Slaughter and May advised Aviva / Direct Line Group in respect of the Prudential Regulation Authority’s ("PRA") investigation and enforcement outcome relating to an historical miscalculation of Direct Line Group’s Solvency II balance sheet during 2023 and 2024 (predating Aviva’s acquisition of Direct Line Group).
The case is described by the PRA as a landmark enforcement outcome, as it represents the first occasion on which the PRA’s Early Account Scheme ("EAS") has been used to resolve an investigation. The EAS became part of the Bank of England’s enforcement policy for PRA firms and financial market infrastructures in January 2024 and provides for an enhanced discount of up to 50% where firms provide a full account and all relevant material to inform the investigation. Aviva/Direct Line were afforded the full 50% enhanced discount.