Compliance
Compliance - E&O
Responsibility
Licensing
Anti-Fraud

Anti-Fraud

Anti-Fraud Policy
In compliance with Section 626.99278, Florida Statutes, s. 817.234, F.S. (Insurance Fraud), s. 626.99275, F.S. (Prohibited practices, penalties), and s. 626.989(4)(d), F.S., Life Insurance Settlements ("LIS") has filed its Anti-Fraud Plan with the Florida Department of Financial Services, Division of Insurance Fraud. Also, as conditions warrant and legislative changes necessitate, LIS continually updates the Plan with the Division of Insurance Fraud to remain compliant. The latest update occurred in May, 2005.

The Compliance Officer of LIS reports suspected fraudulent acts to the Division on its Suspected Fraud Referral Form, and the Officer maintains all records and documents pertaining to cases of suspected fraud separate and distinct from other client files for possible use by the Division.

SECTIONS

  1. Purpose
  2. Procedures for detecting and investigating possible fraudulent acts
  3. Procedures for mandatory reporting
  4. Education
  5. Description of anti-fraud designated employees


1. PURPOSE OF ANTI-FRAUD PLAN

THE PURPOSE OF LIFE INSURANCE SETTLEMENTS, INC.’S ANTI-FRAUD PLAN IS TO ESTABLISH INITIATIVES TO DETECT, PROSECUTE AND PREVENT FRAUDULENT VIATICAL SETTLEMENT ACTIVITY IN COMPLIANCE WITH SECTION 3916.18 (G) (1) (b) OF THE REVISED CODE

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2. PROCEDURES FOR DETECTING AND INVESTIGATING POSSIBLE FRAUDULENT INSURANCE ACTS AND PROCEDURES FOR RESOLVING MATERIAL INCONSISTENCIES BETWEEN MEDICAL RECORDS AND INSURANCE APPLICATIONS

Life Insurance Settlements, Inc. will require its applicants to provide a completed viatical settlement application. The application has been submitted for approval to the State of Florida, and will be added as an attachment to this Plan.

The following anti-fraud statement is prominently displayed on the application:

ANY PERSON WHO KNOWINGLY PRESENTS FALSE INFORMATION IN AN APPLICATION FOR INSURANCE OR VIATICAL SETTLEMENT CONTRACT IS GUILTY OF A CRIME AND MAY BE SUBJECT TO FINES AND IMPRISONMENT.

The Life Insurance Settlements, Inc. application is then reviewed for possible inconsistencies. This review will include but not be limited to comparing the diagnosis date of the primary illness to the effective date of the life insurance coverage.

The following information is then requested for those potential/viable viatical settlement client’s files:

A copy of the client’s medical records. A verification of coverage detailing insurance information.

Upon reviewing these items, Life Insurance Settlements, Inc. will then compare and review them for possible inconsistencies. In the event any of these procedures seem to suggest fraudulent activity, Life Insurance Settlements, Inc. will then report such activity to the Florida Department of Financial Services, Division of Insurance Fraud, 499 NW 70th Avenue, Suite 309, Plantation, Florida 33317.

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3. PROCEDURES FOR MANDATORY REPORTING OF POSSIBLE FRAUDULENT ACTS TO THE DIVISION OF INSURANCE FRAUD

In the event a material inconsistency cannot be resolved, Life Insurance Settlements, Inc. shall determine if the file should be reported to the Florida Department of Financial Services, Division of Insurance Fraud.

Suspected fraudulent activity in connection with a viatical settlement transaction will be reported to the Florida Department of Financial Services, Division of Insurance Fraud, 499 NW 70th Avenue, Suite 309, Plantation, Florida 33317.

Upon request, Life Insurance Settlements, Inc. will provide copies of documents that support the belief that fraud may have taken place.

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4. EDUCATION

Currently, Life Insurance Settlements, Inc. is a corporation operating as a Viatical Settlement Broker. When Life Insurance Settlements, Inc. hires additional brokers and employees, LIS will instruct them on the importance of detecting, eliminating and reporting insurance fraud.

As a method of prevention, brokers will provide an approved application that informs potential new clients of the legal consequences of committing fraudulent acts.

Life Insurance Settlements, Inc. will provide an approved application to inform each potential new client that his or her file will be thoroughly reviewed by Life Insurance Settlements, Inc. and any other provider that Life Insurance Settlements, Inc. may send the file to, and that false information in an application for a life insurance policy constitutes fraud and will be reported to the Division of Insurance Fraud.

Each broker will receive a copy of this document and verify its receipt by signature.

Brokers will receive and review bulletins and publications dealing with fraud, as they are made available from the Florida Department of Financial Services and other relevant industry organizations.

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5. DESCRIPTION OF ANTI-FRAUD DESIGNATED EMPLOYEES

Currently, Life Insurance Settlements, Inc. is a corporation operating as a Viatical Settlement Broker. Any potential new broker will be responsible for investigating and reporting possible fraudulent viatical settlement acts and investigating unresolved material inconsistencies between medical records and insurance applications.

If a potential broker suspects fraud in any particular file, then he/she will report it to the management of Life Insurance Settlements, Inc who is responsible for reviewing the files and reporting instances of suspected fraud to the Division of Insurance Fraud. The designated person under the Immunity Provision in Section 3916.18 (D) (1) (c) includes:

  • Peter M. Gaynor
  • The compliance officer of Life Insurance Settlements, Inc. to be named at a later date.

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