Delivering Quality and Confidence to
Protective Life’s Compliance Program |
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| Protective Life Corporation is a Fortune 500 diversified life insurance and financial services company, whose primary business lines include life insurance, retirement savings and investment products, and asset protection products. Protective distributes its products throughout the United States utilizing a variety of channels, including independent insurance agents, financial planners, insurance brokers, stockbrokers, financial institutions, auto dealerships, and direct response organizations. |
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Problem Solved
The USA PATRIOT Act of 2001, which contains strong measures to prevent, detect, and prosecute terrorism and international money laundering, imposes new compliance obligations on many industries, including insurance. Upon reviewing the Act’s mandates, Protective’s legal department submitted a compliance software project proposal to the corporation’s Information Technology Council. The project team determined that the company would need to implement interdictive compliance software in order to meet the new standards. While the project team conducted a three-month software search and evaluation, Protective built a homegrown compliance solution using Lotus Notes to provide an interim solution for manual searches and look-ups. |
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| During the software evaluation, the project team quickly determined that ensuring the quality of the data would be as important to project success as the ability to match customer names to government-provided suspect lists, such as the U.S. Treasury’s Office of Foreign Assets Control (OFAC) list. Protective ultimately selected Innovative Systems’ i/Lytics SECURE because it was the only product to combine comprehensive data cleansing and matching capabilities. |
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Product Functionality
Phase I of the project required the compliance software to be interfaced with seven different administrative systems that contain approximately 3.5 million contract records and about 6 million names. i/Lytics SECURE was easily implemented and interfaced with these application systems and now runs on a nightly, batch basis. |
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| i/Lytics SECURE’s sophisticated cleansing and matching capabilities reduce the number of ‘false positives’ the product generates, i.e., matches brought together because the software system is not “intelligent” enough to distinguish pairs of name and address records that are similar, but not a true match. Because compliance with the USA PATRIOT Act requires organizations to report ‘hits’ against the OFAC list, all suspect matches generated by the compliance process must be manually reviewed to determine which are true matches and need to be reported. By reducing the number of false positives generated, i/Lytics SECURE enables Protective’s compliance officials to focus their review efforts on those matches that are truly suspect, saving significant time and expense. |
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| i/Lytics SECURE provides a much more efficient compliance solution compared to Protective’s homegrown Lotus Notes process. In addition to improved results, i/Lytics SECURE affords the company a strong measure of confidence that it is in full compliance with the USA PATRIOT Act. Future plans include implementing i/Lytics SECURE’s online, API screening capability. |
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Strengths
The product’s powerful cleansing and matching capabilities are its strongest differentiators. By reducing Protective’s false positives, i/Lytics SECURE enables the company’s compliance officials to focus their review and follow-up resources on true suspect matches. In addition, Protective is confident that i/Lytics SECURE’s power and flexibility will allow the company to extend its use to future mandated compliance activities. |
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“Companies evaluating OFAC software should consider the significant costs of implementing the interfaces between the OFAC software product and the many administrative systems they have,” said Binford. “In doing so, you soon realize that the OFAC software cost ceases to
be a major factor when compared to the costs of implementing the interfaces. Consequently, it is critical that insurance companies select the best system from the most stable vendor available in order to minimize the possibility of having to redo the interfaces later,”
Binford concluded. |
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Weaknesses
Because the matching rules are so powerful, there is a danger of over- or under-matching if the established matching rules and logic are too liberal or too conservative. The set-up of Protective’s matching rules did not initially provide the tight result-set that was desired. However, the process of tuning the matching rules to meet Protective’s expectations was accomplished in a matter of days. |
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Selection Criteria
The Protective project team identified four main selection criteria: performance; quality of the name and address scrubbing process; accuracy, flexibility and sophistication of the match engine; and quality and stability of the software vendor. Innovative was selected because their product and company best met these criteria. Distinguishing factors included: the product’s ability to match on a number of criteria, not just name and address; the product’s consistent scoring levels for variations and permutations of name structures; the company’s impressive list of large clients; and the responsiveness of Innovative’s sales and delivery personnel. |
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Deliverables
Nightly batch runs of i/Lytics SECURE produce suspect reports that are reviewed daily by a Protective compliance officer. |
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Vendor Support
Support throughout the evaluation, sale and implementation has been outstanding. After encountering some initial problems with Protective’s match results, Innovative quickly addressed all concerns and solved the problem within days of our call. |
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