Joe Annotti: What does your company do and how and when did you come across fraternals?
Cailie Currin: I first worked with fraternals when I was an attorney with the New York State Insurance Department in the mid-1990s. I reviewed and approved policy forms there and that included certificates for fraternals. I was at the Department when some fraternals first started offering variable products in New York and I was involved in that process. Since leaving the Department, I have represented fraternals in a variety of compliance matters, often related to New York business, but certainly not exclusively.
Joe Annotti: Our fraternal members are unique, and we embrace their differences from commercial carriers. Tell me how working with fraternals is both the same and different from working with your commercial clients?
Cailie Currin: Probably the thing I like the most about my work as a compliance consultant is that the people I work with all want to do the right thing and my working relationships are very cooperative and pleasant. That is even more so with fraternal clients, where the philosophy and dedication to service and community makes the focus on ethics and good behavior in the insurance marketplace even more prominent. One thing that is different, especially when working with the smaller fraternals is the challenge of small compliance departments and budgets, so moving from that dedication to compliance implementation can be difficult.
Joe Annotti: Our members often say that compliance challenges rank at the top of the list of operational issues. In your experience, what are the common pitfalls that small-to-medium sized insurers fall into?
Cailie Currin: As I mentioned, just having sufficient resources is a challenge for any small or medium sized insurer. Allocation of those resources is the real issue. A small compliance department has a daunting task in trying to not only stay on top of new developments, and then also make sure that they get communicated to the right people and implemented in a timely way. Over time, that is where the real challenge lies – how to continue to exercise the testing and oversight responsibilities of a strong compliance program is a huge task. These all come together in a small company when new information continues to pour in and it needs to get out to the right people so it can be implemented correctly. At the same time there are all the ongoing compliance demands that need to be tested and overseen. It is a huge challenge for small to medium insurers, which is why so many elect to outsource some of their compliance needs.
Joe Annotti: Can you name the “Tough Two” Compliance regulations? Which are the trickiest ones to get right by both commercial and fraternal insurers?
Cailie Currin: If only there were just two! I would have to say that advertising compliance is one of them. The regulations are very vague in most situations about what is permissible and what is not. What is “misleading” is often different to different people. Then there is also a standard that prohibits materials that have a “tendency to mislead” and it can be very difficult to determine what is ok and what is not. There is often no clear bright line until there is a violation. We spend a lot of time talking to insurers about risk analysis when it comes to advertising. The second that I would pick is the duty of care owed to customers. This might be a fiduciary duty, a duty to recommend a suitable product, a best interest standard, a trustworthy standard, or something else. In my experience, most insurance producers are trying to do the right thing by their customers, but it is getting increasingly difficult to know whether or not that is sufficient in any given circumstance.
Joe Annotti: Tell us how your company aligns well with the overall mission of life insurers or fraternals specifically.
Cailie Currin: When I left the law firm where I was a partner to start my own business in this small town of Greenwich, NY, I did not contemplate growing beyond myself and the work I personally did. I walked to the bank and the post office every day to take care of the administrative aspects of running a business and talked to many regulars I saw there every day. However, I soon realized that there was a lot of work out there and that I could create good jobs in our village that would allow some residents to avoid long commutes and it might even let some choose to stay in the community where they grew up rather than having to move to find a professional job with good benefits. We have been able to buy one of the largest buildings in our village and fill the offices with smart and well-trained professionals who have become experts in insurance regulatory compliance. It is truly one of the things that I am most proud of.
Because we are small, I also try to provide other types of benefits to my employees to make Currin Compliance a good place to work. Most recently, we started offering chair massages on a weekly basis. Not only does that offer a nice little perk to us as employees, but it also helps a local massage therapist make a living. As a company, we are very engaged in our community sponsoring many of the local parades, festivals, athletic teams and even the high school prom. It is very important to me to be an active member of our village and to be an asset to the community. It means a lot to me when people stop me on the street to tell me that they appreciate one of our sponsorships. Being a small business in a small town provides a truly great lifestyle and allows us to impact our community in a way we would not be able to in a larger metropolitan area.
Joe Annotti: You do share that with many of our members which are small are also providing jobs and vibrancy to their communities! Most fraternal staff members are touched by compliance regulation and legislation, and I am sure you will have some great dialog with our Spring Symposium attendees. How will you share your story with our fraternal leaders?
Cailie Currin: Primarily, I just want fraternals to know that there is help, and we can make their lives easier. Compliance is a major burden in a highly regulated industry like insurance, but there are ways to make those burdens lighter. Many fraternals have struggled on their own for so long that they may not realize how much more they could do with just a little bit of compliance help. Taking one project off someone’s desk can make a very big difference when staff is small and overworked.
Joe Annotti: I have enjoyed learning more about your company, Cailie, and thank you for supporting the Spring Symposium. See you in May!
Cailie Currin can be reached at
Currin Compliance Services, Inc.
|Cailie Currin, CEO, Currin Compliance Services, Inc|
|Joseph Annotti, President and CEO, American Fraternal Alliance|