Quantum by territory and stream
The $100,743,642 total is built from two concurrent commission streams across three territories. All figures are floors calculated on Aegon's own declared data using a three-phase correction methodology.
The figures on this page derive from one unanswered question: what reinsurance premiums did the Defendants actually receive? The Defendants have admitted the data exists and was not provided to the commission calculation function. No explanation has been provided. These figures are calculated on Aegon’s own declared data — they are a floor. On production of actual bordereaux, all figures will be recalculated upward.
Consolidated summary
| Component | Agreement | Principal | Interest | Total |
|---|---|---|---|---|
| Korea underpayments | EA | ~$16,504,603 | ~$12,200,000 | ~$28,700,000 |
| Japan underpayments | EA | ~$15,456,641 | ~$11,400,000 | ~$26,900,000 |
| Australia — St George / Lumley | EA | ~$5,001,342 | ~$3,700,000 | ~$8,700,000 |
| Australia — CBA | EA | ~$3,003,991 | ~$2,200,000 | ~$5,200,000 |
| EA subtotal — Base Commission | EA | $39,966,577 | $29,490,188 | $69,456,765 |
| CA — Bonus Commission | CA | $16,730,644 | $14,556,233 | $31,286,877 |
| Total claim | EA + CA | $56,697,221 | $44,046,421 | $100,743,642 |
Territory breakdown — EA (Base Commission)
CA — Bonus Commission
Concurrent and cumulative entitlement — not an alternative to EA commission. Applies to the same reinsurance premium stream under a separate contractual instrument.
Base entitlement
Sliding scale reduction on high-volume premiums
Commissions are subject to a sliding scale based on gross premiums collected cumulatively across all territories in each annual period. The 1.75% base rate applies to the first USD $50 million. Commissions reduce on annual cumulative premiums exceeding USD $50 million, and reduce further on premiums exceeding USD $100 million. The first-tier rate (1.75%) applies throughout the periods in evidence — no tier reduction is pleaded as a material adjustment in the current quantum.
One-third reduction from 1 July 2005
Following expiry of the Consulting Agreement on 30 June 2005, Paragraph 5(c) triggered automatically. From 1 July 2005, commissions reduce by one-third — Harrison receives two-thirds of the Schedule 1 commission for as long as premiums continue to be received under the named reinsurance agreements. This two-thirds factor is applied throughout the CA quantum calculation and is a conservative constant in the bundle.
Interest methodology — $44,046,421
Key parameters
Interest is not calculated by applying a single rate to a single figure. Each of the approximately 245 monthly shortfalls carries its own accrual from its own date. The July 2005 shortfall has accrued approximately 245 months of interest. The final shortfall accrues fractionally. The total is the sum of all individual accruals — this is the correct s.100 methodology and is why the interest component is substantial relative to principal.
Three-phase correction methodology
All figures are derived by applying three sequential corrections to Aegon's declared data. Each phase is contractually required — not a modelling choice.
Cohort aggregation — Old + New = ALL
All premium cohorts are aggregated. Aegon's restriction to "new" cohorts only is reversed. This is the most significant correction by quantum. (Claim 2)
Lapse rate normalisation
Aegon's admitted decay factors (Japan ×0.99/month, Korea ×0.982/month, CBA ×0.9865/month per CC-10) are replaced with published industry-standard lapse rates (KLIA / LIAJ / APRA), increasing the cumulative commission base across the 20-year period.
Rate correction
Contractual rates applied (1.875% EA; 1.75% CA base rate before deductions). Korea: rate restored from 0.375% to 1.875% — the reduction is void under EA Clause 20 and GPR-TIMAP s.9.6. (Claim 1)
- Part 1 — OverviewTotal claim construction; EA/CA as cumulative not alternative streams
- Part 2 — EA by territoryKorea, Japan, St George, Lumley, CBA — principal figures and notes for each
- Part 3 — CA by territoryADMS assumed risk percentages; two-thirds run-off factor; all territory breakdown
- Part 4 — Three-phase correction methodologyCohort aggregation, lapse rate normalisation, rate correction — applied territory by territory
- Part 5 — Conservative basis statementFormal certification of the eight constraints suppressing the floor
- Part 6 — Combined territory summaryReconciliation of all territory figures to the locked $100,743,642 total
- Part 1 — Legal basiss.100 Civil Procedure Act 2005 (NSW); RBA + 4% formula; individual accrual per shortfall
- Part 2 — Interest periodJuly 2005 to 25 November 2025; approximately 245 monthly accrual points
- Part 3 — Interest by streamEA interest $29,490,188 and CA interest $14,556,233 — derivation of each
- Part 4 — Why interest is substantialRBA rate history; 20-year accrual period; proportionality analysis
- Part 5 — Simple vs compound interestSimple interest applied; equitable compound interest reserved
- Part 6 — Floor status and ongoing accrualInterest continues daily to judgment; not included in stated $44,046,421
- Part 7 — Rebuttal: Allens "5× greedy claim"Full rebuttal of the anticipated challenge to the interest quantum
- Part 2 — The claim at a glanceTotal construction; interest as ~77.7% of principal — why this is proportionate
- Part 4 — The two claimsEA and CA as concurrent obligations; not alternatives
- Part 5 — Conservative basis certificationFormal statement of all eight conservative constraints
- Part 6 — Correction methodology statementThe three corrections as contractually required — not modelling choices
- Part 7 — Cross-reference map to SOCEach quantum component mapped to its Statement of Claim paragraph number