INSURANCE AND REINSURANCE

Regulation of insurance and reinsurance.

1. Identify the government agencies responsible for regulating insurance and reinsurance companies.

The government agency responsible for the regulation of insurance and reinsurance companies is the Commissioner of Insurance.

2 What are the requirements for formation and licensing of new insurance and reinsurance companies?

Formation of company under Company Act 1991, and then registration with the Commissioner of Insurance under the Insurance
Act, 1998 (the Act) and the Insurance (Company Registration) Regulations No. 14 of 2007 are the relevant requirements.
Section 2(m) of the Act defines insurance business to include reinsurance business.

Section 2(m) states: ‘“insurance business” means the assumption of the obligations of an insurer in any class of insurance business, and included re-insurance business, in Guyana’.

3 What licences, authorisations or qualifications are required for insurance and reinsurance companies to conduct business?

The requirements are:
• the company or association must be solvent;
• the company or association is likely to be able to comply with such provisions of the Act as would be applicable;
• the company or association has made adequate arrangement for reinsurance of that class of insurance business or that there is no justification for making such arrangements;
• the managing director or controller of the company or person in charge of the association is a fit and proper person;
• in the case of a company or association that carries on or purposes to carry on, some other form of business in addition to insurance business, the carrying on of both insurance business and that other business is not contrary to the public interest;
• the name of the company or association is not identical with or does not closely resemble the name of an insurance company or association already registered under this Act as to be likely to deceive; and
• every company or association seeking registration under the Act must pay a filing fee of two hundred and fifty thousand dollars.

4 What are the regulatory requirements with respect to insurance products offered for sale? Are some products regulated by multiple agencies?

Actuarial investigation for long term products is a requirement.
The only agency that regulates insurance products is the Commissioner of Insurance.

5 What are the regulatory requirements with respect to agreements for reinsurance ceded and assumed by insurance and reinsurance companies domiciled in your jurisdiction?

Section 2(m) of the Act defines insurance business to include reinsurance business. Section 2 (m) states: ‘“insurance business” means
the assumption of the obligations of an insurer in any class of insurance business, and included re-insurance business, in Guyana’.

6 What are the regulatory requirements on a change of control of insurance and reinsurance companies? Are officers and directors of the acquirer subject to background investigations?

Section 79 of the Act addresses the issue of changes of management.

Managing directors or their equivalent and controllers of the company are subject to fit and proper investigation.

The Act states:

S.79 (1) No insurer shall appoint a person its chief executive officer, chief
actuary or controller or in the case of an external insurer as a main representative
unless –
(a) the insurer or the external insurer as the case may be has advised the
Commissioner in writing that it proposes to appoint such a person;
and
(b) the Commissioner has before the expiration of three months beginning
with the date of his receiving such written advice, notified the
insurer in writing that there is no objection to that person being
appointed or that period has elapsed without the Commissioner having
served on the insurer a written notice of objection.
S. (2) The Commissioner may serve notice of objection if it appears to
him that the chief executive officer, chief actuary, controller or main representative
is not a fit and proper person appointed to the position in
question.
S. (3) The Commissioner may take account any written or oral representation
made to him by the insurer and the chief executive officer, chief
actuary, controller or main representative concerned in relation to a
notice of objection served or to be served by him.
Section 2(f) defines a controller as a person having the power
directly or indirectly either to direct the management of an insurer
or if that person is a body corporate with shares to exercise or
control 25 per cent or more of any class of voting shares.

7 What are the requirements and restrictions regarding financing of the acquisition of an insurance or reinsurance company?

Sections 56 to 62 of the act read as follows, regarding acquisition, transfer and amalgamation read as follows:

S. 56. (1) An insurer shall not transfer or amalgamate any class of
its insurance business, either in whole or in part, to or with the
insurance business of any other insurer, except in pursuance of a
scheme prepared in accordance with this Part and confirmed by
the Commissioner.
(2) An application for the confirmation of a scheme shall be made to
the Commissioner by or on behalf of any insurer engaged in the
acquisition, transfer or amalgamation, and an application with
respect to any matter connected with a scheme or a proposed
scheme may be made at any time before it is confirmed, by any
person who, in the opinion of the Commissioner is likely to be
affected by the scheme or the proposed scheme.
(3) Where an application is made under subsection (2), the
Commissioner shall set a date not less than two months from the
date of the application for the hearing thereof.
(4) At the hearing of the application the insurer is entitled to appear
and to be heard either through one of its officers or through an
attorney-at-law. The Commissioner may hear such other evidence
as he considers necessary and any person who, in the opinion of
the Commissioner is likely to be affected by the scheme is entitled
to be heard.
(5) In the case of an external insurer, the provisions of this section
shall apply only to the acquisition, transfer or amalgamation of
insurance business relating to policies in Guyana.
S.57 A scheme shall set out the terms of the agreement or deed
under which it is proposed to effect the acquisition, transfer or
amalgamation and shall contain such further provisions as are
necessary to give effect thereto.
S. 58. Before a scheme for the acquisition, transfer or amalgamation of
any class of insurance business of an insurer is confirmed by the
Commissioner –
(a) certified copies of the assets and liabilities of the companies
engaged in the acquisition, transfer or amalgamation shall be
submitted to the Commissioner;
(b) a copy of the scheme together with copies of the actuarial and
other reports, if any, upon which the scheme was founded, shall be
submitted to the Commissioner;
(c) copies of the scheme and of every report submitted to the
Commissioner or summaries of the scheme and reports approved
by the Commissioner shall, unless the Commissioner otherwise
directs, be transmitted to every policy-holder of any class of
insurance business affected by the scheme by the companies
engaged in the acquisition, transfer or amalgamation, at least
fifteen days before the application for confirmation of the scheme
is to be heard;
(d) notice of the.- intention to make the application (the notice to
contain such particulars as may be prescribed) shall, not less
than one month after the copy of the scheme is submitted to the
Commissioner, be published in the Gazette and in such local
newspapers as may be approved by the Commissioner;
(e) the scheme shall be open for inspection by any policy-holder or
shareholder affected by it, for a period of fifteen days after the
publication of the notice, at the office of each insurer engaged in
the acquisition, transfer or amalgamation;
(f) the Commissioner may cause a report on the scheme to be an
independent actuary and shall cause copy of the report to be sent
to each of the companies engaged in the acquisition, transfer or
amalgamation; and
(g) the Commissioner may give directions concerning -
(i) the publication of advertisements of the scheme;
(ii) the giving of notices to shareholders, policy holders or
creditors of the companies; or
(iii) the holding of meetings of any insurer affected arid such
directions shall be complied with by the person to whom they
are given.

S.59. The Commissioner shall not sanction a scheme unless
(a) the provisions of this Part are complied with;
(b) subject to paragraph (c), a number of policy-holders representing
no more than ten percent of the total amount assured in anyone
portfolio involved in the scheme dissent therefrom;
(c) in the case of a group policy, a number of policy-holders
representing not more than twenty-five percent of the total group
in anyone portfolio to which the scheme relates, dissent therefrom;
or
(d) he is satisfied that the acquisition, amalgamation or transfer is not
detrimental to the policy-holders.

S. 60. (1) The Commissioner shall give notice to the insurers regarding
whether he confirms or disapproves of the scheme within one
month of the hearing on the scheme.
(2) When confirmed by the Commissioner, the scheme shall be
binding on all persons and shall have effect notwithstanding
anything in the instruments constituting the insurer or in the
articles of association or in any rules of the insurer. The directors
of any insurer affected by the scheme shall cause a copy of the
scheme to be filed with the Registrar of Companies.
(3) All expenses incurred by the Commissioner in obtaining the .
report of any actuary on the scheme or any other expenses that
the Commissioner has related to approving the acquisition,
amalgamation or transfer shall be defrayed by the companies
engaged in the acquisition, transfer or amalgamation and any sum
due in respect of those expenses may be- recovered summarily as a
civil debt by debt Commissioner from the companies either jointly
or severally.

S. 61. Where any class of insurance business carried on by an insurer
is acquired, transferred to or amalgamated with the insurance
business of another insurer, the insurer to which the insurance
business is acquired, transferred or the insurer carrying on
the amalgamated insurance business shall, within one month
after the acquisition, transfer or amalgamation, submit to the
Commissioner -(
a) a certified copy of the agreement or deed under which the
acquisition, transfer or the amalgamation is effected; and
(b) a statutory declaration made by the Chairman of the Board of
Directors or by the principal representative of the insurer (
i) specifying every payment made or to be made to any person in
respect of the acquisition, transfer or amalgamation; and
(ii) stating that to the best of his knowledge and belief no other
payment, other than those specified has been or is to be made
in money, policies, bonds, valuable securities property of any
description or any other valuable consideration, by or with
the knowledge of any ,parties to the acquisition, transfer or
amalgamation.

S. 62. (1) Notwithstanding anything in its memorandum or other
instruments of incorporation or in its articles or other rules or
in this Act, accompany or association incorporated in Guyana
that has a share capital and that is registered under this Act
to transact long-term insurance business, whether alone or in
combination with any other class of insurance business, may,
with the approval of its shareholders continuing not less than
three-fourths of its share capital and with the permission of
the Commissioner, established and implemented a plan for the
conversion of the company or association into a mutual company
by the purchase of shares of the company or the conversion of the
shares into debentures in accordance with such conditions as my
be prescribed.
(2) A company may be demutualised by means of the procedure
specified in subsection (1).

8 What are the minimum qualification requirements for officers and directors of insurance and reinsurance companies?

The managing director or controller or person in charge must be a fit and proper person.

9 What are the requirements and restrictions concerning the investment in an insurance or reinsurance company by foreign citizens or companies?

Part II of the Schedule to the Insurance (Company Registration)
Regulation No. 14 of 2007 contains the relevant provisions,
which are reprduced below:
1. The application shall specify or include the following:-
(i) Where the information required cannot be supplied on the
application form it should be typed as an appendix on separate
sheets of paper using the same numbering and lettering or sublettering
contained in the application.
(ii) A list of all items submitted with the application and explanations
for omissions, if any.
(iii) The address of the Head Office of the insurer.
(iv) The names of directors and auditors of the company.
(v) The name and address of the main representative of the company.
(vi) For the purposes of these Regulations the main representative
shall be a person resident in Guyana who shall conduct insurance
business at an established branch or agency formed in Guyana on
behalf of the external insurer.
(vii) The name of the actuary of the company.
(viii) The countries in which the company carries on or proposes to
carry out insurance business.
(xi) A copy of the instruments constituting the company or other duly
certified proof of incorporation.
(x) A copy of the articles of association or other equivalent rules of the
company.
(xi) A copy of the latest actuarial valuation report upon the financial
position of the company.
(xii) Proof that the company is lawfully constituted in accordance with
the laws of the country in which it is incorporated.
(xiii) The details of the proposed management structure of the
company including names, designations and reporting lines
of senior management, the underwriting department and the
internal auditor. This should be accompanied by a corporate chart
showing the composition of the group if the company is part of a
group of companies and include details of any related parties and
subsidiaries.
(xiv) A proof that the company , has undertaken insurance business
in the country in which it is incorporated for at least three (3)
years before the date of application and operates as a regulated
institution in the country of its incorporation.
(xv) For companies with shareholders a statement showing the
nominal, subscribed and paid up capital of the company and
details of all major shareholders of the company (20% or greater),
including the exact size of their holding.
(xvi)A letter stating that the company intends to appoint a person
resident in Guyana as its main representative in Guyana and the
name and address of that person.
(xvii) A letter of good standing from the home regulator.
(xviii) The classes of insurance business undertaken by the company
(this should be consistent with the classes defined in Schedule I to
the Act).
(xix) A copy of the latest actuarial valuation report upon the financial
position of the company.
(xx) The specimens of the various standard forms of proposals and
policies to be issued in Guyana, certified by main representative
to be true and correct. A list of an products being sold in other
territories and a brief description of each product if different from
those being proposed to be sold in Guyana.
(xxi) A copy of any applicable reinsurance contracts in effect and in the
absence of these details of what reinsurance arrangements shall be
in place for the company.
(xxii) Completed reinsurance declarations as set out in Form D of Part
III of this Schedule.
(xxiii) A list of agents and other distribution channels to be contracted
and used by the company.
(xxiv) A signed statement by the main representative of the company
that the company has satisfied section 95 of the Act, and in
particular that the company(
a) is satisfied that each agent listed in xvii is a fit and proper and
competent agent.
(b) has considered the suitability of an agent in light of his/her
qualifications.
(c) has considered and taken into account any complaints received
from a proposer or policyholder in relation to the agents
mentioned in the. list furnished against serial number (xxiv)
(xxv) The proof of payment of the filing fee ($250,000 per.company).
(xxvi) Document in support of the fact that the company has made the
required statutory deposits in the prescribed format.
(xxvii) Completed Fit and Proper declarations (as set out in Forms
BI and B2 in Part III of this Schedule) of all applicable persons,
particularly the ‘Fit and Proper’ declaration forms for the
Controllers of the company and for the main representative, where
the main representative is a company, Fit and Proper forms as set
out in Form Bl shall be completed by the board of directors of that
company.
(xxviii) A three year business plan shall be submitted in the forn1at as
set out in Form C in Part III of this Schedule.
(xxix) A detailed breakdown of assets specifying the assets to be used
for the statutory funds (and their market value). The applicant
shall also furnish the particulars of investments and bankers as set
out in Form E of Part ill of this Schedule. An explanation on how
the market value has been derived should also be provided.
(xxx) A list of all business, other than insurance business, carried on by
the company and other members of the group if the company is
part of a group, overseas and local.
(xxxi) The information about the Controller of the company is
required to be furnished. This shal1 include its latest audited
financial statements, and a copy of its articles of incorporation and
association and other relevant rules. If the Controller or any sister
company conducts insurance or any other financial business that
is regulated, a letter of good standing from the home regulator is
required. Letters of good standing from other host regulators are
also required to be furnished.
(xxxii) If a Controller of the applicant is a locally incorporated
company, information about the Controller is required including
its latest audited financial statements, copies of its articles of
incorporation and association or rules. If the Controller conducts
any financial business that is regulated, a letter of good standing
from the official regulator or its equivalent is required.
(xxxiii) If a Controller of the applicant is an individual, he or she is
required to complete a fit and proper declaration as set out in
Form B2 of Part III of this Schedule.
Fit and Proper Declarations

2. The main representative shall be required to personally complete
and sign off a Fit and Proper declaration as set out in Form B2 of
Part III of this Schedule and the company shall provide reasons
for his or her appointment and also seek approval from the
Commissioner.

3. All Controllers shall submit to a fit and proper assessment.

4. The members of the board of directors of the company shall
col1ectively complete and individually sign off the Declaration
Form set out as Form BI in Part III of this Schedule.

5. A shareholder shall not be required to complete a Fit and Proper
declaration provided that the sum total of their shareholding does
not amount to or is less than twenty-five percent (25%) of any
class of voting shares or is a company.

Statutory Deposit

6. In accordance with Part IX of the Act, an insurer shall ensure that
the appropriate deposit is made with the Commissioner.

7. A person is guilty of an offence if he fails to make the deposit
referred to in paragraph 6 with the Commissioner.

10 What are the requirements and restrictions concerning the investment in an insurance or reinsurance company by foreign governments?

Section 21 of the Act provides that only companies or associations
of underwriters registered with and authorised by the
Commissioner of Insurance may carry on insurance business in
Guyana.

11 What are the capital and surplus requirements for insurance and reinsurance companies?

Section 29 of Regulation 15 of 2007 provides:

In accordance with section 39 of the Act and section 14 of the Financial
Institutions Act 1995, the Capital base of an insurance company for the
purpose of these regulations shall be

(i) the total of

(a) the paid up share capital or assigned capital
(b) the paid up share premium
(c) the retained earnings
(d) the asset revaluation reserves arising from a formal revaluation
of an immovable property but limited to one revaluation every
five years and
(e) other capital accounts approved by the Commissioner.

(ii) less the following deductions
(a) the net amount due from head office an down branches abroad
in the case of a registered insurer not incorporated in Guyana

(b) the net amount due from the parent company, subsidiary and
other affiliated companies
(c) deficiencies in provisions for losses on loans and other assets as
may be determined by the Commissioner
(d) any asset revaluation reserves attributed to immovable property
held within the statutory fund and
(e) other deductions as may be determined by the Commissioner
which may impair capital.


12 What are the requirements with respect to reserves maintained by insurance and reinsurance companies?

Pursuant to section 46(5) of the Act, insurers carrying on long term
insurance business in Guyana shall place in trust in Guyana
assets equal to its liabilities and contingency reserves less the
amount deposited on account of the insurance business pursuant
to the Act with respect to policy holders as established by the balance
sheet of the company at the end of its last financial year.

13 What are the collateral requirements for assuming reinsurance companies?

Section 2(m) of the Act defines insurance business to include
reinsurance business.
Section 2 (m) states: ‘“insurance business” means the
assumption of the obligations of an insurer in any class of insurance
business, and included re-insurance business, in Guyana’.

14 What laws govern insolvent or financially troubled insurance and reinsurance companies?

Section 68 of the Act sets for the relevant provisions:

S. 68 (1) An insurer shall be deemed insolvent –
(a) in the case of an insurer carrying on long-term insurance business
and no general insurance business, if the value of its assets does
not exceed the amount of its liabilities, the value of the assets and
liabilities being certified by an independent actuary;
(b) in the case of an insurer carrying on general insurance business
and no long term insurance business, if the value of its assets does
not exceed the amount of its liabilities by
(i) one million dollars or an equivalent sum in other currency; or
(ii) twenty-five percent of its premium income in respect of its
general insurance business in its last preceding financial year,
whichever is, the greater amount;
(c) in the case of an insurer carrying on both long-term insurance
business and general insurance business, if the value of its total
assets does not exceed its total liabilities by the greater of the
amounts specified in subparagraphs (i) and (ii) of paragraph (b); or
(d) until the contrary is proved, if the insurer fails to furnish to the
Commissioner any of the information required by section 30
within the specified time period.
(2) For the purposes of this section –
(a) in computing the amount of the liabilities of an insurer, all
contingent and prospective liabilities shall be taken into account,
but not liabilities in respect of share capital; and
(b) the premium income of an insurer in respect of its general
insurance business in each financial year shall be taken to be the
net amount (after deduction of any premiums paid by the insurer
for re-insurance) of the premiums received by that insurer in that
year in respect of all insurance business of a class specified in
Schedule l.

15 What requirements and restrictions govern the amount of ceded reinsurance and retention of risk by insurers?

There are no specific provisions for amount of ceded reinsurance.

16 What are the licensing requirements for intermediaries representing insurance and reinsurance companies?

Part XV of the Act deals with the requirements for agents and
intermediaries. To wit:

91. In this part, a person who is directly employed by an insurer on
a basis which includes commission on business introduced or
renewed by him is referred to as an agent.
92. (1) No person may carry on insurance business as an agent unless
he is registered to do so under this part.
(2) An existing agent must register within three months of the
commencement of this act.
93. (1) An application shall be made annually to the Commissioner
in the prescribed form and shall be accompanied by evidence of
payment of the prescribed fee and such documents as may be
prescribed.
(2) Each application or renewal shall be accompanied by a filing
fee of two thousand dollars payable to the commissioner.
(3) Upon receipt of the application, the commissioner may request
such additional information as he may consider necessary.
(4) The Commissioner shall not register an applicant as an agent
unless he is satisfied that the applicant is suitable qualified to be an
agent.
94. In carrying out his duties under subsection (4) of section 93, the
commissioner may, at his discretion, delegate his responsibilities to
the Insurance Association of Guyana, or his successors, provided
that the Insurance Association of Guyana
(a) Files its articles or organization and by-laws with the
commissioner.
(b) Is open to membership by all insurers registered in Guyana on a
non- discriminatory basis ; and
(c) Provides a course of continuing education for agents in a
manner satisfactory to the Commissioner.
95. Notwithstanding an agent’s status as a registered agent in Guyana,
it shall nevertheless be the responsibility of each insurer having a
contract with an agent-
(a) to consider whether or not the agent is a fit, proper and competent
person to fulfil the post of agent;
(b) in the case of an agent with whom a contract subsisted prior to the
commencement of this Act to consider whether or not that agent
has been carrying on his insurance business in an efficient manner;
(c) to consider the suitability or continuing suitability of an agent who
has failed or omitted to sit for any examination organized by or on
behalf of the insurer; and
(d) to have regard to any complaint received from a proposer or
policy- holder in relation to an agent.
96. (1) No person shall carry on insurance business as an agent if that
person’s insurance business falls within the definition of broker in
this Act.
(2) Any insurer which transacts insurance business after the
commencement of this Act with an agent in relation to whom that
insurer is aware or ought to be aware that subsection (1) applies
shall be guilty of an offence.
97. An insurer incorporated in Guyana whose insurance business
comprises acting as agent for an external insurer shall, for the
purposes of this Act, be deemed to be a branch of that insurer and
shall comply with the requirements of this Act and shall appoint a
main representative for the purpose of this Act.
98. (1) Every insurer to whom this Act applies shall file with the
Commissioner, along with the documents referred to in section 30,
a list of names and addresses of agents with whom the insurer has
a contract.
(2) It shall be the duty of an insurer to advise the Commissioner in
writing of any -(
a) change in the employment status of the agent; and
(b) of any misconduct or material breach of the agency
agreement between the insurer and any agent, including failure
to pay over premiums.
(3) Where the Commissioner receives any advice under subsection
(2)(b) he shall have the power to require that the insurer
discontinue its association with that agent and that the agent be
banned from serving as an agent in Guyana.
99. (1) Where any agent acts in negotiating or renewing or continuing
a contract of insurance and receives a premium for such a contract
from the insured and fails to pay the premium over to the insurer
within such time after receipt by him as may be agreed between
him and the insurer, less his commission and any other deductions
to which, by written consent, he is entitled, the agent is guilty of an
offence.
(2) Notwithstanding any conditions or stipulations to the contrary,
an insurer shall be deemed to have received any premium received
by an agent appointed by that insurer.
100.No person may carry on or purport to carry on in Guyana the
business of an insurance salesman, sub-agent, adjustor, loss
assessor, insurance consultant, insurance surveyor, or any other
similar function related to the business of insurance unless
registered with the Commissioner pursuant to regulations to be
promulgated by him at such time as he sees fit.


Reinsurance disputes

17 Are formal reinsurance disputes common or do insurers almost always reach business solutions for their disputes without formal proceedings?

Re insurance disputes are rare in Guyana.

18 What are the most common issues that arise in reinsurance disputes?

Reinsurance disputes are rare in Guyana, when they arise, however, they do so in the area of excess of loss under treaty.

19 Can parties to reinsurance arbitrations seek to vacate or confirm arbitration awards through the judicial system? What level of deference does the judiciary give to arbitral awards?

Parties can seek to vacate or confirm arbitration awards under Guyana’s judicial system.

The judiciary would recognise and uphold arbitral awards unless the arbitrators exceeded their jurisdiction or there were errors on the face of the record.

20 Do reinsurance arbitration awards typically include the reasoning for the decision?

Yes.

21 What powers (if any) do reinsurance arbitrators have over non-parties to the arbitration agreement?

None.

Reinsurance principles and practices.

22 Does a reinsurer have an obligation to follow its cedent’s underwriting fortunes and claims payments or settlements in the absence of an express contractual provision to that effect? Where such an obligation exists (whether or not expressly provided by contract), what is the scope of the obligation, and what defences are available to a reinsurer?

There is no obligation to follow a cedent’s underwriting fortunes and claims payments in the absence of an express contractual
obligation.

23 Is a duty of utmost good faith implied in reinsurance agreements?

There is a duty of utmost good faith implied in reinsurance agreements.

24 Is there a different set of laws for facultative reinsurance and treaty reinsurance?

No.

25 Can a policyholder or non-signatory to a reinsurance agreement bring a direct action against a reinsurer for coverage?

No.

26 What is the obligation of a reinsurer (if any) to pay a policyholder’s claim where the insurer is insolvent and cannot pay?

In the event of insolvency the reinsurer is obliged to pay.

27 What type of notice and information must a cedent typically provide its reinsurer with respect to an underlying claim? If the cedent fails to provide timely or sufficient notice, what remedies are available to a reinsurer?

A copy of the underlying policy, application form and perils covered.

28 In the case of multi-year occurrences, such as pollution, how are underlying claim payments or settlements allocated among policy years covered by multiple reinsurance agreements?

There has been no experience of such an event in Guyana.

29 What type of review does the governing law afford reinsurers with respect to a cedent’s claims handling, and settlement and allocation decisions?

There are no specific laws or regulations which provide reinsurers with powers of review of cedent’s claims handling

Insurance claims and coverage.

30. Can a third party bring a direct action against an insurer for coverage?

No. The third party is, however, obliged to notify the insurer of any action commenced against the insured.

32 Can an insurer deny coverage based on late notice of claim without demonstrating prejudice?

When it is within the statutory limitation period, an insurer cannot deny coverage .