The link above will take you to an interesting article that may impact insurer’s evaluation of the reliability of ‘deceased databases’ beyond the Social Security Administration Death Master File (SSA DMF). At times, we have been surprised to hear an insurer claim that they are ‘in compliance’ or ‘not concerned’ about death matching mandates because they are already performing deceased processing on some subset of their policy base using a source other than the SSA DMF. Cross Country Computer has worked with many clients to explore how these ancillary deceased sources may be leveraged to help insurers comply with the NCOIL Model Unclaimed Property Act and state specific regulations such as NY’s Reg-200. Based on extensive testing across many policy bases we have determined that these secondary data sources cannot be reasonably relied on as a primary source for death matching due to their higher error factor, gaps in coverage, and lack of transparency with regard to their sourcing and compilation methods. As such, we have long been an advocate of using these databases as a supplemental source intended to help increase or decrease the relative confidence of marginal matches to the SSA DMF itself. In doing so, it is critical that insurers (or providers such as CCC) segregate these lesser files from the core SSA DMF, as intermingling of data collected from multiple sources will decrease the overall reliability of your death matching results and make it more challenging to manage the research and outreach process. We expect that this directive from the FTC will shed more light into how these sources are compiled, which in turn will help reveal some of their shortcomings. Positively, the increased transparency could lead to improved practices and better reliability over time, however these benefits may be offset should these privacy mandates lead to certain data sources be eliminated. We will continue to monitor this situation and keep you posted.