LMA INTERNAL AUDITORS COMMITTEE (IAC) FORUM EVENT TUESDAY 16 SEPTEMBER 2014

Transcription

1 LMA INTERNAL AUDITORS COMMITTEE (IAC) FORUM EVENT TUESDAY 16 SEPTEMBER 2014 Welcome / Introductions (Fraser White Amlin) Conduct Risk (Steve Southall and David Sansom Ernst & Young) Effective Internal Audit at Lloyd s (Philip Alexander PKF Littlejohn) Lloyd s update (Neil Griffiths Lloyd s) Q&A session / Round-up (Rob Lamprey Ace)

2 LMA Internal Audit Forum Conduct Risk Briefing 16 September 2014 Steve Southall David Sansom

3 Agenda 1. FCA s Approach to Conduct a) FCA s change in approach to Conduct versus FSA b) Key themes and areas of FCA focus (conduct and financial crime) c) Position of London Market against other insurance and FS markets 2. Lloyd s Conduct Minimum Standard a) Key requirements of the new standard b) Timetable around attestation and implementation of the requirements c) Workshop programme for Challenges and practical approaches for Internal Audit a) Key challenges for business in implementing conduct frameworks to meet regulatory requirements b) Practical approaches: how to include as part of Internal Audit programmes 4. Questions 3

4 1 FCA s Approach to Conduct

5 Regulatory Approach to Conduct The regulator s approach to meeting their objectives has changed over the last 10 years, and regulated firms have had to respond to those changes: Regulatory Approach Rules Principles Risks FSA Handbook ICOBS rules from 2005 Increased emphasis of Principle 6 July 2004 FSA report Treating customers fairly progress and next steps Creation of the FCA Risk based regulator risk not rules based approach Industry Response Legal based approach to Compliance Are we compliant with the letter of the law? Greater operational ownership of compliance More emphasis on measurement of customer outcomes through MI Challenge to apply the tools and technique of risk management to conduct and to be more forward looking Not TCF Mark 2 5

6 Retail and Wholesale Conduct Scope Conduct risk is being defined by areas of regulatory focus and market practice: Lloyd s minimum standards on Conduct and consumer product binders Retail Conduct Conduct risk Wholesale Conduct Focus of FCA agenda in GI market for 2014/15 Delivering fair outcomes Delivering fair value Market integrity Financial Crime Wholesale Customers Fair treatment of customers across the customer life cycle Sales practices Financial promotions Claims and complaints Delegated authorities Data security New products Add-ons Renewal process Product governance Aggregators Market derived income Remuneration & incentives structures Bribery & Corruption/Third Party payments Sanctions Money Laundering Fraud Other FC controls Commercial claims Conflicts of interest Distribution models CASS 5 for brokers Firms must be clear on conduct risks within their business and reflect them within their risk management frameworks so they can measure and manage them adequately and appropriately Page 6

7 FCA Conduct Agenda in 2014/15 The FCA Conduct Agenda FCA focus for 2014/15 In the first year of the FCA s operation in 2013/14 saw a large number of thematic reviews and market studies for the GI market that were mostly focused on retail issues. These covered: Delegated Authorities and TPA controls Claims and complaints handling reviews focused on travel and household policies Conflicts of interest focused on commercial brokers Aggregators (price comparison websites) Renewal pricing Mobile Phone Insurance and Motor Legal Expenses Insurance reviews General Insurance Add-ons (market study) Incentives and remuneration structures Financial crime Key messages Greater responsibility falling on the underwriter (see the recent Stonebridge fine) Key test criteria around conduct risk includes Value for money Poor behaviours Poor controls The FCA Risk Outlook sets out the FCA s focus for 2014/15. The shift is towards assessing wholesale conduct, focus on connection between retail and wholesale participants in general insurance markets, with many retail general insurance products coming from wholesale insurance providers Planned GI thematic work covers: Coverholders Commercial claims Premium finance sold as add-on to core GI product Client money controls Follow up of embedding findings from the MPI and MLEI thematic reviews The following cross sector themes have relevance for the GI market: Clarity of terms and conditions (includes looking at marketing / Fin Proms) Financial crimes controls in C3 and C4 firms Performance management how firms manage performance and incentives of sales staff to reduce risk of mis-selling. Visibility of IT risks (resilience of IT systems) at Board level. Page 7

8 FCA thematic reviews 2014/15 Planned thematic review General insurance Description Implications for insurers: likely areas for FCA review Coverholders Assessment of impact of coverholder arrangements and wholesale distribution chains on underlying retail/sme customers Example of FCA focus on connection between retail and wholesale participants in general insurance markets, with many retail general insurance products coming from wholesale insurance providers Looking at conduct risks of product design, sales and post-sale handling Delegation of authorities for underwriting, claims and complaints Coverholder oversight: due diligence, monitoring (esp. for conduct / TCF), audits, and reporting Cultural indicators Management of outsourcing risk and SLA monitoring Premium finance Review of sales practices and disclosures of insurers and intermediaries selling premium finance alongside GI products Linked to new consumer credit remit Sales practices for combined / packaged products Value of premium finance products sold Commercial claims Review of whether commercial customers expectations are met in the claims process Looking at market integrity and risks of poor consumer outcomes Likely to be focused on SME customers Customer classification for retail, SME and commercial customers End to end claims process for commercial claims, including where intermediated Potentially includes complaints Page 8

9 FCA planned thematic reviews Planned thematic review Cross sector Financial crime controls in C3 and C4 firms Description Work to detect and minimise abusive behaviour Extent of focus on insurance firms unclear Implications for insurers: likely areas for FCA review Could include assessment of a range of FC controls, including sanctions, third party payments, KYC procedures, gifts and hospitality Resilience against cyber attacks Assess and test the Financial Services Critical National Infrastructure's resilience to cyber-attacks FCA working with PRA and BoE Insurers may be included in testing exercise Visibility of IT resilience and risks and Board level Review of how firms manage their own exposure to IT risks and to what extent this is challenged at Board level Testing progression of firm s against 2012 Dear Chairman exercise Joint review with PRA and BoE Level of Board awareness and knowledge of IT risks MI / reporting of IT risks and issues Managing the performance of staff Follow up to incentives thematic Review of how firms manage performance and mitigate mis-selling risk with front line sales teams Sales targets and commission structures for front line sales staff Level of bonus vs. fixed salaries Performance appraisals for sales staff Training and competency schemes Extent of monitoring by Risk Function Page 9

10 Financial Crime Financial crime in scope of the FCA conduct agenda Financial crime mitigation is in-scope of the FCA conduct agenda. The following four areas are current areas of focus: Anti-Money Laundering (AML) FCA Risk Outlook 2014 Firms that look to protect market share may move into new product lines, geographical locations or consumer groups, adopt practices or standards, to the detriment consumers outcomes or their financial crime responsibilities. While new entry into other markets may encourage competition, it could also stress governance and oversight or lead firms to pursue growth strategies which ignore potential financial crime issues associated with their proposed plans. Sanctions Risks, Escalation & Controls Anti-Bribery and Corruption (ABC) Management Attestations FCA Business Plan Our supervisory work on firms anti-money laundering (AML) controls is increasingly focusing not only on whether processes are followed, but also on the quality of judgements about money laundering risk and the firms AML culture. Where we find significant issues, we will continue to intervene, for example by restricting firms high risk business or by taking enforcement action. The JLT fine JLT Specialty Limited 19 December 2013 fined 1,876,000 for an "unacceptable" approach to ABC risks from overseas payments. 10

11 2 Lloyd s Conduct Minimum Standards

12 Lloyd s Minimum Standards MS11 Conduct Risk Lloyd s Conduct Minimum standards will assist managing agents in demonstrating to the FCA that their business will ensure good customer outcomes. The standards cover the following: CR 1: Fair Treatment of Lloyd s Customers CR 2: Role of the Board, Management and Staff CR 3: Product Oversight Group CR 4: Effective and Proportionate Product Controls CR 5: Assessing and Recording Product Risk CR 6: Product Design General CR 7: Product Design High Product Risk CR 8: Obtaining Assurance from Others CR 9: Product Sales CR 10: Product Service CR 11: Product Service Handling and Determining Claims CR 12: Product Service Complaints CR 13: Conduct Management Information* CR 14: Product Review CR 15: Distributor Appointment, review and Audit CR 16: TPAs CR 17: Training CR 18: Miscellaneous (Contract Certainty; Competition law and BIPAR principles; Business Continuity) Timetable and application Standards published July 2014 Become live 1 January 2015 and should be embedded by the end of Conduct MI embedded by 1 January 2016; before then managing agents must use best endeavours using information that they are able collect. CR 1 and CR 2 apply in respect of Lloyd s Customers wherever they are located worldwide. CR 3 to CR 17 apply only in respect of Lloyd s Customers domiciled or registered within the EEA. Elsewhere, managing agents must implement effective and proportionate controls and arrangements for the fair treatment of Lloyd s Customers having careful regard to the conduct requirements and good business practices in the territory in question Lloyd s has also launched a new coverholder approval process and Consumer Product Binding Authority (CPB). This addresses a high risk area in the market of agent s oversight of treatment of consumers by their coverholders and TPAs. 12

13 Workshop programme for 2014 Questionnaire issued 26 August 2014 Due 15 September 2014 Do not agonise over it. Will help with preparing case studies and content of workshops Workshop sessions being arranged Assessing and recording product risk: 23 and 26 September 2014 Corporate culture, Governance, MI: October 2014 Role of the board, management and staff Product Oversight Group Use of MI Training Director briefing: November 2014 Underwriter focused workshop: product design, review and role of distributors: November 2014 Broker workshop: late November 2014 Self-assessment templates to be issued in early November: eight weeks to submit Progress discussions with the FCA on overseas complaints: FCA priority is understanding how overseas complaints are handled in a way that satisfies the aims and objectives of DISP. Lloyd s working on providing further information to the FCA to move the discussions forward. Source: Lloyd s of London, 3 September

14 Conduct Assurance Review Programme 2015 Aim: robust, consistent and proportionate approach to assessing Agents compliance with standards Commencing January 2015 Dedicated Conduct Standards Assurance Team being established (cross-departmental and external resource) Overseen by a new Conduct Assurance Working Group, Chaired by Peter Spires/reports to SRC Work closely with the FCA Timetable and approach Current aim to conduct reviews in 2015 Two concurrent reviews All agents will be reviewed by 2016 Prioritise agents that deal with High Product Risk Commence with Pilot of two agents in Q1 Review process Approximately one month (three weeks notice) Increasing intensity of areas of focus during 2015 Review output RAG rated report Identify good practice as well as gaps Consider agent s implementation plan A lot of work will need agents help to achieve Source: Lloyd s of London, 3 September

15 Timeline 2014 Q Q Q Q Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Pilot 1 Review 5 Review 9 Review 14 Pilot 2 Review 6 Review 10 Review 15 Review 3 Review 7 Review 11 Review 16 Review 4 Review 8 Review 12 Review 17 Review 13 Input CASG pilot selection CASG review prioritisation SCR Pilot Review SCR Review Assurance Review type/intensity SELF assess received Focus in plan & resources, culture and governance (other standards high level review) RC RC FB Also focus on plan progress, Also focus on sales, distribution All standards (ex MI) - Intensive product design and assessment customer-outcome focussed Full (inc. MI) Key: Initiation letter Review CASG meeting Source: Lloyd s of London, 3 September 2014

16 3 Business response and Challenges for Internal Audit

17 Conduct Risk Industry Timeline However, the regulatory change in approach has been driven at a supervisory rather than policy level meaning that different sectors have progressed at different speeds. The London Market is therefore is in catch up mode FCA Dialogue Designing Conduct Risk Framework Implementing Framework Embedding Framework Banks Q Q onwards Ongoing Insurers Q Q and Q onwards Ongoing Beginning London Market The London Market has not had the benefit of early engagement and push from the regulator until Therefore, the design of a conduct risk framework is just beginning approximately 12 months behind other markets. Explicit request from some Supervisors to some firms to develop framework 17

18 Lessons Learned and Challenges Although Lloyd s and the London Market are starting on their journey later than other markets, there is at least the advantage of learning from others. Key lessons and challenges that we have seen include: Approach Conduct risk needs to be considered top down starting with the business strategy and business model. What do we sell, to whom and through what channels? Where do we make money? Given the answers to those questions, where are our key conduct risks and how do we mitigate them? The answers to these questions elsewhere has led to some difficult conclusions stop selling a product and/or using a distributor Risk management framework The FCA expects the tools and techniques of risk management to be applied to conduct. Hence there is an expectation that firms will develop a conduct risk appetite and MI to support the assessment of whether they are in or outside appetite. Other Sectors have found both the definition of a risk appetite statement, and the assessment of where they are, a considerable challenge. Firms may need to revise their risk frameworks to reflect conduct risk. 18

19 Lessons Learned and Challenges (2) Roles & Responsibilities Governance Compliance has often reported at Audit Committee, risk at Risk Committee. Where should it be discussed going forward? At an Executive level, many firms have TCF-type Committees but in many cases these are backward looking Committees that review MI. They need to be more forward looking and encompass a more pro-active management of potential risks through, for example, greater oversight of product development. Firms need to consider governance arrangements over conduct both at a Board and Executive level Control functions Compliance and Risk functions have often been separate departments in firms reporting to different members of the Executive. Terms of reference for these functions do not necessarily reflect conduct risk responsibilities. Given the overlap of compliance and risk firms need to consider roles and responsibilities in the context of conduct risk. In other Sectors we have seen Risk and Compliance functions merge. The roles of Compliance, Risk and Internal Audit need to be agreed going forward Control frameworks Control frameworks need to be updated to reflect conduct risk Training Staff training on conduct will be a key element of any programme 19

20 Lessons Learned and Challenges (3) Management information The area of greatest challenge, not least because of the need to obtain MI from distributors, but also because of a lack of robust data internally. Most banks and insurers are still struggling with this issue. Conduct Risk MI is not necessarily the same as TCF MI there are overlaps, but Conduct Risk MI is typically more forward looking. The mistakes of TCF are still being repeated, i.e. volumes of data, but not enough quality information. Planning Having a plan, and managing it effectively is key both to successful change and to managing the expectations of regulators 20

21 How should Internal Audit approach Conduct Risk Planning Review the FCA s Annual Report and Risk Outlook, as well as other relevant publications such as thematic review reports, to understand the significance of Conduct Risk and incorporate relevant aspects into IA planning Review and understand the Lloyd s Minimum Standards for Conduct Risk Coordinate with Risk and Compliance to understand the 2 nd LOD monitoring reviews planned to assess conduct risk frameworks Establish at what stage (i.e. design, implementation, embedding) the firm is in respect of enhancing or developing the conduct risk framework Execution Incorporate Conduct Risk into the audit universe. Engage the Audit Committee through communication of the Lloyd s Minimum Standards and FCA s approach to Conduct Risk and how it is the focus of its work going forward. Ensure Conduct Risk is in-scope and recorded in the terms of reference for audits covering areas of the business such as underwriting, marketing/financial promotions, claims and complaints handling. Incorporate Conduct Risk issues in audits of any outsourcing arrangements and external parties, such as coverholders and MGAs. 21

22 4. Questions

23 Contacts Steve Southall Head of Insurance Regulatory Advisory David Sansom Director Insurance Regulatory Advisory

24 Effective Internal Audit at Lloyd s A presentation for the LMA September 2014

25 Agenda Effective internal audit in the financial services sector Challenges Management Information / Key Corporate Events Governance and tone at the top Resourcing and it's implications for you Conclusions

26 Background to the Survey 2008 Financial Services Crash Where was Internal Audit? July 2013 IIA Guidance Builds on existing IIA Standards Not insurance specific Proportionate application Viewed as best practice by the Regulator Survey of the market to find out issues with practical implementation

27 Big issues MI and Corporate Events Instances where Internal Audit is being asked to make qualitative assessments We were surprised more people didn t highlight this as an issue Second guessing the Board / more guidance required

28 Governance and 'tone at top' Most respondents (74%) seem happy that they are qualified to look at this area Extremely sensitive issue an easy win for the regulator Independence is critical surprised this didn t come out!

29 Resourcing Structural Issues The London Market Cluster Specialist skills cause a barrier to entry The impact of the recession on Big 4 recruitment 50 managing agents at Lloyd's 50 Heads of Internal Audit 70% of Head of Internal Audit have been in situ for less than 2 years New Profession Last years Evolving role impetus by the CIIA s Guidance But lack of a career structure Where are you going?

30 Changing the perception Head of Internal Audit drives the agenda Valuing adding solutions Existing Team as part of project team Investigations Existing Team / Co-source partner Existing Team Specialist reviews Core compliance reviews

31 The solutions Short term co-sourcing / outsourcing Medium to long-term - Innovative approaches to recruitment From other insurers the status quo From other sectors within the Financial Services Industry From outside the sector Training role for Lloyd s, the CII and the IIAG Medium to long-term - Secondments from within your firms Part of a defined career development programme Re-entry strategies Sponsorship by senior management Training role for Lloyd s, the CII and the IIAG

32 Any questions?

33 Philip Alexander Internal Audit Partner Philip has over 25 years experience of servicing clients operating in the insurance sector. He has experience of delivering both internal and external audit services and has carried out a number of due diligence and forensic engagements. He oversees the firm s internal audit relationships with a number of general insurers. T: M: E: palexander@pkf-littlejohn.com He has excellent technical skills and has presented seminars on financial reporting for insurers and on the impact that Solvency II will have on the internal audit function. He has also written on these subjects with articles appearing in the Post and Insurance Day. A copy of PKF s survey can be downloaded from:

34 This seminar and the accompanying handouts cover topics only in general terms and are intended to give a wide audience an outline understanding of issues relating to accounting applicable to entities in general, and therefore cannot be relied upon to cover specific situations; applications of the principles would depend on the particular circumstances involved. Furthermore, responses given in the seminar to questions are only based on an outline understanding of the facts and circumstances of the cases and therefore do not form an appropriate substitute for considered specific advice tailored to your circumstances. We recommend that you obtain professional advice before acting, or refraining from acting, on any of the contents. We would be pleased to advise you on the application of the principles demonstrated at the seminar, or on any other matters, to your specific circumstances, but in the absence of such specific advice, we cannot be responsible or held liable. PKF Littlejohn LLP is a member firm of the PKF International network of legally independent firms and does not accept any responsibility or liability for the actions or inactions on the part of any other individual member or correspondent firm or firms. PKF Littlejohn

35 < Picture to go here > IAC Forum Lloyd s update 16 September 2014 Lloyd s 35

36 Agenda Minimum Standards Solvency II Questions Lloyd s 36

37 Reminder of why we did this. The overall objective is one set of standards covering all requirements for Managing Agents: A clear framework within which all Managing Agents are expected to operate Claims management Risk management Solvency II Internal model tests & standards & Pillars 1,2 & 3 Consistency in interpretation, presentation and Underwriting management Brand & reputation Governance publication Alignment to Solvency II Management of investment risk Effective operational processes Lloyd s 37

38 ..and this is how it looks now CODE MS1 MS2 MS3 MS4 MS5 MS6 MS7 MS8 MS9 MS10 MS11 MS12 MINIMUM STANDARDS NAME Underwriting Management Claims Management Governance Risk Management Scope, Change and Use Modelling, Design and Implementation Validation Investment Management Reserving Regulatory Conduct Risk Operating at Lloyd s Lloyd s 38

39 What has changed Clear definitions for each element have been adopted as follows: Element Definition Standard Group Groups of standards, generally aligned to Lloyd s technical review teams. Standard A brief statement of capability or level of conduct required. Requirement A sub-set of requirements that specifies key areas that must be addressed in meeting the standard. Lloyd s will seek positive assurance that each requirement has been met. Guidance Explanation of how Lloyd s will assess whether standards have been met as well as potential ways of achieving this. These definitions have enabled consistency in presentation and interpretation within each standard and made very clear which of the elements above are mandatory and which are purely guidance. A user friendly and consistent format and structure has also been adopted across all standards. Lloyd s 39

40 Existing standards that have been refreshed Underwriting Management General update to reflect current practice. Relevant Solvency II requirements included. Claims Management One of the more recent sets of standards to be published. Very few changes in relation to market practice or Solvency II. More clearly linked to other relevant standards e.g. Governance. Risk Management Significant Solvency II requirements added. A number of additional Solvency II sections added e.g. ORSA. Governance Relevant Solvency II requirements added. Formalisation of a number of areas of general market practice e.g. requirement for two independent non-executive directors. Investment Management Standards only recently published. Update to reflect relevant Solvency II requirements e.g. Use Test. Reserving Standards had previously been through extensive consultation process through LMA CALM. Refresh has involved re-formatting of existing standards into a consistent format with the others. Lloyd s 40

41 Standards driven by Solvency II requirements Modelling, Design & Implementation Scope, change and use Technical modelling standards of Solvency II: Statistical Quality Methodology Calibration Actuarial aspects which form a critical element of internal model approval. Qualitative aspects of internal model covering: Internal Model Scope Model change Use of the model Validation Covers the process and activity to validate the output of the internal model. Governance and reporting of validation to support the use of the model to make key business decisions. Standards derived from the SII level 2 text Allows managing agents to use as part of their continuous compliance with SII Mapping of IMAP to standards by E&Y Lloyd s 41

42 Other new standards Operating at Lloyd s Replaces the previous Operational Processes standard. Covers any organisational element of a Managing Agent which are not covered by other Lloyd s standard e.g. HR, IT etc. Regulatory Reflect the need to meet all regulatory requirements within areas in which Lloyd s operates. A number of these elements were previously included at a high level in the Operational Processes standard. Increasing importance as we deliver Vision Conduct Risk Developed to meet the regulatory requirements as issued by the Financial Conduct Authority. Whilst feel new they were previously included but at a higher level Reflect both current regulatory and ethical behaviours Alignment with Vision 2025 Lloyd s 42

43 Conduct Risk Questionnaire issued 26 August and due 15 September Workshop sessions: Workshop Assessing & recording product risk Corporate culture, governance, MI (inc. role of the board, management & staff, Product Oversight Group, Use of MI, Training) Director briefing Underwriter focussed workshop (product design, review and role of distributors) Broker workshop When? 23/26 Sept October November November November Self-assessment templates to be issued in early November with 8 weeks to submit Lloyd s 43

44 Compliance with standards Launch 1 July 2014 versus 1 January 2015 compliance No change in the requirement to meet those standards which have just been updated What does failure to meet a standard mean? Regulatory vs Solvency II Regular review by SAG Planned self-assessments post 2014 will be published as part of 2015 plan. Lloyd s 44

45 Current minimum standards under review MS1 (Underwriting) and MS2 (Claims) self assessments spreadsheets issued Monday 3 September workshops 12 September and 3 October submission of completed self assessments by 1pm 24 October Conduct Risk (MS11) kick off session held 3 September workshops on 23 and 26 September specifically looking at assessing and recording conduct risk self-assessment to be issued early November Lloyd s 45

46 Agenda Minimum Standards update Solvency II Questions Lloyd s 46

47 Lloyd s is abuzz with Solvency II activity LIM IMAP submission April 2015 Complex project plan and delivery A number of workstreams, including the Syndicate Workstream Additional resources Ongoing PRA interaction in the lead up to April 2015 Current SCR and Validation report submissions and reviews Key Lloyd s process for assessing Solvency II compliance SAG meetings and SII agent ratings Ongoing through September Prudential Measures Interaction between CPG and SAG PRA interaction PRA Panel meetings for 30 agents in the sample but implications for all agents Lloyd s 47

48 Reminder of the prudential measures Syndicates rated Red shall be subject to a 20% loading to the final capital assessment Syndicates rated Amber shall be subject to a 10% loading to the final capital assessment following the CPG process for applications for release of funds from Lloyd s This will be reassessed in Q1 2015, leading to either alignment with red agents (full 20% loading for release or injection of capital), or its removal Application of prudential measures will be determined after final SCR and Validation reports have been submitted and reviewed but before the capital approval deadline dates non-aligned syndicates: 24 October 2014 aligned syndicates: 21 November 2014 Lloyd s 48

49 Lloyd s interaction with the PRA 30 managing agents in the sample PRA Panel meetings from June to October PRA Supervisory Teams meeting with Lloyd's teams Followed by feedback letters In most cases, PRA will look to Lloyd s to follow up feedback points Increased PRA interaction at all levels of the Lloyd s Solvency II programme Syndicate Workstream is material to Lloyd s Internal Model approval PRA need to be comfortable that Lloyd s process is robust We are expected to be able to justify agent SII ratings Understand any differences of opinion Regular meetings with the PRA s LIM review team Lloyd s 49

50 December attestation requirements By end October Lloyd's will provide an updated schedule of SII status to each agent Please note the requirement to submit: Model Change Policy Model Scope Policy Validation Policy Data Management Policy Lloyd s will review all agent submissions during Q and will continue to work with agents during Q to assess and monitor the closure of any remaining gaps in the lead up to the LIM IMAP submission in April Lloyd s 50

51 Lloyd s 51

52 Q&A session / Round-up Rob Lamprey Ace