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Regulation and Compliance > State Regulation

New York Forges Unclaimed Property Rule

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New York has imposed new rules on insurers regarding identifying recently-deceased policyholders.

The new regulation is part of a nationwide effort by state governments to force insurers to comply with state unclaimed property laws.

The latest development on the issue is a multi-state settlement with MetLife in April. Twenty-two states have signed on to that agreement.

Under that agreement, MetLife paid a $40 million fine and agreed to regularly check the death master file managed by the Social Security Administration, or a similar source of death records, to determine if its life insurance policyholders, annuity owners or retained asset account holders have died.

It has also agreed to check small-value policies last issued in the 1960s to ensure that death claims are paid, that distributions of cash in lieu of stock from its mutual-to-stock conversion are paid or the money is remitted to the appropriate state.

Under the new regulation all life insurers doing business in New York will be required to regularly search a government list of recent deaths to identify deceased policyholders and then find and pay beneficiaries of policies for which no claims have been made.

Benjamin M. Lawsky, superintendent of the New York Financial Services Department said the new regulation will now ensure that insurance companies match their life insurance policy lists with the death index database on a regular basis.

“Conducting computer matches isn’t much of a burden and the benefits to consumers are significant,” Lawsky said.

“With these matches and with New York’s new free online Lost Policy Finder, we have substantially reduced the chances of life insurance policies not being paid when someone dies,” he said.

The new regulation requires insurers to implement reasonable procedures to identify unclaimed death benefits, locate beneficiaries, and make prompt payments. In NY now insurers must:

· Cross check their policies at least every three months with recent deaths using the Social Security Master File of deaths or use another database acceptable to the Superintendent of Financial Services.

· When a policy is sold, request more detailed beneficiary information, such as social security number and address, to facilitate locating and making payments to beneficiaries when a death occurs.

· Search for multiple policies on the same person in the files of all insurers owned by a holding company.

· Cross-check policies with consumer requests received through the State’s new Lost Policy Finder, a free on-line service, located at, to help consumers locate life insurance policies that have been lost or misplaced.

Lawsky acknowledged that insurers, like many other businesses, are legally required to turn over to the state funds that are payable to consumers but remain unpaid for a legally determined period of time.

In the case of life insurance policies, the term is generally three years.

In New York, those unclaimed funds are transferred to the Office of the State Comptroller, which provides an on-line database where consumers can search for and claim their property.

The new regulation also requires life insurers to submit every year to the Office of the State Comptroller the number of policies for which a death occurred but for which the insurers were unable to find the beneficiary.

 A copy of the regulation can be found at


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