitisation trust funds,23 very few assured-side lawyers appear to have the skill to perform it. Numerous U.S. law firms will settle expensively. Some small boutique law firms may be wiped out. To credibly untangle the underlying technicalities requires legal time and perseverance of an order that U.S. law firms have self-evidently been reluctant to deploy, though they unhesitatingly charge their clients for giving "commercial" and materially erroneous information and advice. Successful claims of fraudulent malpractice should not be ruled out, for some U.S. lawyers may have deliberately falsely represented expertise in this most abstruse field of law, and should never have been handling Lloyd's or Equitas claims in the first place.

At least one major Lloyd's broker is on record as advising its client EquitasRe-assureds-at-Lloyd's to sell out prematurely and excessively cheaply at Equitas Re. English law on brokers' claims broking functions is unambiguously pro-policyholder. These secondary deep-pocket recoveries may be of material financial help to foundering U.S. EquitasRe-assureds-at-Lloyd's and their creditors;

3. Full-value claims recoveries against the Lloyd's enterprise: The Lloyd's enterprise in effect wrote open-ended, not-time-barred blank checks to corporate America for asbestos, pollution and health hazard risks. Some of those risks have yet to mature into claims, with some EquitasRe-assureds-at-Lloyd's yet to succumb to Equitas Re's efforts to buy back those checks ('commutation'). When it becomes widely realised that commutation at Equitas Re has been merely a way to protect the Lloyd's enterprise rather than (as claimed) the commercial, realistic choice of pragmatists, U.S. holders of APH policies will settle for nothing less—nor is there any reason why they should settle for anything less—than 100 percent payout at Lloyd's. Those payouts may well save some U.S. businesses from bankruptcy. The professional and transactional rewards to the few U.S. law firms genuinely in command of the detail will be considerable.

A Booby Trap at an Insolvent Equitas Re

A diversionary booby trap lies in wait for EquitasRe-assureds-at-Lloyd's on Equitas Re's formal insolvency, and it is important that it be clearly recognised and decisively defused so that no further material shortchanging occurs. It is called Equitas Policyholders Trustee Limited.24

Ordinarily, in an insolvency of a conventional reinsurer, the cedant proves his debt and personally receives a dividend. In an illogical attempt to prevent each individual relevant member of Lloyd's from proving against Equitas Re and personally pocketing insolvency dividends, he was compelled to assign his reinsurance recovery rights against Equitas Re to Equitas Policyholders Trustee Ltd., which in its turn is to hold eventual recoveries in trust for relevant EquitasRe-assureds-at-Lloyd's. When Equitas Re does go into a formal insolvency process, enter Equitas Policyholders Trustee Ltd. on behalf of the policyholder. Touchingly wholesome.

What recoveries from Equitas Re on behalf of the EquitasRe-reinsured member of Lloyd's may eventually accrue to a dedicated protected pot is a question entirely irrelevant to any EquitasRe-assured-at-Lloyd's.

EquitasRe-assureds-at-Lloyd's can expect Equitas Policyholders Trustee Ltd.—owned by Equitas Holdings Ltd.25—to require, request or invite EquitasRe-assureds-at-Lloyd's to lodge proofs of claim with it. One can easily imagine relevant EquitasRe-assured-at-Lloyd's forming creditor committees in relation to Equitas Re, formulating and lodging proofs of gross and net debt against Equitas Re, monitoring and giving due credit for dividends paid out of Equitas Re, being grateful for eventual recoveries from Equitas Re and formally releasing the Lloyd's enterprise in relation to the difference.

In reality, however, Equitas Policyholders Trustee Ltd. is a superfluous front-office intrusion on the straightforward relationship between the EquitasRe-assured-at-Lloyd's and the Lloyd's enterprise. It is yet another diversion of the EquitasRe-assured-at-Lloyd's away from his true quarry and recourse, the Lloyd's enterprise, for there is no reason in English or any other law why the EquitasRe-assured-at-Lloyd's need concern himself with any aspect of Equitas Re's personal financial condition, especially including its formal insolvency and whatever companies, trusts and other devices appear to be on his side.

There is simply no instrument—contract, trust deed, statute, statutory instrument, regulation, byelaw26 or anything else—depriving an EquitasRe-assured-at-Lloyd's of his full securitisation at Lloyd's or requiring him to in any way treat or be concerned with Equitas Re. Equitas Re's formal insolvency is a back-office affair solely between the Lloyd's enterprise and Equitas Re of—at least for as long as the entire Lloyd's enterprise remains solvent—no formal relevance, concern or interest to any Lloyd's EquitasRe-assured-at-Lloyd's. Equitas Re's personal financial condition is particularly utterly irrelevant to the Lloyd's enterprise's liability to pay claims on insurance contracts sold at Lloyd's, whoever happens to have subsequently reinsured that liability.

Bottom Line

In reality, the EquitasRe-assured-at-Lloyd's has never been a creditor of, and has no legal relationship whatever with, Equitas Re. He can and should recourse for payment of 100 percent of his valid claim directly to Lloyd's enterprises, which, under pressure from angry EquitasRe-assureds-at-Lloyd's, will likely be forced to make its own claims-handling facilities available to them rather than compel their recourse to an insolvent and irrelevant Equitas Re. Readmitting this surreptitiously engineered underclass of Lloyd's policyholder to the proper claims-handling facilities at Lloyd's will be one of the immediate challenges following Equitas Re's apparently imminent insolvency. What recoveries from Equitas Re on behalf of the EquitasRe-reinsured member of Lloyd's may eventually accrue to a dedicated protected pot is a question entirely irrelevant to any EquitasRe-assured-at-Lloyd's. Such recoveries may help the Lloyd's enterprise in the back office, but they are no substitute for its own full and immediate payment in the front office of every valid claim on every EquitasRe-reinsured insurance contract.

Equitas Re's formal overt27 insolvency—which itself habitually foretells in settlement discussions, as a negotiation ploy—thus promises to be an insurance insolvency lawyer's jamboree of years of inappropriate front-office, mid-office and back-office28 litigation and arbitration, and pandemic obfuscation, confusion, misunderstanding and misconception if the insurance insolvency bar is not careful. Lawyer beware.


1 A detailed account of the Lloyd's enterprise is at Astor's Law of Lloyd's, 2nd Ed. (ISBN 1 873994 41 9). A detailed account of Equitas Re is at Astor's Equitas Re Handbook (ISBN 1 873994 26 5). A detailed account of insolvency at Lloyd's and Equitas Re is at Astor's Insolvency at Lloyd's and Equitas Re (ISBN 1 873994 76 1). Return to article

2 See Equitas NLs 1-5; R&R 1-14; S&M, etc. Return to article

3 Salient parts of the story are set out in detail at Lloyd's v Jaffray [2000], CLC 725 (Cresswell J), and Ibid. [2002] EWCA Civ. 1101 (court of appeal). Return to article

4 Incorporated in England and Wales, number 3136300. Its one £100 ordinary share is owned by Equitas Holdings Ltd. Where appropriate, the phrase "Equitas Re" as used in this article refers to Equitas Ltd., incorporated in England and Wales, number 3173352, all of whose all 780,000,001 £1 ordinary shares are owned by Equitas Re. Return to article

5 Principally through an ingenious back-office "pass the parcel" device intrinsic to insurance business at Lloyd's called reinsurance-to-close, summarised at Astor, Richard J., "Equitas Under English Law": An English Lawyer Replies (August 2003; http://www.astorlaw.com). Return to article

6 Actually, the principal operating company is another company, Equitas Ltd., incorporated in England and Wales, number 3173352. All its 780,000,001 £1 ordinary shares are owned by Equitas Re. Return to article

7 See R&R 1-14; RRCs 1, 4, 5, 7 and 17, and other documents in the RRC series. Return to article

8 Indeed, it is even more a closed system than the current Lloyd's enterprise. At least the latter, purporting since 1996 to do business as usual, has fresh premium income. Equitas Re, on the other hand, has no premium income. Return to article

9 Relevant proposed provisions in CP 04/7 (importing EquitasRe-reinsured liabilities back to the Lloyd's enterprise's balance sheet as contingent liabilities) are still framed as options, not requirements; see, e.g., Ibid., §§2.99-2.100 (p. 34). Return to article

10 See, e.g., LLD, §12.3.3R(4). Return to article

11 See his talk to the New York Law School Center for International Law Symposium, "Implications of the Reconstruction of Lloyd's of London," Nov. 6, 1996 (found at http://www.nyls.edu/CIL/lloyds.htm, July 25, 2001), pp. 3-6 of 28. Return to article

12 English law has no assumption reinsurance doctrine. Return to article

13 See, generally, RRC 4, §9. Return to article

14 Moser, Scott, "Equitas Claims," Address to the Insurance Institute of London, Jan. 14, 1999:

One of the things you learn in kindergarten is to share. What happens if we just share? We would need to pay $36.84 on the first day to produce the equivalent of $100 after 10 years, but neither of us would incur any legal costs. The result is a claimant that receives $36.84 instead of $17.19, and an Equitas that pays $36.84 instead of $66.08. Even if the claimant would have won $175 at Year 10—75 percent more—the net present value of that sum on Day 1 is only $35.73, still less than the $36.84 in my sample compromise. And even if we would only have had to pay $50 in Year 10, only half of the $100 we thought, the cost to us as of Day 1 would have been $38.96, still more than the cost of my sample Day 1 compromise. Thus, for both sides, any risk that the value we arrive at early may be wrong is far more than offset by a deal in which the parties share the benefits of settling early.
See, also, Mealey's Seminar, Friday, Nov. 16, 2001, "Presentation by Scott Moser, Equitas Claims Director," at Mealey's Litigation Report: Insurance, Dec. 11, 2001, p. 27, 28. Return to article

15 As well as being a reinsurer, Equitas Re is exclusive run-off agent of the EquitasRe-reinsured liabilities; see, respectively, RRC 4, §§3 and 9. Return to article

16 J.W. Wells & Co., Family Sorcerers, was (and perhaps still is) located at 70 St. Mary Axe; see Gilbert, W.S., The Sorcerer (1877). See, also, of possible relevance to the Lloyd's enterprise more generally, Ibid., Act I: Alexis Pointdextre: "I have sent for you to consult you on a very important matter. I believe you advertise a Patent Oxy-Hydrogen Love-at-first-sight Philtre?" Mr. Wells: "Sir, it is our leading article." Alexis: "Now, I want to know if you can confidently guarantee it as possessing all the qualities you claim for it in your advertisement?" Wells: "Sir, we are not in the habit of puffing our goods. Ours in an old-established house with a large family connection, and every assurance held out in the advertisement is fully realised." Return to article

17 Self-regulators-at-Lloyd's are then able plausibly to represent to U.S. state insurance regulators that the regulatorily stipulated minimum levels of claims-payment securitisation trust funds maintained in the United States to pay EquitasRe-reinsured liabilities are too high and should be reduced. Return to article

18 Some EquitasRe-assured-at-Lloyd's-side lawyers, espousing the present value of money, argue that whatever the precise technical legal details of recourse at or not at Lloyd's, commercial reality demands that the EquitasRe-assured-at-Lloyd's take now a reasonable offer from Equitas Re rather than spend the years apparently required in litigation or arbitration to get a decision or award against underwriters at Lloyd's capable of being banked at a relevant claims payment securitisation trust fund. The specialist lawyer is often stuck for an honest answer when asked whether the client has made a fully informed decision to be materially shortchanged at Equitas Re—in particular, whether the client has been fully informed and advised (1) that he is still fully securitised at Lloyd's, (2) that the standard Equitas Re line is materially incorrect, and (3) of the existence, sufficiency, availability and accessibility of relevant trust fund monies furnished by the Lloyd's enterprise specifically to pay his claim in full. Return to article

19 Recalling Mackay, Charles, Extraordinary Popular Delusions and the Madness of Crowds (Bentley, London, 1852), p. 177 ("The Crusades" chapter): "Every age has its peculiar folly, some scheme, project or phantasy into which it plunges, spurred on either by the love of gain, the necessity of excitement or the mere force of imitation." Return to article

20 For a summary of relevant English law insurance insolvency processes (administration, CVA, provisional liquidation, liquidation, insolvent scheme of arrangement, etc.), see Astor's Principles of Insurance Insolvency Law (ISBN 1 873994 61 3) and Astor's Insolvency at Lloyd's and Equitas Re (ISBN 1 873994 76 1). Return to article

21 See, e.g., [Old] Central Fund Byelaw (No. 4 of 1986) as amended; New Central Fund Byelaw (No. 23 of 1996) as amended. In the present context, "Byelaw" means a byelaw made by the Council of Lloyd's (see Lloyd's Act 1982, s.3) under Lloyd's Act 1982, s.6(2). Return to article

22 Whether a particular settlement agreement itself can be vitiated for fraudulent non-disclosure (if it be the case) by Equitas Re of the EquitasRe-assured's-at-Lloyd's recourse to the Lloyd's enterprise depends on the case, but the possibility should not be ruled out. Return to article

23 Including, for example, LATF, etc. and, by default, the Central Fund. Return to article

24 Incorporated in England and Wales with members' liability limited by shares, number 3243970. Its one £100 ordinary share is owned by Equitas Holdings Ltd. Return to article

25 Incorporated in England & Wales, number 3136296. It owns all the shares in both Equitas Re and Equitas Policyholders Trustee. Its one £1 preference share is owned by the corporation. Its two £50 ordinary shares are owned by EquitasRe-reinsurance trustees, who hold those shares under the trust set out in RRC 17. Return to article

26 The New Central Fund Byelaw, §§8(3)(b) and 8(4)(b); so-called "ringfences" are mere back-office political gestures between Lloyd's and members of Lloyd's, not binding on, or even addressed to, any assured-at-Lloyd's. In any event, the provisions are probably ultra vires. Return to article

27 Equitas Re's overt insolvency—viz., its entry into a formal English-law insolvency process such as administration, provisional liquidation, liquidation or insolvent scheme of arrangement—is to be distinguished from the somewhat covert insolvency that the so-called "Proportionate Cover Plan" is designed to protect it from. See the relevant provisions at RRC 4, Sch. 3 ("Operation of proportionate cover") (and the parallel provisions in relation to Equitas Ltd. at RRC 5, Sch. 3 ("Operation of retrocession plan")). Return to article

28 On the front, mid- and back offices at Lloyd's, see Astor, Richard J., "Liability on an Insurance Contract Made at Lloyd's," Torts, Insurance & Compensation Law Section Journal (New York State Bar Association), Winter 2004, Vol. 33, No. 1, pp. 18-25. Return to article

Journal Date: 
Friday, October 1, 2004