2nd Circuit: Arbitrators Retained Right To Clarify Award Against Reinsurer

Mealey's (November 30, 2018, 11:56 AM EST) -- NEW YORK — Recognizing an exception to the doctrine of functus officio where an arbitration award is ambiguous, the Second Circuit U.S. Court of Appeals on Nov. 28 held that arbitrators retained their authority to clarify an award requiring a reinsurer to pay up to an additional $18 million in reinsurance proceeds to an insurer (General Re Life Corp. v. Lincoln National Life Insurance Co., No. 17-2496, 2nd Cir., 2018 U.S. App. LEXIS 33340)....