Questions relating to follow the settlements in reinsurance under English law with comparative reference to the laws of Germany and the USA


For the reinsurance markets follow the settlements is a crucial principle. The law has been developing in the most important jurisdictions and this article attempts, by taking key questions, to analyse these developments and differences in the English, US and German jurisdictions.
The analysis indicates differences as well as similarities between these jurisdictions and further that there are areas which are not well settled, in particular allocation of reinsurance losses to the following reinsurer.