Member Insured
Employers participating in an East Isles Re policyholder insurance program are not owners or investors in East Isles Re or in the segregated accounts linked to the policyholder insurance program in which they participate. East Isles Re structures each program so that the rights and obligations of each participant are defined in the Segregated Account Program Agreement (“SAPA”) for the particular program in which they are participating. A participant signing a SAPA is a “counterparty” to its designated segregated account and is entitled to all of the rights and subject to all of the obligations of a counterparty as set forth in the SAPA.
East Isles Re’s management maintains a high degree of control over the assets and liabilities linked to a segregated account. Participation in an East Isles Re program is not intended to mirror the rights and control that a participant would have in its own wholly owned captive. Rather, it is intended to be a simplified way to participate in a group captive program. The decreased control is the trade-off for a greatly simplified entry and exit process.
East Isles Re encourages employers seeking a higher degree of control to consider forming their own wholly owned captive. Many employers start in a segregated account program and migrate to a wholly owned captive in subsequent years. East Isles Re will work with participants that want to transition from East Isles Re to a wholly owned captive.
East Isles Re has sought and received a “no action letter” from the Division of Corporate Finance of the United States Securities and Exchange Commission (“SEC”) with respect to this matter.
A copy of East Isles Re’s submission to and the response received from the SEC can be found at:
