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Coordinator’s
Handbook
Tips on How to Prepare for
an Examination
Joy Morton, VA Bureau of Insurance
Jim Mealer, MO DIFP
Jon Brynga, The Hanover Insurance Group
Libby Magnus, Travelers
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
Market Conduct Exam
Life Cycle
Pre-Exam
Corrective
Actions
During
Exam
Post Exam
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
Market Conduct Protocol
Pre-Exam
Planning
Determine
Exposure
On-site Exam
Oversight
$ Billing &
Expenses
Non-Financial
Market Conduct
Examinations
&
Audits
CORRECTIVE
ACTION
PLANS
Post Exam
Closure
Corrective
Action
Monitoring
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
Pre-Exam
 Appoint a Lead to Represent Company
 The “Perfect Coordinator”
 Review Coordinator’s Guide
 Determine Scope of Request and Key Areas Involved
 Make Contact with EIC
 Confirm Receipt of Notice Letter and Scope
 Why was Exam Called?
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
Pre-Exam
 Identify Internal Resources
 What key areas should be involved?
 Key business areas, Filings, Consumer Affairs, IT,
Producer Licensing, Legal, Operations, Product
 Set Up Internal Pre-Exam Meetings
 Delegate, Delegate, Delegate!
 Establish a Project Plan with Target Dates and
Accountabilities
 Data runs
 Consistent tracking during exam
 Pro-active research
 Onsite logistics
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
During the Exam
 Kick-Off Meeting
 Introduce the Company Team
 Set Exam Protocols
 Clearly Establish Who is Authorized to Respond on
Behalf of Insurer
 Designate Support Staff Person For Administrative
Needs for On-site Exams at Location
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
During the Exam
 Criticisms and Responses
 Acknowledge Receipt to Examiners
 Verify Information BEFORE Responding
 Track Timeliness, Completeness and Quality of Responses
 Request Extensions Where Necessary
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
During the Exam
 Criticisms and Responses (cont.)
 Ask for Clarification Upon Receipt, As Needed
 If you Disagree, Provide Factual Support
 Determine Amounts of Over & Undercharges on Rating and
Adjustments and on Claim Files
 Look for Adverse Trends and Begin Corrective Actions and
Restitution, if Appropriate
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
During the Exam
 Communicate Well and Often
 Timely Payment of Bills and Invoices
 Verify Expenses Prior to Payment
 Discuss Discrepancies with EIC
 Tracking Exam Expenses:
 Internal Expenses – Staff, facilities, equipment, travel, fees….
 External Expenses – Regulator’s fees, expenses
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
Post Exam

Wrap- Up Meeting
 What is it and Why Have One?
 Who Should Attend?
 Draft Report
 Opportunity for Company to Review for Accuracy
 Time Frames Given to Company
 Company Response to Report
 Document Mitigating and Corrective Actions
 Make Rebuttals
 Responses May be Part of Final Report
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
Post Exam
 Negotiation and Settlement
 Where, When and With Whom?
 Use of Outside Counsel?
 When Informal Discussions Fail – The Hearing Process
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA
Corrective Actions
 Implementing Corrective Action Plans
 Never too Early to Start Planning and Implementing
 Corrective Actions Started or Implemented DURING the
Course of the Exam May Produce Favorable Outcome
 Get Support of Senior Management
 Get Commitment from Business Groups
 Develop Plan in Conjunction With Examiners
 Verify and Monitor Compliance
IRES Foundation 2015 National School on Market Regulation
Surfin’ the waves of Regulation | April 12-14, 2015 | Hilton La Jolla | San Diego, CA