Received Notices: Can I just say?
Yesterday I was frustrated by one issue where it seemed that scarce resources were being spent on an issue that seems small to me in the overall scheme of things, and today I am confronted by another - this time one from the NYSID.
Post-approval reviews often raise the issue of terminology in when a change of owner/beneficiary is effective and when an assignment is effective. The outlines indicate that the former should be effective upon receipt. They are silent on assignments. But if any word appears in the policy provision beside receipt, e.g. "received for recording" an objection is very likely to follow. Post-approval review letters are often quite assertive on this issue stating along the lines of: A policy change subject to recording by the company has the potential for excessive delays which are beyond the control of the policyowner. The Department has found such administrative delays to be unfair, unjust, and inequitable in violation of Section 3201(c)(2).
This assertion is regardless of whether there is any evidence that any administrative delay has ever occurred or whether any policyowner has ever been disadvantaged. Further, it is not considered sufficient to provide the Department with an assurance that received for recording (or whatever similar language is used by the particular company) merely means date stamping a piece of mail received, which is obviously no different than receiving. An endorsement to in-force business to eliminate any reference to any word other than received or receipt is still demanded.
Absolutely no change will be made to any company process as a result of this endorsement. To the best of anyone's knowledge that I have talked to, this has never been a problem in the real world. Obviously, an endorsement is very costly to the company both in actual immediate costs, and also in dealing with subsequent customer service calls asking what the endorsement is about.
The Department is spending its very limited resources demanding these endorsements, reviewing them, approving them and overseeing their mailing to in-force business. Increased company costs get passed along to the very same consumers who call (further increasing costs) asking what the endorsement means. Those confused consumers get told not to worry, the endorsement doesn't mean anything because absolutely nothing changes in policy administration. Where is the benefit here? Is that what the post-approval process is really about?
