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From Resource, February 2006
Copyright by LOMA
This Compliance Report
contains 2 parts:
Part 1, Capital Gains, immediately
below, followed by
Part 2, Comments from
Suppliers
Part
1:
Capitol Gains: Report on Compliance
Federal involvement in insurance regulation is a hot topic in C-suites across
the country. Here’s a status report—and what various proposals mean for
compliance and market conduct professionals.
By Jennifer C. Rankin
Ever
since the Boston Tea Party, Americans have had a love-hate relationship
with big government. Most want broad government involvement to protect their
ability to earn a living, own property, choose a religion and other constitutionally-granted
rights. But they’re also an independent lot who resist being over-managed,
especially by
Washington
.
You
could say the same about financial services and insurance companies, which are
among the most heavily regulated entities in the country.
At
the recent LIMRA/LOMA
Compliance
& Market Conduct Exchange, evolving
regulatory mandates were topic No. 1, with everyone from insurance compliance
officers to representatives from AARP discussing new legislation and offering
practical, hands-on solutions.
The
current business climate for insurers is one of the most challenging in industry
history. They face an increasingly competitive market place with a low projected
growth rate; complex compliance and suitability requirements; heightened data
security and privacy concerns; changing market place expectations; and
increasing customer receptivity to e-business, wireless devices and the
Internet.
Regulators
have their hands full as well. They are working to help insurers meet those
challenges by crafting proposed legislation that will enable insurers to compete
effectively and, at the same time, protect their customers from corporate
mismanagement.
You
could sum up their efforts in two words: conduct and compliance.
What
do we mean by compliance? It is a company’s efforts to adhere to government
regulations, including those designed to require ethical business
practices—that is, proper corporate governance; thwart money laundering;
guarantee consumer privacy; and ensure suitability—that is, that the right
product has been sold to the right client—and irreproachable market conduct
practices.
What
Rules?
It’s one thing to commit
to compliance. It’s quite another to figure out what rules to follow. These
days, both states rights advocates and proponents of federal regulation want you
to support their vision for the future.
At
present, three major proposals to revamp insurance regulation are on the table.
One
is an optional federal charter, which has the full support of the American
Council of Life Insurers (ACLI) and other insurance trade associations.
Another
is the State Modernization and Regulatory Transparency (SMART) Act, which has
been introduced by two Republican congressmen.
Finally,
there is a portfolio of initiatives sponsored by the National Association of
Insurance Commissioners (NAIC). These include the System for Electronic Rates
and Form Filing (SERFF), which provides benefits to the filing process, but does
not address redundancy or uniformity issues; the Interstate Insurance Product
Regulation Compact, which has the potential to address uniformity and redundancy
in the filing process, but only for product approval; and the NCOIL/NAIC Market
Conduct Surveillance Model Act, which has the potential to ameliorate market
conduct exam issues.
Although
they offer different solutions, all of these proposals are efforts to address
the challenges posed by the current state-based regulatory system in the
United States
.
The
states have had the power to regulate insurance for 150 years. As a result,
there is no central authority in
Washington
overseeing insurers. Under state regulation, most insurance writers must
register with each and every state in which they want to do business. This is
expensive and time-consuming for companies that want to do business nationally.
And,
for the first time since the 1930s, banks may now merge with brokerage companies
and both banks and brokerages may own insurance companies, thanks to the
Gramm-Leach-Bliley Act of 1999. Although serious competition has yet to emerge,
many insurers believe it’s on the horizon as their new competitors figure out
the insurance game. Unlike insurers, banks may choose between federal and state
regulation, which gives them an edge.
Let’s
take a closer look at some of the regulatory proposals under consideration at
the moment.
Major
life insurers continue to push—thus far, unsuccessfully—for an optional
federal charter to simplify nationwide filing of products and licensing and to
compete effectively against other financial services providers, especially banks
and international financial conglomerates.
The
optional federal charter offers dual chartering—that is, a system under which
insurers may choose to come under either state or federal regulation, depending
upon their circumstances and business strategies. The optional federal charter
proposal:
*Creates
a new Office of National
Insurers within the Department of the Treasury
*Permits
the organization of national insurers in stock, mutual or fraternal form
*
Allows federal
U.S.
branches of non-U.S. insurers in the same manner as current state
U.S.
branches
*
Allows state-to-federal conversion and
vice versa
*
Allows national life insurers to
introduce new products in all states upon national filing and certification
*
Establishes uniform rules, applicable laws and procedures for a national
insurer
*
Offers tax neutrality
*
Allows for issue of federal producer licenses good in all states and
uniform certification rules.
Those
advocating this system believe it will allow the states to retain much of their
power; allow insurers to sell their products nationally with one—versus
50—contact point and set of rules, which will speed up time to market and
decrease their costs; and place insurers on a equal footing with bank, brokerage
and foreign competitors. Those opposing the system believe it will result in
less effective regulatory oversight, hurt smaller insurance companies, and
dangerously deplete state coffers, which depend heavily on premium taxes,
licensing fees and other income from insurers.
Led
by the ACLI, several national insurance trade associations are looking for a
Senator to sponsor an optional federal charter bill. This has yet to happen, but
momentum is building.
State
insurance commissioners are pushing back, most recently with the NAIC-proposed
Interstate Insurance Product Regulation Compact, which it believes addresses
industry concerns about speed to market and competitive advantage while keeping
regulation under state purview.
At
the start of 2002, NAIC members began to discuss options for achieving true
uniform product filing standards in response to a changing market place that
includes increasing competition from banks and securities firms and the growing
mobility of consumers. It established a working group to identify and analyze
possible options to modernize this regulatory process and make a formal
recommendation. In March 2002, the working group proposed the development of an
interstate compact whereby state insurance regulators would jointly set uniform
product standards and establish a single point of filing for designated
insurance products. If properly structured, an interstate compact would allow
the states to address the issue of state variations affecting product standards.
Throughout
2002, the Interstate Compact Working Group and interested regulators worked to
develop draft language for an interstate compact and received comments from
representatives of the insurance industry and
consumer groups. Eleven draft versions of the model language were developed and
four public hearings were held. During the NAIC’s national meeting in December
2002, members adopted model legislation for the creation of the Interstate
Insurance Product Regulation Compact “for presentation to interested state
lawmakers and policy makers for their review, input, and approval”.
On
July 17, 2003, the NAIC adopted amendments to the interstate compact that
provided clarification of certain provisions. Specifically, the amendments
addressed such items as publishing bylaws, conducting open meetings, making
information regarding the operations of the interstate commission available to
the public, and preserving the authority of state attorneys general. During
their respective annual meetings during 2003, both the National Conference of
State Legislatures (NCSL) and the National Conference of Insurance Legislators (NCOIL)
adopted resolutions in support of the proposed interstate compact. During 2003,
a working group was appointed to begin drafting standards for policy filings.
These are intended as sample products that may be adopted by the Interstate
Compact Commission when it is formed. After a draft of standards for a
particular product is prepared, it is released for public comment. These draft
standards will provide helpful evidence to legislators as to the types of
standards that might be adopted by the Compact Commission.
The
NAIC’s Regulatory Modernization Action Plan, adopted by the NAIC membership in
September 2003, is a commitment by state regulators to continue modernizing the
state-based system of insurance regulation. One facet of the plan is
implementation of an interstate compact. State regulators are urged to work with
state policymakers with the intent of having the Compact operational in at least
30 states or states representing 60 percent of the premium volume for life
insurance, annuities, disability income insurance and long-term care insurance
products entered into the Compact by year-end 2008.
States
that opt into the compact will adhere to an identical set of rules for product
approval. However, 26 state legislatures (40 percent) must do so for the compact
to take effect. Thus far, 20 states have enacted the compact and nine others
expect to consider legislation this year.
The
NAIC also endorses the Market Conduct Surveillance Model Act. NCOIL crafted the
Act in February 2004; later that year, the NAIC got involved and the two
organizations began to promote their first-ever joint model law.
The
model act establishes a framework for insurance department market conduct
actions, including identifying, assessing and prioritizing market conduct
problems; establishing actions and procedures for commissioners to remedy
significant problems; and coordinating communication to make actions by multiple
states more efficient.
This
month, the model act comes up for discussion and reauthorization. During the
past two years, NCOIL and the NAIC have disagreed over two of its provisions.
One is “domestic deference,” under which regulators would be required to
defer to the authority of an insurer’s domiciliary state commissioner before
launching a market conduct exam unless they were able to show cause that a
separate inquiry was necessary. The other is a requirement that requests for
information not collected by insurers in their ordinary course of business not
impose an “unreasonable cost” on the companies. The NAIC opposed both
provisions, which were removed from the model act.
At
press time, industry watchers were wondering if NCOIL would press to reinsert
them in this round of discussions. If so, it may lose NAIC buy in. Resource
will keep you posted as events unfold.
Meanwhile,
in the House of Representatives, Michael Oxley (R-Ohio) and Richard Baker
(R-La.), who chair the U.S. House Financial Services Committee and its Subcommittee on Capitol Markets,
Insurance and Government-Sponsored Enterprises, respectively, have been talking
up their SMART Act, which would deregulate insurance pricing, impose uniform
oversight, and leave enforcement in the hands of state regulators. In brief, the
federal government would set standards and the states would implement them. The
Act has gotten mixed reactions. Some players believe the blend of state and
federal oversight offers the best of both worlds. Others feel the Act not only
offers the worst of both worlds, but also will cause confusion, impose the cost
of a new regulatory entity on the public, lead to high prices, and dilute
consumer rights.
Where
do all of these proposals stand right now? Last year, each seemed to gain
significant momentum. In fact, industry watchers were certain the 109th Congress
would, at a minimum, hold hearings on the future of insurance regulation this
past fall. Many believed Sen. Paul Sarbanes (D-Md.) would introduce a bill to
adopt the optional federal charter during that session. Instead, Hurricane
Katrina hit the gulf coast and Congress had its hands full with media
interviews, fact-finding missions, and community service efforts. No one knows
if this is a temporary blip or if discussions about insurance regulation will
languish throughout 2006.
Industry
watchers are hopeful the debate about federal versus state regulation will not
begin to mirror the contentious rivalry between Republicans and Democrats in
American politics today—that is, that semantics will not trump problem solving
and —dare we say it?—common sense. Lately, however, neutral phrases like
federal oversight, involvement and modernization have given way, on some fronts,
to loaded words like federal incursion, intrusion and interference. The debate
about insurance regulation is complex and emotional and there’s a lot at
stake. Don’t expect that to change any time soon.
While
the debate over state and federal regulation got the most print over the past
several months, other regulatory issues did not languish. Two high profile
matters are the new FinCEN rules regarding anti-money laundering (AML) and
suspicious activity reporting (SAR) and Section 404 of the SarbOx Act.
Wait Over
When President Bush signed
the USA PATRIOT (Uniting and Strengthening America by Providing Appropriate
Tools Required to Intercept and Obstruct Terrorism) Act on October 26, 2001,
insurance companies joined the ranks of financial institutions that must comply
with regulations designed to deter terrorists and terrorist groups from
laundering money through private-sector businesses.
The
PATRIOT Act is counted among other anti-money laundering legislation, including
the Bank Secrecy Act of 1970, which required financial institutions to report
suspicious transactions, and the Money Laundering Control Act of 1986, which
criminalized any attempt to route illegally acquired cash through financial
institutions in order to make the funds appear legitimate. These laws are not
focused strictly on terrorist financing, but on any and all schemes designed to
launder illicit funds.
Title
III of the PATRIOT Act amends the Bank Secrecy Act to promote the detection,
prevention and prosecution of money laundering and financing of terrorism.
Section 352 requires that all financial institutions implement anti-money
laundering programs.
In
addition, the insurance industry already has the obligation to comply with
requirements from the U.S. Treasury Department’s Office of Foreign Asset
Control (OFAC). This agency maintains lists of known terrorists, terrorist
groups, specially designated nationals (SDNs), terrorist aliases, and other
groups or persons against which the
United States
enforces economic and trade sanctions. Insurers must comply with requirements
to check their customers’ names against the OFAC lists of blocked groups or
persons and notify the government if these groups have placed assets with the
insurance company.
At
the LOMA/LIMRA
Compliance & Market Conduct Exchange,
Gary W. Sutton, senior legal advisor for financial crimes, Department of the
Treasury, defined money laundering as converting money gained from illegal
activity into money that appears legitimate so that its illegal source can not
be traced. The activity involves placement (introducing criminal proceeds into
the financial system), layering (distancing money from its criminal source), and
integration (distributing laundered proceeds back to the criminal, thus creating
an appearance of legitimate wealth).
Since
its passage in 2001, financial institutions have been working to meet the
anti-money laundering mandate of Section 352 of the PATRIOT Act. Although
depository institutions have been required to have AML programs since 1987,
they’ve beefed up their efforts. In April 2002, rules were issued for
broker-dealers, futures commission merchants (FCMs), mutual funds, money
services businesses (MSBs), and credit card
systems. In September 2002, a notice of proposed rule making (NPRM) was issued
for unregistered investment companies. In May 2003, an NPRM was issued for
investment advisers. The final rules governing insurers were released just three
months ago.
On
October 31, 2005, the Financial Crimes Enforcement Network (FinCEN) issued two
final rules, requiring certain U.S. insurance companies to establish an
anti-money laundering (AML) program and to file suspicious activity reports (SARs)
in compliance with the Bank Secrecy Act (BSA) as revised by the USA Patriot Act.
The
final rules apply to insurance companies that issue or underwrite certain
products that present what FinCEN calls “a high degree of risk for money
laundering or the financing of terrorism or other illicit activity.” The
insurance products subject to these rules include:
*
Permanent life insurance policies, other than group life insurance
policies
*
Annuity contracts, other than group annuity contracts
*Any other insurance
products with cash-value or investment features.
Along
with group products, the rules exclude products offered by charitable
organizations (such as charitable annuities), term life, credit life, property,
casualty, health, and title insurance, and reinsurance and retrocession
contracts. Contracts of indemnity and structured settlements (including
workers’ compensation payments) also fall outside the definition of “covered
products” for purposes of the final rule.
Insurers
subject to these rules must establish an AML program and start filing SARs 180
days after the date of the publication of the final rules in the Federal
Register. The effective date of the
regulation is December 5, 2005 and it applies to activity occurring after May 2,
2006.
Under
these new rules, insurance agents and brokers are not required to have separate
AML programs. However, companies must integrate them into their programs.
According to Sutton, there are several reasons behind that decision. First,
companies develop and bear the risk of products. Second, companies are better
able to bear the costs of AML programs and to effectively monitor compliance.
Finally, agents often operate independently or in small agencies.
In
their November 28, 2005 e-briefing on the new rules, KPMG experts Fred Donner,
partner and national sector leader for insurance, and Ellen Zimiles, principal
and national financial services industry leader for forensics, emphasize that
“insurance companies have a significant role to play in preventing money
laundering. Money launderers use insurance products with cash surrender value,
stored value, and transferability to mask the movement of criminal proceeds and
to finance crime and terrorism.”
According
to Section 352 of the USA Patriot Act, a company’s AML program must include,
at a minimum, four elements:
*
A compliance officer who is responsible for ensuring that the program is
implemented effectively
*
Written policies, procedures, and internal controls reasonably designed
to control the risks of money laundering, terrorist financing, and other
financial crime associated with its business
*
Ongoing training of appropriate persons concerning their responsibilities
under the program
*
Independent testing to monitor and maintain an adequate program
FinCEN
also requires affected companies to report suspicious transactions over US$
5,000 per individual or in aggregate in funds or other assets.
“Insurance
companies must have systems/processes in place to assist in the identification
and reporting of unusual and potentially suspicious transactional activity,”
write Donner and Zimiles. “Exception reporting processes [should] address the
investigation, escalation and resolution of potentially suspicious activity. A
coordinated response requires identification and investigation of unusual
transactions and accounts; assistance with inquiries from law enforcement and
regulators; and investigative due diligence for customers and counter-parties
involved in transactions.”
FinCEN
plans to continue issuing guidance to insurers, and it operates a regulatory
helpline for questions.
Many
life insurers moved forward with AML programs before the final rules were
published, based on already existing guidelines, and those with affiliated
broker-dealers and proprietary mutual funds must comply with final laws.
On
a more practical level, what does combating money laundering involve? According
to researchers in LOMA’s
Information
Center
, it typically involves:
*Customer
identification. Section 326 of the PATRIOT Act is known as the “know your
customer” (KYC) or customer identification program (CIP) provision. To comply,
financial institutions perform identity-verification checks on their prospective
customers, screening them against OFAC lists of blocked persons and similar
government watch lists. This activity usually requires that an institution
obtain or develop software to check customers’ identities (interdiction
software) and maintain some sort of database for these accounts.
*
Reporting. Anomalous activity
must be reported to regulatory bodies. The
U.S.
government requires suspicious activity reports (SARs) from banks and other
financial institutions; to help companies narrow their reporting focus, there
are thresholds, such as dollar amounts, in place.
*
Auditing. Companies can check to see if their AML processes are
effective by conducting audits, which are usually carried out by independent
specialists. Institutions also check to make sure that their processes do not
discriminate against specific groups.
*
Training. Ongoing regulatory and procedural training is necessary
for staff.
AML
programs go beyond anti-fraud training or procedures. Fraud programs of the past
have tended to focus on payment—either ensuring that the client’s premium
payments clear, or that the insurer’s claims payout is for a legitimately
insured event. But, the definition and activities associated with money
laundering are broader—the perpetrators are looking to “clean” their
illicit funds by storing or transferring them through the financial system.
Thus, knowing the customer and ensuring that systems are in place to
analyze anomalous behavior are much deeper activities that require more than
anti-fraud controls.
(NOTE:
LOMA offers an anti-money laundering course on-line, for details, visit
LOMALearn Online, https://www.lomalearn.org/
)
Mutual
Dissent
Another hot button right
now is Section 404 of the Sarbanes-Oxley Act of 2002. SarbOx requires public
companies in the
U.S.
to shore up their corporate governance with internal procedures designed to
prevent the kinds of financial abuse that took place at Enron and Global
Crossings.
Since
2003, the NAIC has worked toward incorporating some best practices principles
from SarbOx into its Model Regulation Requirement Annual Audited Financial
Reports, which is often called its Model Audit Rule.
The
move has not been without controversy, as SarbOx generally applies only to
publicly-traded companies and those that sell some products regulated by the
Securities Exchange Commission (SEC). The NAIC’s proposed changes to the audit
rule, however, would apply to all insurers, including mutual insurance
companies.
Section
404 of SarbOx is the provision most strongly opposed by mutuals. It requires
senior executives to certify the adequacy of the company’s internal controls
and company auditors to then affirm that management’s assessment is
sufficient.
The
NAIC launched a study of SarbOx applications to the industry in March 2003. A
mock-up of potential changes to the Model Audit Rule was released in 2004, and
the joint NAIC/American Institute of Certified Public Accountants Working Group
is now hashing out the possible incorporation of SarbOx best practices to the
rule. Three subgroups of this working group are tackling specific sections of
SarbOx: Titles II, III and IV.
Insurance
groups and regulators have been debating the pros and cons of the Model Audit
Rule’s changes for over a year. Those in favor of the changes to the Model
Audit Rule believe they will promote a shift to a more risk-based assessment
model, hold publicly-traded and private insurers to the same standards imposed
on the rest of corporate
America
, and minimize the chances for insolvency brought on by mismanagement.
Those
opposed to the proposed changes are worried about implementation costs,
especially for smaller mutuals without the resources of multinational
corporations. A cross-industry study conducted by Financial Executives
International found companies’ total costs for year-one Section 404 compliance
averaged $4.36 million, up 39 percent from the $3.14 million they expected to
pay.
The
National Association of Mutual Insurers (NAMIC) is one of the strongest
opponents of attempts to apply Section 404 to mutual insurers. Its cost-benefit
study found that for every $1 saved in guaranty-fund assessments, $8 would be
spent in implementation costs. The study also found that first-year compliance
costs for mutuals could reach more than $300 million, a figure equal to the
total cost of all mutual failures since 1992. NAMIC presented its findings at
the June 2005 meeting of the NAIC/AICPA Working Group.
NAMIC
and others assert that SarbOx essentially amends the Securities Exchange Act of
1934, legislation that applies only to issuers of registered securities and is
intended to protect investors. As such, they believe that applying SarbOx
principles to mutual companies is unsound and inconsistent with the intentions
of SarbOx and the Securities and Exchange Act.
Finally,
opponents are concerned about redundancy in an industry that’s already heavily
regulated. Mutual insurers aren’t the only ones concerned about this. Some
publicy-held insurers that are already subject to SarbOx don’t want a similar,
but still separate, NAIC rule that could potentially double their compliance
workload.
Where
do matters stand today? The NAIC/AICPA Working Group Title II, III and IV
Subgroups continue to work on various components of Model Audit Rule revisions.
At the NAIC Winter National Meeting, the Title IV subgroup discussed and
adopted changes regarding best practices for internal controls over reporting
and referred those changes to the working group. The compiled changes from the
II, III, and IV subgroups were released for a 45-day exposure period, after
which a series of conference calls will be held to address the changes.
In
the meantime, insurers and other industry trade groups have been working on
their own ideas, which could represent a compromise between insurance companies
and regulators. The ACLI drafted a proposal in which legal entities of a large
group holding company conglomerate structure would be exempt from filing their
own individual reports; everything would be handled at the highest corporate
level. The ACLI also suggests a premium exemption of $500 million. In addition,
a group of property/casualty organizations and “interested parties” have
developed a draft proposal similar to the ACLI’s.
As
you can see, there are lots of good ideas on the table. If you’re an industry
professional with a few years under your belt, you also know that it’s rare
for a good idea to go unpunished. That’s because people come and go in
organizations, but processes and systems stay. Over time, an organization may
become totally invested in its structure. When that happens, a sort of
schizophrenia develops where, on the one hand, out-of-step ideas or pushing back
are seen as threats to the structure and, on the other, every idea is a good
one, even if it’s terrible, because there are processes in place to funnel
those ideas safely through the system.
Regulatory systems are no
different. The systems in place—and the new systems being proposed
today—have the power to take away—or confer—status, power, and money. They
are vulnerable to the same rigidity and myopia that can develop in any
organizational structure. The good news is that every industry player involved
in the current regulatory debate is committed to crafting a structure that
enables insurers to compete successfully, protects their consumers, and bolsters
governmental bottom lines. It will be interesting to see which good idea wins.
LOMA Help:
LOMA offers a variety of solutions for compliance. For details,
visit:
http://www.loma.org/Finindex.asp
******
Part 2:
Solution
Providers Look At Compliance
Industry solution providers discuss compliance issues and how they can help
insurers.
Recognizing
the importance of compliance in today’s insurance industry,
many industry suppliers and solution providers are ready to offer advice. Here
are examples of what some of them say.
PossibleNow
Scott Frey, President/CEO
of Possible Now, says “The federal government and state Attorney General’s
are aggressively seeking violators of the DNC laws. This is evident from the
recent record-setting fine issued to a marketer of satellite services for $5.3
million from the FTC and $5 million from State AG’s.
“It
has never been more apparent for the need to have processes, procedures,
guidelines and technology in place for your marketing campaigns. There is no
such thing as complying “half way” on your programs. Companies conducting
telemarketing campaigns must ensure they are complying with the legal
requirements including those marketing on their behalf including 3rd parties
and independent agents.
“Companies
should consider outsourced technology solutions along with periodic vendor
compliance audits and compliance certification reporting. Compliance education
and training are other key compo-nents that
sellers and affiliate marketers must conduct with their representatives and
independent agents. Monitoring, enforcement and record keeping are all essential
components of a compliant tele-
marketing program.
“PossibleNOW
technology helps you ensure Do Not Call regulatory compliance while also
addressing a broader range of compliance needs — Do Not E-mail, Do Not Mail,
Do Not Fax and corporate privacy directives. The result is a comprehensive Do
Not Contact solution that meets the demands of today’s complex regulatory
environment.”
Adminserver
Michael J. Mullin, Chief
Operating Officer of Adminserver, says, “Insurance executives today have the
burden of proof placed on them as they report their earnings to shareholders and
regulatory agencies. There has never been a time in our industry when the burden
of proof has loomed so large, but what has really changed? Companies continue to
struggle with antiquated technology, dated processes, and disparate
applications. Data may be available, but is it correct?
“With
the new technologies available today from AdminServer, there has never been a
better time for companies to consolidate applications and processes to a single
platform, where all financial calculations (illustrations, policy values, tax
and compliance) use one common calculation engine. This environment delivers
perfect results every time and exposes the most granular levels of data for
audit while ensuring suitability and legislative compliance. In effect, a common
calculation architecture without compromise.
“AdminServer
transforms the way insurance companies service their clients, manage their
processes, and control their data.
“Common
calculations mean precise history, accurate data and unified processing for the
enterprise. Take a
Test Drive
and let AdminServer prove it to you.
ODEN
InsuranceServices, Inc.
Jim Oden, Co-President, of
ODEN, says “ Implementing the requirements of the Patriot Act, SOX, Anti-Money
Laundering or other regulatory enactments requires communication, coordination
and account-ability
from many people within an organization.
“Recognizing
the growing need for a compliance management solution, ODEN Insurance Services,
Inc. has developed ODENtrack®.
This workflow product tracks, communicates, and manages each stage of the
regulatory implementation process throughout the organization. Newly enacted
bills, adopted regulations and issued bulletins are delivered to the user for
risk assessment. The user may also manually add other corporate compliance
directives to be managed within ODENtrack®.
From discovery through implement-tation, the entire process is
accomplished by ensuring effective communication, accountability, timeliness,
tracking, and archiving.”
“For
more information about ODENtrack® and
other compliance products, please contact us at
800-633-5289, access www.oden-ins.com, or email sales@oden-ins.com.
InSys
tems Technologies
According to an official at
InSystems, few words can evoke a sense of dread like “audit”. Carriers
operating in the complex
U.S.
regulatory environment live with the reality that every state they do business
in could today decide it’s time to undertake a market conduct audit of their
activities. For most insurers the question is not if, but when will they receive
notice from one of the Departments of Insurance? In this era of intensified
regulatory pressure, accompanied by unprecedented levels of public scrutiny of
corporate behavior, effectively handling market conduct audits is vital to
maintaining hard earned trust and protecting brand reputation.
Ensuring the integrity of what
has been filed, approved, issued and delivered to policyholders is a cornerstone
of compliance. Traditional paper-intensive, manual methods of managing product
development, state filing and implementation processes are highly susceptible to
potentially costly over-sights and inconsistencies. According to Debbi Marquette,
Director Compliance Solutions, market conduct exposure and possible fines can be
dramatically reduced by leveraging solutions such as InSystems Writer and
Tracker to manage these key business processes. Further, having all filings
stored electronically in a secure searchable, repository reduces the burdensome
effort and cost of locating and assembling historical documents in preparation
for an auditor’s review. Contact InSystems at www.insystems.com,
1-888-InSystems.
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