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Journey to Market Conduct

Having spent the morning fighting crime, the ICAE journey continued. Two regulators served on the Journey to Market Conduct panel, moderated by Christine Palmieri, Vice President of Travelers. The regulators pulled back the curtain to reveal a little more about the regulator mindset of market conduct and the role of the consumer professional.

The regulators noted that market regulation is now performed more proactively than in the past. Due to better data analysis, a product, company or group of companies can be reviewed carefully—but less intrusively. This is accomplished by using the data to determine what companies may be outliers. However, even today, one of the main elements reviewed in the analysis is complaints.

Why consumer affairs specialists are important
The regulators clearly stated that complaint-handling professionals are vital to providing information that either triggers or deflects a market conduct exam. Actions big and small can help avoid market conduct investigations. Some comments from regulators about those big-and-small actions included:

Dialogue works
When corporate or regulator analysts identify anomalies, additional reviews are typically initiated to isolate and resolve those anomalies. It was noted that a single complaint (that is out of the ordinary) could escalate to market conduct exams, review, restitution and more. Regulators encouraged companies to simply reach out and talk about identified issues—even if something happens in another state. Regulators work to analyze all data to determine what level of escalation or review is necessary—working with the carriers will make analysis more productive for regulator, carrier and consumer.

Role of NAIC
State departments of insurance do, in fact, talk to each other and will work with NAIC. State DOIs will review multi-state companies OR the same complaint in multiple states to identify national-impact action items. Any state DOI can refer a single issue or a single company to the Market Action Working Group (NAIC committee for review) for more review.  This regulator-only group provides intense review of a specific issue or company. And, yet again, complaints are a critical component of this process.

The regulators completed the session with a quick-hit list of best practices for companies to consider.  Here’s a list of their favorite things:


Leslie Krier
Market Conduct Oversight Manager
State of Washington, Office of Insurance Commissioner
PO Box 40259
Olympia, WA  98504
lesliek@oic.wa.gov [1]
www.oic.wa.gov [2]

Jim Mealer
Chief Examiner, Market Conduct Section
Missouri Department of Insurance
PO Box 690
Jefferson City, MO  65102
jim.mealer@insurance.mo.gov [3]
www.insurance.mo.gov [4]

Christine Palmieri
Vice President, Corporate Compliance
One Tower Square
Hartford, CT  06183
cpalmier@travelers.com [5]
www.travelers.com [6]