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Thomas Lockley

Partner

CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
London
EC4N 6AF
United Kingdom
Languages English

Thomas Lockley is a partner in the CMS Financial Services team and specialises in advising financial institutions on regulatory matters, and corporate finance and risk transactions.

Thomas advises investment banks, pension funds, private equity, insurers and reinsurers on financial regulation and a wide variety of capital related transactions. He has expertise in corporate finance, insurance, and structured finance (including associated collateral and counterparty risk mitigation techniques), and has experience in CRR and Solvency II-driven transactions.

Thomas is an expert in prudential regulation and capital and advises UK and global (re)insurers (including L&G, PIC, Phoenix, Pacific Life, RGA and Zurich). 

Alongside Jenny Nanalal and Owen Ross, Thomas is part of the Insurance, Risk and Capital Transactions Team, which has been hugely successful, becoming the largest team in the City for bespoke insurance and pensions risk transactions. Thomas is a member of the Insurance Scoping Forum of the Financial Markets Law Committee.

Thomas has more than 15 years’ experience in this area and has worked on some of the largest financial institution and risk transfer transactions in the market (including recently innovative reinsurance structures involving funded reinsurance, funds withheld, and illiquid asset holding and fund structures).

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Relevant experience

  • Legal & General on the conversion into a bulk annuity transaction, of a longevity swap entered into between trustees of a FTSE 100 company pension scheme and the swap provider. This complex conversion was the first of its type, and required the termination of the existing swap arrangements. the collapse of a transformer cell structure and the contemporaneous transition of a portfolio of reinsurances.
  • Pacific Life Re on an onshore and offshore pass through longevity swap transaction including £10Bn of pension liabilities of the Lloyd Bank Pension Scheme.
  • RGA on a EUR7Bn longevity reinsurance of pension liabilities of Aegon.
  • A UK insurer on the financial conglomeration, group capital regulations and Part VII matters in connection with an M&A transaction.
  • A global reinsurer on a commercial mortgage origination and equity release platform and putting in place arrangements for the relevant interests to collateralise reinsurances.
  • International investment banks on the use of credit insurance and risk participations to provide for risk mitigation under the CRR.
  • A global reinsurer on its reinsurance of North American life risk including relating funds withheld portfolio management arrangements.
  • A UK insurance company on the acquisition of a portfolio of unit-linked business including advising on security arrangements over an Authorised Contractual Scheme (the first transaction of its kind) and the associated Part VII arrangements.
  • UK, European and Bermudan insurance companies on capital treatment of assets and liabilities, counterparty risk solutions and matching adjustments under risk based capital regimes (particularly Solvency II).
  • A Bermudan reinsurer on a proxy revenue swap as part of an acquisition structure.
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Memberships & Roles

  • Financial Markets Law Commission
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Education

2001 – MChem, Trinity College, Oxford

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Feed

18/05/2023
CMS advises Legal & General on £2.7bn buy-in with British Steel Pension...
CMS advised Legal & General Assurance Society (Legal & General) on its fourth and final buy-in policy with the British Steel Pension Scheme (the Scheme), totalling £2.7bn, under which the remaining 40%...
04/05/2023
CMS advises Pacific Life Re on c.£1.6bn longevity swap with trustee of...
International law firm CMS has advised Pacific Life Re International Limited (UK branch) (PL Re) on a c.£1.6bn disintermediated longevity swap with the trustee of the Yorkshire and Clydesdale Bank Pension...
07/02/2023
Insurer Resolution Regime will be time- and re­source-in­tens­ive for firms...
HM Treasury is proposing to introduce an Insurer Resolution Regime (IRR). The regime will provide the Bank of England (BoE) with tools to manage the failure of insurance companies. The aim of the proposed...
24/11/2022
Unlocking the potential of Solvency II?
According to the HMT Response, the majority of its proposals were supported by the evidence collected as part of the consultation process[3], namely the proposals to: change the calculation of the risk...
23/11/2022
Unlocking the potential of Solvency II?
Few Autumn Statements have been of as much interest to insurers (and annuity insurers, in particular) as the one delivered by Jeremy Hunt on 17 November 2022. With a promise of “unlock[ing] tens of...
05/05/2021
CMS Pensions Briefing | Investment and Risk
Welcome to the first of our new regular briefings on topical issues relating to investment and risk management. In this briefing we explore some key news stories for UK defined benefit and defined contribution...
27/04/2021
CMS Pensions Briefing - Investment and Risk
Welcome to the first of our new regular briefings on topical issues relating to investment and risk management. In this briefing we explore some key news stories for UK defined benefit and defined contribution...
11/12/2020
Court of Appeal overturns the High Court’s decision in Pruden­tial-Rothesay...
Process During a Part VII scheme affected policyholders have to be consulted (but not granted a right of veto or vote), regulatory approval must be sought from the PRA and the FCA and an independent expert...
11/12/2020
Court of Appeal overturns the High Court’s decision in Pruden­tial-Rothesay...
Context Without Part VII transfers the UK life market would be very different. Once a Part VII transfer is effective, it will transfer retail policies, buy-in contracts, reinsurance and other connected...
18/11/2020
CMS advises Pacific Life Re on £3.7bn longevity swap
International law firm CMS has advised Pacific Life Re, a global life reinsurance firm, on a £3.7 billion longevity swap transaction with the Trustee of the Prudential Staff Pension Scheme. The longevity...
12/03/2020
Insurance 2020: Insurance Company Investment and the Prudent Person Principle
“No other protection is wanting, provided you are under the guidance of prudence” Juvenal, Roman poet Since the implementation of Solvency II, insurance companies have had great flexibility to determine...