Article

Factual Summary: Under a reinsurance contract, the reinsurer refused to increase the amount of the letter of credit to cover the insurer's increased reserves, claiming that the insurer miscalculated the amount.

The parties took their dispute to arbitration where the panel, in an award which did not state its grounds, required that the reinsurer post a letter of credit as prehearing security whereupon the reinsurer moved to vacate the order. The court denied the motion.


Legal Analysis:

1. Arbitration: Rejecting the applicant's argument that the arbitration panel exceeded its power in ordering the security, the court concluded that there was a rational basis for the award in the reinsurance agreement, and the award was not in manifest disregard of it. Thus, the award met the test under the controlling Federal Arbitration Act.

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