The importance of Difference in Conditions (DIC), Difference in Limits (DIL) and Financial Interest Coverage (FINC) in international programs

Along with the opportunities of operating on a global level – such as increased trade with diverse markets, economies of scale, increased collaboration, and shared resource potential to mention a few - multinational companies with assets around the world face a changing exposure landscape which brings new challenges.

For example, cyber-attacks, supply chain disruption, climate change and natural disasters, the pandemic and ongoing economic upheaval. In this ever-changing global risk landscape, it's imperative that you have consistent coverage across your international program worldwide to protect your commercial activities.

As a risk manager there is increased pressure from the C-Suite to have control of the risks facing your business. This is particularly important with the increased frequency and severity of global events, from floods and factory fires causing business interruption and Supply Chain disruption. These events can quickly lead to difficult questions about whether the business is covered for the fallout of these events and the impact on the companies’ P&L. 

So how can you answer that call with confidence – and ensure there are no surprises?

Knowing exactly what is covered in every local policy, and the respective limits and conditions, is unrealistic. There are almost 200 countries worldwide, each with their own language, culture, and legal system, and virtually all with their own insurance rules and regulations.

This is where international insurance programs with DIC/DIL cover can prove invaluable.

A quick recap on the structure of international programs

International programs can be structured in different ways, but here we’re looking at those that have local policies in each of the territories where you’re active, backed by a master policy which is placed in the country where you’re headquartered.

In most cases, and particularly for Casualty and Financial Lines programs, the master policy will offer wider cover and higher limits than the local policies.  This additional cover can complement what’s provided by your local policies.  With Property programs, customers typically aim to replicate the master policy as closely as possible into the local policies, although DIC/DIL can still play an important role where local regulations restrict certain coverages.

One way master policies achieve this is through difference in conditions (DIC) and difference in limits (DIL) cover.

The local policies will have different conditions and limits to that of the master policy. The DIC/DIL component of the international program gives the risk manager confidence and certainty about the level of cover and limits of insurance they purchased. The overarching aim of an international program is to make sure you get a level of cover globally that matches, to the extent possible, the cover provided by the master policy in your home territory. 

The DIC/DIL clauses are typically in place for what is known as a Controlled Master Program (CMP). This type of program combines a master policy that is issued in the country where the corporation is headquartered and includes a DIC/DIL clause and, with locally issued and admitted coverages in one or more countries across the globe where the corporation has assets and operations. 

What is Difference in Conditions?

The DIC clause in a multinational insurance program enables the master policy, which typically has broader coverage than the local policy, to be triggered when a claim happens if the local policy is not able to respond to the claim. It’s important to note that a local policy must be in place in the country where the claim occurs, otherwise the master policy and DIC clause will not respond. This places increased importance on corporations to consider what local policies need to be purchased especially in countries where non-admitted insurance is not allowed due to regulatory reasons. 

What is Difference in Limits?

This is very similar to the DIC clause – but essentially it says that once the local policy limits are exhausted, the master policy will provide additional limits to respond to the claim up to the amount stated in the DIL clause.

Here we look at some of the features of an international program that enable it to meet the demands of different geographies in order to provide the consistent cover you need globally. 

In the case of DIL, the aim is to provide top-up limits to those set out in the local policy. In the event of a loss that exhausts local policy limits, additional cover can be triggered under the DIL clause in the master policy, assuming it has a higher limit. 

It’s important to note that DIC and DIL cover responds to shortfalls in the local policy when compared against the master and so can’t provide cover if there’s no local policy in place.  

The role of FINC in international programs

Each country will have different rules concerning whether the insurers are allowed to offer cover in their territory. This creates three insurance covers that make up an international program – admitted, non-admitted and financial interest. 

Admitted insurance is where an insurer performs insurance activities in a country where it does have a valid license issued by the local regulator. For example, a local policy.

Non-admitted insurance is when an insurer performs insurance activities in a country where it does not hold a valid license issued by the local regulatory but is otherwise allowed to provide cover under the applicable insurance regulation. For example, no local policy or claims is
covered by local policy.​

Now, imagine you're a risk manager for a company with subsidiaries around the world. What happens if there's a fire at a plant in Brazil, a country which doesn't allow DIC/DIL?

In this type of scenario Financial Interest Cover (FINC) offers a means to reimburse a parent company in respect of losses suffered by its subsidiaries. 

Further Information

Key terms

  • Admitted insurance - cover provided by an insurer licensed to write business and operate in that country.  

  • Non-admitted insurance - cover from an insurer without a local license. Where non-admitted is not permitted, it prohibits such insurers from carrying out any insurance operations in the country including issuing policies, collecting premiums and/or conducting claims handling activities.  

  • Financial Interest Cover (FINC) - A FINC loss is the devaluation of shares of financial interests of the parent company resulting from a loss to its local subsidiary in a not permissible country.

We go into more detail DIC, DIL and FINC considerations in this article

FINC in focus

FINC (Financial Interest Coverage) isn’t a like-for-like replacement for DIC/DIL cover. Instead, it provides cover for the reduction in the financial interest a parent has in a subsidiary as a result of the subsidiary suffering a loss. FINC also offers the parent company a means of compensation regarding losses suffered by subsidiaries in territories where there’s no local policy in place.

Generally, the reduction in financial interest will typically be quantified as what would have been paid to the subsidiary under the master policy if the cover were admitted in the local territory. 

There are two important considerations here:

  • If it is a FINC claim, there is no coverage for loss locally. Handling or quantifying the loss locally must be completed by locally licensed practitioners. 

  • The insured is the parent company and any reimbursement under a FINC claim must be paid to the parent in its home country. If money is returned to the subsidiary, it can trigger legal, regulatory and tax implications so you must be certain as a risk manager to discuss your options with your internal Tax and Legal departments. 

The interplay between local and master policies requires detailed consideration, but it’ll enable you to secure a consistent level of insurance cover across your international operations.  

A special thanks to some of the experts in our network who shared their insights for this piece: 

  • Karen Gorman, Global Services & Solutions Leader Europe, Risk & Broking at Willis Towers Watson
  • Thomas Markert, Head of Strategy and Product Development, German Broking Center Property, Aon
  • Christopher Ueink, Specialist for Property Insurance at Aon Risk Solutions, Aon

You might also be interested our series on navigating claims in international programs, read part 1 here.

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