Frequently asked Questions
1. What are the consequences of not having a complete CDR?
The automation and simplification of risk premium technical accounting (and related tax and regulatory reporting for Lloyd’s Market) will not be achievable. Processing will require manual intervention by central services. This will cost more and take longer.
2. What happens if I complete the required elements of the CDR as lead insurer, but the follow markets do not? Will I still have to process the risk manually?
This represents an incomplete CDR scenario (see Q1).
3. How will queries raised on data required in the CDR be managed? Who is responsible for responding to queries?
The party who created the data will be responsible for dealing with any questions or queries raised by the party responsible for approving the data. Errors identified by the Digital Gateway Service validation will be returned to the source of the CDR submission. This source platform will be required to orchestrate the error resolution process and pass it to the relevant party for their review and corrective action.
4. If I am trading directly with another market participant and one of us sends the CDR via API to the Digital Gateway directly, how will the Gateway know that the correct sequence of presentation and agreement has taken place?
The ‘how’ is out of scope of the PRR Working Group and the consultation. However, for a CDR to be submitted, it will be required to have gone through a presentation and acceptance process. This will form part of the accreditation process for all submitting systems/platforms.
5. If the Technical Account (TA) contains information that is lacking from the CDR, can the data in the TA be used to complete the CDR?
No, it is the intention that the ACORD Technical Account submission will be validated against a complete and valid CDR which contains data that the broker and all carriers on risk have agreed at the time of the CDR submission to the Digital Gateway.
6. How will non-structured data be added to the CDR e.g. Schedule of Values (SOVs)?
This is a matter for the accredited system/platform operators to decide with their customers. What’s important is clarity on which party is responsible for creating the data from information sources they have in their possession.
7. Will an incomplete or invalid CDR impact the ability to effect a valid contract of insurance?
No. If errors are detected by Gateway validation with the completeness &/or validity of the CDR, this does not impact the contract formation.
8. How will non-bureau carrier lines written as part of a risk be handled in CDR processing?
Non-bureau lines should not be included in the CDR submission to the Gateway. If they are, they will be rejected by the Gateway validation. The Gateway Service operates to support businesses to be transacted using central Digital Processing Services.
9. Why has Lloyd’s mandated the submission of the CDR when the Lead Lloyd’s Line is written?
It is important for managing agents to record the insurance contract as soon as it is written and make the data available at the point of bind to drive all necessary downstream processing and reporting. This also provides improved visibility to a near real-time view of business being written which assists Lloyd’s in its market oversight and reporting obligations to regulators on the country/class exposure should there be an immediate need to (e.g. Ukraine). Currently, Lloyd’s gets visibility only once the business has been processed through XIS, which may occur many weeks after binding.
10. How will the data required for the CDR be created and approved during the placement process?
There will be a presentation and acceptance process, orchestrated via an accredited system / third-party placing platform, through which the CDR data will be assembled (created and approved) by the market participants involved. MRC data extraction solutions may or may not be involved depending on the method of CDR assembly in-play.
11. As an underwriter, should I check that all the data included in the CDR is accurate before it is submitted to the Digital Gateway?
Yes, the underwriter(s) involved in the risk need to be confident that the data has been accurately recorded before it is included in a CDR submission to the Gateway. Use of the ‘soft validation’ may assist with this, as may any data assurance processes carriers operate as part of updating policy administration systems with risk data. The underwriters decide how to manage this process and what assistance is required from third-party placing platform or data quality assurance systems they use.
12. As a broker, should I supply all the data that is required in the CDR?
Most of the data, but not all the data. MRC v3 content is an indicator of most, not all, data required for the CDR that the broker is responsible for creating.
Precise information is contained in the CDR Assembly Table
13. How can I ensure the completeness of a CDR for any given risk?
Users can optionally check the completeness of a CDR for any given risk by performing a “soft call” to the Digital Gateway. The response will highlight errors, queries, or missing information for a given risk. This can occur well in advance of written lines or submission of the CDR to the Gateway.
14. Will the CDR apply to non-London Market insurers?
No, unless the non-London re/insurer is a central Digital Processing Services customer. See Q8 also.
1. As a broker, how significant are the changes in the process required to submit a complete CDR?
It depends on how far that broker is on their journey to being a ‘data-first’ operation. No fundamental changes to the Submit, Quote, Bind, and sign Down placement process were proposed. However, what is required is earlier creation and approval of risk data and interaction with the Gateway Service, which validates that data.
2. Can I send the data required to complete the CDR via ACORD placing and pre-accounting standard messages (XML)?
The CDR is using a JSON message standard. If there is an XML-JSON convertor, then it could be used.
3. What happens if a claim is received before the CDR is complete?
If a claim is received before the CDR for the placement is complete, then the claim will need to be validated against the MRC v3 and processed outside of the digital processing services solution.
4. Where will my third party supplier get the necessary information to understand how to implement the CDR submission process?Each third party supplier who wishes to assemble and submit CDRs will need to go through an accreditation process. This will provide information on how to implement the assembly process within their solutions.
There will be an ACORD Implementation Guide available for third party suppliers.
Each supplier should have a dedicated point of contact through the Lloyd’s Market Engagement team, who they can reach out to with any queries.
5. What is the CDR going to be used for?
The main purpose of the CDR is to enable automated digital processing of risk premium technical accounts,Lloyd’s tax and regulatory reporting (if applicable) and automated validation of new claim notifications against a policy record.
6. Why does the CDR have to be ‘irrefutable’?
Automated premium processing is only possible if all parties to the transaction have agreed that the contents of the CDR can be relied on to validate the technical account submission. Avoidance of a situation where a broker or carrier says: ‘that CDR data is not reliable’ is the aim. The CDR also provides the data that will be used to fulfil Lloyd’s tax and regulatory reporting obligations.
7. What is the ‘definitive’ source in the event that the MRC (v3) and CDR do not match?
The MRC (v3) document which forms the basis of the contract with the client. However this entire consultation process aims to secure understanding and commitment to process, roles and responsibilities for ensuring the documentation and CDR data are consistent.
8. If the placing platform I use does not support the CDR, or business is written outside of a placing platform, how will the CDR be submitted?
There will be several methods and platforms available to users, and they can decide which one is most appropriate.
Some options could be:
• Use a placing platform which supports the CDR
• Build your own system/platform, but it will need to get accredited
• Use another service provider.
9. If I use multiple e-trading platforms to complete a single contract with a single Unique Market Reference (UMR), how do I create a single CDR?
You cannot submit the CDR in parts. Therefore, although you can use multiple platforms for any given CDR submission, you will be required to submit the entire CDR up to that point in the process, restating all data from any previous submission(s).
10. What are the benefits of this recommendation for me?
Refer to the Blueprint Two Benefits Framework
11. What happens if the CDR passes validation when submitted, but participants identify that there is something wrong and wish to change the CDR?
For any changes required to a CDR post-submission, an amendment will be required. For more information, please see Placement Theme 6- Amendments (which can be found in the Placement Theme Interactive Pack).