Prior to the 1990’s Bellefonte Reinsurance Co. v. Aetna Cas. & Sur. Co., 903 F.2d910 (2d Cir. 1990) (“Bellefonte”) decision, the insurance/reinsurance industry operated under the assumption that expenses in addition to loss, unless explicitly excluded, were included coverages under facultative reinsurance certificates. The Bellefonte decision, and its progeny, was a real ‘game changer’. Almost 30 years later, we appear to be returning to the same familiar playing field.