Primer On Civil And Common Law For The Int'l Insurer
Law360, New York ( October 31, 2014, 10:18 AM EDT) -- In large, complex coverage disputes, it is common for international insurers and reinsurers based in a common law jurisdiction to get involved in the adjustment and dispute resolution of claims subject to the laws of civil law jurisdictions in Europe and Latin America. The reverse is also true for European insurers and reinsurers underwriting risks in the U.S. There are significant differences between common law and civil law systems, however, that impact how a claim can be adjusted and insurance coverage disputes are handled. This article provides an overview of some of those differences and identifies specific issues that may arise to assist carriers providing coverage for risks in foreign jurisdictions....
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