What is changing?

Core Data Record (CDR) and Digital Gateway (IROS)

• The Core Data Record (CDR) will enable a more digitised processing of both premium and claims. The use of the CDR will support automation in 4 key areas:

  • Lloyd’s tax validation and calculation

  • Lloyd’s regulatory reporting

  • Matching claims to the original contract at FNOL

  • Accounting and settlement

• The CDR consists of:

  • 37 mandatory fields, which must always be provided,

  • 180 conditional mandatory fields, of which a subset will need to be provided, based on the individual circumstances of each policy and

  • 15 derived fields, which will be derived from the information provided in the mandatory and conditional mandatory fields.

  • A number of fields have to be populated for each carrier on the risk, and other fields have to be populated for each section of the contract. Therefore, multi-section or multi-carrier risks will have fields repeated multiple times.

• The latest version of the CDR specification can be found on the LIMOSS Market Business Glossary (MBG) https://glossary.londonmarketgroup.co.uk/

• The Process, Roles and Responsibilities (PRR) Final Recommendations for the creation of the CDR can be found on the LIMOSS website here: https://limoss.london/prr-final-recommendations 

• Some Blueprint Two events have included the mention of a “claims CDR”. Work is currently underway by the Blueprint Two team and the Data Council to clarify the business data requirements for claims. 

  • The technical data standards for claims will be ACORD ECOT and EBOT messages, and Velonetic (previously London Market Joint Ventures), Blueprint Two Team, and Data Council will work with ACORD to ensure that the ECOT and EBOT standards are fit for purpose for the London market. 

  • The claims data records will be held in ICOS.

• Two further important artefacts will soon be published for the CDR: ​

  • The ACORD Solutions Group will publish lower-level technical information on how to interact with APIs and security in early 2024.

  • The Good Practice Guide, which is relevant for overall business processes, is expected in Q4 2023.

• The Digital Gateway (IROS) is also planned to go live in phase two and is the set of gateway services used for the submission, validation, update and retrieval of the CDR.

• The Digital Gateway (IROS) is distinct from the Market Gateway (ASG Adept) that goes live in phase one. The Digital Gateway (IROS) will be performing all functions related to the CDR.  All CDR submissions must utilise the Digital Gateway (IROS) to submit in an ACORD CRP format. The Market Gateway (ASG Adept) is the single access point for IPOS, ICOS and the Digital Gateway (IROS).  

• ACORD has worked with its members to ensure that a new ACORD Global Risk & Large Commercial (GRLC) standard for Contract Risk and Pre-Accounting (CRP) can be used to build the technical functionality for submitting, updating and retrieving the CDR. 

• ACORD’s GRLC is a set of data specifications and standards for managing Placement, Accounting & Settlement and Claims. GRLC also includes EBOT and ECOT messages for submitting premium and claims data.

• ACORD’s technical specifications for the CRP can be found on the ACORD website: https://www.acord.org/standards-architecture/acord-data-standards/Global_Reinsurance_Data_Standards#Contract  
  You will need an ACORD licence to access these.

• Please note that some types of business will not be covered by the Digital Gateway (IROS). The following is a non-exhaustive list of types that will not be supported at phase two go-live: 

  • Delegated Authority, including binders;  line-slips and consortia; Treaty Reinsurance; Verticalised policies; policies with adjustable premiums; and sections with certain premium splits (e.g., multiple perils, insured interests). 

  • These policies must be placed without a CDR and processed manually by Velonetic.

  • If or when these will be supported in the future has not been decided.

The business process market participants will need to follow regarding the CDR

The London Market Group (LMG) Data Council have published their Process, Roles and Responsibilities (PRR) Final Recommendations here: https://limoss.london/prr-final-recommendations

• The PRR Final Recommendations outline two types of submission of CDR data to the Digital Gateway (IROS):

  • Soft call, which can be triggered at any time throughout the placing journey, will allow market participants to check the accuracy and completeness of the CDR data without creating a permanent record.

  • Hard submission, which will allow market participants to submit a complete and accurate CDR and to create a referenced and versioned record. 

  • The Market Journey section of the PRR Final Recommendations outlines how data is collected in a new business journey through the stages of Submission & Quote, Firm Order & Bind (Written Lines), and Signing Down & Contract Completion. As a risk progresses through these stages, more and more fields are expected to be available, with the full CDR data available to be populated at the point of Contract Completion.

• For new placements, hard submission is expected to happen at the point of Written Line for Lloyd’s, and optionally for Company Market Written Lines. This will create a risk record in the Digital Gateway (IROS), which can later be supplemented at Signing Down and Contract Completion. Please see the PRR document  (here) for scenarios.

• In case of an Endorsement (a genuine policy change), Correction (fixing an error in a previously submitted CDR) or Renewal, the CDR will have to be restated and resubmitted. More details are outlined in the Market Journey section of the PRR Final Recommendations. 

• In the Process, Roles and Responsibilities (PRR) Final Recommendations, the CDR Assembly chapter, Key Message 1.1.6., describes the different routes to assemble a CDR: Data-first and Document-first.

  • The Data-first route can happen with or without a placing platform and involves brokers and insurers entering structured data to assemble the CDR.

  • The Document-first route is envisaged as a short-term method, which involves the MRC v3 being submitted to a placing platform, which would then build the CDR, ensure agreement from appropriate parties, and submit it to the Digital Gateway (IROS).

• The recommended broker and insurer responsibilities for assembling the CDR can be found in:

  • The PRR Final Recommendations, CDR Assembly chapter, Key Message 1.1.7., describes the recommended broker and insurer responsibilities for creating and approving the data.

  • The latest CDR specification gives a more detailed view: for each CDR field, the three columns on the right-hand side list the recommended creator, approver, and stage of the journey when each field is expected to be available. The latest CDR specification can be found on the LIMOSS Market Business Glossary (MBG): https://glossary.londonmarketgroup.co.uk/

• If your organisation is a Direct Dealing Insurer (DDMA), i.e., it has an internal broker, then the roles and responsibilities of the internal broker will be the same as those for a standalone broker. Study these responsibilities in the PRR Final Recommendations (https://limoss.london/prr-final-recommendations) and in the latest CDR specification.

• Insurers will be responsible for creating certain fields and for approving certain fields, for example, by entering the fields themselves into a trading platform or by providing them to the broker so that they can add them to the data they are creating. The specific fields they will be responsible for will depend on their role in that policy:

  • Whether they are writing the line as a Lloyd’s syndicate or as a company market carrier, or

  • Whether they are the lead carrier or a follow carrier.

• You should study the field-by-field recommendations carefully to ensure that you understand your organisation’s responsibilities in each of the scenarios in which you are trading.

• In each of the journeys described, the broker is the party who triggers the hard submission of CDR data to the Digital Gateway (IROS). 

  • Even where an insurer who has adopted the CDR and PRR, if they are working on a policy with a broker who has not, there will be no mechanism for the insurer to trigger the CDR submission process. Therefore, this policy will have to follow the phase one journey and be processed without a CDR.

  • Additionally, the process to create and approve the CDR fields requires the participation of all insurers subscribing to a risk. Even if one insurer has adopted the CDR, if they are subscribing to a policy with another insurer that has not adopted the CDR, this policy will not have a complete CDR. It will, therefore, have to follow the phase one journey and be processed without a CDR.

• There is going to be an accredited process for insurers and brokers to create and approve CDR fields, but this process is currently to be confirmed. It is currently unknown whether the process will require placement platforms or APIs or whether traditional methods like email will suffice.

• Velonetic will be able to manually process premium and claims with a missing CDR, just as it does today and will do in phase one. Premium and claims will not be rejected by Velonetic on the grounds of a missing CDR, but this will mean that there is less opportunity to automate, and more of the processing will be handled manually.

Placing platforms and the CDR

• Placing platforms are envisaged to be the main method of submitting a CDR, but not the only method. 

  • Market participants who choose to do so, can elect to submit or retrieve the CDR via direct API to the Digital Gateway (IROS). 

  • With a direct submission, brokers will be obliged to adhere to the accreditation criteria, which are still to be confirmed. 

PPL’s plans for CDR are as follows:

• In Q4 2023, they will pilot their APIs with a small number of brokers. In Q1 2024, APIs are going to become available for brokers, and in Q2 2024, they are going to become available to carriers.

• There will be a CDR API that will enable PPL to submit a CDR to the Digital Gateway (IROS), with a target go-live date in Q4 2024, synchronised to when the Digital Gateway (IROS) goes live. 

• Brokers and carriers will be able to retrieve their completed CDRs from PPL via an API.

• Brokers who are ready to go data first and provide the necessary data via API, will benefit from PPL submitting the complete and accurate CDR on their behalf without any additional effort on the brokers’ part. 

• It is recognised that many brokers will not be able to provide complete CDR data when the Gateway goes live. PPL therefore intend to invoke two services which will be provided by Velonetic: Firstly, a digitiser service which will extract CDR data from the MRC, and secondly, a BPO service which can assist the broker in completing and correcting any missing or invalid CDR data. These services are envisioned to remain in place for an interim period (possibly an extended one) while the entire market transitions to becoming fully digital. 

EBOT, ECOT and supplementary APIs from IPOS and ICOS

• Phase two will also introduce the ACORD EBOT and ECOT standards for submitting transaction and claim information and receiving outputs. The EBOT and ECOT messages allow a more efficient, digital premium and claims journey, and provide a single, global standard across the London and global markets. 

• The new EBOT and ECOT messages will replace the need for EDI messaging in phase two. End-of-day batching of EDI messages will be replaced by transactional EBOT and ECOT messaging throughout the day.

• Velonetic will support the 2016-10 standard. This will be reviewed over time and any changes will be discussed in market consultations. Anything prior to 2016-10 will not be supported, whilst 2016-10 v.2 will be published later this year.​ The specifications for EBOT and ECOT messages can be found on the ACORD website here.

• The supplementary APIs from IPOS and ICOS are designed to provide additional information used by the market today that is not part of the EBOT and ECOT messages. This will be reconciliation information that is currently available in EDI messages, but not in EBOT and ECOT, for example non-fundamental splits and actual payment date (APD). It is Velonetic’s intention that any field available in EDI messages will continue to be available via supplementary APIs from IPOS and ICOS, but it will have to be confirmed once APIs are built.

• Velonetic will provide an updated schedule for publication of API specifications in Sep 2023. Some APIs have already been published and can be accessed on the ASG website. The API specification schedule, as well as instructions on how to access the API specifications, can be found on the Blueprint Two website here: https://www.velonetic.co.uk/blueprint-two/resources 

• You need ACORD membership to access the ACORD GRLC data standards. For managing agents in Lloyd’s, a restricted ACORD licence is already provided to you through LIMOSS, giving you access to the necessary standards. Provided you have already signed an end user license agreement with ACORD, there is no further action you need to take in this regard.

• With the introduction of EBOT and ECOT, the process around Accounting and Settlement is expected to be substantially different from the phase one process:

  • EBOT will split transactions into a Financial Account (FA) and a Technical Account (TA). ​The broker will originate both FA and TA messages, which IPOS and ICOS will automatically process.

  • There will be a cross-reference between FA and TA messages to enable systems to identify that they relate to the same transaction.

  • Velonetic will support cash TAs. This will mean that the broker can send a cash TA, allowing Velonetic to process it through settlement without the need for the broker to submit an FA.

  • EBOT supports payment by instalments, but not deferred instalments, so the Deferred Scheme will no longer be available in the EBOT process. In EBOT, every instalment requires a separate TA and FA to be submitted at the appropriate time (unless a cash TA is submitted). The broker will have to trigger the release of the TA for each instalment as it becomes ready. In EBOT, instalments will show as Additional Premium or Return Premium transactions.

  • In the EBOT process, there will be the option to send Syndicate, ILU, and LIRMA transactions as separate transactions or as a single mixed market transaction.

  • In phase two, Velonetic will still initiate settlement on any agreed claims, but there will be a new criterion of what constitutes an agreed claim: a claim will be considered agreed if it has the following three things: 

    • agreed Claim Movements, 

    • agreed TA and

    • agreed FA.

• This does not necessarily mean that there is an extra manual action on the broker to provide a TA and an FA; some broking systems already have an automated process in place.