Porter Flashcards
Which state had the 1st DOI and which state was first to be chartered?
New York in 1859
Pennsylvania in 1792, many others by 1797
chartered under the British Crown….
Regulation in the early 1800s
regulated by states in which the charter was obtained in
different regulations by state
agents could sell in other states if informaton was on file about that insurer in that state
felt pressure to protect domestic insurers from British insurers entering the market
How was NY a leader in regulating insurance?
Established a process for managing liquidation of insurers
imposed 10% retaliatory premium tax for fire insurers from other states
Filing of annual statements (Comptroller ensures solvency)
Required UEPR
in 1859 created DOI
Paul v Virginia (1869)
Supreme court reviewed constitionality of VA licensure law
Paul applied to be agent in home state VA for NY insurer
he got denied (no foreign insurer bond), sold anyway = arrested
appealed conviction which…
- affirmed lower court ruling
- insurance is contract delivered locally, not interstate commerce
- states CONTINUE to regulate insurance
National Insurance Convention (1871)
-States not happy with Paul decision, more operating in many states
-issues with meeting state demands (varying regulations)
-first meeting of NAIC
NIC did this…
- consititution for regulator goals
- uniform accounting statement
- guidelines for taxes
- adopted 1st model law (commissioners duties, regulation)
Evolution of multiline insurers
in Early 1900s, DOIs didn’t allow multiline insurers (auto,prop)
- insureds needed policies from 2 separate insurers
- package policies from 2 insurers (sharing P/L)
- finally allowed in 1945, 1930s disapproved still
before that…
- company sold via subsidiaries
Industry before the SEUA case
1800s = fierce competition / insolvencies => insurer compacts
Late 1800s, little corporate reg, unethical behavior led to
Sherman (not apply to insurers) …..
made insurers pass their own anti-trust laws (no compacts)
When were anti-compact laws repealed (by states)?
regulators wanted to stop ineffective competition = > insolvencies
1923 NCIC passed resolution to repeal anti-compact laws
this led to formation of SEUA
Insurers NEED! to cooperate in setting rates, its the nature of the business
NCIC = National Center for Interstate Compacts
Indictments on SEUA
• Continuing agreement and concert of action to take control
of 90% of the fire & allied lines market
• Fixing premium rates and agents’ commissions
• Using boycott and other forms of coercion and intimidation to
force non-SEUA members to comply
• Withdrawing rights of agents to represent SEUA members if
they also represented non-SEUA companies
• Threatening insurance consumers with boycott and loss of
patronage if they didn’t purchase insurance from SEUA
members
SEUA Decision (1944)
Initially dismissed bc Paul v Virginia ruling
Ruling….
- insurance is interconnected
- only 18/200 SEUA were domiciled in the 1/6 states
- no other business is beyond Congress powers
- other intangibles, telegraph, subject to Congress
Now, federal reg applies to insurance (Sherman/Clayton, Robinson)
2 Key questions for SEUA case
(1) Did Congress intend the Sherman Act to prohibit insurer’s
conduct of restraining/ monopolizing business?
(2) Do insurance transactions across state lines constitute
“commerce among several states”, which will subject them to
Congressional regulation?
Sherman Act (1890)
prohibits collusion to attempts to gain monopoly power
- any act that restricts trade/commerce = illegal
- e.g. boycotting / intimidation / coercion
Clayton Act (1914)
ID’d and prohibited practices that either lessen competition or create monopolies
T ying
E xclusive deadlings
M &A that lessen competition
P rice discrimination
O ne director at multiple companies
What did the subcomittee on federal legislation recommend post SEUA?
-pressure Congress to enact Legislation under commerce clause to give states authority back
-amend sherman/clayton to allow cooperation in rate setting
-FTC act / robinson amended to exclude insurance
McCarran - Ferguson (1945)
-returned authority to states, in public interest
-states had until 1948 to regulate insurance to limit federal regulation
Exceptions to MF
-if states are not regulating, federal takes over
-sherman applies for intimidation/coercion/boycotting
-applicable federal law»_space;> state insurance law
Post MF
NAIC & state legislatures developed laws to
- allow rate cooperation
- keep congress from interfering
NAIC passed 2 model bills to
- rates not excess/unfair discrim / inadequate
- rate cooperation, as long no hinder competition
Required prior approval of rates, explained filing, said how rating orgs helped, recommended anti-rebate laws
STATES DONT HAVE TO ADOPT THESE LAWS, and many did not
NAIC Unfair Methods of Competition (1947)
-preempt application of FTC to insurance
what is unfair or deceptive? (BIC- FURD)
- boycott
- intimidation
- coercion
- false info & financial statements
- unfair discrimination
- rebating
- defamation
What are regulators most concerned about post MF?
-insolvencies
-unavailable coverages
-inequitable treatment of consumers
Guaranty Association Model Act (1969)
-created state guaranty funds
NAIC 1971 - Early Warning Tests Program
-renamed to IRIS in 1977
-to prevent need for guaranty fund assessment by taking over
insurers and returning them to capacity or merging
NAIC Model Accreditation Program
1989
-created similar solvency standards in all states
FAIR
-insurance pool where private insurers address unmet need for property ins, on a state level
-1968, loss by riot or civil commotion
LRRA 1981
Products Liability Risk Retention Act - FEDERAL
-address unsafe products, regulatory uncertainty, questionable price/reserving practices for PL, especially medical malpractice
-allowed RRGs to form
-pool of companies, similar exposures
-regulated via NAIC Accreditation
-no guaranty funds
-can use GAAP, no rate filing, but normal financial reporting
-only licensed in domiciliary state
Key area where surplus lines is NOT regulated.
rates and forms…
meaning it can quickly adapt to consumer needs
Key surplus lines attributes
-only specially licensed producers
-insurers need to meet financial and managerial reqs
-diligent search must be performed in admitted market, UNLESS…
ECP + other applicable rules
What laws apply to surplus lines?
-need a surplus lines broker
-domiciliary jurisdiction reviews for solvency
-surplus lines licensing needs P&C standard license
capital reqs usually over 15m
often reqs to be licensed in 1+ other states, need to be multiple years
NO GUARANTY FUNDS!!!!!!
Gramm - Leach - Bliley Act Background
in 90s, affiliations bw insurers and banks caused questions abt who regulated (banks = federal, insurance = state)
GLB Financial Services Modernization Act (1999)
-prohibits state from preventing banks from selling insurance
- UW != (sales + marketing) =>
-banks can’t form subsidiary to UW insurance (make it harder for bank to use insurer assets to avoid insolvency)
-reqs bank to disclose info sharing policies (can lead to inconsistency in practice)
-makes states faciliate producers ability to operate in 2+ states => NAIC Producer Licensing Model Act
GLB Concerns
-privacy of info
-ability of states to serve global financial market adequately
-consumers need or desire for integrated services
NAIC Producer Licensing Model Act
requires states to establish either a system of reciprocal producer licensing or uniform licensing standards
3 Circumstances where state laws are void under U.S Constitution
-state law contradicts a federal
-courts determine state law interferes with purpose/results of a federal but not contradict
-imposes improper burden on interstate commerce
Business of Insurance Definition Evolution
U.S vs SEUA (1944) - fixing rates is part of it
Robertson vs Cali (1946) - licensing of comp/agent is part
FTC v National Casualty Co (1958) - selling/advertising is part of it
SEC vs Variable Annuity Life (1959) - variable annuities not part
SEC v National Sec (1969) - company/stockholder relationship != insurance
Group Life & Health vs Royal Drug (79) - mccarran exempts BOI, not insurance companies
Union Labor Life vs Pireno (82) - three criteria from group life not enough, must be reviewed case by case
Business of Insurance def post- SEC v National Securities Inc (1969)
⇒ Relationship between insurer and insured
⇒ Types of policies that can be issued
⇒ Reliability, interpretation, and enforcement of
policies
Business of Insurance def post- Group Life & Health (1979)
⇒ Spreading and underwriting of risk
⇒ Direct connection between insurer & insured
⇒ Activity needs to be exclusive to entities within the
insurance industry
What is the current def of the business of insurance?
Activity with 1+ of these
* Insurer spreads or underwrites the policyholder’s risk
* Insurer and the insured have a direct contractual agreement
* Activity is unique to entities within the insurance industry
receives protection from federal intervention (under MF Act)
Securities Act of 1933
prevent abuses of fraud,deceit, and misrepresentation in the sale of securities
market system so investors can gain knowledge on securities to buy/sell
stock orgs must register securities to sell (prospectus)
When/how was the SEC established?
in 1934, in conjunction with Securities exchange act of 1934 to help regulate U.S markets
Securities Act of 1934 requirements
annual reports to shareholders
5 yrs of financial data
managements discussion on liquidity/capital
income statements / cash flows / balance sheets (3,2 yrs)
Federal Taxes on insurers
apply general corporate tax rules
can deduct reserves
ERISA (1974)
stop abuse in private pension system + employee benefits
-employers took tax deductions for benefits employees didn’t get
- ERISA ensures participants are more informed
- also set greater standards, funding levels, protection to participants
How does ERISA impact insurance?
insurers that administer relevant benefit plans are subject to certain reponsibilities to plan fiduciaries
must also verify plan benefits and comply with ERISA
Miscellaneous Acts that apply to insurance
Civil Rights Acts
Age discimination in employment
older workers benefit protection act
americans with disabilities act
How does the FBI impact insurance?
-works to detect and prosecute fraid
-crime investigation, auto theft for example
How does the EPA impact insurance?
dictates exact wording in certain policies
can apply to surety bonds as well
How did the ICC (Interstate Commerce Commission) impact insurance?
policy forms must be prescribed & approved by ICC
iCC needs 30 days notice b4 cancelling policies
dictates minimum policy limits & conditions
-ABOLISHED AND REPLACED IN 1995
Briefly describe how courts impact insurers.
-decisions from cases can change regulation
-can impact DOI functions court can shut down regulator issued rule
-courts interpretation for one situation can affect all insureds
-court tested language usually helps insurer
-can influence claims settlement procedures
Contract of adhesion
⇒ Contract drawn up by only one party, insurer
⇒ Ambiguous language will be interpreted in favor of
insured
Doctrine of reasonable expectations
⇒ Insured’s reasonable expectation of coverage will be
honored
What are the functions of Insurance Trade Associations?
-provide services to insurers,agents,brokers
-prompt access to legislative developments
-continually watch for new regulations from state insurance departments
-exert influence on NAIC, state regulators
-give more accurate info on critical issues
What do insurance advisory organizations do?
-filing rates & loss costs
-develop rating systems
-collect & tabulate stats
-educate members
-monitor regulatory issues
-research important topics
-Actuarial Analysis
Consumer Groups
-PH may feel against insurance company
-help them tackle public interest issues
-PH complaints can trigger market conduct exams, basically make regulators force companies to do something
What consumer complaints have led to major legislation?
-redlining prohibitions
-unfair claims and trade practices laws
-FAIR plans
-tort reform
-high-risk drivers pools
Source of State Insurance Law
-Legislative (House of rep & senate) - standard insurance code, statutory law creation => statutory law
-Executive - insurance department (enforces and adopts regulation) and attorney general => administrative law
Judicial branch - state court system => case law
Briefly describe the four features that a typical state insurance regulatory system contains.
licensing reqs - need certificate of authority to write, need to be licensed 1st
reporting & filing reqs
periodic exams
power to post sanctions
Describe NCOIL and its activities.
org of state legislators who care mostly about insurance
-improve regulation
-educating legislators on issues
-assist communications b/w state legislators
2 Key ways state legislatures influence insurance regulation
- Often directly control DOI budgets (performance reviews can affect this)
- Pass the insurance laws that insurance commissioners must
enforce
How does legislature directly overlook insurance commissioners
-regulators submit periodic report to legislature
-commissioner submits annual report summarizing activities of dpt and status of industry which must…
- list insurers closed for that year
- names of companies in receivership
- recs by com about laws
- exhibit summarizing financial status of licensed insurers
How does legislation affect insurers in non-insurance laws?
Banking
Contract law
Fraud (many DOIs have fraud dpts now)
Investments
Lobbying
NAIC Purpose
established in 1871
Coordinate the regulation of insurers operating in multiple
jurisdictions
uniform financial reporting was 1st step
NAIC 5 fundamental regulatory objectives
- Protect the public interest
- Promote competitive markets
- Facilitate the fair and equitable treatment of insurance
consumers - Promote the reliability, solvency, and financial solidity of
insurance institutions - Support and improve state regulation of insurance
How does NAIC help state regulators?
- scrutinizing alien insurers
-track insurance issues @ federal level - pricing and coverage help
-valuing securites (securities valuation office)
-maintain DBs to track financial adequacy (IRIS)
NAIC leadership
annually elect a president, VP & secretary from among their members for one year terms
How can model laws help state legislators?
NAIC researches and drafts model laws
-streamlines the process of new laws
-states can choose to adopt, or modify
-benefit from legal uniformity
-produced during NAIC national meeting
Why might model laws not be adopted or changed?
-may view as inappropriate or unnecessary
-may modify to better match needs
-legislature considers many matters, NAIC not that important
DOI Financial Accreditation
-NAIC basic standards for solvency regulation
Steps
-com submits request => NAIC
-NAIC review team visits dpt, interviews, reviews laws/prior exams, inspects regulatory files, gains understanding, and has closing conference to prepare a report
Financial Regulation Standards Accreditation Committee and Review Team decide together
3 criteria to be accepted for Fin Accred
(LRD)
* Laws and regulations used by the state must meet certain
basic standards of NAIC models
* Regulatory methods of the state must be acceptable
* Department practices must be adequate
Why do states have concerns about NAIC Accreditation?
⇒ May create resentment due to some legislators who
may feel accreditation usurps legislative authority
⇒ Additional and revised model law requirements
create a continual need for new legislation
Who does the day to day regulation of insurance?
executive branch of government
-either separate department within the executive branch
or by a unit that is part of a larger group in the branch
Regulatory Functions of DOI
-licensing for companies,agents,claims adj
-regulate pricing
-some states have no pricing laws, have legal power under powers and duties provision
even w/o prior approval, states can force withdrawal of rate/coverage
List some common reasons for disapproval of filed rates.
not in public interest
illegal
unfairly discriminatory
other, excessive, inadequate, not min standards
Most states have prior approval
What is the Financial Condition Examiners Handbook?
its used by all states to promote uniform financial exams
How often are financial exams conducted?
every few years, varies in length based on financial condition, extent of exam and number of examiners
Basic purposes for financial exams
⇒ Detect as early as possible those insurers in
financial trouble and/or engaging in unlawful and
improper activities
⇒ Develop the information needed for timely,
appropriate regulatory action
What is reviewed in a financial exam?
statistical statements
accounting procedures
financial statements
financial controls
IRIS
investments
Market Conduct Exams
Review how insurers do business
Market Conduct Examiners Handbook
-sales & advertising
-UW
-Pricing
-Claims
How does DOI license producers?
May need to pass examinations and
pay fees to obtain licenses
May require that licensed agents and brokers meet continuing
education requirements and conflict of interest standards to maintain their licenses
How does DOI regulate adjusters?
-practices covered in market conduct exams
-may be licensed through a test and CE
-may have law that com can examine their records
1968 Omnibus Crime Control and Safe Streets Act
- Made it illegal to defraud, loot, or plunder an insurer
- Established a multi-state approach to anti fraud activity
Before 1994, why did few states have fraud departments?
- Restraints on budgets
- Lack of insurance fraud laws
What is a receiver?
disinterested person/business appointed to
receive, protect, and account for money or other property
due
a receiver appointment creates a receiver(ship)
What might require an insurer undergo rehab efforts?
- Liabilities exceed assets
- Insurance company refused to submit books, records,
accounts or affairs to insurance department - Insurer willfully violates its charter or any other state law
What is the initial free surplus requirement?
Amount new stock insurer needs to provide ABOVE minimum capital
What is the minimum required basic surplus?
Amount of surplus existing insurers need to continue writing
What impacts the capital required to write business?
Lines of Business (more hazardous = more capital)
Ownership type (stock insurers lower cuz can issue stock, captives lower as well, repriocals higher)
How are domestic insurers licensed?
regulator needs access to books and records (in- state)
usually required to have an in-state office (create jobs, easier access)
Exam….
min capital and surplus
good management
records in order
forms and rates have approval
How are foreign insurers licensed?
better than start-up, gone through rigor of another state
2-3 yrs annual statements, recent financial exam copy
financial statements (SAP, maybe GAAP)
needs certificate of compliance from dom state
Holding insurer registration statement = if in holding system
cant shift business to affiliate in the new state
Seasoning for foreign insurer licensing
⇒ Only experienced insurers are acceptable
candidates
⇒ Exceptions if insurer has substantial capital, owned
by an insurer with lengthy history, or if the
department is satisfied with the application for other
reasons
⇒ Prevent start-ups from engaging in multistate
licensing projects in initial years of operation
Alien insurer licensing
need to select a state as port of entry for U.S branch establishment
needs data required for foreign insurer as well as
U.S manager
Trust agreement
Certificate of alien funds on deposit
Briefly describe three ways methods to achieve goals are unique in insurance.
rates are set before costs are known
regulatory environment differs by state
has many information sharing and joint product development mechanisms
Ocean Marine Regulation
little regulation
individualized risks
no statistical info
knowledgeable buyers and sellers
Inland Marine Regulation
only informational filings
* Highly individualized risks
* No statistical info to justify rates
* Diverse coverages and classification
Surety Regulation
rate manuals filed, little review
* Less detailed stat plan and ratemaking data
* Fewer statistically based rating factors
* Subjective risk evaluation
* Less credible loss experience
Title regulation
filed, little review
* No stat plan or ratemaking data
* Few rating or risk evaluation factors
* Underwriting and exposure identification key to controlling
losses
* Driven more by business expense than by insured losses
CGL Regulation
general regulation
-sophisticated buyers
PPA Regulation
review rates/plan
* Legally required or socially desirable for consumers to
purchase
* Uninformed consumers
* Highly uniform stat plan with credible rate data
* Complex rates and classification system
WC Regulation
close regulation, pripr approval of rates
* Legally required of most employers
* Costly, widespread business
* Complex rating and classification system
Political Theory of Regulation
a. Partially explains the rate regulatory system
b. Regulatory attention can be greatest for issues that attract
substantial voter interest and are easy for policymakers to
understand
P&C Ratemaking Principles
- A rate is an estimate of the expected value of future costs
- A rate provides for all costs associated with the transfer of risk
- A rate provides for the costs associated with an individual risk transfer
- A rate is reasonable and not excessive, inadequate, or unfairly discriminatory
What do statistical agents do (examples)?
collect and report loss experience
examples. ISO, NCCI, NAII
Have rating bureaus faced regulatory pressure?
Yes (Anti-Trust concerns) which led to
ISO (& others) stopped filing final rates in the 90s
only do loss costs and trends now
What is a statistical plan?
formal set of directions for reporting losses (and possibly
expenses) to a statistical agent
Briefly describe several functions of a rating bureau.
loss development
loss trending
developing classification systems and class relativities
make filings to DOI / develop forms / producing statistical reports to regulators
What are the three levels to control financial struggles?
- Mandatory corrective action
- Administrative supervision
- Receiverships, rehabilitation, and liquidation
Questions surrounding Guaranty Funds
How effective is state regulation?
How much of the cost is passed on to PH and tax payers?
Do GFs diminsh the pressure on regulators to shut down insurers?
Does it make consumers less concerned about selecting good insurers?
What is the greatest regulatory failure?
to allow liabilities to go unmatched by assets to pay for them
State reasons for insurer insolvency.
- Rapid premium growth
- Inadequate rates and reserves
- Unusual expenses, such as unexpected catastrophic losses
- Lax controls over managing general agents
- Uncollectible reinsurance
- Fraud
always rapid premium growth
NAIC Model Act on Rehab discreet intervention
knows mergers and acquisitions can cover up bad operations, NAIC can intervene discreetly
2 Key steps in regulatory intervention
a. Fact finding
b. Implementation of regulatory action to control financial difficulties
facing insurers
What does ‘fact finding’ entail?
regulators from multiple states examine an insurer
IRIS + FAST != intervention, judgement is needed
management has actuaries / accountants to assist in preparing, evaluating, and auditing financial reports, SAO needed
Describe Mandatory Corrective Action as promulgated in NAIC Hazardous Condition Regulation
- Perform certain actions to reduce its liabilities
- Limit its new or renewal business on products that are not
guaranteed renewable - Reduce its general and commission expenses by specified
methods - Increase its capital and surplus
- Suspend or limit dividend payments to stockholders /
policyholders - Limit or withdraw from specified investments
- File reports concerning the value of its assets
- Document the adequacy of its premium rates
Describe Administrative Supervision as promulgated in Model Supervision Act
- can seek approval from court to take formal control, to rehab
needs legal permission to… (do anything important!)
⇒ Selling or transferring assets or inforce business or
using them as collateral
⇒ Withdrawing, lending, or investing funds
⇒ Incurring debt
⇒ Accepting new premiums
⇒ Renewing policies that are not guaranteed for
renewal
⇒ Merging with another insurer
What should regulators consider when deciding whether or not to take over an insurer?
⇒ How accurate are loss reserves?
⇒ If assets were liquidated quickly to meet current
creditor demands, what would proceeds be?
⇒ Has management enacted measures that are
stringent enough to stem the operating losses?
⇒ Is the insurer’s reinsurance adequate and
collectible?
Briefly describe a receivership.
very severe financial difficulties - place in receivership
type of bankruptcy where a receiver is appointed who
formulates plan to distribute assets
complex activities bw receivers, courts, GFs
2 outcomes
rehab
liquidiation
What is rehab?
impaired insurer continues to exist after receivership
compare A to L, if feasible try to find an investor to invest capital for equity
rehab usually retired executive or lawyer - needs to stabilize cash flows and protect assets from creditor claims
prelude to liquidation, almost always
Considerations in rehab
⇒ How will loss reserves develop
⇒ Can expenses be trimmed, and how fast
⇒ How far are rates from being actuarially adequate to
meet costs
⇒ Can rates be raised without destroying the
company’s ability to market to its desired market
segment
What is liquidation?
bankrupt org doesnt have enough assets to pay all creditors
usually receivership => liquidation is a few months
2 options
(1) transfer all business to another insurer
(2) sell all assets and terminate all business
Briefly describe 2 choices a policyholder can make in the event of a liquidation.
⇒ Continue coverage, subject to specified maximum
amounts, and be credited with a specified
percentage of the account value with a new carrier
⇒ Discontinue coverage and receive a specified
smaller percentage of the account value in cash
What does a special deputy liquidator do?
Appt by com
Has broad powers to seize and dispose of insurer’s assets,
hire and fire personnel, enter contracts and lawsuits, and
manage affairs of company
2 tasks
(1) freeze and quantify liabilities
(2) marshal assets and liquidate them
What happens in the 1st few months of a liquidation?
- Give notices of liquidation to creditors and policyholders and
inform them of their right to file claims - Cancel policy coverage
- Notify agents of their duties in the liquidation
- Identify, sell, and collect assets
- Recover any improperly transferred assets
Liquidiation Bureaus
liquidations are so complex, led to states creating these to manage
Priority asset classes in liquidation
- Costs and expenses of administering the liquidation
- Partial payment of debts to employees for service rendered
within one year of the order for liquidation - All claims for policy losses incurred
- Claims for unearned premiums and claims of general
creditors
What is a guaranty fund?
not-for-profit unincorporated entity established by state law
ensured to protect PH from insolvent insurer
Limits on GF coverage
Lines (C- STORM), no RRGs, surplus lines, pools
UEP has stated limit
max covered claim (except WC)
claim deductibe + policy deductible
net worth deductible
insurer needs to be deemed insolvent by court and placed in liquidation
How are GFs operated?
any insurer covering lines incl is a member
director of fund has broad authority to organize
assessment made based on WP (incl lines)
some states have 2% or so cap on assessments
studies show GFs have had sufficient capacity
Why is the cost of insolvency high?
- Insurers are directly assessed for the operation of guaranty
funds - Competition is distorted
⇒ Insurers that can aggressively market or loosely
underwrite can gain a greater share of market
What must an insurer do regarding GFs?
a. Insurer can’t use the fact that the guaranty fund exists to help sell
business
b. Needs to provide new policyholders with a guaranty fund disclaimer
What can a state do if an insurer fails to pay GF assessments?
may suspend or revoke license
Do GFs pay obligations to general creditors?
No, only policyholders
Why is insolvency tough for multi-state insurers regarding GFs?
- Each state guaranty fund must decide how much to assess
for the policyholders living in its state - State of domicile has primary authority, but each state
involved must approve - Due to differing guaranty fund coverages and laws,
establishing a single settlement plan for an insolvency
involving many states can be complex
Describe two actions a guaranty fund board is authorized to perform that could help prevent an insolvency.
Can make recommendation to state regulator about actions needed to take to prevent insolvency
Can actively participate in the correction activities for those companies which show financial difficulties
What must a DOI do to remain accredited by the NAIC?
Full accreditation review must be completed every 5 years
pre-accreditation review performed the year before the full review
interim annual reviews
