As of January 2011, nearly all states participate in the NAIC Market Conduct Annual Statement (MCAS) market conduct data collection tool. Begun in 2002, with 8 participating states collecting life and annuity data, the program now encompasses property and casualty data collection along with life and annuity. The MCAS goal is to promote uniformity, both in the market conduct related data that is collected and in its analysis, through the application of consistent measurements and comparisons among companies. Beginning in November 2011, insurers will be able to access “scorecards” on the NAIC MCAS web page . By comparing company-specific information to aggregated industry information for a specific state, a company may gain a better understanding of where they fit in the insurance marketplace and what opportunities may exist to improve performance and potentially avert market conduct violations. Think of it as a wellness tool that may help prevent the need for acute medical treatment.
Beginning April 15, 2011, insurers may submit MCAS data files online to each jurisdiction rather than use the past download process. This online application will enable companies to make both manual and electronic data entries for all required jurisdictions, or to request a waiver or extension from any jurisdiction on a single screen. The due date for filing all MCAS lines of business with the states is June 30, 2011.
Another key change is an expanded role for the Market Conduct Contact. The designated Contact will have increased internal company administration abilities, including control of company user access to the MCAS application, and the ability to designate a specific MCAS contact to serve as the point person for MCAS filing issues and regulator questions.
Also beginning this year, companies submitting an MCAS filing must certify the completeness and accuracy of their submission through use of an attestation. The attestation replaces the Certificate of Compliance, is required once per filing period, and applies to all submissions for that company code.
As my colleague Kathy Donovan recently wrote, there will be an opportunity for training on MCAS filing at the upcoming IRES Foundation National School for Market Conduct Regulation and at other industry events .
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