Proposed venue · subject to licensing and market interest
The Cuttleflow Marketplace is a proposed placement venue. It is not operating. Cuttleflow Pty Ltd does not hold an AFSL and does not issue, arrange or advise on insurance products. Launch depends on obtaining appropriate licensing and on expressions of interest from brokers and markets.
The Cuttleflow Marketplace Constitution
Draft v2.0 — subject to adoption at launch. Supersedes v1.4 on adoption.
Short form — the nineteen rules the operator would be bound by.
What this document is
The Rulebook (to be published before the venue opens) would tell brokers and underwriters how to use the marketplace. This document tells everyone how we must run it. If the two disagree, this document wins.
These rules would bind Cuttleflow as operator from the day the venue opens. The follow facility described in rule 16 is proposed. It is not operating, and whether it launches depends on licensing and on the binder terms agreed.
01 · Joining
1
Any licensed broker or authorised underwriter can join. We check licence, financial standing and conduct record, and nothing else.
2
Joining requires no equity, no gating fee, no minimum volume and no exclusivity.
3
There is one participation agreement and one published fee card. No participant holds terms that are not on the register.
4
A refusal or suspension comes with written reasons against the published criteria, and an appeal.
02 · What we do and what we charge
5
We charge published venue fees and published programme fees. We take no payment that depends on which participant wins.
6
We do not broke, underwrite, or advise on price or terms in a live placement, and no Cuttleflow role exercises per-risk selection or pricing judgement.
7
The platform assigns the placement format using published logic. We do not set the price.
03 · Conflicts — declared, not prohibited
8
Cuttleflow, its directors, its shareholders and its related companies may hold interests in participants and may participate on the venue. Every such interest goes on the register before it operates.
9
Anyone participating under rule 8 does so on the standard agreement at the standard fees. Cuttleflow people conflicted by it record their recusal from the decision.
10
Where Cuttleflow runs another business that deals with participants, it is named on the register and gets no term, price or information unavailable to an unrelated firm.
04 · Information
11
Reserve prices and client maximums are sealed from the market and from Cuttleflow, except where a published format sets a public price during a placement.
12
Roles with access to live placement data carry no commercial function. Access is logged and reviewed annually by an independent reviewer.
13
Venue data is not available to any other Cuttleflow business. It is enforced in the access architecture rather than left to policy.
14
A participant’s data is theirs. We use it to run the venue and for nothing else without consent. Published statistics are de-identified above minimum group sizes.
05 · Getting in and out
15
A browser is enough to transact. Integration is optional and the interfaces are the same for everyone. Participants can export their own data in a documented format.
06 · The follow facility — proposed
16
The venue would operate one standing follow facility: a single capped pool of committed capacity, attaching automatically to qualifying placements. It would never bid and would exercise no pricing judgement — it would attach at the price the open market has cleared, or at prices mechanically derived from that price under published, pre-set relativities. Risks needing per-risk pricing judgement would fall outside it and be referred to the managing agent. The open market would fill first. Whether it launches, and in what form, depends on licensing and on the binder terms agreed.
07 · Publication and change
17
We keep a public register: fees; every interest declared under rules 8 to 10; the current Rulebook version; and, once the follow facility operates, its cap, backers, protection terms and what we earn from it.
18
Once a year the directors sign and publish a statement of whether these rules were kept, what was breached, and what was done about it.
19
These rules are reviewed once a year and published with the statement in rule 18. A change that loosens a rule is made at that review and published with the reasons for it. Rules can be tightened at any time. No change applies to a placement already under way.
Systems for underwriters, built by underwriters. · 33°53′S · 151°16′E · Sydney