As many in the insurance industry now know, New York Life Insurance Co. (NY Life) has recently agreed to a $15 million dollar settlement to close its unclaimed property audits. While NY Life has been considered by many to be a role model regarding the proper and proactive use of the Social Security Administration’s Death Master File (DMF), until this point, their lack of a settlement was viewed as a roadblock to moving towards a national standard.
On Friday October 25th, 2013, the National Association of Insurance Commissioners (NAIC) Executive Committee held an open meeting via conference call with a primary focus:
“To review life insurance company use of the Social Security Death Master File or similar databases, including available examination reports and settlement agreements, and determine whether a model law, guideline, regulation or other vehicle should be developed to ensure fair and uniform claims settlement practices with the understanding that this charge in no way interferes with states’ ability to continue to take action with regard to such practices that may be in violation of existing state law.”
I, along with over 100 others, joined that call as an ‘interested party’. Following a roll-call and some brief attention to other matters, the committee immediately moved to close the meeting for private discussion. After approximately 45 minutes of ‘exhaustive discussion’, the interested parties were brought back on the line and advised that the NAIC executive committee will not be taking further action at this time with regard to this matter. In response, the sole comment came from American Council of Life Insurers (ACLI) Senior Vice President of State Relations Bruce Ferguson, who thanked the committee for their consideration and reiterated the challenges of the fractured state of affairs that exist today along with Congress’ recent attempts to limit access to the DMF. Mr. Ferguson concluded by urging the NAIC to give this topic renewed attention as soon as reasonably possible. With no other comments, the meeting was adjourned.
Looking ahead, this reaffirms the clear message that insurers’ must take immediate steps to comply with the myriad of different regulations that have already been passed, while also giving consideration to proactively implementing practices that will satisfy those states that have not yet made their own expectations clear.
The Cross Country Computer perspective remains unchanged. Our strong recommendation is that insurers should be applying a disciplined approach, such as that offered by APEARS® which incorporates fuzzy matching logic that has been drawn directly from the negotiated Global Resolution Agreements and Regulatory Settlement Agreements (GRAs & RSAs), which the states have already accepted. APEARS® layers-in additional screening techniques to help differentiate strong from weak or false positive matches in order to simplify and reduce the cost of an insurer’s downstream research efforts.
The application of a rigorous set of rules can serve as a proxy for insurer “best practice” while we wait for a formal resolution to be established.
Related articles on this topic:
Unclaimed Property: Status quo Prevails
At the request of Nebraska Insurance Director Bruce Ramge, the NAIC plans to reopen discussions about whether the NAIC should develop a formal position regarding life insurers’ use of the SSA Death Master File or other sources to identify unclaimed death benefits: http://www.lifehealthpro.com/2013/11/07/unclaimed-property-back-on-naic-agenda.
For more information on Cross Country Computer’s APEARS® death matching capabilities and to stay informed about other relevant insurance legislation, please contact Thomas Berger at (631) 220-6947 or via email to TBerger@crosscountrycomputer.com.
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