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Risks Associated with Insurers’ Extended Enterprise GLBA Non-Compliance
Robb Chastain - General Counsel, Compliance Assurance Corporation
Jeffery A. Daily - Counsel, Akin Gump Strauss Hauer & Feld LLP, Attorneys at Law

Compliance Policies Require Periodic Review
Robert Chastain - General Counsel
Compliance Assurance Corporation
First appeared in December 2005 Pennsylvania Health Underwriter Magazine

Insurance Firm Risk in the Extended Enterprise
Non-Compliance Creates SOX issues


FAQ

Common Questions Insurance Producers/Agents ask:

  • If my insurance company is compliant with Gramm-Leach-Bliley, am I?
    NO

    All Licensees are required to comply with the Safeguard sections of the law. It is the responsibility of each licensee to carry out and implement these regulations. Both the insurance company as well as individual producers must separately comply with these regulations. If the insurance company is compliant, and you are out of compliance, then your liability may increase putting your commissions at risk.
  • I am compliant on the investments side of my business and my broker-dealer does audits. Does this carry-over?
    NO

    This compliance relates specifically to the sale of investment instruments and will not in way cover you under Gramm Leach Bliley or the state based regulations. The regulations are specific to your license to sell insurance in the state(s) and differ significantly.
  • I’ve been trained on Security & Identity theft issues by an insurance company; is that enough to make my organization compliant?
    NO

    Training is just one small part of what each licensee is required to do under the law. Each licensee must conduct a risk assessment, create a policy and procedure manual, make appropriate changes in their businesses, be trained and train employees, record that training for auditors, monitor their information systems including both paper and electronic and then regularly check and update their policies and procedures. Being trained does not make you compliant with the law.
  • I believe I’ve made all the necessary changes to my business to comply; am I compliant?
    Maybe

    Did a risk analyst evaluate your office’s risk? Did a legal advisor who understands the law and your computer systems evaluate your service contracts along with your administrative and electronic systems? Did computer security professionals evaluate your computer systems and or your web site? Have your people been trained by a qualified person, do have a regular training schedule and do you keeps records of those training sessions? Do you have a system in place to monitor changes? If you don’t know then, the Maybe becomes a NO.
  • I have successfully completed all aspects of compliance including receiving an assessment from a qualified party. Can I forget about this issue?
    NO

    The law states that each licensee must continue to monitor and adjust your program for changes in your business. These changes can be anything from hiring a new employee to doing nothing. Yes, doing nothing. Your office might remain the same for 20 years but the world around you is changing. The law requires you to look at the changes and adjust your office if needed. The question is: Are you absolutely sure you know what is needed?

Press Releases Get Adobe Acrobat Reader

Leaders in Insurance Company Compliance Solutions announce Seminar Series on Insurers’ Risks Associated with Noncompliance in the Extended Enterprise
Pittsburgh, PA - November 12, 2007

Compliance Assurance Corporation Announces New Director of Enterprise Sales Position
Industry expert joins the Compliance Assurance Team
Pittsburgh, PA - June 25, 2007

Compliance Assurance Corporation Adds Expertise to Board
CEO of Corporate Synergies Inc joins Board of Directors
Pittsburgh, PA - June 1, 2007

PA Health Underwriters (PAHU) selects Compliance Assurance Corp to help membership
Pittsburgh, PA – April 4, 2006

NAIFA-PA selects Comply On-Demand for member compliance
Pittsburgh, PA - January 28, 2006


News & Events Archive

Association of Insurance Compliance Professionals (AICP) National Conference

Pfizer confirms third breach involving employee data since June
Computerworld
September 4, 2007

Sarbanes-Oxley compliance may spur Enterprise Risk Management
Business Insurance
August 14, 2007

A "major identity-theft incident" has occurred at brokerage giant Merrill Lynch that may affect more than 30,000 employees...
CNBC
August 7, 2007

2.3 Million Consumer Financial Records Stolen
MSNBC
July 2007

Insurer’s use Identity restoration to win clients, what about Id theft prevention?
Insurance Networking News
July 2007

Open Compliance and Ethics Group (OCEG) Benchmarking Series
Managing Privacy Practices: Promulgating Compliance through the Extended Enterprise


 
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Webinar - Controls and Compliance in the Extended Enterprise :::
...expanded global footprint creates an increased risk of non-compliance...
The Three R’s Will Drive Carriers’ Fates in 2008 :::
Insurance & Technology - Nov 22, 2007
TJX Cos said on Friday it agreed to a settlement... under which it will pay up to $40.9 million related to a security breach... :::
Reuters - Nov 2007