MARYLAND INSURANCE ADMINISTRATION
JUNE 24, 2004
XV. COMPANY COMPREHENSIVE ON LINE MANAGEMENT
The examiners asked the Company to explain how remedial training for its account representatives is tracked.
The Company states that in 1998 it implemented an on-line ‘Corrective Action Log’. The purpose of which is to document and maintain in an easily retrievable form all corrective action relating to sales practices and compliance.
The Manager’s Guide informs managers that they should complete the Corrective Action Log each time corrective action is taken. The Guide also informs managers that when an account representative has finished the requirements of his or her corrective action, the date completed is entered in the Corrective Action Log.
During the semi-annual reviews of a sales office, the Regional Vice Presidents check all open corrective action items associated with Corporate Ethics and Compliance reviews. In addition the Vice President may check open corrective action items on representatives that have been identified through the Company Comprehensive Online Management System (“COMS”) to have been involved in more than one compliance related issue.
COMS presents issues within the historical context of that particular account representative’s past compliance performance. The analysis assists the manager in focusing on the potential patterns or trends of activity and allows the review to be done in the context of that account representative’s writings and the agency and Company compliance indicators.
COMS is designed to allow the Corporate Compliance organization to focus resources on trends, being more proactive in identifying and acting on emerging issues and patterns.
The examiners note that COMS was implemented in 1998. This could mean certain problems with trends that occurred during the examination period were not yet identified. However for those agents identified in Section XIV of this report, and those District Offices pointed out in that section, there is not sufficient documentation to show the new system provided the oversight needed for the effective management of what has determined to be problem areas.
MET LIFE REPORT NO. 786-01