Unclaimed Property Compliance: How to Prepare for New Regulation

Given the fast-paced change underway in regard to unclaimed property compliance, Insurance companies are faced with challenges to develop the capabilities necessary to comply with new unclaimed property regulations.

Some of the challenges facing Insurance companies such as changes in the regulatory landscape include the recently signed Global Resolution Agreements, Regulatory Settlement Agreements and approved regulations from a number of states including New York, Kentucky and Maryland, among others. All of the changing regulations require Insurance companies to perform periodic matches to the Social Security Death Master File (DMF) and compare their insurance and annuity contracts against State Policy Finder files.

As a result, Navigant has been working with Insurers who are responding to unclaimed property audits and implementing settlements, or preparing for new regulation.

If you are involved in unclaimed property audit and are facing a dilemma due to the evolving regulatory landscape, consider the following:

  • Develop a strategy for collecting relevant data across administrative, claims and beneficiary platforms.
  • Proactively run your book of business up against the SSA Death Master File to understand your potential exposure.
  • Analyze data to look for gaps such as missing names, social security numbers and birth dates and undertake efforts to fill in the gaps  to prepare for abandon property audits and respond to new regulations.
  • Implement a beneficiary outreach communication strategy as contacting beneficiaries about long lost policies are often perceived with skepticism.
  • Utilize full data analytics and heuristics to mechanically remove or “refute” false positives and policies without a payable benefit.
  • Create a supportive workflow system that has the additional information needed for these types of claims.
  • Invest in building a valuation tool that will automate a majority of the calculations of the death benefit due.
  • Consider sourcing to an expert the effort to locate beneficiaries and connect them with you for claim validation and adjudication.
  • Build out a capacity model to help you understand the resources required to complete the work and to identify the most labor intensive processes that may benefit from process reengineering or technology enablement.
  • Create a feedback loop to bring the actual results into the reserving process and periodically refresh the analysis.

Navigant can assist Insurers with addressing unclaimed property compliance requirements and related issues through its Unclaimed Property Solution—an end-to-end solution to help clients understand, plan and meet the requirements of the newly signed regulations. The Unclaimed Property Solution includes strategy and governance advisory, matching of administrative records to public deceased records, complex data analytics, regulatory response guidance, settlement and exposure (reserves) projections, and both operational and IT readiness. Navigant’s Unclaimed Property Solution also includes a toolset, tailored to the most recent regulatory requirements to support Insurers in adhering to the dynamic regulatory landscape.

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