CCS Services

  • We review advertising and marketing materials (life & health and property & casualty) created by insurance companies, marketing organizations, lead generating companies, and producers for compliance with state insurance laws and regulations.

    OUR SERVICES

    • Review advertising and marketing materials—from ad hoc pieces to full department outsourcing.

    • Identify issues that may be regulatory “red flags.”

    • Assisit you to implement your advertising compliance manuals, policies, and procedures.

    • Train your staff on advertising and producer compliance.

  • Whether your company is a multinational corporation or a small financial institution, a well-designed Anti-Money Laundering (AML) program should target your exposure to risks presented by your products, distribution channels, clients, services, and location(s).

    OUR SERVICES

    AML Independent Review (in person or remote)

    • An independent AML program review (aka audit) is a crucial pillar of AML compliance — the most effective tool in ensuring that regulatory examinations have an optimal outcome.

    • Regulations require that AML programs be tested periodically by a qualified, independent party to mitigate money laundering risks. We have extensive experience in insurance products, services, and distribution channels, plus certification in AML and Countering Financing of Terrorism (CFT).

    AML Risk Assessment

    • The first step to right-sized compliance requires insurance companies to have an AML program. You must understand your company's exposure to reduce the risk of money laundering – avoiding fines and damage to the company's reputation. When companies do not have the resources, expertise, or time to perform an AML risk assessment, we step in.

    AML Policies and Procedures

    • These are the controls to protect your company, stockholders, and customers from money laundering and fraud! Bank Secrecy Act (BSA) and AML regulations require that you establish and implement policies and procedures reasonably designed to detect and prevent or cause the reporting of suspicious transactions. Our services include AML program drafting and identifying what you need to cover your risk profile.

    Independent AML Auditor Training

    • We can co-audit and train your internal reviewers. Our support will provide your team with the knowledge, techniques, and tools they need to perform their next independent audit with insights into leading practices and regulators’ expectations.

  • Currin Compliance Services began in 2007 by helping clients develop products and review and file life and annuity products. Product review and filing remain a significant part of our business. However, our focus is no longer solely on New York State.

    OUR SERVICES

    • Assist in developing life, annuity, and supplemental health product lines. Our early and active involvement in the development process will identify compliance issues upfront.

    • Review and file products in appropriate jurisdictions or with the Interstate Compact. We draft, edit, analyze, and recommend appropriate revisions.

    • Handle all Uniform Certificate of Authority Applications (UCAA)—primary, expansion, corporate amendments—and other regulatory filings. We work to meet your needs with UCAA filings, Holding Company Act filings, and re-domestications.

  • Insurance carriers and marketing organizations are committed to helping consumers understand the benefits of life insurance and annuity products. State and federal levels are heavily regulated; therefore, navigating regulations is complicated.

    We offer customized compliance services to help insurance carriers and distribution partners identify and mitigate compliance risks. Our services include compliance training, risk assessments, advertising, operational processes, sales practice issues, suitability, and more.

    INSURANCE CARRIERS

    Insurance carriers face the unique challenge of complying with state regulations and federal mandates. Often, insurance companies address regulatory compliance in a reactive mode, not fully aware of compliance problems until faced with a market conduct examination or complaints from regulators or policyholders. The risks to that approach include fines, litigation, and potentially harmful media coverage. We help our clients master the complex regulatory environment and proactively handle compliance challenges with training and tools to manage risk and protect their reputation.

    MARKETING ORGANIZATIONS

    As your business grows, so do your compliance risks. In the past, regulators and plaintiffs’ attorneys turned to the deep pockets of insurance companies who manufacture products to resolve any compliance issue arising from the sale of its products. Today, state insurance regulators also look closely at product distributors – marketing organizations and insurance producers – raising the bar, expecting all parties to the sale to follow ethical and fair sales practice regulations. We help our clients manage risk exposure through risk identification and mitigation services.

  • Our services include all aspects of compliance research, training, and education concerning life insurance, annuities, supplemental health, and the DOL Fiduciary Rule (the Rule) — customized to meet your needs.

    Our most requested topics are:

    • Replacement Issues (including or excluding NY Reg 60)

    • Advertising Compliance

    • 50-State Research

    • 50-State Filing

    • DOL Fiduciary Rule

    • General Sales Practice Issues

    • Operational Compliance Policies and Procedures

    • Supervision and Oversight

    • New Business Compliance and how to spot Problems

    • What is different about NY?

    • What can we do electronically?

    • Indexed Annuities in NY

    • ORSA and ERM: “We read the regulations; what do we do now?”

    Our compliance professionals also perform complex national and multi-state regulatory and compliance research for life, health, annuity insurers, banks, and trust companies.

    We provide regulatory updates addressing changes to the laws and regulations in the life, annuity, LTC, and supplemental health industries tailored for where your company does business. We will help implement regulatory changes efficiently to assure compliance.

  • We prepare you for the demands of a market conduct exam and train you to look for potential areas of vulnerability, identify risks, reveal what you don’t know, and correct issues before they become problems.

    OUR SERVICES

    • Review your policies, procedures, and job descriptions against actual operations and files to reduce regulatory risks.

    • Train your staff on market conduct and sales practice issues.

    • Ensure that you are well-positioned heading into an exam.

    • Assist your team with responding to regulator inquiries, if needed.

    • Facilitate a strategy to deal with any issues raised and, if needed, negotiate a settlement that may result.

    • Develop a plan for remedial measures to avoid similar problems in the future.

  • We work with you to assess and remediate any issues related to the reporting mandates associated with a Market Conduct Annual Statement (MCAS). An MCAS is only valuable to regulators if the reported data is accurate. Therefore, data integrity is raised increasingly on exams, with some states issuing significant fines for inaccurate reporting.

    How it works:

    1. Together, we’ll discover any problems before the MCAS gets filed. Our assessments typically include an on-site analysis where we randomly choose samples to evaluate.

    2. We review the files for accuracy and compliance and interview applicable staff and management during the assessment.

    3. We report preliminary findings to management and decide what remediation, if any, is warranted.

    4. We work with you to determine what type of report would best accomplish your goals for the project. In most cases, a report is prepared to represent the evaluation of the findings and recommendations to improve the complaint handling process.

    Taking the time to review these processes will reduce the risk of inaccurate data in your reporting and thus implement timely remediation measures for any problems.

  • Own Risk and Solvency Assessment (ORSA) is a component of an insurer's Enterprise Risk Management (ERM) program. The goals of ORSA do not appear too complicated, as articulated in the NAIC Model Act #505 (indented text from NAIC).

    “Pursuant to the ORSA Guidance Manual and the Risk Management and Own Risk and Solvency Assessment Model Act (#505), the ORSA has two primary goals.

    1. To foster an effective level of ERM at all insurers, through which each insurer identifies, assesses, monitors, prioritizes and reports on its material and relevant risk identified by the insurer, using techniques that are appropriate to support risk and capital decisions; and

    2. To provide a group-level perspective on risk and capital, as a supplement to the existing legal entity view.”

    Risk Management and Own Risk and Solvency (MO-505)

    Assessment Model Act (ST-505)

    Neither ERM nor ORSA is simple and efforts to fit into a one-size-fits-all format will fail. A cookie-cutter or template approach will not bring the results you want. Individualized corporate initiatives are helpful. No other company has your business or your risks—so no other company's analysis should be the same as yours.