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Currin Chronicles

Quarterly Newsletter

August 2017

(click here to view/download PDF)

Cailie Currin

President's Corner

I hope you are enjoying the summer and have taken the time for a vacation or at least a couple of long weekends. Summer goes by so fast here in the Northeast, it is easy for me to just let it slip through my fingers. This year, though, I have had some reminders of the importance of now and living life to its fullest each day. I am lucky to love my work and the people I work with, but I also need to remember the importance of vacation and getting away from work completely for a while. This year I am planning short getaways, mostly long weekends – time to spend with friends, family and animals, as well as on my bike and on the water in a kayak, Sunfish, or paddleboard. I have scheduled my biggest bike vacation ever for 2018, about which I am super excited – and a little scared, if I am honest. I will tell you more about that as it gets closer. I hope you have either had a great vacation or are planning something fun! 

Many of you generously donated to my bicycle ride in memory of my father, for which I am extremely grateful. Unfortunately, I was not able to do the ride I had planned in Lake Tahoe because of a significant injury to my foot in March. However, I have rescheduled and rolled my fundraising over to the Maine Lighthouse Ride on September 9, 2017. Along the route, we see eight lighthouses over the 62-mile ride. It is going to be a lot of fun – I can’t wait. I am having a custom bicycle built that I really hope will be ready in time – fingers crossed! She is going to be a made in the US, steel beauty! 

I am about $2500 short of my $7500 goal for this effort. If you would like to donate to my ride to benefit the Leukemia and Lymphoma Society, here is the link to my page. Perhaps there will even be pictures for the next issue.   ~ Cailie

Symposium on NY Issues

Many of you have received our emails regarding the upcoming Symposium in Hartford, CT on November 3, 2017. We love taking our expertise on the road and the feedback has been very positive. I am really excited about the next one. It will be a whole day on NY issues, from granular filing challenges to high level policy issues. I will lead a deep dive into some challenging NY issues, including Regulation 210 and the evolving positions around unfair discrimination in individual products. I hope you are planning to come.

Our symposia have changed format somewhat since we began doing them regularly a couple of years ago. We limit registrations so that we can have effective group discussions and we have shortened them to one day so travel costs are reduced as is time away from the office. We know you are all very busy. 

That said, there is a lot going on in NY to talk about and you will want to be a part of the conversation. It will be a full and productive day for all. Note that the Early Bird registration of $399 is effective now and it will not be extended past August 21 – don’t miss out. See you in Hartford on November 3rd! 


New York Update

By Sarah Huffer

I have started to see things creep up in my personal facebook feed about paid family leave. There has been local news coverage this month about the fact that employers can start taking deductions from employee’s wages to cover the premiums. The rate was set by NY Department of Financial Services (DFS) and maxes out at $1.64 per week, which is intended to fully fund the coverage. 

Meanwhile, insurers are still waiting to submit form filings to provide for this coverage. At the LICONY and DFS seminar that was held on July 11, representatives from the Health Bureau stated that they have put ample resources into drafting model language for the program, which they will require to be used. The language is drafted to be a rider that is added to an existing Disability Benefits Law (DBL) policy. The language has also been pre-approved by the Worker’s Compensation Board, which means insurers will only need to submit filings to DFS. At the time of publication, the model language has still not been released, but it was promised to be available soon. Department staff also promised that there will be a checklist that includes detailed filing instructions to aid in these submissions. Given the circumstances, I am hopeful that there will be a very quick turnaround on these filings. 

I am most interested to find out what happens January 1, 2019 after the first year of the program is complete. The rate regulation requires detailed reporting from all insurers and a complete levelling of all experience, categorized by group size. Will it be a loss? Are the premiums adequate?

Searching for Lost Policies

By Suzanne Seay

I believe I spend way too much time searching for things: my wallet, my reading glasses, an overdue library book, my 14-year-old’s soccer knee pads, my 16-year-old’s mouth guard for lacrosse, and the like. But it appears that the NY Department of Financial Services (DFS) thinks life insurers doing business in the state should be devoting more time and more resources to searching for one thing: lost insurance policies.

Like many states, DFS is working on a project that will coordinate its Lost Policy Finder Service with the NAIC’s Life Insurance Policy Locator Service. While insurers currently volunteer to participate in NAIC’s service, an insurer’s participation in the NY service is not voluntary, it’s mandatory.

Under the current system, when a request comes into NY’s Lost Policy Finder, NY domestics are required to search their electronic records of all policies, no matter the state it was issued in. Insurers domiciled outside of NY are required to search only those policies, contracts and certificates issued in NY. Once the coordination with the NAIC is complete, there could be a significant increase in NY requests, because all requests going to the NAIC service will come to NY also.

James Regalbuto, NY’s deputy superintendent for life insurance, said at a recent LICONY forum that the NAIC has done more promotion of its locator service to the general public and it seems that more people know about the NAIC service than the NY service. Because participation by insurers in NY’s service is compulsory, he expects that more requests will result in the identification of a greater number of lost policies.

It’s not yet clear how often NAIC-received requests will be pushed out to insurers licensed in NY, but it will probably be done daily or weekly. Insurers have 30 days to respond if they maintain their own records, or 45 days if they contract with a third-party to maintain records. If an insurer participates in the NAIC service, it does not have to search again when NY sends the NAIC-received requests.

Regalbuto said the market conduct fines issued by DFS have been driven up lately because of companies’ non-compliance with §3240, NY’s Unclaimed Benefits statute, which includes law relating to the Lost Policy Finder.

There is still an outstanding question of how NY wants to handle all of the requests that have come into the NAIC over the past year or so, since the NAIC’s service was established, Regalbuto indicated in response to a specific question that he is not willing to ignore all of the previous requests, but has not yet decided how insurers will be required to address them.

Another upcoming change to coordinate with the NAIC service is that NY will no longer require a certified copy of the death certificate to accompany a request, as the NAIC does not require one. As I was writing this article, I decided to submit a policy locator request on the NAIC website for my father, who passed away in March last year. I would not have done so if I’d been required to submit a death certificate.

CCS at AICP 2017

By Glenda Bean

Can you believe summer is already halfway over? It doesn’t seem possible, yet here we are! While I don’t want to rush away our warm days, fall will be here before we know it – and so will the AICP National Conference, an event I always look forward to.  

A number of the CCS team will be making the cross-country (and one up the coast) trip to Seattle to present on a bunch of different compliance issues. 

I’ll be teaming up with a panel to discuss hot topics in advertising, a great session for anyone who may have had a sleepless night (in Seattle or elsewhere) wondering about what you’ve seen and what you may have missed!

Sarah Huffer will be waxing poetic on combination products – where we are today and the opportunities that lay ahead, as well as challenges that go along with change. 

Machael Heise will be bringing you insights on all types of regulatory reporting. How to manage the volume and requirements, and real-life strategies for managing it all.

Finally, Cailie Currin will be rounding out our speakers with a panel discussion on technology start-ups and innovation in the life, annuity, and health space. 

Of course, we’ll have a booth set up filled with fun compliance swag and chocolate to fix those late afternoon cravings so don’t forget to stop by and say hello!

Will we be seeing you there?  Drop us a line and let us know!

IAdCA Developments

By Glenda Bean

As we mentioned in our last newsletter, both Cailie and I have the honor and privilege of holding the president and vice president officer positions for the Insurance Advertising Compliance Association. 

Recently there have been some changes, as tends to happen with a volunteer organization, and I’ve had the opportunity to join our Conference Committee Planning team as a co-chair with Jennifer Herens. 

In this role, I’ll be working directly with Jennifer on ensuring all goes off smoothly for the 2018 Austin conference, as well as planning our venue for 2019! In fact, we’ve recently determined which city we’ll be hosting in for 2019, and it’s certainly one for the history books ::wink:: 

IAdCA is a great organization and resource. If you interact with advertising compliance and are looking to develop a network while enriching your understanding of issues, then you should consider volunteering on one of our fabulous committees. Education, Public Relations, and Conference Planning are just a couple of the options. If you’re interested in how you can get started, please e-mail today!

One Year

By Machael Heise

Well, it has been a year now that I have been an official employee of CCS, and the year has absolutely flown by - more quickly than any other time in my life. Of course, as we all get older the days don’t drag in the same way they did when we were kids, but this year has been something else! 

Some of you may already know that I live in Southern California and travel once a month to the CCS office in Greenwich, NY, where I spend a week working and meeting with the local staff. Going to the office is a great way to connect with the rest of the CCS gang, especially since I work from home in Huntington Beach. 

Huntington Beach and Greenwich are different in about every way imaginable. Huntington Beach, aka Surf City, USA has a population hovering around 190,000. Known for a casual surfer “vibe,” HB is a laid-back town with temperatures averaging mid-70’s nearly all year-round. While the folks are friendly, it is a rare occasion that I run into someone I already know – there are just so many people, busy with their lives, just like the rest of us. Housing tracks, shopping centers, and traffic jams are all part of the local scene. Riding a beach cruiser, smelling a beach bonfire, and a craving for fish tacos are a common occurrence. My daily routine with my boys and work doesn’t vary often, and one quiet day blends into the next.

Take two zeros off the end of HB’s population, and you will have exceeded the Greenwich population of around 1,800. The area is loaded with farms and Revolutionary War history, and Greenwich boasts homes that were part of the underground railroad during the Civil War. In Greenwich, many residents have lived in the area all their lives and and are connected in a way that blows the Kevin Bacon theory to shame. If you want to know the status of your Fed-Ex package, you can call the driver on his cell phone and he will give you a status. That honking you hear coming from Main Street? That is Glenda’s mom driving by and saying “hello” in her usual fashion. It seems there is always something going on – from concerts in the park, to the holiday tractor parade down Main Street. In such a small town, no matter where you are, you are a part of the energy and excitement.

For me, the biggest difference and time accelerant is the weather. Living in SoCal for the past 35 years or so, I have grown used to little variation in the temperature between seasons. Shorts and flip-flops are always in season, and jackets are rarely taken from the coat closet. While this month in Greenwich I will be wearing t-shirts, the coming month’s fall colors may introduce a sweater or two, and before you know it, winter white and snow boots will be back in the mix. It is odd, but now I can measure my year in milestones related to my trips to Greenwich. Each time I ask myself what I will need to bring for the next trip? Sandals? Uggs? In just a dozen or so quick trips, another year has come and gone.