Unclaimed Property V
April 22, 2015
CEFLI Conducts Another Successful Unclaimed Property Summit Meeting – Outstanding Faculty Offers Valuable Insights for Attendees
CEFLI recently completed the fifth edition in its popular Unclaimed Property Summit Meeting series on April 22 in Chicago. The meeting explored a range of
issues on this important and challenging compliance issue and offered attendees unique insights from outstanding faculty members with broad experience in unclaimed property matters.
The Summit Meeting began with a review of legislative developments in the states with respect to enactment of various versions of the NCOIL Model Law. It was noted that many states have adopted disparate versions of the NCOIL Model Law including some laws that apply retrospectively and others that apply prospectively only. The discussion also reviewed the distinctions between market conduct examination activities conducted by State Insurance Departments versus unclaimed property audits conducted primarily by State Treasurers or Unclaimed Property offices. The session concluded with a review of the policy considerations and compliance implications that life insurance companies should consider to address recent developments in a comprehensive manner.
Summit Meeting attendees heard an update on recent litigation developments and their potential implications for life insurance company unclaimed property compliance strategies. It was noted that it will be important to continue to monitor litigation activity related to unclaimed property matters as decisions have not yet been rendered in several significant litigation matters.
The meeting also offered an opportunity for industry experts and company representatives to explore the likelihood of future unclaimed property audits and examination activities for those companies that may not have been subject to examinations and audits thus far. The general consensus of the discussion was that unclaimed property matters are “here to stay” and companies, regardless of size, would be well advised to be prepared to undergo unclaimed property examinations and audits over the months ahead.
Attendees were able to hear insights from industry experts and representatives of life insurance companies that have entered into settlement agreements concerning unclaimed property matters. The session focused on “lessons learned” in going through the settlement agreement process and explored the implications for overall process improvements in compliance practices across corporate enterprises.
CEFLI was fortunate to have a panel of industry experts representing organizations that are considered to be leaders in information technology related to the Social Security Death Master File access that discussed the current status of the certification process to gain access to the DMF and strategies that companies are exploring in anticipation of issuance of the final rule regarding the certification process by the National Technical Information Service.