Beneficiary Location: How To Excel in the Face of Changing Insurance Industry Regulations. Insurance Regulations & Compliance

Transcription

1 Beneficiary Location: How To Excel in the Face of Changing Insurance Industry Regulations Insurance Regulations & Compliance

2 Since 2008, insurance companies have been involved in audits, hearings, and public debate regarding their historical claims practices. The focus is on companies that have not proactively identified deceased policyowners and sought to locate the beneficiaries to initiate a claim. Today, the industry has reached a tipping point. Major settlement announcements and new regulations involving virtually every state are requiring insurers to develop new proactive processes that identify deceased policy holders and initiate claims on a regular basis. These regulations are far reaching and impact the way insurers handle life policies, annuities and retained asset accounts. Understandably, much of the early focus has been on the question, How will we comply with the new rules to identify which policyowners have died? However, there is a far more important question for insurers to consider: How will we handle the overwhelming wave of deceased policyowner accounts that we are likely to find? The question is so critical because the settlement agreements and the new regulations allow a very narrow window of time for insurers to locate beneficiaries before policy proceeds must be reported (or escheated ) to the states as unclaimed property. Therefore, every insurer now faces a fundamental choice in how they will manage this challenge: Option A. Do it internally by stretching resources or hiring employees and increasing overhead Option B. Hire an expert who can maximize their beneficiary location and policy claims assistance and indemnify them from audits This choice directly impacts thousands of policies and hundreds of millions dollars. The remainder of this paper will explore both the challenges and opportunities that exist for insurers who choose to implement robust beneficiary location and communication programs. Specifically, we will discuss: New state requirements Critical factors of proactive beneficiary location and outreach Success-based beneficiary location Benefits of outsourcing By maximizing the return of policy proceeds to the entitled parties, insurers can: Strengthen their reputation Fulfill the intent of the policies Retain more assets under management Minimize escheatment to the states Demonstrate a clear culture of compliance to state regulatory agencies State Requirements On April 11, 2012 Kentucky passed HB 135, the first state law modeled after the National Conference of Insurance Legislators (NCOIL) Unclaimed Life Insurance Benefits Act. Since its start in April, several states have either proposed or enacted laws containing the basic stipulations of the model, while others are making market conduct recommendations for carriers to complete or outline Death Master File (DMF) analyses. It is becoming more and more evident that in the future insurers will have to: 1. Regularly compare the list of in-force life and annuity policies against the Social Security Administration s Death Master File (DMF) database to identify deceased individuals. 2. Search for the beneficiaries who are entitled to proceeds from those policies. 3. Notify beneficiaries of their ability to make a claim and provide them with the appropriate claims documentation. 4. Report policies as unclaimed property if beneficiaries are not located and do not make a claim within as few as 90 days. As these new laws continue to emerge, insurers have been focused on understanding how to comply and looking for ways to conduct DMF searches. First-time compliance with these new procedures will obviously generate some operational adjustments as a search process is implemented. The NCOIL model itself follows closely the remediation practices required by some of the

3 Minimize Escheatment Reduce Audit Risk Increase Claims Paid Keane Beneficiary Location Expertise Provide Service On-Demand Reduce Operating Costs Help Protect Your Reputation As the nation s #1 provider of unclaimed property communications, compliance and consulting services, Keane provides customized beneficiary claims assistance programs to maximize the return of account benefits and minimize the number of accounts and policy proceeds that are lost as unclaimed property. major settlement agreements. The settlements contain many details regarding specific data manipulations and fuzzy matching criteria that must be followed when conducting DMF searches. The bottom line is that there are many options, internal and external, for meeting the basic criteria. The biggest challenge, however, has little to do with how companies identify the deceased. It s what they do with the thousands of deceased policyowners that could surface by complying with these regulations. The problem is that these policies and their proceeds are at immediate risk of becoming reportable to the states as unclaimed property. Therefore, insurance companies need to establish a program to: Manage the volume of deceased accounts that will be identified Locate the beneficiaries quickly and accurately Communicate with the beneficiaries to effect a claim Document and establish a systematic process with an audit trail This reality places a premium on the function of beneficiary location and outreach. Unlike the DMF searches, the task of communicating with beneficiaries and helping them to claim policy proceeds is not something easily automated or handled by employing electronic database searches. Proactive Beneficiary Location and Outreach There are 6 primary factors that make proactive beneficiary location and outreach a highly complex and specialized function. Specifically: 1. Scope - Large volumes of deceased-owner accounts must be reviewed and processed within a short period. 2. Data Quality - Beneficiary information typically contains incomplete, outdated, or inconsistent data. 3. Research Experience - Unique tools, research techniques, and trained resources are required to maximize beneficiary location in large volumes. 4. Beneficiary Variability - Many beneficiary designations are classes of people (e.g. the spouse or the children of the insured) requiring extensive research to identify the entitled individuals. 5. Deceased Beneficiaries - As many as 25% of named beneficiaries are also deceased, requiring additional research to locate the correct heirs or estate representatives. 6. Communication Challenges - Aggressive and customized communication programs are necessary to generate timely responses. Each of these critical factors is explained in more depth on the following pages.

4 Critical Factors for Beneficiary Location Success 1. Scope High Volumes, Narrow Time Frames As mentioned, conducting the newly required DMF searches will uncover hundreds, thousands, or even tens of thousands of policies whose owners are deceased. Unfortunately, there may only be a three month window to reconnect with beneficiaries and complete the claim. Managing large volumes of policyholder information and records is complex in itself, and navigating the information to find and leverage data is even more challenging. At the same time, most insurance companies have limited internal resources to handle such a task. The ability to rapidly analyze the deceased population, segregate the accounts into the proper categories and provide specialized processing based on the data variations is critical. 3 MONTHS to reconnect with beneficiaries. 2. Beneficiary Variability Layers of Research Add Complexity Another factor that adds difficulty, is that many policies define the beneficiary as a class, meaning that it s not a specific individual. The policy will indicate that the policy proceeds are to be distributed to the children or the spouse of the insured. In these circumstances, extensive preliminary research may be required to first identify how many children there are or what the spouse s name is. Then comes the challenge of identifying current address and/ or contact information for those individuals so that contact can be attempted. 4. Data Quality Improving Data Quality Reduces Risk One of the largest challenges in complying with the new unclaimed property laws is that legacy data of both the insured and beneficiary can be less than perfect. In some cases, an insurer s books may only have poorly formatted and hard to read, scanned records. Statistics prove that the higher the data quality, the higher the response rate. Only by accurately categorizing, separating, and enhancing the quality of your historical owner data can you ensure the effectiveness of life status assessments and beneficiary location efforts. Keane s analysis of data from many insurers reveals the same issues that are seen across financial services firms. These include outdated addresses, missing data fields, inaccurate Social Security Numbers, and formatting variations. Rehabilitation of data empowers companies to: Expedite beneficiary searches Improve research accuracy Speed data verification Enable streamlined beneficiary communication with increased response rates Reduce the risk of inaccurate deceased identification 3. Missing or Deceased Beneficiaries In many cases, beneficiary information is missing or the beneficiary is deceased. This is a greater risk when the account data itself is old. Keane s analysis of insurance company records indicates that as many as 25% of the beneficiaries on the file may be deceased.

5 5. Research Requirements Experience Drives Performance Locating beneficiaries is not a core competency for most insurance companies. Conducting searches for beneficiaries is a very detail oriented task that requires specialized skills and resources. This is especially true when the beneficiary data is outdated or incomplete. Beneficiary location practices must be more rigorous than simply mailing notices to the address that may be currently on file. If the named beneficiary is living, comprehensive searches for new address and contact information should be conducted. This often requires research analysts to manually locate the beneficiaries by examining public records, wills, or estate documents and to investigate the situation through a series of manual database searches and other research techniques. Keane analysis indicates that approximately of beneficiaries 15 to 25% on legacy policies are deceased. 6. Communication Challenges Compliance with the DMF searches identifies and triggers the need to commence a targeted, skilled and efficient outreach. Once the appropriate individuals are identified, the outreach effort can be conducted. Key components may include: Mailing notice and instruction letters to beneficiaries or legal claimants Outbound telephone calling Collection of returned mail items to identify needs for further research and advanced research Rapid Beneficiary Location Collect, Format, and Rehabilitate Beneficiary Data Categorize by Beneficiary Type and Degree of Research Required Named Beneficiary: Single Multiple Trust Research and Life Status Review for Named Beneficiaries DECEASED LIVING Children My Spouse Next of Kin None Manual Research to Identify Beneficiaries and Legal Claimants Review and Validate Newly Collected Information

6 Customized Outreach for Maximum Efficiency: Success-Based Beneficiary Location Comes in Many Flavors One size definitely does not fit all when it comes to building the perfect beneficiary location program according to Nick Nichols, Chief Operating Officer for Keane, the largest beneficiary location company in the US. Our beneficiary research team has the ability to successfully locate more than 90% of the individuals who are entitled to claim policy proceeds, but no two companies or situations are alike, he explains. For instance, the research timeframe, outreach methodology, documentation requirements, and communication needs may be completely different from one organization to the next. We have to embrace these challenges and deliver the best results possible given the regulatory constraints or, in the case of an audit, the requirements set forth by the auditors. The tools Keane employs are the same as we ve used to locate millions of people for banks, brokers, mutual funds and corporations for the last 40 years. However, the insurance industry has many unique challenges and a variety of location requirements. That s why Keane s solutions are customized for each insurer. Each file has its unique challenges. To maximize success with any population, our first step is to analyze the data. This provides an understanding of its complexities and the research variations needed. For instance, in situations where the beneficiary is listed as the children of the deceased, determining who to locate and talk to can prove to be a difficult first step. Measurable Success The biggest constraint we deal with is limited time. It is very common in an insurance audit scenario that we will have only 60 days in which to locate the account beneficiary and get the appropriate individuals to claim the proceeds. We are successfully locating 73% of the beneficiaries and effecting claims in 57% of these situations. Our clients are thrilled because they understand the issues that must be overcome in order to achieve this level of success. We have built our research team to complete the majority of research within the first 30 days. This allows us to spend up to 8 weeks, on the outreach effort to communicate with the beneficiaries. Beyond audits there are several other scenarios and product lines for which we have developed very successful beneficiary location solutions for our clients. New York 308 Letters: Keane was brought into an emergency project to help one carrier comply with New York s new beneficiary location requirements. Keane located 6,600 beneficiaries in less than two weeks and was able to drive more than 70% of those located to contact the insurer regarding the claim. Minnesota Audits: Verus audits are no longer the only audit programs out there. Minnesota initiated a program to which our clients are responding. Jumping on this population early, we ve been able to locate 81% of the beneficiaries in 30 days. Retained Asset Accounts: In addition to life insurance policies, many audits are reviewing populations of retained asset accounts to identify those that may qualify as unclaimed property. Keane helps insurers locate the owners and beneficiaries of these dormant accounts, empowering them to maximize account and asset retention. Additonal agreements are being implemented for business as usual. Business As Usual: The industry settlements and current audits are focused on identifying past-due property. The challenge of locating beneficiaries is now an issue that must be part of every insurers day-to-day operations. Keane is helping companies optimize their going forward programs by customizing locations solutions that work in tandem with Death Master File (DMF) compliance searches.

7 Keane s beneficiary research process can successfully locate more than 90% of the individuals who are entitled to claim policy proceeds. 90% of Beneficiaries Successfully Located Beneficiary Location Can Potentially Save Millions The new insurance regulations have companies facing penalties for policies that are out of compliance, and many are unaware of how quickly the fees can add up. Take for example, a company that has 5,000 policies out of compliance, assuming an average 3% penalty (this varies from state-to-state) and nine years out of compliance. The following are potential penalties for different policy sizes: Average Policy Size Potential Penalty* $1,000 $1,333,850 $2,500 $3,334,626 $5,000 $6,669,252 It becomes clear that employing a beneficiary location program that can prevent assets from escheating to the state can potentially save millions in penalty fees alone. The Benefits of Outsourcing Many leading insurance companies are choosing to outsource beneficiary location and communication services. Those that do realize several performance-driving and money saving benefits: Higher success rates Lower costs Reduced escheatment Working with trusted third-party consultants can also be used to demonstrate an organization s commitment to and investment in ensuring compliance if questioned by state examiners. Lean on Keane When faced with beneficiary location challenges, leading financial services companies rely on Keane. We are the insurance industry s only comprehensive provider of beneficiary location, communication and related unclaimed property services. Keane provides a range of compliance, communications, and consulting services to some of the nation s largest insurance companies, mutual funds, banks, brokerage firms and publicly traded companies. Keane s customized beneficiary location solutions help insurance companies: Locate named beneficiaries and perform advanced research to determine heirs or estate representatives Conduct outreach programs to help beneficiaries complete their claim Improve data quality Our success-based pricing model ensures that you only pay when we deliver on our promises. The Bottom Line Recent events have forever changed the unclaimed property landscape for insurance companies. But with adversity comes opportunity. By embracing this new environment and its challenges, insurers can comply with the rules and realize business benefits. Working with an experienced partner like Keane will allow you to optimize beneficiary location, maximize beneficiary claims, and build new business relationships. * Please note: Penalty percentages can vary based on state regulations and audit settlement agreements.

8 Lean on Keane Keane is the leading provider of unclaimed property communications, compliance, and consulting services to the financial services industry. We deliver customized solutions for each insurance company s unique circumstances to proactively protect as many dormant accounts as possible. We will help you preserve your customers, your reputation, and your bottom line. Unclaimed property. Uncompromising performance. Corporate Offices: 1001 Avenue of the Americas, 14th Floor New York, NY Operations Center: 640 Freedom Business Center Drive, Suite 600 King of Prussia, PA