August 22, 2014
Colorado’s comments on the proposed RIRS updates based on the attachment from the 06/25/2014 RIRS Subgroup meeting:
Colorado would like to request that the following Reason Codes be kept (see pg 11 of 14):
• 2028 TPA Violation – The comment section indicates that the new code "Violation related to TPA, MGA, or other third party" should be used instead. However, this new code is not included within the 06/25/2014 attachment. We want to ensure that either the new code is included or the old TPA code is kept.
• 2063 Employed Unlicensed Individuals – The feedback that was received from the section that regulates producer activity indicated that this would not necessarily be redundant with code 2062, allowed business from agent not appointed/licensed, and therefore should be kept.
• 2064 Paid Commissions to Unappointed Agents - The feedback that was received from the section that regulates producer activity indicated that this would not necessarily be redundant with code 2062, allowed business from agent not appointed/licensed, and therefore should be kept.
• 2074 Other States Action - The feedback that was received from the section that regulates producer activity indicated that they have taken actions against producers solely based on the action of another state. Therefore they do utilize this code and requested that it be kept.
• 2101 Certification Violation • 2102 Unauthorized Insurance Business
Colorado would like to request that the following Disposition Codes be kept (see pg 13 of 14):
• 3004 License, Cancelled • 3009 License, Probation • 3010 License, Conditional • 3012 License, Reinstatement • 3013 License, Granted • 3015 License, Voluntarily Surrendered • 3046 Stipulated Agreement/Order • 3051 Final Agency Order • 3052 Ordered to Comply with Specific Statue or Regulation • 3070 Re-Exam
Other: • RIRS code 2040 – Failure to Timely File does not appear to be consistently included with the
attached. Colorado would like to ensure that this code is kept. • Will a new “Notice of Regulatory Activity Form” be created to accommodate the updated
coding? (see last page)
DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
CodeCode Description
Code
StatusComments
TBA Market Add
TBA Financial Add
TBA Producer Add
TBA Company Licensing Add
Type of Action
To allow for filtering out some actions not weighted as much for market analysis, such as in MAPT.
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
1 of 14
DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
Description Status Comments
Bail Bond Add Will match ETS Lines of Business
Commercial Auto Add Will match ETS Lines of Business
Commercial Liability Add Will match ETS Lines of Business
Commercial Property Add Will match ETS Lines of Business
Credit Add Will match ETS Lines of Business
Fidelity and Surety Add Will match ETS Lines of Business
Group Accident and Health Add Will match ETS Lines of Business
Group Annuity Add Will match ETS Lines of Business
Group Life Add Will match ETS Lines of Business
Homeowner Add Will match ETS Lines of Business
Individual Accident and Health Add Will match ETS Lines of Business
Individual Life Add Will match ETS Lines of Business
Long Term Care Add Will match ETS Lines of Business
Medical Malpractice Add Will match ETS Lines of Business
Medicare Supplement Add Will match ETS Lines of Business
Other Add Will match ETS Lines of Business
Private Passenger Add Will match ETS Lines of Business
Title Add Will match ETS Lines of Business
Workers Comp Add Will match ETS Lines of Business
Line of Business
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
CodeDescription
Code
StatusIndividual
Count
2011 - Current
Risk Bearing/
Business Entities
Count
2011 - Current
On Current
RIRS Form
On Current
CDS FormComments
ADJ Adjuster/Appraiser Keep x 1,991 x 451 x x
AIR Alien Insurer/Reinsurer Keep x 7 x x
BBA Bail Bond Agency Keep x 46 x
BNK Bank Keep x 1
BOG Bogus Firm Keep 17 x 2 x
BOG Bogus Representative Keep x
CAI Captive Insurer Keep x 7 x x
CAC Cert. Appl. Counselor Keep x x x Added for ACA
CEO Chief Executive Officer Keep x 1 x x
COO Chief Operation Officer Keep x x x
COP CO-OP Insurer Keep x x
DIT Director/Trustee Keep x 1 x x x
EMP Employee Keep x 9 x x
HCP Health Care Provider Keep x 1 x 1 x x
HMO Health Maintenance Org Keep x 2 x x
IPA In-Person Assister Keep x x Added for ACA
INC Insurance Consultant Keep x 3 x x x
JUA Joint Underwriting Assn Keep x x x
KEE Key Employee Keep x 2 x x
MGA Managing General Agent Keep x 3 x 8 x x
MET MET/MEWA Keep x 15 x x
NAV Navigator Keep x 1 x x Added for ACA
OFF Officer Keep x 4 x x
OTH Other Keep x 2,377 x 876 x x
PPO Preferred Provider Org Keep x x
PFC Premium Finance Co Keep x 11 x x
PRE President Keep x 9 x x
PRI Principal/Owner Keep x 99 x 31 x x
PRO Producer Keep x 24,038 x 3,013 x x
PAJ Public Adjustor Keep x 23 x
REI Reinsurance Intermediary Keep x x x x
RPG Risk Purchasing Group Keep x x x
RRG Risk Retention Group Keep x 7 x x
SEC Secretary Keep x x x
SCY Security Keep x x
SEI Self-Insured Keep x 3 x x
STF State Fund Keep x 1 x x
TPA Third Party Administrator Keep x 3 x 376 x x
TAG Title Agency Keep x 168 x
TRE Treasurer Keep x x
UDI U.S. Domiciled Insurer Keep x 10,618 x x
Entity Function/Role Codes
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
CodeDescription
Code
StatusIndividual
Count
2011 - Current
Risk Bearing/
Business Entities
Count
2011 - Current
On Current
RIRS Form
On Current
CDS FormComments
Entity Function/Role Codes
UNK Unknown Keep x 1,639 x 614 x x
URO Utilization Review Org Keep x x 39 x x
VIP Vice President Keep x x
WBK Web Broker Keep x x Added for ACA
Total 30,221 16,297
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
4 of 14
DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
CodeCode Description
Code
StatusComments
1003 Market Analysis Keep
1005 Complaint Investigation Keep
1007 Field Investigation Keep
1008 Public Inquiry Drop Use new code: Other Inquiry, Investigation, or Audit
1010 Routine Dept Action Keep
1013 Financial Drop Use new code: Financial Analysis
1015 Other States Action Keep
1016 Annual Statement Drop Use new code: Financial Analysis
1018 Information/Referral From Another State Agency Keep
1020 Insurer Report Keep
1023 Statistical Filing Drop Use new code: Other Filing
1025 Legal Keep
1030 Market Conduct Exam Keep
1035 Financial Exam Keep
1040 Workers Comp Exam Drop Use Market Conduct Exam, Financial Exam, or new code: Other Inquiry, Investigation, or Audit
1045 Combined Exam Drop Use Market Conduct Exam or Financial Exam
1050 Bankruptcy Notices Keep
1055 Third Party Information Keep
1060 Licensing Administration Keep
1063 Background Check Keep
1065 Other Keep Change wording to 'State Specific'
TBA Market Conduct Investigation Add
TBA Other Inquiry, Investigation, or Audit Add
TBA Financial Analysis Add
TBA Rate/Form Filing Add
TBA Other Filing Add
TBA Multi State Regulatory Action Add
Origin of Action
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
Code
Code
StatusCode Description in RIRS ETS Equivalent Category Comments
Add No RIRS Equivalent Internal/External audit Operations and Management
Add No RIRS Equivalent Safeguards for security of data and
information
Operations and Management
Add No RIRS Equivalent Monitoring contracts with MGAs, TPAs,
or other third party
Operations and Management
2039 Keep FAILURE TO MAINTAIN BOOKS &
RECORDS
Maintenance of adequate books and
records
Operations and Management
Add No RIRS Equivalent Privacy issues Operations and Management
Add No close match; could be similar to
(2102) Unauthorized insurance business
Appropriate licensure/certifications for
lines of business
Operations and Management
Add No RIRS Equivalent Other Operations and Management issue Operations and Management
Add No RIRS Equivalent Maintenance of complaint log Complaint Handling
Add No RIRS Equivalent Failure to timely respond/manage
complaints
Complaint Handling
Add No RIRS Equivalent Failure to provide an adequate
response/resolution to complaints
Complaint Handling
Add No RIRS Equivalent Other Complaint Handling issue Complaint Handling
Add No RIRS Equivalent Timeliness of premium/billing notices Policyholder Service
Add No RIRS Equivalent Premium/billing notices not provided Policyholder Service
Add No RIRS Equivalent Other required notification/
correspondence not sent or not timely
Policyholder Service
Add No RIRS Equivalent Reasonable attempts to locate
policyholders
Policyholder Service
Add No RIRS Equivalent Nonforfeiture Policyholder Service
Add No RIRS Equivalent Free-look handling Policyholder Service
Add No RIRS Equivalent Reinstatements Policyholder Service
Add No RIRS Equivalent HIPAA compliance Policyholder Service
Add No RIRS Equivalent COBRA compliance Policyholder Service
Add No RIRS Equivalent Other Policyholder Service issue Policyholder Service
Add No RIRS Equivalent Rates filed and approved as necessary Rating
Add No RIRS Equivalent Rates not unfairly discriminatory Rating
Add No RIRS Equivalent Use of prohibited rating factors Rating
Add No RIRS Equivalent Incorrect application of rate Rating
Add No RIRS Equivalent Excessive rate Rating
Add No RIRS Equivalent Inadequate rate Rating
Add No RIRS Equivalent IPRM procedures/scheduled rating Rating
Add No RIRS Equivalent Other Rating issue Rating
Reason Codes Related to ETS Categories of Market Findings
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
Reason Codes Related to ETS Categories of Market Findings
Add No RIRS Equivalent Underwriting unfairly discriminatory Underwriting
Add No RIRS Equivalent Provision of disclosures/notifications Underwriting
2045 Keep REBATING Rebating Underwriting
Add No RIRS Equivalent Cancellation/nonrenewal notices not
timely
Underwriting
2003 Keep FAILURE TO SEND REQUIRED
CANCELLATION/NONRENEWAL
NOTICE
Cancellation/nonrenewal notices not
issued
Underwriting
Add No RIRS Equivalent Other cancellation/nonrenewal/rescission
issue
Underwriting
Add No RIRS Equivalent Declination notice - inadequate Underwriting
Add No RIRS Equivalent Declination notice - untimely or not
issued
Underwriting
Add No RIRS Equivalent Other declination problems Underwriting
Add No RIRS Equivalent Improper question on application Underwriting
Add No RIRS Equivalent Other Underwriting issue Underwriting
2053 Keep USE OF UNAPPROVED FORMS Forms filed and approved as necessary Forms
Add No RIRS Equivalent Mandated Coverages/Offerings Forms
Add No RIRS Equivalent Other Forms issue Forms
2014 Keep MISREPRESENTATION OF
INSURANCE PRODUCT/POLICY
Misrepresentation of insurance
products/policy
Marketing and Sales
Add No RIRS Equivalent Producer training, education, compliance Marketing and Sales
Add No RIRS Equivalent Illustrations Marketing and Sales
2012 Keep LIFE INSURANCE REPLACEMENT
VIOLATION
Replacement requirements Marketing and Sales
Add No RIRS Equivalent Disclosure/outline of coverage Marketing and Sales
Add No RIRS Equivalent Other Marketing and Sales issues Marketing and Sales
Add No RIRS Equivalent Initial contact Claims
Add No RIRS Equivalent Provision of appropriate claims materials
or other reasonable assistance
Claims
Add No RIRS Equivalent Adequate/timely investigation Claims
Add No RIRS Equivalent Timely resolution/prompt pay Claims
Add No RIRS Equivalent Files adequately documented Claims
Add No RIRS Equivalent Adequate explanations of claims
denied/closed without payment
Claims
Add No RIRS Equivalent Loss valuation Claims
Add No RIRS Equivalent Appropriate representation of coverage Claims
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
Reason Codes Related to ETS Categories of Market Findings
Add No RIRS Equivalent Not improperly compelling claimant to
litigate
Claims
Add No RIRS Equivalent Claim denials due to improper rescission Claims
Add No RIRS Equivalent Appropriate subrogation practices Claims
Add No RIRS Equivalent Payment of mandated coverages Claims
Add No RIRS Equivalent Other improper denial of claim Claims
Add No RIRS Equivalent Other improper claim settlement practice Claims
Add No RIRS Equivalent Other Claims Handling issue Claims
2062 Keep ALLOWED BUSINESS FROM AGENT
NOT APPOINTED/LICENSED
Producer/adjuster properly licensed Producer/Adjuster Licensing
2062 Keep ALLOWED BUSINESS FROM AGENT
NOT APPOINTED/LICENSED
Producer/adjuster properly appointed Producer/Adjuster Licensing
Add No RIRS Equivalent Producer/adjuster properly terminated Producer/Adjuster Licensing
Add No RIRS Equivalent Other Producer/Adjuster Licensing issue Producer/Adjustor Licensing
Add No RIRS Equivalent Network adequacy Improper Practices Related to Health
Insurance
Add No RIRS Equivalent Utilization review practices/procedures Improper Practices Related to Health
Insurance
Add No RIRS Equivalent Quality assurance practices Improper Practices Related to Health
Insurance
Add No RIRS Equivalent Grievance practices Improper Practices Related to Health
Insurance
Add No RIRS Equivalent Appeals practices/ procedures Improper Practices Related to Health
Insurance
Add No RIRS Equivalent External/independent review practices/
procedures
Improper Practices Related to Health
Insurance
Add No RIRS Equivalent Provider credentialing/monitoring Improper Practices Related to Health
Insurance
Add No RIRS Equivalent Other Improper Practices Related to
Health Insurance issue
Improper Practices Related to Health
Insurance
Add No RIRS Equivalent Cooperation with
examination/investigation
Inquiries/Investigations
2038 Keep FAILURE TO COMPLY WITH
PREVIOUS ORDER
Failure to comply with previous order Inquiries/Investigations
2035 Keep FAILURE TO RESPOND No ETS Equivalent Inquiries/Investigations
2036 Keep LATE OR INCOMPLETE RESPONSE No ETS equivalent Inquiries/Investigations
Add No RIRS Equivalent Other Inquiries/Investigations issue Inquiries/Investigations
Add No RIRS Equivalent Funds submitted for collection/ deposited
in qualified institution
Escrow/Settlement, Closing or Security
Deposit Funds
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
Reason Codes Related to ETS Categories of Market Findings
Add No RIRS Equivalent Appropriate interest paid Escrow/Settlement, Closing or Security
Deposit Funds
Add No RIRS Equivalent Appropriate disbursement
procedures/practices
Escrow/Settlement, Closing or Security
Deposit Funds
Add No RIRS Equivalent Other Escrow/Settlement, Closing or
Security Deposit Funds issue
Escrow/Settlement, Closing or Security
Deposit Funds
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
Code
Code
StatusRIRS ETS Equivalent Category Comments
2072 Keep CURE OF FINANCIAL IMPAIRMENT No ETS Equivalent Impairment
2080 Keep DISSOLUTION No ETS Equivalent Impairment
2070 Keep FINANCIAL IMPAIRMENT No ETS Equivalent Impairment
2065 Keep NOTICE OF FINANCIAL IMPAIRMENT FROM OTHER
STATE
No ETS Equivalent Impairment
2097 Keep BAIL BOND FORFEITURE JUDGMENT No ETS equivalent Producer Related
2032 Keep CONTINUING EDUCATION REQUIREMENTS MET No ETS equivalent Producer Related
2108 Keep CRIMINAL PROCEEDINGS No ETS equivalent Producer Related
2107 Keep CRIMINAL RECORD/HISTORY No ETS equivalent Producer Related
2059 Keep FAILURE TO MAKE REQUIRED DISCLOSURE ON
LICENSE APP
No ETS equivalent Producer Related
2030 Keep FAILURE TO MEET CONTINUING EDUCATION
REQUIREMENTS
No ETS equivalent Producer Related
2037 Keep FAILURE TO NOTIFY DEPARTMENT OF ADDRESS
CHANGE
No ETS equivalent Producer Related
2042 Keep FAILURE TO PAY CHILD SUPPORT No ETS equivalent Producer Related
2104 Keep FAILURE TO REMIT PREMIUMS TO INSURER No ETS equivalent Producer Related
2075 Keep FAILURE TO REPORT OTHER STATE ACTION No ETS equivalent Producer Related
2103 Keep FIDUCIARY VIOLATION No ETS equivalent Producer Related
2106 Keep FORGERY No ETS equivalent Producer Related
2105 Keep MISAPPROPRIATION OF PREMIUM No ETS equivalent Producer Related
2058 Keep MISSTATEMENT ON APPLICATION No ETS equivalent Producer Related
2055 Keep NO LICENSE No ETS equivalent Producer Related
2060 Keep NOT APPOINTED No ETS equivalent Producer Related
2061 Keep SELLING FOR UNLICENSED INSURER No ETS equivalent Producer Related
RIRS
Code
Code
StatusRIRS ETS Equivalent Category Comments
2056 Keep DEMONSTRATED LACK OF FITNESS OR
TRUSTWORTHINESS
No ETS equivalent Need a category
2085 Keep FAILURE TO PAY TAX No ETS equivalent Need a category
2087 Keep FAILURE TO PAY FEES No ETS equivalent Need a category
2090 Keep FAILURE TO PAY FINE No ETS equivalent Need a category
2095 Keep FAILURE TO PAY ASSESSMENT No ETS equivalent Need a category
2100 Keep NO CERTIFICATE OF AUTHORITY No ETS equivalent Need a category
2115 Keep OTHER No ETS Equivalent Need a category; change wording to
'State Specific'
Reason Codes Related to Non-ETS Categories of Market Findings
Reason Codes With No Categories
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
Code
Code
StatusRIRS ETS Equivalent Category Comments
2005 Drop UNDERWRITING New detailed underwriting codes are
added
2007 Drop MARKET CONDUCT EXAMINATION Does not describe a vioaltion
2010 Drop MARKETING & SALES New detailed marketing & sales codes
are added
2015 Drop CLAIM HANDLING New detailed claim violation codes are
added
2020 Drop POLICYHOLDER SERVICE New detailed policyholder violation
codes are added
2025 Drop ADVERTISING New detailed marketing & sales codes
are added
2026 Drop PREMIUM FINANCE ACT VIOLATION Codes added to described specific
violations. Citing an act can imply
numerous violations
2027 Drop SURPLUS LINES VIOLATION Does not describe a specific violation.
Suplus lines status can be determined
from the entity
2028 Drop TPA VIOLATION Replaced with new code "Violation
related to TPA, MGA, or other third
party"
2029 Drop UNFAIR INSURANCE PRACTICES ACT VIOLATION Codes added to described specific
violations. Citing an act can imply
numerous violations
2050 Drop RATE VIOLATION New detailed rating violating codes
added
2063 Drop EMPLOYED UNLICENSED INDIVIDUALS Redundent with respect to 2062 -
Allowed business from agent not
appointed/licensed
2064 Drop PAID COMMISSIONS TO UNAPPOINTED AGENTS Redundent with respect to 2062 -
Allowed business from agent not
appointed/licensed
2074 Drop OTHER STATES ACTION Does not describe a violation
2110 Drop RECONSIDERATION Does not describe a violation
2111 Drop INAPPROPRIATE SALES OR SOLICITATION TO A
MILITARY SERVICE MEMBER
Not used in prior three years. Replace
2111 and 2112 with new "military sales"
code
2112 Drop INAPPROPRIATE SALES OR SOLICITATION ON A
MILITARY INSTALLATION
Not used in prior three years. Replace
2111 and 2112 with new "military sales"
code
Reason Codes To Drop
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
Code
Code
StatusRIRS ETS Equivalent Category Comments
2101 ? CERTIFICATION VIOLATION
2102 ? UNAUTHORIZED INSURANCE BUSINESS
Reason Codes To Address
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
CodeCode Description
Code
StatusComments
3001 License, Denied Keep
3003 License, Suspended Keep
3004 License, Cancelled Keep
3006 License, Revoked Keep
3009 License, Probation Keep
3010 License, Conditional Keep
3011 License, Supervision Keep
3012 License, Reinstatement Drop Does not describe an action pursuant to a violation
3013 License, Granted Drop Does not describe an action pursuant to a violation
3014 License, Surrendered Keep
3015 License, Voluntarily Surrendered Drop Collapse into the broader 3014, License, Surrendered
3016 License, Other Keep Change wording to License, State Specific Disposition
3021 Certificate of Authority, Denied Keep
3023 Certificate of Authority, Suspended Keep
3025 Certificate of Authority, Suspension Extended Drop Should not generate new RIRS record
3026 Certificate of Authority, Revoked Keep
3028 Certificate of Authority, Expired Drop Does not describe an action pursuant to a violation
3029 Certificate of Authority, Probation Keep
3031 Certificate of Authority, Reinstated Drop Does not describe an action pursuant to a violation; Should not generate a new RIRS record
3034 Certificate of Authority, Surrendered Keep
3036 Certificate of Authority, Other Keep Change wording to Certificate of Authority, State Specific Disposition
3042 Cease and Desist from Violations Keep
3043 Cease and Desist from all Insurance Activity Keep
3044 Remedial Measures Ordered Keep
3045 Consent Order Keep
3046 Stipulated Agreement/Order Keep
3047 Previous Order Vacated Keep
3048 Ordered to provide requested information Keep
3049 Stayed Order Keep
3050 Temporary Restraining Order Keep
3051 Final Agency Order Drop Not sure what this is, too generic. Use other existing code
3052 Ordered to Comply with Specific Statute or Regulation Drop Seems redundant with respect to 3042
3055 Reprimand Keep
3060 Hearing Waiver Keep
3065 Show Cause Keep
3070 Re-exam Drop Does not describe an action pursuant to a violation
3075 Rescission of Drop Does not describe an action pursuant to a violation
3076 Involuntary Forfeiture Keep
3078 Restitution Keep
Disposition of Action
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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DRAFT Attachment One
Regulatory Information Retrieval System (D) Subgroup
6/25/2014
RIRS
CodeCode Description
Code
StatusComments
Disposition of Action
3079 Suspended from Writing New Business; Renewals ok Keep
3080 Supervision Keep
3085 Rehabilitation Keep
3090 Liquidation Keep
3095 Conservatorship Keep
3097 Hearing Drop Not final disposition.
3100 Receivership Keep
3101 Ancillary Receivership Keep
3102 Monetary Penalty Keep
3103 Aggregate Monetary Penalty Drop New "Aggregate Multistate Monetary Penalty"
3103 Aggregate Monetary Penalty Keep Some monetary penalties are aggregates and not allocated per company
3104 Settlement Keep
3105 Other Keep Change wording to 'State Specific'
TBA Order or fine stayed Add
TBA Premium refund Add
TBA Return of excess profits Add
TBA Aggregate Multistate Monetary penalty Add
© 2014 National Association of Insurance CommissionersAs of 6/20/2014
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