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How We’re Dealing with Brexit
The UK has left the EU, and the Brexit transition period is ending on 31st December 2020. We don’t know what’s going to happen after that date, so we’re preparing for a No Deal scenario.
Before we brief you on our preparations, it’s important to stress that there are no changes to our UK staffing levels, the benefits or coverage provided by our insurance plans, or our member experience. Our relationship with Allianz continues, and there are no changes to our relationships with our assistance service and regional insurance partners.
We’ve set up a subsidiary company in Brussels called William Russell Europe SRL. From 1st January 2021, we’ll administer insurance policies through this subsidiary. We’ve established a UK branch of the subsidiary at William Russell House, Lightwater, so there’ll be no operational disruption.
We’ve also set up an association in Brussels for insurance, health, and well-being. Existing policyholders will automatically be entitled to membership of this association upon their first renewal date after 31st December 2020. Employees and dependants will also be entitled to membership of the association, along with new customers who purchase one of our plans after 31st December 2020.
The insurer of the plans remains AWP Health & Life SA, an Allianz company with an AA financial strength rating from Standard & Poor’s.
There are some exceptions to these arrangements. For policyholders who hold a health plan and who are resident in the UK, we’ve arranged insurance cover with AWP P&C SA UK, a UK-based insurance company in the Allianz group. Again, this change will have no effect on the benefits and coverage that the plans provide.
Further, these changes do not apply to customers whose plans are insured by our regional insurance partners located outside the EU: Dubai Insurance Company in the UAE, Lippo Insurance in Indonesia, Sompo in Hong Kong, and Orient Insurance Company in Egypt.
|WRA||– The William Russell Association for Health, Financial Protection, and Well-Being|
|WRL||– William Russell Limited|
|WRE||– William Russell Europe SRL|
|FCA||– The UK Financial Conduct Authority|
|TPR||– The FCA’s Temporary Permissions Regime|
|FSMA||– The Belgian Financial Services & Markets Authority WRA The William Russell Association|
|EEA||– European Economic Area|
The UK has left the European Union, and the transition period is coming to an end on 31st December 2020. This article explains what William Russell is doing to remain compliant and to preserve relationships with our insurance partners and brokers, regardless of whether the UK and the EU strike a deal before 31st December 2020.
This article also introduces the William Russell Association for Health, Financial Protection, and Well-Being, what it does, and how it affects our customers.
WRL, a company incorporated in the UK, acts as an insurance intermediary for AWP Health & Life SA, an Allianz insurer incorporated in France.
Our relationship with Allianz has been possible thanks to the freedom of services afforded by the UK and France’s shared membership of the EU. From 1st January 2021, these freedoms will cease to exist. At present, we do not know what alternative arrangements the UK and the EU will agree.
If no alternative arrangements transpire, countries in the EU will become third countries to the UK. If we did nothing about this likely situation, there would be severe repercussions:
- As a UK company, WRL could no longer sell policies to residents or businesses in the EU
- As a French insurer, Allianz could not insure policies administered by WRL, a UK company
Our company in Belgium
We want to preserve and grow both our business in Europe and our relationship with Allianz, so we needed to incorporate a company in an EU member state.
In September 2019, we incorporated WRE in Belgium as a wholly-owned subsidiary of WRL. We received authorisation from the FSMA a few weeks later. WRE is now authorised as a Mandated Underwriter (the Belgian equivalent of a Managing General Agent).
We chose Brussels, Belgium for three reasons:
- Its geographical proximity and transport links to the UK
- Its growing international community, including the European outpost of Lloyd’s of London
- The FSMA is taking a pragmatic view on companies like WRL that are dealing with the fallout of Brexit
WRE has a UK branch
Most of our staff members work at William Russell House, Lightwater, and we don’t want this to change. So, to avoid moving staff to Brussels, we have opened a branch of WRE in the UK. Conveniently, we registered this branch at William Russell House, Lightwater.
The UK branch of WRE has entered an arrangement called the TPR that has been set up by the FCA. The TPR allows EU financial services firms to continue carrying out regulated activities in the UK even if there is no deal between the UK and the EU by 31st December 2020.
If the UK and the EU do not reach a satisfactory deal on financial services, then most broker and customer-facing services (eg policy services, claims) that we currently carry out as WRL will instead be carried out as the UK branch of WRE.
What does WRE mean for existing customers?
The changes above will apply to all individual and business policyholders with a plan currently insured by Allianz, unless they hold a health plan and are resident in the UK. We’ve arranged insurance cover with a UK-based insurer in the Allianz group for policyholders with a health plan who are resident in the UK.
The location of employees and dependants of policyholders is not relevant for determining which arrangement will apply: it’s the location of the policyholder that matters.
Whichever arrangement applies, the benefits, scope of coverage, and personal underwritten terms provided by the customer’s existing plan will not be affected.
Introducing our members’ association
An association is a group of people who come together under a common goal. The common goal can be anything from people forming a local sports association or a group of people working for a charitable association. Insurance providers can use associations to organise insurance cover for a group of members.
Our association is called the William Russell Association for Health, Financial Protection, and Well-Being, or WRA for short.
It’s important to note that the WRA will not insure our products. The WRA is a free-to-join and not-for-profit organisation, set up solely for the benefit of its members. The WRA will be the policyholder of the collective, ‘master’ policies issued by the insurer (AWP Health & Life SA, or to keep things simple—Allianz).
The WRA will take out master policies with Allianz. Customers that we currently define as the ‘Policyholder’ on Certificates of Insurance and plan agreements (the employer for group policies and the policyholder for individual policies) will no longer enter into insurance contracts directly with Allianz.
Instead, those customers will become members of the WRA. As members, those customers (and their dependants and employees) will be insured under the master policy that the WRA has taken out with Allianz. However, members will retain their existing date of entry.
Benefits of the WRA
We’ve been planning an association for a couple of years. Brexit has changed our timelines, so we’ve had to bring things forward.
Brexit is a complex political, cultural, and economic exercise. It has made things extremely difficult for many British companies, and we are certainly not the only British insurance intermediary who has formed a company in Belgium or another EU member state.
That said, forming an association does have clear advantages:
- Community of people
Our customers are enrolling as members of an association, which is a community of people rather than a corporate entity
- No grey areas
We can offer products and services to potential new members, including some increased scope to insure local nationals in countries where barriers have traditionally existed.
- Altruistic goals
The WRA has altruistic goals and exists solely for the benefit of its members: a real point of difference against our direct competitors
- Setting strong foundations
There is no change to our products, services, insurance partners, internal teams, or commitments to data protection, member experience, and developmental roadmaps
Anything else to know about the WRA?
The WRA is not a subsidiary or department of WRL or WRE. It’s an entirely independent, not-for-profit organisation, and it has a duty to act in the interest of its members. If there is any conflict between the interests of the WRA’s members and any other party, such as WRE or Allianz, then the WRA’s directors have a legal obligation to act in the interest of its members.
The WRA will not involve itself in arranging cover for its members or providing policy administration services. It will not offer insurance advice, nor will it assist with claims. WRE and WRL will handle all of the above activities.
However, membership of the WRA allows the member to become insured under the master policies the WRA takes out with Allianz in its own name.
The WRA has a defined purpose, which appears in the foundational documents for the association and which also appears in the plan agreements.
“The purpose of this Association is to research, develop, arrange, and promote a range of international insurance and assistance products and services, designed to protect the health and well-being of international citizens and expatriates throughout the world.”
Inez Cooper, Managing Director
How do our customers become members of the association?
We’ll start enrolling members with health, life, and income protection plans into the WRA from 1st January 2021. This means the first renewal invitations for 2021, which are issued from mid-November, will contain details of the WRA.
New customers whose plans start on or after the 1st January 2021 will automatically enrol as members into the WRA.
What about customers with health plans when the policyholder resides in the UK?
At present, we treat our customers who are resident in the UK like anywhere else in the world: the insurer is AWP Health & Life SA, and the insurance intermediary is WRL.
From 1st January 2021, we will offer policyholders who are resident in the UK with a health plan continuation of their cover with a different insurer: one of the Allianz group’s UK-based insurance companies, AWP P&C SA UK. This means the first renewal invitations for 2021, which are issued from mid-November, will contain details of the new insurer.
The benefits, exclusions, and terms and conditions for these UK policies are the same as those for the WRA’s master policies, with a few technical and legal changes.
What about customers with life or income protection plan in the UK?
Customers with a life or income protection plan will be enrolled in the WRA from 1st January 2021, even if they are resident in the UK.
How do customers enrol as members of the WRA?
We’ll introduce the WRA to our individual and business customers with renewal dates after 31st December 2020 from mid-November 2020. We will provide the usual documentation, highlighting any changes.
If customers wish to continue their cover with us, we will automatically enrol them in the WRA. Customers need not do anything different from what they would typically do at renewal.
William Russell is a trading name of William Russell Ltd, which is authorised and regulated in the UK by the Financial Conduct Authority. We provide insurance plans on behalf of AWP Health & Life SA, an Allianz group company registered in France, and Griffin Underwriting Ltd. We do not offer advice on insurance.
Article published: 04/11/2020 at 15:34.
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