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Anti-Fraud Plan
Statement of Anti-Fraud Policy
First Secured Life, LLC is committed to dealing in the most ethical
and forthright manner with its policy owner and insured consumers,
insurance companies, state regulators and the public. First Secured
Life, LLC is also committed to "fight fraud" by making
an effort to detect and report suspected fraud that it may encounter
in the marketplace. As a viatical/life settlement broker, First
Secured Life, LLC, understands that it is the "first line of
defense" against fraud because of its ability to identify and
eliminate fraudulent life insurance policies from ever entering
the marketplace.
Establishment of Compliance and Fraud Review Team
First Secured Life, LLC has established a Compliance and Fraud Review
Team. Currently, Keith Campbell and Jolene D. Fullerton, General
Counsel, are members. The members of the Compliance and Fraud Review
Team will grow commensurately with the growth of the business. The
Compliance and Fraud Review Team is responsible for ensuring that
the anti-fraud procedures listed below are implemented at all levels
and that deviations from these procedures are formally reported.
If document inconsistencies or fraudulent activity indicators are
identified, they will be reported to the Compliance and Fraud Review
Team as part of standard procedure. The Compliance and Fraud Review
Team will make a recommendation for further action. This action
may include, but not be limited to, requesting additional information/explanation
from the policy owner and/or insured, the insured's physician or
other medical providers and/or the insurance company that issued
the life insurance policy and/or reporting the matter to state regulatory
authorities.
*Keith Campbell (#EO48885) is a licensed Viatical Settlement Broker
in the State of Florida acting on behalf of First Secured Life,
LLC, a Florida limited liability company.
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Fraud Notice
The viatical/life settlement application used by First Secured Life,
LLC, includes the following Fraud Notice:
"The presentation of false or fraudulent information
to First Secured Life, LLC and/or the company that issued the life
insurance policy could be a crime and may be subject to fines and
confinement in prison. In some states, First Secured Life, LLC is
required by law to report suspected insurance fraud. First Secured
Life, LLC will report to the appropriate authorities all suspected
fraudulent activity that it discovers related to the life insurance
policy and/or this Application."
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Education and Training
Those persons who are responsible for the initial interaction and
information gathering process with the policy owner and/or insured
shall undergo at least eight (8) hours of initial training on how
to identify material inconsistencies in the submitted documents
and what activity(ies) of the policy owner and/or insured may indicate
possible fraud. Every six (6) months, or more frequently if the
situation dictates, a refresher training session of at least one
(1) hour shall be conducted. These persons shall be made aware of
the high importance and priority status of this function and be
able to readily access the appropriate member of the Compliance
and Fraud Review Team to report said inconsistencies and/or activities.
Before a file may be transferred for further processing, the following
documents, at a minimum, must be obtained:
1. A complete, signed viatical/life settlement
application with current street address (no P.O. Box) and copy of
photo identification.
2. A copy of the life insurance policy including
the signed application for said policy. (For individual policies,
the original or a complete copy of the policy of insurance. For
group policies, a copy of the certificate of insurance and a copy
of the group policy handbook or group plan document);
3. A copy of the current signed and dated verification
of coverage documents from the insurance company issuing the life
insurance policy;
4. Full and complete medical files, including laboratory
reports and physician/health care provider notes for the past three
(3) years.
The information/documents gathered shall be reviewed in order to
identify the following potential fraud indicators and material inconsistencies
-"red flags" - that are to be reported to the Compliance
and Fraud Review Team for further action.
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Document Inconsistencies
If a submitted document shows any of the following, it shall be
forwarded to the Compliance and Fraud Review Team for further action.
1. Dates on life insurance policy applications
that do not coincide with dates in medical records, specifically,
a date of diagnosis of a medical condition (terminal or otherwise)
that precedes the date of the life insurance policy application
and is not disclosed on the life insurance policy application.
2. Answers on life insurance policy application
that do not coincide with information found on viatical/life settlement
application and/or in medical records;
3. Alterations/inconsistencies on any forms or
in the medical records (e.g. erasures, white-out, strikeovers, different
type inks, different handwriting, mixture of handwriting and typing
on any documents, typed (rather than printed) letterhead or no letterhead);
4. Inaccurate and/or out-of-date information on
viatical/life settlement application. (e.g. old telephone number,
former address);
5. Inconsistent statements by the policy owner,
insured, insurance company, physician and/or other interested party;
6. Submitted life insurance policy does not include
a copy of the insurance application for that particular policy;
7. Gross inconsistency in policy owner and/or insured's
signatures;
8. History of prior viatical/life settlement applications
and/or transactions;
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Activity Indicators
If any of the following occurs, it shall be forwarded to the Compliance
and Fraud Review Team for further action.
1. Disagreement of prognosis by insured's attending
physicians;
2. Withdrawal of viatical/life settlement application
by the policy owner and/or insured after questions are asked regarding
a viatical/life settlement application or an investigation by the
company has been started;
3. A policy owner and/or insured who will not provide
a current residential address (non post office box), or a current
telephone number;
4. A policy owner and/or insured who is evasive
or becomes irate about important information relating to his/her
viatical/life settlement application. (e.g. can't recall what year
terminal illness was diagnosed);
5. A policy owner and/or insured who has purchased
and/or is insured under multiple life insurance policies within
a short period of time or has a history of purchasing life insurance
policies and selling them within relatively short period of time;
6. A policy owner and/or insured who is hesitant
to allow direct contact with the life insurance company that issued
the policy;
7. Submission of a viatical/life settlement application
with new or different data by the same policy owner and/or insured
of a previously submitted and rejected viatical/life settlement
application;
8. The insured moves frequently and fails to advise
their treating physician(s).
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Further Action
If any of the above document inconsistencies and/or activity indicators
are identified, they shall be reported to the Compliance and Fraud
Review Team for further review. If the inconsistency(ies) and other
issues can not be resolved by reviewing the material on hand, the
Compliance and Fraud Review Team shall contact the policy owner,
the insured, the life insurance company, and/or the medical provider(s)
for clarification. Failure to resolve the inconsistency(ies) and/or
other issues will result in cessation of the processing of that
case. At this point, the policy owner and/or insured shall be notified
in writing that processing of their file has been suspended, the
reasons therefore and that if no plausible explanation or supplemental
documentation is forthcoming within a reasonable period of time,
their file may be forwarded to the appropriate state Department
of Insurance for further review. If in the opinion of the Compliance
and Fraud Review Team, it is suspected that any fraudulent activity
did or will occur, the file shall be forwarded to the appropriate
state Department of Insurance for further review.
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