Reputational Risk

  • I sincerely believe we have a flawed instrument in today's sales illustrations.
    • ...we did not communicate the impact of change as well as  ...we should have.
    • Our biggest mistake would be to delay.
    • I don't believe the consumer will tolerate or forgive us, let alone the regulators, if we do nothing.

-- Robert Nelson, chairperson of the National Association of Life Underwriters (NALU) Task Force on Illustrations - <Currently NAIFA>

1993 - SOA - Sales Illustrations: We Can't Life With Them, But We Can't Live Without Them!, Society of Actuaries - 28p

  • (p78) - And doubts about the value of AIG life insurance products could have generated doubts about similar products provided by other life insurance companies, feeding the panic that was crippling the economy.
  • (p79) - People do not buy insurance products from firms they do not believe have the financial capacity to make good on those commitments over the long term— firms that they do not believe will pay out a life insurance policy...

--  Tim Geithner

2009 1210 - COP - Hearing - Hearing With Treasury Secretary Timothy Geithner - [PDF-98p,  VIDEO-CSPAN]  ---  [BonkNote]

  • Life insurance is especially an outgrowth of public confidence in the good management and integrity of officers and directors, and anything which shocks this faith on the part of policy-holders is vastly detrimental to the interests of a company.

1872 - New York State - GOV - Report and Testimony of the Committee on Insurance on Resolution of the Assembly, to Investigate Into the Conduct of George W. Miller, Superintendent of the Insurance Department, Relative to His Receiving Fees and Perquisites for His Use and Emolument, Etc - [GooglePlay - link

  • (p175) - 484. Institute of International Finance
    • Altering a company's sales practices, imposing large exposure limits, restricting the transfer of assets, restricting the activities of a subsidiary, freezing assets, imposing stays on surrenders, or lowering the maximum rate of guarantees would likely result in grave harm to an insurer's franchise and to the entire industry through the abrogation of contracts and reduced market and policyholder confidence
  • (p180) - 501. International Actuarial Association International
    • The IAA notes that the exercise of any power to implement a stay on surrenders may have a cost to the reputation of the insurance industry and may result in conflicting positions between the prudential and conduct supervisors if they are separate.  

2018 - IAIS - Compiled Comments on Holistic Framework for Systemic Risk in the Insurance Sector 14-Nov-18 to 30-Jan-19 - 264p

  • 39 - Comment on paragraph 39:
    • We suggest to mention that the appearance of conflict of interest can be as harmful to the reputation risk to the insurer or the industry than the conflict of interest itself.

-- Autorite des marches financiers (Quebec) - lautorite.qc.ca/grand-public

2015 - IAIS - Compiled Comments on Consultation Document: Issues Paper on Conduct of Business Risk and its Management - Comments as compiled on 15 August 2015

  • The analyst should have a firm understanding of the following risk classifications:
    • Reputational—Negative publicity, whether true or not, causes a decline in the customer base, costly litigation and/or revenue reductions.  (p37)
  • Procedure #17 guides the analyst through the assessment of any legal risk the insurer or group may have.
    • The analyst should ensure that a thorough understanding of the litigation and potential financial impact is documented.
    • Further, the analyst should communicate with the insurer’s management regarding the impact of reputation risk on continuing operations.
    • The analyst should understand the insurer’s plan to address the reputational risk and track the progress.  (p113)

2012 - NAIC - NAIC Financial Analysis Solvency Tools, Financial Analysis Handbook: Life/A&H/Fraternal Edition. 2012 Annual/2013 Quarterly - 398p

  • madoff/ SEC/ Ackerman part 2 of 3
  • 199x GOV - Metzenbaum - good biz, why would they do this?
  • GOV Video - ?? 1st COP Hearing - Sununu
  • GOV - Vaughan - perspectives / Systemic Risk
Fri__Oct_27__1995
  • Financial Market Regulation and Practices, Panel 1
    • [VIDEO-CSPAN]
    • 00:24:25 - Luigi Zingales - Professor - University of Chicago - Graduate School of Business
    • These managers were also hoping that if a shock occurred, all their competitors would face the same problem, thereby reducing their (reputational?) costs and possibly triggering a government support.
    • The September 19 decision to ensure all money market funds validated this gamble, forever destroying money market managers' incentives to be careful in regarding to the risks they take.
  • We have served countless millions of American families in helping to provide an important means of family financial security.
  • We are also a major source of long-term financing to American business and industry.
  • The life insurance business has earned a reputation for integrity, reliability, and service for the good of society.
  • It therefore, comes as a shock indeed to find it necessary to have to defend this industry's record and refute the charges recently made to this committee that in effect we have been employing deceptive practices to sell shoddy merchandise.
  • We feel it is important to set the record straight.  (p32)

-- John Filer, chairman of the Aetna Life & Casualty Co.  ...spokesman for the life insurance industry and its major trade association, the American Council of Life Insurance (ACLI)

1979 0710 and 1017 - GOV (Senate) - FTC Study of Life Insurance Cost Disclosure, Senator Cannon (D-NV) - [PDF-592p]

  • IN RECOGNITION OF JOHN TURNER, CHAIR, AMERICAN COUNCIL OF LIFE INSURERS - HON. JIM RAMSTAD OF MINNESOTA IN THE HOUSE OF REPRESENTATIVES - Thursday, November 16, 1995
  • Mr. RAMSTAD. Mr. Speaker, I rise to recognize the efforts of an outstanding Minnesotan, John Turner, chief executive of Reliastar Financial and the new chair of the American Council of Life Insurers [ACLI].
    • In his role as chair of the ACLI, John Turner will continue to work to improve the image of the life insurance industry by encouraging the Nation’s life insurers to adopt a code of ethical market conduct.
    • By imposing strict standards on itself, in addition to those State insurance regulators used to police the industry, life insurers will take strides in improving their standing with the public and their customers.
    • While scandals have damaged the reputation of some life insurance companies and agents in recent years, with John Turner at the helm, Reliastar’s image has remained unblemished.
    • In addition, Turner helped the company through some tough financial times in the early 1990’s, and its financial position is solid.
    • I wish John Turner the best as he works with life insurers across the country in the coming months, urging them to embrace higher standards and increased accountability.
    • If his track record is any indication, John Turner’s latest endeavor is sure to be a resounding success.

govinfo.gov/content/pkg/CREC-1995-11-16/pdf/CREC-1995-11-16.pdf