MAPWG - Market Analysis Procedures Working Group (D) - NAIC

  • 2023 0717 - MAPWG - NAIC -
    • Jo LeDuc (Chair-MO), Rebecca Rebholz (WI)
    • Birny Birnbaum (CEJ)
    • MCAS - Health
      • Samantha Burns - Interested Party - complaints per thousand might be useful
      • ... Samantha Explanation
      • Jo LeDuc - That makes no sense.
      • Mary Kay
    • Lunch and Learn - Trainings - New to Market Conduct, etc
      • Regulator Only, Practical real world, back to the beginning, Walk through analysis using real data, 
      • [BonkNote] - Comments
    • Fraternals - MCAS - Annuity and Life
      • Jo LeDuc - 
        • Information to prepare for discussion...
  • [  ] - 2018 0807 - EX - NAIC - minutes - 
  • 2019 0612 - MAPWG - NAIC - Letter - ACLI - RE: Consider Adoption of Disability Insurance MCAS Proposed Scorecard Ratios - 2p
  • 2019 0613 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 14p
  • 2019 0722 - Letter - NAIC to GOV (Senate) - 1p
  • [  ]  - 2019 - Letter - AHIP - 
  • 2019 0822 - MAPWG - NAIC - Letter - ACLI - RE: Consider Adoption of Disability Insurance MCAS Proposed Scorecard Ratios - 4p
    • To: NAIC - John Haworth, Chair (WA)
    • From: ACLI - Michael Lovendusky
    • 7 August 2018 and reported to the NAIC Executive/Plenary meeting that occurred during the 2018 Summer National Meeting. 
    • (p4) - The ACLI is concerned that non-mandated, lines of insurance, such as life and disability income, may not fit within the MCAS mechanism. Because these lines are sold, not bought, the products and product management are not standardized. Data collection about them might be useful or it might generate numerous false positives. If numerous false positives are generated from MCAS data elements, definitions or ratios, they will mislead regulators to examine companies for statistical anomalies which are anomalous because they relate to non-standardized products or product managements. At some point the wisdom of cost-benefit analysis of including the life insurance line in MCAS arises.
  • 2019 0826 - MAPWG - NAIC - Letter - CEJ, Birny Birnbaum - 6p
    • (p6) - Finally, not content to obstruct Disability MCAS ratios, ACLI concludes its diatribe by arguing that MCAS isn’t needed for life insurance and annuities, based on a false history of the purpose and development of MCAS. Clearly, these comments are not appropriate and must not be considered by the MAP WG.
  • [  ] - September 10, 2020
  • 2020 1022 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 3p-Draft: 11/5/20
    • 2020 1022 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 2p-Draft: 9/14/20
  • [  ] - November 12, 2020
  • 2021 0127 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 4p
  • 2021 0319 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 3p
  • [  ] - 2021 0624 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 
  • 2021 0701 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 16p
  • 2021 1118 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 6p
  • [  ] - 2022 0606 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 
  • 2022 0608 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 5p
  • 2022 0713 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 3p
  • content.naic.org/cmte_d_mapwg.htm
    • The NAIC's Market Analysis Procedures (D) Working Group (MAP) is the national forum for states to share and coordinate their market analysis programs.
    • MAP reviews and coordinates state market analysis programs and develops procedures for uniform, nationwide analysis using their adopted Framework for Market Analysis.
  • 2002-4v1, NAIC Proceedings - 1. Report of the Market Analysis Working Group 
    • (p552) - Administrator Ario responded the market analysis guide has a section that indicates states should review litigation activities as part of their market analysis efforts.
    • Commissioner Parsons said the NAIC already has a process in place to respond to litigation and states already monitor class action litigation.
  • [  ] - 2018 0807 - EX - NAIC - minutes - 
  • 2019 0612 - MAPWG - NAIC - Letter - ACLI - RE: Consider Adoption of Disability Insurance MCAS Proposed Scorecard Ratios - 2p
  • 2019 0613 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 14p
  • 2019 0722 - Letter - NAIC to GOV (Senate) - 1p
  • 2019 0822 - MAPWG - NAIC - Letter - ACLI - RE: Consider Adoption of Disability Insurance MCAS Proposed Scorecard Ratios - 4p
    • To: NAIC - John Haworth, Chair (WA)
    • From: ACLI - Michael Lovendusky
    • 7 August 2018 and reported to the NAIC Executive/Plenary meeting that occurred during the 2018 Summer National Meeting. 
  • 2019 0826 - MAPWG - NAIC - Letter - CEJ, Birny Birnbaum - 6p
  • [  ] - September 10, 2020
  • 2020 1022 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 3p-Draft: 11/5/20
    • 2020 1022 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 2p-Draft: 9/14/20
  • [  ] - November 12, 2020
  • 2021 0127 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 4p
  • 2021 0319 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 3p
  • [  ] - 2021 0624 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 
  • 2021 0701 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 16p
  • 2021 1118 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 6p
  • [  ] - 2022 0606 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 
  • 2022 0608 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 5p
  • 2022 0713 - MAPWG - NAIC - Market Analysis Procedures (D) Working Group - 3p
  • 2019 0826 - MAPWG - NAIC - Letter - CEJ, Birny Birnbaum - 6p
  • 2019 1030 - MAPWG - NAIC - Letter - CEJ, Birny Birnbaum - 3p
  • 2010 0908 - Market Conduct Annual Statement Data Element Revision Process, Adopted by the Market Information Systems (D) Task Force - 1p
  • 2019 0822 - MAPWG - NAIC - Letter - ACLI - RE: Consider Adoption of Disability Insurance MCAS Proposed Scorecard Ratios - 4p
    • ACLI - Michael Lovendusky
    • RE: Consider Adoption of Disability Insurance MCAS Proposed Scorecard Ratios
    • Insight regarding the NAIC process in this area is welcomed.
    • Ratio #7: The percentage of lawsuits closed with consideration for the consumer. More insight regarding this ratio is desired. What will this ratio measure and what value or insight will be derived? The “number of lawsuits closed with consideration for consumer” is not a measure of wrong-doing or fault on the part of insurer. On the contrary, some litigation efforts result in a good-will settlement to limit a company’s exposure to negative publicity even when the carrier had no wrong-doing. Other litigation matters may be settled due to economic interests—a balancing of the cost of continued litigation with the cost of settling the claim (with payment in whole or in part). Litigation that results in consideration for the consumer does not equate to, nor correlate with, carrier malfeasance. For this reason, any data obtained from such a ratio would be both misleading and irrelevant in ascertaining a carrier’s level of compliance with insurance regulations or its adherence to contract provisions. Such erroneous information could lead to increased frivolous litigation. This ratio should be omitted.
    • The ACLI respectfully observes that proceeding in a manner where evaluation of the Ratios has illuminated errors in the Definitions but then marched in combination to market, likely will lead to data collections and analyses which might be useless at best, and possibly even misleading.
    • The new system created a mechanism automatically spotting company practices anomalous to generally acceptable market conduct. Regulators could then efficiently focus examination upon the anomalous company practices.
    • The MCAS was first built to collect and analyze data on lines of insurance business which are mandated by law to be purchased by consumers.
      • Mandated insurances have heightened consumer protection considerations because they are mandated.
      • Mandated insurance coverages have statutory requirements standardizing the coverage for all consumers enabling meaningful data collection, analyses and identification of anomalous behavior by MCAS.
    • The ACLI is concerned that non-mandated, lines of insurance, such as life and disability income, may not fit within the MCAS mechanism.
      • Because these lines are sold, not bought, the products and product management are not standardized.
      • Data collection about them might be useful or it might generate numerous false positives.
      • If numerous false positives are generated from MCAS data elements, definitions or ratios, they will mislead regulators to examine companies for statistical anomalies which are anomalous because they relate to non-standardized products or product managements.
      • At some point the wisdom of cost-benefit analysis of including the life insurance line in MCAS arises.