Are Standardized Death-Matching Guidelines on the Horizon for Insurers?

As many in the insurance industry now know, New York Life Insurance Co. (NY Life) has recently agreed to a $15 million dollar settlement to close its unclaimed property audits.  While NY Life has been considered by many to be a role model regarding the proper and proactive use of the Social Security Administration’s Death Master File (DMF), until this point, their lack of a settlement was viewed as a roadblock to moving towards a national standard.

On Friday October 25th, 2013, the National Association of Insurance Commissioners (NAIC) Executive Committee held an open meeting via conference call with a primary focus:

“To review life insurance company use of the Social Security Death Master File or similar databases, including available examination reports and settlement agreements, and determine whether a model law, guideline, regulation or other vehicle should be developed to ensure fair and uniform claims settlement practices with the understanding that this charge in no way interferes with states’ ability to continue to take action with regard to such practices that may be in violation of existing state law.”

I, along with over 100 others, joined that call as an ‘interested party’.  Following a roll-call and some brief attention to other matters, the committee immediately moved to close the meeting for private discussion.  After approximately 45 minutes of ‘exhaustive discussion’, the interested parties were brought back on the line and advised that the NAIC executive committee will not be taking further action at this time with regard to this matter.  In response, the sole comment came from American Council of Life Insurers (ACLI) Senior Vice President of State Relations Bruce Ferguson, who thanked the committee for their consideration and reiterated the challenges of the fractured state of affairs that exist today along with Congress’ recent attempts to limit access to the DMF.  Mr. Ferguson concluded by urging the NAIC to give this topic renewed attention as soon as reasonably possible.  With no other comments, the meeting was adjourned.

Looking ahead, this reaffirms the clear message that insurers’ must take immediate steps to comply with the myriad of different regulations that have already been passed, while also giving consideration to proactively implementing practices that will satisfy those states that have not yet made their own expectations clear.

The Cross Country Computer perspective remains unchanged.  Our strong recommendation is that insurers should be applying a disciplined approach, such as that offered by APEARS®  which incorporates fuzzy matching logic that has been drawn directly from the negotiated Global Resolution Agreements and Regulatory Settlement Agreements (GRAs & RSAs), which the states have already accepted.  APEARS® layers-in additional screening techniques to help differentiate strong from weak or false positive matches in order to simplify and reduce the cost of an insurer’s downstream research efforts.

The application of a rigorous set of rules can serve as a proxy for insurer “best practice” while we wait for a formal resolution to be established.

Another related article on this topic Unclaimed Property: Status quo Prevails

For more information on Cross Country Computer’s APEARS® death matching capabilities and to stay informed about other relevant insurance legislation, please contact Thomas Berger at (631) 220-6947 or via email to


About Tom Berger

Thomas Berger is Chief Executive Officer of Cross Country Computer. Tom joined Cross Country in 1991 and acquired the company in 1996. During his tenure, Tom has overseen the debt-free growth of CCC and has been instrumental in strengthening the company’s infrastructure while simultaneously developing new services and diversifying into new business lines. Tom has personally developed the vision and design specifications for many of Cross Country’s systems, including TBeaut and CBeaut, our proprietary title and company name standardization products. In addition, Tom holds the patent for our Abandoned Property Escheat Assignment & Reporting System (APEARS™). Tom has served two terms as Treasurer of the Unclaimed Property Professionals Organization (UPPO) as well as two years as Secretary of the Unclaimed Property Committee within the Securities Transfer Association. He assisted in the creation of a white paper designed to educate the holder community about unclaimed property review and reporting practices. Tom has spoken frequently at Unclaimed Property conferences and was honored with the 2005 Unclaimed Property Holders Liaison Council’s (UPHLC) President’s Award. Tom is also an active member in numerous direct marketing related organizations including the Direct Marketing Association of Long Island, where, in 2012, he was selected as one of three inductees into the DMALI Hall of Fame. He is also a lifetime member of MENSA, the international High IQ society. Tom holds a BS degree in Management and Marketing from the Rochester Institute of Technology and has received military security clearance to oversee our government accounts.
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2 Responses to Are Standardized Death-Matching Guidelines on the Horizon for Insurers?

  1. Avatar Tom Berger says:

    At the request of Nebraska Insurance Director Bruce Ramge, the NAIC plans to reopen discussions about whether the NAIC should develop a formal position regarding life insurers’ use of the SSA Death Master File or other sources to identify unclaimed death benefits:

  2. Avatar Thomas Berger says:

    On Dec. 4, the NAIC agreed to undertake a study to determine if recommendations should be made to address unclaimed death benefits aimed at ensuring “fair and uniform” settlement practices.

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