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The Berwyn Group

The Berwyn Group. Compliance & Deceased Policyholder Audits May 2013. Compliance. State Insurance Department Requirements Settlement Agreement Compliance Privacy Law Compliance. Insurance Department Compliance AND Settlement Agreements Compliance. Prescribed Audit Methodology Fuzzy Logic

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The Berwyn Group

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  1. The Berwyn Group Compliance & Deceased Policyholder Audits May 2013

  2. Compliance • State Insurance Department Requirements • Settlement Agreement Compliance • Privacy Law Compliance

  3. Insurance Department ComplianceANDSettlement Agreements Compliance • Prescribed Audit Methodology • Fuzzy Logic • Reasonable Effort • Audit Frequency • Monthly • Quarterly • Semi-annually • Every 3 Years (Alabama) • Audit Types • Audits Against Full Master Death File • Audits Against Updates to Master Death File

  4. Privacy Law Compliance • Death Audits require access to the Non-Public Personal Information (NPPI Data) • NPPI Data is governed by the use, non-disclosure and privacy obligations of: • Gramm-Leach-Bliley Act (GLB) (15 U.S.C. § 6801 et seq.) • Federal Fair Credit Reporting Act (FFCRA), (15 U.S.C. § 1681 et seq.) • Federal Trade Commission Tasked with Enforcement • Guideline - do not post any NPPI on any forward facing website unlessmission critical.

  5. What this means to you! • Exercise Prudence when selecting a Death Audit vendor • Vendor should : • Be SOC Type II Compliant • Have Controls Audited and Tested Annually • Maintain Thoroughly Documented Security Protocols and Procedures • Single Source your Vendor • Be Adequately Insured • Identity Theft is a Real Concern • High Cost in terms of Reputations • High Cost in terms of Remediation • Customer Notifications, Forensics, Public Relations, Credit Monitoring

  6. Final Thoughts • Death Data Adequacy • New Entrants into this field could have inferior data sets • Programming for Data Nuances • Auditing Solutions • Look for the Most Secure Business Model • Safest Data is the Data you Control

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