This is the FAQs section of the website where we hope that we'll be able to answer any question that you may have about completing an ELTO return for RSA. If you have a question that isn't answered here, contact your usual RSA representative for more information.
What happens to policies cancelled mid-term?
What’s the purpose of the ‘original insurer’ field on the ELTO template?
What do I do if a policyholder has multiple ERNs?
If an Insured comprises of multiple entities with different ERNs, would a separate record be required for each entity?
If a policy covers a policyholder and four subsidiaries, five individual records will need to be sent to the EL database. The first entry will be the parent company and the ‘Policy Type’ field on the ELTO template must be set to 'P' (for parent company). The following subsidiaries will be indicated with 'C' (child company).
Where an Insured comprises of multiple entities but these are not subsidiary companies, will all entities be recorded as the parent record?
Provided that they are all covered under the same policy, the main policyholder needs to be defined and a parent record created. The other parties to the policy should be assigned child records.
If the companies do not share the same EL policy, each must be named as parent companies under their own separate records.
What happens to policies cancelled mid-term?
Currently, the functionality of the database doesn’t cater for cancellations. Instead, we can send a new record with a change in cover end date. However, this will not override the original policy record but instead will indicate a change in the policy by way of the additional record in the policy history.
Additionally, our own system will capture the policy’s cancellation date which we will be able to impart should we receive a claim in error.
What about EL business written from an overseas office on a Freedom of Services basis: would details of these need to be fed through to the ELD?
If the policyholder is based overseas, eg. In the Channel Islands, but has UK subsidiaries, this information must be passed onto the database.
Information on the overseas policyholder should be sent as a parent record with the ERN exempt flag set to 'Y'; UK subsidiaries can be issued as child records with ERN details.
What’s the purpose of the ‘original insurer’ field on the ELTO template?
The original insurer question is to take into account those circumstances where one insurer has taken over or merged with another. RSA will populate this field with information for policies that were initially incepted with either Royal Insurance or Sun Alliance.
Brokers should use the 9999 code in the original Insurer field
What about single rated package policies where a company could automatically receive EL cover as part of a package, despite not having any employees and therefore, no ERN.
This would thus constitute a legitimate ERN exemption where the ERN exempt flag should be set to Y.
ELTO will be running audits to ensure against the abuse of the ERN exempt flag.
What should I do if a policyholder has employees but pays them less than the basic tax allowance, and therefore doesn’t have an ERN?
We would record this as ERN exempt as there is a legitimate reason why they have no ERN.
What about companies that UK with employees but the structure of the company is such that the employees' salaries are paid by foreign-registered company that has separate dealings with HMRC and no ERN?
In these circumstances we would see no alternative other than to record as ERN
exempt status.
As long as the nature of this exemption is well documented we cannot see any issues. If the PAYE is through an overseas company this will be a legitimate exemption and so the ERN exempt flag will need to be set.
A charity using volunteers would still require EL cover but will not have a PAYE reference as volunteers aren’t paid. Are they ERN exempt?
In this situation you would need to show ERN exempt as ‘yes’. However, you need to be careful as many charities do have paid employees in some positions.
What do I do if a policyholder has multiple ERNs?
Please provide all of the additional ERN information and the most relevant will be supplied to the ELD. ELTO are considering specifically how to tackle this issue in the future and once more information is available we shall make it known to you.
How should I deal with subsidiaries with no employees that have been set up by parent organisations for tax or property development purposes?
The EL database should only contain UK companies who have EL insurance so those subsidiaries without should not be submitted to the database.
Some policyholders have employees but outsource payroll operations to umbrella bodies so the ERN supplied will not be in the name of our Insured. What should I do?
As this is not a case where the insured is ERN exempt then the ERN will still need to be supplied despite this not being in the name of the insured.
If an insured says that they are ERN exempt are we expected to do any more than have a sense check based on the number of employees, etc?
Work is underway to establish a set of criteria that can be used to determine whether a policyholder should receive a ERN legitimate exemption, and the results will become part of the new audit process to ensure against abuse of the ERN exempt flag.
You are currently not expected to do any active investigation on your own count.
If a business changes its name part way through a year but effectively remains the same business we would usually amend the Insured’s name on the policy, rather than cancel the policy and issue a new policy in the new name. From an ELTO perspective are there any issues with this arrangement?
No, there would be no issues. ELTO would accept this as a mid-term adjustment which would be applied to the policyholder name as all other details would remain the same.
