Life Insurance Law Blog

Best Practices for Social Media - Insurance Compliance Insight Recommendations

Cailie Currin — Fri, 19 Feb 2010 09:07:09 -0500

The February 8 issue of [Insurance Compliance Insight (ICI)] had a very informative piece entitled Best Practice Tip: Use FINRA Regulatory Notice as Guidance for Insurer Social Media Policies.

Just last year I attended an insurance compliance conference and in a regulator session that was not on this topic but had an open Q & A session, I asked a state regulator what his state was doing about social media. He gave me a line describing what he thinks of Twitter that got a lot of laughs and was very funny, but revealing in that it made clear that his department had not seriously addressed these issues. FINRA is taking a different approach and ICI suggests that companies would be wise to look to FINRA's Notices when they draft their own social media policies and procedures.

As a blogger, one of the areas discussed in the ICI piece that is of particular interest to me relates to blogs and is the distinctions between static content blogs as advertising and those which are interactive, which are called an interactive communication forum. In the latter situation, prior approval is not required from FINRA, but if it appears that the firm as somehow endorsed or approved the content, then the comments could be considered to be endorsed or approved by the firm. Most of my posts here could be viewed as static, in that comments are not often submitted (though they are welcome!) but it is also potentially interactive in that the comment facility does exist and is sometimes used, (though most often comments are sent to me privately via e-mail). So how does that fit?

My understanding is that since this blog is not used to engage in real-time, interactive communication, it would be considered static content. However, under the FINRA Notices, I would still be concerned about the possibility that the comments that are made could somehow be attributed to me or be viewed as being approved by me. FINRA looks at whether there is a disclaimer saying that third party posts don't reflect the views of the firm and have not been reviewed for completeness or accuracy.

Clearly, it would seem such a disclaimer is a best practice. Though mine is not a firm regulated by FINRA, that type of disclaimer is going on the To Do list!

The Insurance Compliance Insight article makes several other "Best Practices" recommendations that make good sense for all of us who use social media in business. These include:

Establishing appropriate usage guidelines for customers and other third parties that are permitted to post on firm-sponsored Web sites;
Establishing processes for screening third-party content based on the expected usage and frequency of third party posts; and
Disclosing firm policies regarding its responsibility for third-party posts.

My guess is that the regulator who made the Twitter comment just a few short months ago would not do so today. Social media can't be laughed at or ignored. It is just too big. We all need to be looking at it and these best practices make sense for today's social media. Keeping up with the new developments is what will be the challenge for regulators as well as companies… Wouldn't it be nice if we could just make fun of Twitter?

Life Insurance/Annuity Sales in 2009

Cailie Currin — Wed, 17 Feb 2010 18:28:55 -0500

Darla Mercado reports in today's edition of Investment News that while fixed annuity sales fell for 2009, down 2% from 2008 sales, indexed annuities did better— up $3.5 billion year-over-year. [ Fixed annuity sales slid in '09]. Based on Ms. Mercado's reporting, fixed annuities in several distribution channels and designs (book value vs. MVA) fared poorly, due to low interest rates, according to Scott Stathis of Kehrer-LIMRA. Variable annuities are only discussed in the bank channel, where she reports that in November sales were down .1 billion from other monthly sales figures in 2009, while they rebounded a bit in December to be .1 billion higher than those previous months. Mr. Stathis reportedly attributes the somewhat depressed sales of variable annuities to higher fees and decreased benefits.

Meanwhile on the life insurance front, the [MIB reported late last week] that U.S. application activity for individually underwritten life insurance increased 1.2% in January year-over-year. The MIB states that January 2010 represents the sixth consecutive month where year-over-year change is positive for the U.S. Life Index, and they report that as being the longest sustained trend of U.S. increases on record. Application activity for the period December 2009 to January 2010 remained virtually flat.

From where I sit, I look at the future and not the past. From here, I see a lot of product development with some significant innovation being discussed. It would not surprise me at all if this year sees a large increase in product filings and new products coming to market. My evidence is far less scientific than was reported above, but I like what I see; people I know who were laid off are finding jobs and product development seems to be churning. I like to know what the research says about past sales, but when I think about what the future holds, I have learned to trust my desk. And 2010 is shaping up as a busy year!

New York Announces New Med Supp Product Checklists

Cailie Currin — Wed, 10 Feb 2010 14:09:51 -0500

Updated product checklists are now available on the New York State Insurance Department's website for Medicare Supplement product filings. Checklists are available for both group and individual filings. These refer to the new regulation (Regulation 193) that has been recently promulgated in order to bring all the Med Supp requirements into a single regulation and to make the necessary changes to comply with federal law.

February Best's has interesting article on LTC Annuities

Cailie Currin — Tue, 09 Feb 2010 11:21:40 -0500

The February 2010 issue of [Best's Review] has an interesting article, written by Lori Chordas, on LTC Annuities. I have heard a lot of chatter about these products over the last few months as we approached and then passed the 1/1/2010 Pension Protection Act changes. The change in the tax treatment of withdrawals from annuity account values when used to pay LTC premiums, makes these combo products more desirable for consumers now than they have been previously.

Because there is no taxable event when the premiums are deducted from the annuity's value, the cost of the LTC premiums is effectively lowered. Chordas quotes Scott Goldberg of Bankers LIfe and Casualty Co., on two advantages over stand-alone policies: 1) long-term care annuities lower the cost of long-term care insurance and, 2) they remove the 'use it or lose it' fear with respect to the annual LTC premiums.

Chordas' article provides general descriptions of three currently marketed products, each with unique design features; those of OneAmerica, Bankers Life and Casualty Company, and Mutual of Omaha. Although different in the design details, each of the products appears to achieve the goal of keeping the actual cost of LTC down. There was little discussion of the fee structure of the products, to know how those might impact performance, but all seemed to have the potential to achieve the combo product goals. Ms. Chordas cites LIMRA sales research showing that LTC sales have fallen considerably from the 580,000 policies sold in 2002. It will be interesting to see how the various products that are in development come to market and whether they are able to meet the challenges that stand-alone LTC policies have faced.

Of course I would love to have the opportunity to be involved in the development and filing of these new and innovative products as companies bring them to market, but even if I am not, I look forward to seeing how they develop and what their impact is when they get out there on the street.

NY on DOMA Disclosure for Annuities

Cailie Currin — Wed, 27 Jan 2010 19:24:14 -0500

The New York State Department of Insurance (NYSID) demonstrated its flexibility and good sense yesterday when it allowed us to remove two words from its recommended disclosure language regarding the impact of DOMA (the federal Defense of Marriage Act) on annuity products.

As we have discussed here previously, the NYSID now requires that annuity products warn lesbians and gay men who are legally married to their same-sex partners that their tax-related benefits are limited by the federal government. This is because the federal government, including the IRS, defines marriage as between one man and one woman. NYSID recommends that specific disclosure language be included in annuity contracts in its Supplement No. 1 to Circular Letter No. 27 (2008). If different language is used, the product cannot be submitted in a certified filing, but must be submitted for review and approval, which is a much more time-consuming process.

We’ve had numerous endorsements cross our desks that duplicate the required language. When we were reviewing an individual annuity that included the required language right in the contract, we stumbled on this phrase: “To the extent that an annuity contract or certificate accords to spouses other rights or benefits…” (emphasis ours)

We thought it might be confusing to an individual owner to come across the word “certificate” in an annuity that has nothing to do with a group contract. We called Mr. Peter Dumar, an attorney at NYSID, and asked if we could delete the words “or certificate.” Without hesitation, he agreed that these words are irrelevant in this situation. He said we could remove them, and he said he would let others at the Department know that this change would still be considered compliant under the supplement’s guidance.

Thanks Mr. Dumar, you made our day. Sometimes, it’s the little things …

Suzanne Seay, Analyst

NU Reports Study Finds GMWB Use Lower than Expected

Cailie Currin — Fri, 22 Jan 2010 10:57:50 -0500

The National Underwriter's Online News Service is reporting today that Ruark Consulting, LLC out of Simsbury, CT, concludes that use of the guaranteed minimum withdrawal benefit options has been lower than originally expected. If these trends continue, Ruark opines, that could be a favorable development for insurers' reserves and capital levels.

The Ruark study found in the 3 million policy years of data that only 1 in 5 are taking any partial withdrawals. Of those who are taking the partials, only 1 in 3 are taking the maximum amount allowed.

One of the things I would have been interested in that was not reported was how many of those taking partial withdrawals are taking excess withdrawals. Ruark finds 1 in 3 are taking the maximum, but I wonder how many may have gone beyond that maximum withdrawal. I look at a lot of numerical examples explaining how excess withdrawals impact values. It would be interesting to me to know how much of an impact those examples have, if any. I recognize that it is easier to determine the "how many" than the "why," but reading the report of this study made me wonder about the allocation of disclosure resources on excess withdrawals, when in fact such a small percentage of owners are taking withdrawals of any size.

Are you Lobbying in MA When You Talk to the Division?

Cailie Currin — Tue, 12 Jan 2010 10:23:12 -0500

Without specifics, it is very tough to know, so I'll just pass [this] along for your reading pleasure.

Monday Morning Musings

Cailie Currin — Mon, 11 Jan 2010 09:32:43 -0500

For a variety of reasons, over the weekend, I spent a fair amount of time thinking about why I do what I do. Much to the surprise of many, I am quite passionate about my work. I was thinking about that in the context of some recent jobs and posts here. I realized several things, none of which are rocket science, but here they are nonetheless:

1) I totally love what I do. I loved it at the NYSID. I loved it when I was in-house. I have found my place. I am happy to get up every morning and go to work, because I love what I do. I am very lucky.

2) I have tremendous respect for the people I work for and with.

3) I love that I am not asked by my clients to cut corners or find ways around the right way.

4) I believe in regulation, not for the sake of regulation, but in effective regulation.

5) I believe in fairness in regulation.

It is this last point that I really spent time working with, in the context of the others in my list. In my opinion, the most important aspect to fairness in regulation is openness, consistency and predictability. I think in many cases it matters less what the rules are, than that the rules are known and change only with advanced warning.

When the rules change without warning—especially if the changes are applied retroactively—it feels unfair. When negative consequences are imposed for acts that were not against the rules when they were done, but at some unknown point in time became so, it feels incredibly unfair. It starts to feel impossible to stay compliant over time because it is impossible to know what the rules are at any given point in time. It is a short step to an attitude of "why should I bother?" "If I can't succeed, why should I try?" "If I am going to be punished even when I try hard to do things right, why should I try?"

If we as a society want insurance and we want a compliant industry, compliance should be made as easy as possible, given that this is a complicated industry. Insurers should have the best possible chance to be compliant while they are doing what they really do, which is sell insurance.

I think a big part of why I like what I do so much is that I get to give some of that. I get to help make it easier for companies be compliant. I can't make it easy, but I can make it easier. I get to help keep good, strong, and intelligent people from getting to the point where they don't think compliance is possible and they stop trying because they can't figure out what the rules are today. I love that!

NY Illustration Annual Certifications

Cailie Currin — Tue, 05 Jan 2010 16:04:43 -0500

Happy New Year!

With the new year upon us, many insurers are working on annual filings. Some companies may have done their annual illustration filings for 1/1/2010, but if your company uses a later date in the year for NY, be sure to consult the [guidance] issued by the NYSID last fall on this topic.

Of particular note is the section titled How Should Policy Forms be Listed? This will come as a surprise to many, I believe. The Department states: "Many certifications only contain lists of policy forms that are currently being issued; however, the certification also pertains to illustrations for existing policies on forms no longer being issued." They emphasize that the list must include all forms for which in-force illustrations subject to the regulation could have been made. The guidance says that the list should distinguish between forms currently being issued and those no longer issued. Note also that all riders "involved" in illustrations must be listed in the annual certification as well as the base policy form.

While guidance setting out best practices and recommendations for clean submissions are always appreciated, this seems to be a new interpretation of this long-standing requirement. Nonetheless, the guidance does indicate that this is one of the Department's "expectations" and it seems likely that those companies submitting lists formatted in ways that have been accepted previously may find they are not accepted this time around.

For those submitting via SERFF, the filing guidance is quite helpful: TOI "Life Insurance & Annuity Products" Sub-TOI "General" and filing type "Life Annual Illustration Certification."

'Twas the night before filing . . .

Cailie Currin — Thu, 24 Dec 2009 15:01:58 -0500

‘Twas the night before filing, and all through the joint,

Not a pencil was moving, ‘cause none had a point.

Every ‘t’ had been crossed, every ‘i’ had been dotted,

All the coffee was drunk, every stomach was knotted.

New York compliance cert’s dated and signed.

We’d assured the signer she’d never get fined.

PDF’s were all ready, uploading begun,

We at Currin Compliance were up for some fun.

But wait, just a minute, something’s not right.

Some brackets are missing, my God, not tonight!

It’s that damn interest rate, with which we’d been fussing.

The percentage is good, but the bracket’s gone missing!

We jumped into action, typing like mad.

We Adobed that thing, putting back what we had.

We quickly revised that bad SOV.

And made it compliant, Cailie and me.

And now we’re so ready, to put it to rest.

Submit it on SERFF. We gave it our best.

We hope when returning the next working day,

The approval we seek, will be heading our way.

But for now we head home, it’s done and we’re leaving.

And to you, Merry Christmas, and to all, a good evening.

...Suzanne Seay

To those who celebrate this week, Happy Holidays...

Cailie Currin — Tue, 22 Dec 2009 15:05:05 -0500

A New Year's resolution (in addition to the usual exercise more and eat less) is to post here more often. I had hoped to get off to an early start by posting more this month, but as some of you know, I had an unfortunate collision with the sidewalk while running with a puppy at Thanksgiving. Bones were broken. As of today I have a cast on my left arm and a splint on my right arm, and I am starting physical therapy for the broken elbow soon. Typing is hard. So, the New Year's resolution will have to wait a bit.

In the meantime, I appreciate all of you; those who read and give me feedback regularly, those who are the more silent type, and those who pop in just occasionally. I like knowing you are there.

For those who celebrate a holiday this week, Merry Christmas or Happy Kwanzaa. For the rest of us, Happy New Year! 2010 is sure to be an interesting one in the world of insurance compliance.

Cailie

Article in Best's Review Makes Life Settlement Confusion Clear

Cailie Currin — Wed, 09 Dec 2009 17:08:09 -0500

In the December 2009 edition of Best's Review, Al Slavin wrote an article entitled "Settlement Strategies" in which the confusing state of life settlement regulation is made a bit clearer. There are helpful charts and tables setting out the differences between the NCOIL and NAIC models and indicating which states have gone in what directions. One thing he touches on, but does not focus on as much as I think he could, is the possible relationship between increasingly red state budgets, due to the recession, and the changing perspective of state regulators to sales of life insurance policies.

It is in quoting Scott Hawkins of Conning Research that this connection is made. He states: "Unfortunately, a lot of people will impoverish themselves in order to qualify for medicaid to have the state support them in the nursing homes...So to the extent that life settlements are one more option among many that a person may turn to at this point in their life, the states may be interested in expanding that discussion."

That seems to directly relate to the lead in Mr. Slavin's article where he describes ME and WA's new requirement that senior citizens and chronically ill individuals, who are about to surrender their policies, be told of the option to sell their life insurance policies to a third party. And that made me think a little differently about some of the issues presented. In addition to the tables and graphs mentioned above, two actual life settlements are sketched.

In one settlement a 54-year old in poor health settled his/her $928,526 face amount policy for $590,000 when the cash surrender value was $6,145. The article states that "The policy owner used the proceeds of the settlement to get out of personal bankruptcy and save her house." While no one wants to see someone lose their house while they are in poor health, the personal bankruptcy is what got my attention. How much of those proceeds are going to pay off creditors with unsecured claims? If any of those are health care related, a whole other set of public policy issues arise: Given the number of personal bankruptcy cases that are a direct result of health crises, that seems quite possible for a 54 year old. If the debts leading to the bankruptcy were not paid, what would have happened? Would any heirs have been responsible? Would s/he have been eligible for medicaid? If all the proceeds of the life insurance policy were used to pay these debts, what is left for the beneficiaries? Who are they and what are their needs?

I don't pretend to know what is right for this individual, or any other specific instance of a life settlement. And as a general rule, I am wary of paternalistic determinations of what is right for consumers. I don't usually support taking options away from individuals if they are capable of making reasonable decisions.

However, when issues converge as they do in life settlement cases like this one, it is very hard to be sure what any interested party's motives might be. And when medicaid and nursing home costs are involved, states are also interested parties. In the past, I would have been much more inclined to view this as a dispute between life settlement and life insurance companies than I do now after reading Mr. Slavin's article. I never thought these were simple issues, but I did not fully realize how truly complicated they can be.

Federal Insurance Office Act approved unanimously by House Financial Services Committee today

Cailie Currin — Wed, 02 Dec 2009 14:46:47 -0500

As a quick FYI, today the House Financial Services Committee unanimously passed, by voice vote, H.R. 2609, the Federal Insurance Office Act. "Today, the Financial Services Committee completed its initial work to reform the regulatory structure of the financial services industry by passing my Federal Insurance Office Act," said Chairman Kanjorski. "I have been working on this bipartisan bill since 2008, and I am pleased that the new Administration recognizes the importance of ensuring that the federal government has a knowledge base on insurance. With the improvements made to the bill today through amendments, we can now continue to move this important bill and the other regulatory reform bills through the legislative process. I am eager to pass these bills in the House." The bill is available [here.]

Surprising Post-Approval Review Objection from NYSID

Cailie Currin — Mon, 30 Nov 2009 09:00:00 -0500

As we all know, post-approval reviews often reveal new and unexpected positions on the part of the New York State Insurance Department. However, some are just downright astonishing—especially when accompanied by a demand for a "corrective endorsement" for in-force policies.

If your company issues UL policies, you are advised to note the following objection: "Minimum loan amounts are not authorized by statute and are not permitted. Please provide a corrective endorsement." The Department does not say that there is a statutory PROHIBITION against a minimum loan amount. There is simply no specific authorization for a minimum loan amount on UL policies. The legislature did not address this issue at all and there is no NYSID regulation governing UL products.

The Department did, however, draft a regulation regarding VUL products and guess what? Minimum loans are expressly permitted. Section 54.6(b)(10)(vii) of regulation 77 states: "The policy may specify a reasonable minimum amount which may be borrowed at any time, but such minimum shall not apply to any automatic premium loan provision." Can a company really be faulted for thinking the same standard would apply to UL policies absent anything in a law or regulation to the contrary? The Department created that standard for VUL itself, wouldn't you rationally think it would apply to UL policies too?

And of course here we are talking about having to do a "corrective" endorsement? What is being corrected? The Department permits reasonable minimum loans on VUL, but having a minimum loan amount is so egregious a "violation of law, regulation, or circular letter" that a corrective endorsement must be provided to all in-force business. But what law; regulation or circular letter you might ask? The silent law, the silent regulation, the silent circular letter.

Missouri's Requirements Regarding Variable Material Combinations

Cailie Currin — Tue, 24 Nov 2009 11:35:01 -0500

Remember factorials? Brush off your 9^th-grade math book, because [Missouri recently began requiring that companies report the total number of form combinations that are possible, given all the text bracketed as variable material.]

We have received several inquiries regarding our experience and recent e-mail list exchanges have suggested there is much confusion out there. However, it's not as daunting as it may sound. The number indicated should represent the number of TYPES of insurance (on the life side), or types of PLANS (on the health side), being offered, according to a representative of the Missouri Department of Insurance, Financial Institutions, and Professional Registration. So, for example, on a variable annuity contract with lots of bracketing of the usual items on the specifications page, it's a "1" because it's a variable annuity with a particular set of charges that happen to be variable. One type of insurance.

A variable annuity contract with six optional riders, each of them bracketed? Still a "1." Still a variable annuity. It is not the number of items bracketed that they care about, but whether additional types of products are created by the use of bracketing.

Of course, it may not be as hard as it sounds, but it isn't completely easy either. There is room for error. The variable annuity with the six riders could be identified as a "6" (although we believe the Department would prefer a "1"). But let's say five of the riders address tax-related issues, and one offers Guaranteed Minimum Withdrawal Benefits. A reasonable person could identify this as "2" types of insurance being offered: a plain VA and a VA with GMWB.

Ok, so what if you're wrong? No worries. The number designation is not a compliance issue. The Department is not presently regulating the assigning of the number of combinations; it's just requiring that it be calculated. However, because of this new requirement, they do seem to be looking more carefully at variable material, so other problems are coming to light for some companies.

We specifically asked if an explanation accompanying the number might be helpful for the reviewer? Answer: No, just the number, please.

By way of context, the Department is using the information it collects to identify trends. The rule was inspired by the overwhelming amount of bracketing on health policies being filed recently, where it’s clear that a wide variety of plans, offering a wide variety of benefits, is being offered through one "form." So, be careful with variable material, prepare it well, and assign the number of types/plans of insurance as accurately as possible, but do not lose sleep over whether this new requirement will result in your file being closed. All else being correctly done, it will not.

NY Ins. Dep't Cites 2 Life Ins. Complaints in 11/20 Press Release

Cailie Currin — Fri, 20 Nov 2009 15:47:29 -0500

Historically, life insurance has resulted in few complaints to Insurance Departments when compared to property/casualty or health insurance. However a [press release] issued today by the New York State Insurance Department discusses three complaints, two of which are life insurance complaints.

The press release touts $8.12 million in funds returned to consumers in the third quarter 2009 as a result of NYSID intervention. The two life insurance complaints together amounted to less than $60,000. Both complaints involved pretty small face amount policies. Despite the low dollar amounts involved, they are featured prominently in the release suggesting that perhaps life insurance complaints are more common and are higher on the Department's radar than they have been in the past.

Insurers would be very well served by making sure, in these difficult times when budgets are under great pressure but regulatory attention is heightened, that compliance, market conduct, claims and complaint handling do not get short shrift. The reputational harm to the company and the industry far outweighs the short-term budget relief that may result from cuts to these areas. A quick look at this press release is a good reminder for life insurers.

UPDATE: PIMCO is NAIC's Choice

Cailie Currin — Tue, 17 Nov 2009 18:26:45 -0500

The NAIC announced late today that PIMCO has been selected as the third party financial modeler to assist state regulators in their determination of the risk based capital (RBC) requirements for residential mortgage-backed securities (RMBS).

In today's press release, Roger Sevigny, NAIC President stated: “Creating this new assessment process is an important step toward providing more transparency about these complex securities. This unique treatment of residential mortgage-backed securities distinguishes the NAIC as the only regulator to analyze these securities and require capital based upon the expected loss amount for a particular company. ”

An open Valuation of Securities Task Force call is scheduled to take place on November 30 as the next step. There will also be a task force briefing at the NAIC Winter National Meeting on December 7 in San Francisco. Because companies need to begin reporting under the appropriate designation in early 2010, the pressure will remain to keep this process moving quickly.

Tele-Applications and Underwriting for Smoking

Cailie Currin — Fri, 13 Nov 2009 08:00:00 -0500

Currin Compliance has seen an increase lately in the number of telephone applications crossing our desks for review. A recent article in the National Underwriter (Nov. 2, 2009) may offer one reason why:

Hank George offers a nicely written piece titled [“Cigarette Smoking: Time to Upgrade the Underwriting.”] He suggests that in telephone interviews, applicants are more likely to be forthcoming in answering smoking-related questions than in the traditional application-taking process.

George goes on to offer an example of a person who smoked for 2 years as a young adult, quit for the next 60 years, then started smoking recently as a result of a personal loss. He’s classified as a smoker. Yet the person who smoked 2 packs a day for those 6 decades, but has been nicotine-free for the last 5 years, is classified as a non-smoker. Who is the greater life insurance risk? he asks. George says framing questions to determine “pack years” makes more sense for underwriting purposes. And asking those questions over the telephone is a better way to get truthful answers.

Based on George's assertions, which certainly seem reasonable, it seems the applications we've been reviewing and filing will contribute to more accurate underwriting of smoking risk. Assuming of course, that they are approved.

NAIC Announces Rating Model for Mortgage-Backed Securities

Cailie Currin — Mon, 09 Nov 2009 10:57:28 -0500

Earlier this year the NAIC formed the Rating Agency Working Group to look at the use of ratings by state insurance regulators and the risk posed by the use of these ratings in the regulatory process. Last week a [proposal was approved] by the NAIC membership that will result in a new model for determining the treatment of residential mortgage-back securities. In addition, it will produce ratings designations for roughly 18,000 of these securities for year-end 2009 RBC calculations. An independent third party will be partnering with the NAIC to develop the model and responses to an RFP were due last week. The selection will be announced mid-November according to a [press release] issued by the NAIC.

Time is of the essence as we rapidly approach year-end. Taking on a project of this scope on such a short timeline could be significant in demonstrating the effectiveness of state regulation over the solvency of insurers. NAIC President Roger Sevigny stated in the press release: "Compared to the rest of financial services, the insurance industry has weathered the impact of the credit crisis extremely well." This project could tell us quite a bit about how state insurance regulators are weathering the resulting regulatory challenges.

AICP National Conference in Phoenix

Cailie Currin — Thu, 15 Oct 2009 10:26:20 -0500

I can't believe it has already been more than a week since I returned from the great AICP conference in Phoenix. This was the first time that Currin Compliance was a sponsor of this conference and it made for quite a different experience. Anne Martin, who heads our Iowa office, and I went together so we could take turns being at the booth and it was really interesting seeing the conference from that perspective. I also presented on Rule 151A and annexed is a copy of an [excerpted presentation]. I shared the allotted time with Sheryl Moore from AnnuitySpecs.com and Eric Nordman from the NAIC.

I want to thank all of the volunteers who made the conference such a success even in these tough times when many were unable to travel for the event. It still felt well-attended and there were many interesting discussions during the conference - not to mention plenty of fun. I look forward to next years' event in Dallas!