Business Plan BERMUDA MONETARY AUTHORITY Bermuda Monetary Authority

2015 Business Plan BERMUDA MONETARY AUTHORITY Bermuda Monetary Authority

Contents

01 CEO Introduction

03 Supervision

09 International Developments

11 Operations and Resourcing BUSINESS PLAN 2015

CEO Introduction

In at least one respect, I am disappointed with a “result that seems to place the Bermuda Monetary Authority at a crossroads.” The 2015 Business Plan manage the impact of a short-term stress period. clearly indicates the principal work streams and deliverables The Special Resolution Regime (SRR) is also referenced in the Plan. The SRR that will assist those seeking empowers Bermudian authorities to take guidance on what to expect swift and decisive action in the event of a from the Bermuda Monetary severe economic loss by a Bermuda bank. Primary legislation is due to be completed Authority (BMA) in the year by Q2-2015 with drafts of the subordinate ahead. Rules, Regulations and Codes prepared by Q4-2015. Perhaps predictably, the Plan makes Among our other areas of focus, the clear that we remain fully engaged in the Authority will this year continue to prepare process of obtaining equivalence under for Money Services Businesses, Corporate Europe’s Solvency II Directive prior to Service Providers, developments leading the implementation date of 1st January to an AIFMD regime and the International 2016. It’s worth repeating that the guiding Monetary Fund’s (IMF) assessment of principle of our Solvency II-driven revisions Bermuda’s Anti-Money Laundering/Anti- remains broad alignment with international Terrorist Financing (AML/ATF) regime. The regulatory standards in a risk-based manner IMF assessment is expected to take place appropriate for Bermuda’s market. in 2016. In the captive insurance sector, the Business In many ways, it would appear that the BMA Plan reviews Enhanced Reporting proposals is gearing up for another successful year of for Insurance Classes 1, 2, 3, A and B and achievements. discusses legislative amendments that will be made to streamline the reporting process However, in at least one respect, I am for these entities. disappointed with a result that seems to place the Bermuda Monetary Authority at a The Banking and Asset Management section crossroads. of the Plan explains the prudential liquidity standards that will be put in place to focus Recently, we had begun to feel that in 2015 on the Bermuda banking system’s ability to we would be celebrating our progress and

1 Bermuda Monetary Authority

There is no question about our unreserved commitment to securing “third-country equivalence under the Solvency II Directive. ” claiming victories. We seemed closer to been paid to European policyholders. Yet we completing some of the biggest projects ever are still treated with suspicion. We still hear undertaken by the BMA. the mantra: Offshore fi nancial centres are a threat to our economies. Solvency II and Basel III had tested us but we were not found wanting. Though I believe it is time for Europe and Bermuda to we have yet to cross the fi nish line on decide whether their relationship can ever be these two deliverables, our people have one built on mutual trust and understanding. performed magnifi cently and our policies There is no question about our unreserved and procedures have proved to be robust. commitment to securing third-country Yes, there are caveats but we are responding equivalence under the Solvency II Directive. to them. Everything we have done and said points to our unequivocal pursuit of this objective. Over the past year, the Authority’s The question is what that relationship, when macroprudential unit added a new task it fi nally matures, will look like in practice. to the list. It began work on a fi nancial stability framework, collaborating with senior In what is likely to become a post equivalent personnel from the Bermuda Government’s environment in Q1 of 2016, the challenge Ministry of Finance with the aim of improving for the BMA will be to decide whether we and strengthening Bermuda’s ability to cope have friends and colleagues in Brussels and with systemic issues. London or whether we should simply assume the worst and recognise that this will always So why do I believe we are at a crossroads? be a strained and uneasy relationship at best The answer, quite simply, is that despite a and a hostile one at worst. massive investment on our part in framework revisions which not only work for Bermuda The crossroads is not where the BMA wants but are designed to secure support from to be. We want, need, sensible working relationships with our counter parties around Europe, we are still fi ghting for survival in a the world. Anything less is unacceptable. world in which international fi nancial centres such as Bermuda are routinely attacked and demonised.

For the last 30 years, Bermuda has Jeremy Cox Chief Executive Ofﬁ cer played a major role in furthering the risk- shifting capabilities of Europe’s developed economies. Billions of dollars of risk have been moved from Europe’s balance sheet to Bermuda’s. Billions of dollars in claims have

2 BUSINESS PLAN 2015

Supervision

Quality supervision: Balancing international equivalence with SUMMARY OF SUPERVISORY ACTIVITIES 2015 local pragmatism Having surpassed major milestones in two Banking and Asset • Implement Basel III standards international insurance assessments last Management • Continue the development of an AIFMD ‘opt-in’ year, the Authority does not plan to rest on its regime for Bermuda laurels in 2015. Instead, its focus this year will • Update the regulatory framework for investment largely fall on the development of updated and businesses enhanced regimes in the banking, corporate • Enact Special Resolution Regime legislation and payment services and asset management sectors. As always, these new regimes will seek to adhere to international standards Insurance • Expand the Economic Balance Sheet framework while maintaining a pragmatic regulatory • Enhance reporting for Insurance Classes 1, 2, environment for the entities which operate 3, A and B in Bermuda. The Authority will also phase in • Further develop the Authority’s Supervisory necessary enhancements to provide effective, Toolkit globally-recognised regulation to one of the world’s most important (re)insurance markets. A quality supervisory environment lies at the Other • Expand the money services providers framework heart of Bermuda’s unique value proposition. • Implement Corporate Services Provider (CSP) In 2015, the Authority will continue to foster regime stability and predictability within Bermuda’s • Continue international engagement efforts vital ﬁ nancial services sector, while still • Prepare for transition to a post-equivalent remaining adaptable and keeping supervisory environment costs at a reasonable level. • Prepare for International Monetary Fund assessment of Bermuda’s AML/ATF regime Banking, Payment Services and • Initiate second AML/ATF National Risk Corporate Service Providers Assessment Basel III implementation: The continuing evolution of banking supervision To further strengthen the resilience of Bermuda’s banking sector, the Authority will implement Basel III measures for Bermuda’s banks in 2015. This work continues from the implementation of Basel I and Basel II global banking standards. Speciﬁ cally, new prudential liquidity standards will be put in place to determine a Bermuda bank’s ability to manage the impact of a short-term stress period. Additionally, in 2015 new capital buffers, which can be drawn down if severe losses are incurred, will be required by banks.

3 Bermuda Monetary Authority

These changes are to preserve prudent capital in Q2-2014 about the regulation of payment regime as well as any amendments that are buffers and liquidity resilience in order to services in Bermuda. likely to be required to the existing Bermuda protect depositors and maintain the stability of Corporate Services Provider (CSP) regime law. Specifi cally, the Authority has proposed Bermuda’s banking sector. implemented that EU AIFM requirements would be The Authority’s Basel III fi nal rules also applicable to those Bermuda fund managers Corporate Services Providers (CSPs) are empower the Authority to designate Domestic- which choose to come under a Bermuda AIFM often gatekeepers into the Bermudian Systemically Important Banks (D-SIBs). In regime via amendments to the Investment fi nancial services sector. In order to maintain this way, the Authority will assess the extent Business Act 2003 and associated Bermuda Bermuda’s quality reputation, the CSP regime to which Bermuda’s banks, collectively AIFM regulations. The Authority’s AIFM work expects these gatekeepers to develop and and individually, pose a degree of material draws, among other things, on feedback promote a culture of good governance via systemic risk to the economy of Bermuda. received from a 2014 Discussion Paper on a robust system of controls. To this end, the This assessment will be based on a range of the matter. Authority will implement the CSP regime in factors including size, interconnectedness, 2015, starting early in the year. New regulatory framework for Bermuda’s substitutability, and complexity. The Authority investment businesses The groundwork is already in place, including will apply a capital surcharge buffer for banks the CSP Act, Guidance Notes and a Statement As part of the Authority’s overall framework designated as D-SIBs. of Principles. The Authority released a CSP enhancements, and mindful of the The Authority believes it is important Code of Practice for consultation in Q4-2014. Authority’s ongoing AIFM initiative, a review to implement international standards In Q1-2015, a public forum will be held to of the Investment Funds Act 2006 (IFA) and pragmatically and has used its discretion to address comments received during this Investment Business Act 2003 (IBA) will set a Leverage Ratio which is appropriate for consultation. The Authority will also release take place throughout 2015. Following an Bermuda’s banks. a Corporate Governance Policy for the CSP appropriate process of industry engagement The publishing of the Authority’s Basel III sector in 2015. and consultation, conclusions regarding fi nal rules in Q4-2014 followed a Consultation recommended amendments to the Acts Paper issued in Q4-2013 and a Discussion in question will be reached by Q4-2015. Paper published in Q4-2011. Asset Management: A promising Principles established by the International Organisation of Securities Commissions Framework for payment services providers future (IOSCO) will also be considered during this Creation of Bermuda’s Alternative Investment The Authority recognises that a safe, reliable review. In addition, a Corporate Governance Fund Managers Directive (AIFMD) opt-in and effi cient payment services system is Code for Investment Funds will be released regime central to the stability of the Bermuda fi nancial in 2015. system. As a result, in 2015 the Authority To further enhance the competitiveness of will continue to review its regulatory and Bermuda’s important asset management supervisory powers in relation to Bermuda’s sector, the Authority will continue to develop an Insurance Supervision: Beyond burgeoning payment services providers sector. Alternative Investment Fund Managers (AIFM) Solvency II This review will ensure that the regulatory regime for Bermuda in 2015. The objective of In 2015, the Authority will continue to interact environment for money services businesses, the proposed new opt-in regime is to facilitate with the European Insurance and Occupational payment services providers and foreign Bermuda’s fund managers’ ability to market Pensions Authority (EIOPA) and the European exchange businesses remains effective, Bermuda funds in the European Union (EU). Commission to work towards full equivalence with especially in light of increased interest by such In 2015, the Authority will issue more detailed Europe’s Solvency II Directive. Specifi cally, the entities to provide new types of services to their consultation on the approach to be taken Authority will: consult on enforcement options for customers. The framework will not only cover as well as draft legislation for the proposed dealing with the parent of a Bermuda insurance Bermuda’s existing money service businesses AIFM regime. group; implement the Economic Balance Sheet but also prospective payment services and This consultation follows the release of regime for agreed commercial insurers; and foreign exchange services. This work follows a a Discussion Paper in Q4-2014 which draft legislation for agreed amendments to the Discussion Paper which the Authority released highlighted key components of the potential Bermuda Solvency Capital Requirement (BSCR).

4 BUSINESS PLAN 2015

Economic Balance Sheet framework implementation of enhanced reporting for limited purpose insurers until 2015, in order to In the absence of any international make revisions to its electronic fi ling platform consensus, the Authority is showing global and models. This work will continue into 2015. regulatory leadership by developing its own Economic Balance Sheet (EBS) framework. Developing the Authority’s supervisory toolkit The fundamental premise underlying the The Authority regularly makes necessary Authority’s EBS framework is that assets and adjustments to its highly technical toolkit of liabilities should be valued on a consistent supervisory reporting mechanisms and in economic basis. This approach should 2015, the Authority will make changes to reduce accounting mismatches and provide its Bermuda Solvency Capital Requirement a more accurate picture of a (re)insurer’s or (BSCR). group’s solvency position, thereby enhancing In addition to changes related to the EBS policyholder protection. framework, in 2015 the Authority will work EBS provisions will apply to Bermuda’s with industry to refi ne the risk sensitivity of the commercial (re)insurers, i.e. Bermuda BSCR. Specifi c changes will include currency insurance groups, Class 3A, 3B and 4 general risk, concentration risk, the risk charge on business insurers, and Long-Term (life cash and cash equivalents and adjustments insurance) Classes C, D and E. for geographical diversifi cation. A trial run on The Authority’s EBS proposal was created in the proposed BSCR changes will take place collaboration with the Association of Bermuda in Q2-2015 alongside the EBS proposals, with Insurers and Reinsurers (ABIR) and Bermuda changes to be effective from year-end 2016. International Long-Term Insurers and The Authority is also expanding its Eligible Reinsurers (BILTIR) by means of Economic Capital schedule to align it with the International Balance Sheet Working Groups. This industry Association of Insurance Supervisors’ (IAIS) partnership will continue with additional Common Framework for the Supervision EBS trial runs, stakeholder meetings and of Internationally Active Insurance Groups Quantitative Impact Assessments scheduled (Comframe). The Authority’s eligible capital for 2015. schedule will also be applied to Long-Term Enhanced reporting for Insurance Classes 1, Classes C and D. 2, 3, A and B Last but not least, in 2015 the Authority will In 2015, the Authority will introduce consult with industry about holding companies the necessary legislative amendments that own or control insurance licence-holders. to streamline the reporting process for Similarly, in 2015 the Authority will consult with Bermuda’s limited purpose (captive) insurers. industry on proposals for enhanced reporting These amendments will implement enhanced around insurers’ usage of Segregated Account fi nancial returns for general business Class 1, Companies. Finally, in 2015 the Authority 2 and 3 captive insurers as well as Long-Term will review its various supervisory tools and (life insurance) Class A and B captive insurers. mechanisms to ensure it continues to provide Enhanced returns will furnish the Authority appropriate regulation of Bermuda’s Special with a more robust statistical dataset about Purpose Insurers (SPIs.) this important segment of Bermuda’s insurance market. In Q4-2014, the Authority advised Bermuda’s captives that it would be deferring

5 Bermuda Monetary Authority Q4 Q3 2016 G Q2 G G Q1 G Q4 G Q3 2015 G G Q2 Q1 SAC reporting consultation on extension of limited purposes proposals reporting limited of on extension SAC consultation classes commercial to IAIS Relationships Capital including (ICS) Capital Standard development, Insurance in Participation B A and 3, 2, Class for 1, le: Implementation ﬁ to Requirement INSURANCE Economic Balance Sheet EBS of proposal review and testing Field Group Working Testing Field and Group Working Development Capital/OwnEligible Funds Capital Rules Eligible existing of implementation from Consultation on issues arising guidance with enhancing to a view published Consultation on draft Rules Bermuda Solvency Capital (BSCR) Requirement BSCR of amendments implementation Consultation and Solvency Equivalence II equivalence in involved Advocacy institutions with European PurposeLimited Reporting Insurer Requirements platform completed ling e-ﬁ and enacted Legislation Adoption of Rules Adoption of Rules Implementation Rules of Implementation

6 BUSINESS PLAN 2015 Q4 Q3 2016 Q2 Q1 G G G G G G Q4 Q3 2015 G G G Q2 Q1 Consultation on Guidance and Code ﬁ nalised Code and ﬁ Consultation on Guidance Investment Regime draft legislation and AIFMD: with market Consult Draft legislation BANKING, TRUST, CORPORATE SERVICES AND INVESTMENT AND SERVICES CORPORATE TRUST, BANKING, Basel III basis on a transitional Implementation Corporate Service Regime Provider implementation regime and Licensing Special Resolution Regime Legislation enacted Corporate Code Governance – Corporate Service Providers Consultation Paper Issue structure Act legislative Funds Investment Act and Business Investment Review Services Payment and Money consultation Follow-up OTHER Macroprudential Surveillance Stability Framework Financial Implementation: and Commencement Enhanced Enforcement Act legislation:Enact Funds powers Enforcement Investment under Financing Laundering/Anti-Terrorism Anti-Money Assessment IMF for Prepare Assessment Risk National 2nd for Prepare

7 Bermuda Monetary Authority

Financial Stability Money Laundering Reporting Offi cers (MLRO) and senior executives across Bermuda’s fi nancial services sector are The objective of Bermuda’s Financial Stability framework planned throughout the year. The Authority will also perform is to identify, monitor and respond to emerging risks in the on-site AML reviews of regulated entities as required. Bermudian fi nancial sector and economy as a whole. The Authority will also revise its Bermuda National Risk The framework has three main focuses: prudential regulation Assessment (NRA) questionnaires in 2015. The revised and supervision; the Deposit Insurance Scheme; and the questionnaire will be sent out to the fi nancial services sector Special Resolution Regime. in Q1-2015. In addition, the Authority will continue to hold The Authority has primary responsibility for the fi rst, namely market briefi ngs regarding the results of the fi rst NRA which ensuring that appropriate resources are allocated to the was conducted in 2013. A public report announcing the prudent regulation and supervision of entities which may results of the fi rst phase of Bermuda’s NRA will be released pose a risk to the stability of the Bermudian economy. in 2015. The Deposit Insurance Scheme (DIS), is due to come online in 2015. A Bermuda Deposit Insurance Corporation has already been established as an independent body to administer and Enforcement enforce the DIS, as well as manage the DIS fund. In 2015, the Authority will continue to exercise its The Special Resolution Regime (SRR) for Bermuda’s comprehensive range of enforcement powers as required. banks, is an initiative that will require preparatory work to be As per previous years, such enforcement activities will range undertaken in 2015. Essentially, the SRR regime empowers from discussions with individual entities, to full regulatory Bermudian authorities to take swift and decisive action in actions. the event of a severe economic loss by a Bermuda bank. In 2015, the Authority will continue to review Bermuda’s Primary SRR legislation is due to be completed by Q2-2015 fi nancial services legislation to ensure it meets evolving with drafts of the subordinate Rules, Regulations and Codes enforcement recommendations as well as principles outlined prepared by Q4-2015. by other international standard-setting bodies, such as the In addition to the fi nancial stability framework, macro- and International Association of Insurance Supervisors (IAIS). As micro-prudential economic issues which could potentially a result of this review, any required legislative amendments impact Bermuda’s fi nancial stability are discussed at regular will be presented to the Bermuda Parliament and Senate in Financial Stability Committee meetings, attended by senior 2015. Industry-specifi c Guidance Notes are scheduled for Authority and Ministry of Finance personnel, as well as release prior to the end of the year. representatives of other relevant local agencies. In 2015, the Authority will introduce enforcement powers into the Investment Funds Act 2006, which will mirror those introduced in other regulatory Acts in 2012. Anti-Money Laundering / Anti-Terrorist Financing Throughout 2015, the Authority will continue to prepare for the International Monetary Fund’s (IMF) assessment of Bermuda’s Anti-Money Laundering/Anti-Terrorist Financing (AML/ATF) regime, which is currently expected to take place in 2016. In 2015, the Authority will meet with Bermuda’s banks, trust, insurance and investment sectors to refi ne its AML risk assessment framework. In addition, outreach sessions with

8 BUSINESS PLAN 2015

International Developments

With an increasingly interconnected global Solvency II Directive. The Authority intends economy, regulators must continue to achieve to achieve full equivalence for Bermuda’s supervisory cooperation and coordination commercial insurance sector regime under the with their counterparts overseas. Trust and Directive prior to the implementation date of cooperation between supervisors has never 1st January 2016. been more vital than it is today. Accordingly, On the other side of the Atlantic, having the Authority’s international advocacy efforts successfully achieved Qualifi ed Jurisdiction will gain additional momentum in 2015. In Status from the National Association of order to develop effective global regulatory Insurance Commissioners (NAIC) in 2014, the proposals, the Authority will continue to Authority looks forward to continuing to develop participate in relevant international standard- important relations with US State supervisors in setting bodies. This will include contributing 2015. Finally, with the International Monetary to the development of the global capital Fund’s (IMF) Anti-Money Laundering/Anti- standards being developed by the International Terrorist Financing (AML/ATF) assessment in Association of Insurance Supervisors (IAIS). mind, the Authority will increase its interaction While the Authority’s international activities will with overseas bodies on the AML front, in be focused primarily on Europe and the US, particular the Financial Action Task Force it is also seeking to deepen relationships with (FATF), the Caribbean FATF (CFATF), the fellow regulators from further afi eld in 2015. World Bank and the International Association Activities will include: active participation in key of Insurance Supervisors (IAIS) in 2015. committees; a range of technical presentations; contributions to emerging global fi nancial policy proposals and market surveys; as well as conducting and participating in supervisory colleges to support the ongoing development of group supervision initiatives of entities in the banking, insurance and investment sectors. In the asset management space, the Authority will hold additional meetings with representatives of the European Securities and Markets Authority (ESMA) to discuss the upcoming Alternative Investment Fund Managers Directive (AIFMD). The Authority intends to maintain a high level of dialogue with ESMA and specifi c EU states as we develop Bermuda’s asset management regime. In 2015 the Authority will maintain its active dialogue with European public bodies, especially the European Commission and the European Insurance and Occupational Pensions Authority (EIOPA). This comes on the heels of a successful Solvency II assessment, affi rming that, with caveats, Bermuda has so far met the criteria for the

9 Bermuda Monetary Authority

In 2015, the Authority will continue to work with organisations around the world on numerous global activities:

INTERNATIONAL ENGAGEMENT HIGHLIGHTS: 2015

International Cooperation • Engage with and provide critical input to the following: the International Association of Insurance Supervisors’ (IAIS) Technical Committee and IAIS Financial Stability Committee; the Insurance Groups Working Group; the Signatories Working Group; the Supervisory Forum; the Macroprudential Policy and Surveillance Working Group; the Capital Development Working Group; the Field Testing Working Group; the Financial Crime Task Force; and the Global Systemically Important Insurers (G-SII) Methodology Task Force. • Participate in a regional shadow banking monitoring exercise conducted by the Financial Stability Board’s (FSB) Regional Consultative Group for the Americas. • Provide Bermuda data to: the International Monetary Fund’s (IMF) Coordinated Portfolio Investment Survey (CPIS); and Securities Held as Foreign Exchange Reserves (SEFER) survey, the Bank for International Settlements’ (BIS) International Locational Banking Statistics survey, and the IAIS’ Global Insurance Market report. • Assist global and regional training bodies, such as the Financial Stability Institute (FSI) and the Latin American Association of Insurance Supervisors (ASSAL) by conducting technical presentations and training seminars for supervisors overseas.

Advocacy • Build upon the National Association of Insurance Commissioners’ (NAIC) Qualiﬁ ed Jurisdiction status granted to Bermuda in December 2014 by strengthening dialogue with US State Commissioners. • Work closely with the European Commission and European Insurance and Occupational Pensions Authority (EIOPA) with respect to the Solvency II equivalence process. • Continue dialogue with the European Securities Markets Authority (ESMA) oriented to the development of an Alternative Investment Funds Managers Directive (AIFMD) ‘opt-in’ regime for those Bermudian investment fund managers wishing to transact with European Union (EU) countries. The Authority will also continue its dialogue with speciﬁ c EU states on this matter.

Supervisory Cooperation • Host and participate in supervisory colleges for the insurance sector. Colleges for the banking and investment sectors were held in Q4-2014. • Explore additional Memoranda of Understanding with regulatory counterparts.

10 BUSINESS PLAN 2015

Operations and Resourcing

Resourcing Technology The Authority will continue to recruit highly- In an increasingly complex regulatory reporting skilled individuals across the organisation environment, the Authority is committed to in 2015, as required. However, maintaining leveraging technology to achieve its supervisory reasonable supervisory costs for the entities objectives. During 2015, a primary goal will we supervise remains a priority. To this end, be development and implementation of the the Authority will increase its focus on utilising Authority’s systems to support improvements resources strategically in 2015, making the to the Bermuda Solvency Capital Requirement, most of in-house talent, particularly in the Prudential Information Return, and Captive areas of risk assessment, macroprudential Risk Return. surveillance and the Authority’s responsibilities The Authority’s applications are built on a stable under the Public Access to Information (PATI) infrastructure that supports the Authority’s legislation which will come into effect on 1st authorisation processing, compliance reporting April 2015. and operational obligations. In addition, a major In terms of staff development, the Authority data and information identiﬁ cation project will will continue its leadership development and take place in 2015 to enhance the Authority’s performance management programmes in reporting capabilities using real time data and 2015. Focus will also be placed on coaching statistical information. The Authority’s records and development opportunities to increase and information management programme knowledge transfer within the Authority. continues to be embedded and further work will be completed in 2015 to fully evolve it into an electronic records management system.

11 Bermuda Monetary Authority

BMA Management Team as at January 2015

Jeremy Cox Chief Executive Officer

Supervision

Craig Swan Graham Lamb Managing Director, Supervision Assistant Director, Insurance Supervision Andrew Gibbs David Lawler Director, Supervision (Insurance) Assistant Director, Insurance Supervision Marcia Woolridge-Allwood Richard May Director, Supervision (Banking, Trust, Corporate Assistant Director, Actuarial Services, Long-Term Services & Investment) Lee Maximchuk David Theaker Assistant Director, Insurance Supervision Chief Actuary, Supervision (Actuarial Services) Moses Muoki Suzanne Williams Assistant Director, Insurance Supervision Deputy Director, Supervision (Insurance) Montgomery Nearon Leanne Alami-Merrouni Assistant Director, Macroprudential Risk Assistant Director, Investment Business & Funds Thomas O’Rourke Collin Anderson Assistant Director, Financial Groups Assistant Director, Insurance Supervision Gina Smith Tamara Anfossi Assistant Director, Actuarial Services, Assistant Director, Trust & Corporate Service Providers Property & Casualty Laila Burke Gary Thomas Assistant Director, Insurance Supervision Assistant Director, Actuarial Services, Long-Term Eric Donkoh Donald Treanor Assistant Director, Insurance Supervision Assistant Director, Actuarial Services, Gerald Gakundi Property & Casualty Assistant Director, Insurance Supervision Christopher Tribley Ricardo Garcia Assistant Director, Investment Groups Assistant Director, Actuarial Services, Property & Casualty

12 BUSINESS PLAN 2015

Licensing & Authorisations Management Services

Shelby Weldon Sheridan Smith Director Director Carlos Lee Deputy Director, Licensing & Authorisations Operations Leslie Robinson Assistant Director, Corporate Authorisations Shanna Lespere Melissa Morton Director Assistant Director, Authorisations Mesheiah Crockwell Akilah Wilson Deputy Director, Head of Human Resources Assistant Director, Licensing Terry Pitcher Deputy Director, Head of Finance & Policy, Legal & Enforcement Currency Operations

Shauna MacKenzie Organisational Development Director Thomas Galloway Verna Hollis-Smith Deputy Director, Enforcement Assistant Director Marcelo Ramella Deputy Director, Policy & Research Communications Ifor Hughes Assistant Director, Policy Roger Scotton Senior Adviser & Head of Communications Leo Mucheriwa Assistant Director, Research Amanda Outerbridge Deputy Director Yvette Pierre Assistant Director, Policy Dina Wilson Assistant Director, Legal Services

13 BMA HOUSE 43 Victoria Street Hamilton HM 12 Bermuda

P.O. Box 2447 Hamilton HM JX Bermuda tel: (441) 295 5278 fax: (441) 292 7471 email: [email protected] www.bma.bm