In 1990, the Second Circuit in Bellefonte Reinsurance Co. v. Aetna Casualty & Surety Co., 903 F.2d ‎‎910 (2d Cir. 1990), affirmed a District Court judgment that reinsurers were not obligated to pay ‎additional sums for defense costs over and above the limits of liability specified in a facultative ‎reinsurance certificate. Since then, the Bellefonte rule acted as a de facto cap for both indemnity and ‎expense under a facultative certificate. This issue of ‘limits’ had been hotly contested, and Bellefonte ‎seemed to put it to rest. ‎

The global reinsurance landscape is an interconnected, intertwined marketplace that continues to grow and evolve. As insurance companies, agencies, program administrators and other industry actors continue to expand their creative horizons and develop innovative insurance products, the need for reinsurance coverage has accelerated as well.