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Agency Compliance Tool Kit © 2016 Allstate Insurance Company. Proprietary and Confidential Information. 12/5/2016

Agency Compliance

Tool Kit


Agency Compliance

Why is an Agency Compliance program in your agency important? An Agency Compliance Program provides the Company and you the Agency a reasonable assurance that functions performed in your agency will be executed as designed.

Florida Region’s goal is to support our Agents to grow good business!

In order to play by the rules, you need to know what they are. Below are resources for you to reference.

1. Allstate Agency Principles, We are the Good Hands: We help people realize their hopes and dreams through products and services designed to protect them from life’s uncertainties and to prepare them for the future.

Integrity Principles

Ethics

Act with honesty and integrity in a manner that protects our reputation

Treat people with empathy, fairness and respect

Ensure that our customers’ confidence and trust is well placed

Cultivate an ethical culture

Compliance

Comply with laws, regulations and company requirements

Promptly report all unknown or suspected violations of law, regulation or company policy

Privacy

Respect and protect the privacy of every individual’s personal information

Request and retain only the personal information that is needed

Communicate clearly how personal information is used, retained and disclosed

Embed strong privacy protection practices in all business systems and processes

2. Allstate Agency Standards, Allstate is committed to operating its business in an ethical manner. When acting on behalf of Allstate, agents are required to act in compliance with the company’s ethical standards and adhere to the Allstate Agency Standards. Agents are also solely responsible for their employees or others working on their behalf and must ensure those individuals comply with the Allstate Agency Standards, the company’s standards with respect to ethical business practices, and all federal, state and local laws and regulations.

The EA R3001 program materials and agency standards are available on the Gateway. In Gateway type: EA R3001 Program Materials


This Compliance Tool Kit contains reference to material that is available to you on the Gateway, as well as, job aids you may consider using in your agency to establish an agency Compliance Process

Gateway Resources

References to Gateway will be made throughout this toolkit. The Agency Gateway is an online resource tool that you and your staff you can leverage when you need to know information, on such issues as Company News, Billing/Rate News, Products, My Work Items, Binding Requirements for LSP and My Agency Results. It also contains information you can utilize related to Compliance, Field Business Conduct and Risk Management.

The Following Applies to this Compliance Tool Kit

Uses of these tools or ideas within this Compliance Tool Kit are strictly voluntary. You have the sole and exclusive control over the manner, method and means by which you operate your agency, including how you hold your staff accountable.

Allstate makes no warranty or representation as to whether the samples provided for your agency are compliant with state and/or federal laws or regulations.


Table of Contents

Suggested Compliance Process 5-10

Agency Compliance Scorecard 11

ASDT Job Aids 12

New Business Checklist 13

Credit Report Ordering 13

No Hit Validation Form .................................................................. 13

PQB Reconciliation Form.............................................................. 14

How to Prevent or Minimize Duplicate Credit Re-Orders .............. 14

Gateway Additional Resources 3

Allstate University Home Page ..................................................... 15

Risk Management Policy (RMP) Resource Web Page .................. 15

Adherence to Rules and Rates……………………………………….17

Field Business Conduct Site ......................................................... 18

Appendix 19

Agency Compliance Tool Kit 19

ASDT Job Aid to Add Staff in the Agency ..................................... 19

ASDT Terminate Staff in the Agency ............................................ 23

Policy Checklist Examples ............................................................ 24-27

No Hit Validation Form .................................................................. 28

PQB Reconciliation ....................................................................... 29

How to Prevent or Minimize Duplicate Credit Orders .................... 30

Business Conduct Back to Basics ................................................. 31


This step-by-step suggested compliance process is not all inclusive and does not supersede local Risk Management Policies (RMP’s) or the Rules and Rates filed with the State of Florida.

STEP 1: Open e-Agent and Gateway on two screens (or split screen)

STEP 2: Open documents which have been loaded onto e-Agent by producer after binding:

• Consumer Report (LIS,CCDB,Credit,MVR) • Homeownership Property Appraiser Search • Vehicle Registration Search • Proof of Prior (if declared by the agency)

Once the consumer reports have been run, it is the producer’s responsibility to review the results, check IS score for a No Hit, etc. A best practice is for the producer to upload the consumer report into eAgent by clicking on the Print Consumer Reports radio button then accessing the print driver in eAgent to upload a copy of the consumer reports for verification compliances purposes. Below is a copy of the first page of the consumer report, showing the customer’s name and IS score. Continuing to scroll will show the CCDB, LIS and MVR results in PDF format. All Personally Identifiable Information (PII) is masked.


STEP 3: Compare LIS & CCDB control numbers and insured names. If LSP ran LIS/CCDB before ordering credit, make sure to check the name on CCDB to match policy holder. If they do not match, the LSP may have run more than 1 consumer report. The agency can download all Duplicate Credit Orders from the Agency Compliance Scorecard and search for the customer name to see how many orders were initiated. Control numbers that do not match the one used to issue the policy should be researched to ascertain why duplicates are being ordered.

D

Ensure your agency has a process to check the Agency Compliance Scorecard on the 15th of every month. Click on the View Complete POSIS Detail Report for additional compliance categories.


Tip: to see a complete of acceptable documentation pertaining to the RMBC homeownership solicitation process, type RMBC in the Gateway search field to reach the landing page for the Risk Management Business Center.

STEP 4: Match property search record to address and insured name, make sure insured owns the property. Homeownership will be verified by any of the following documents: - Property tax appraisal or bill - Online public records, where available

If the address on the public record does not match either the mailing or garaging address on the policy, additional proof is required. Acceptable forms of proof include any other document in this list, utility bill, or property insurance declarations, mortgage statement. Supplemental proof address must match the address on the online public record. Source: AFCIC RMP page 14

Property Appraiser Document(s) can be found by county at: HTTP://FLORIDAREVENUE.COM/DOR/PROPERTY/APPRAISERS.HTML

http://floridarevenue.com/dor/property/appraisers.html


Tip: in Gateway search field type: Jointly Titled Vehicles for a complete list of scenarios for handling different types of title exceptions.

STEP 5: There is currently no mandate to collect registrations however, a good practice is to upload to eAgent then review a copy of the DMV/Vehicle Information Check for Insurable Interest and prevention of a potential E&O or Undisclosed Operator. *Note: in all cases it is only

a partial birthdate match. Utility vehicles over 5000lbs have an expiration date of 12/31.

Insurable Interest The named insured(s) must be the registered owner(s) of all vehicles to be insured on the policy. Administrative Requirement: Agencies must confirm that all vehicles written at the time of new business or endorsed onto the policy at any time are owned by the named insured and/or spouse. Agencies may be asked to submit proof in the form of vehicle registration or title for spot-check purposes. Source: AFCIC RMP page 8. Vehicle Information Check can be found at: HTTPS://SERVICES.FLHSMV.GOV/MVCHECKWEB/

https://services.flhsmv.gov/MVCheckWeb/


EZP – **Remember, there are 2 opportunities to enter account information correctly.

DASH – **Remember to review this report for policies ending in “@Allstate.com” to potentially assign eSmart

discount and possibly avoid ePolicy enrollment. Please correct emails for indicated policies if warranted.

Tip: in Gateway search field type: Easy Pay Plan Toolkit for information on billing. The site provides an overview about payment plans, Easy Pay, Recurring Credit Card, Paperless Billing, down payments, how to calculate a payment plan, safe driving bonus, payroll deduction and more.

Tip: in Gateway search field type: eSign. eSign gives customers the capability to sign and

submit their documents with a simple click of a mouse. Includes how to ask customers to participate,

signing documents in eSignature, the follow-up process, contact information for assistance and more.

STEP 6: Perform a discount review to ensure enrollment processes are completed:

DriveWise (follow through on activation), EZP (pay attention to EZP at Risk notices), Multi-policy discount (make sure there is an active renters or PUPS), eSmart (make sure customer enrolls in ePolicy and check the Email Discrepancy Report on DASH), etc…


STEP 7: Follow through to make sure collection of documentation took place at the point of sale if

prior insurance was Declared or Modified by the agency. Check for an RMBC solicitation.

PRIOR INSURANCE VERIFICATION Agencies are required to obtain documentation from the customer prior to adding any application

information affecting Tier (5 years at prior carrier, homeownership, prior BI limits, etc.),

Qualification of a new business policy or Discount on a policy. Source: AFCIC RMP page 13-15.

Tip: to locate additional comprehensive information around the RMBC solicitation process, type RMBC in the Gateway search field to reach the landing page for the Risk Management Business Center.


Agency Compliance Scorecard

Intended Use:

A tool used by the Company to ensure compliance to policy and procedure and the Agency Standards is the Point of Sale Information System (POSIS).

The Point of Sale compliance process is used to monitor adherence to specific risk controls defined by the company. Agencies have access to this information through DASH.

All reported noncompliance are based on the best available information at the time the Scorecard is populated.

Tips for Using

The Agency Compliance Scorecard and the LSP Activity Report is updated on the 15th of each month and are self-evaluation tools to holistically monitor business processes and agency level transactions performed by your Licensed Sales Producers.

The scorecard is a good first level of defense, but do not assume that a clean scorecard means there are no underlying issues in the agency. That is why you may want to install a Compliance Process in your Agency to ensure your agency is compliant to company policy, procedure and Agency Standards.


ASDT Job Aids

Intended Use:

Steps to follow to Add and/or Terminate Staff from accessing Allstate applications.

Things to Know:

Regardless of licensure all authorized users of Allstate applications must have their own unique user name and password in order to maintain individual accountability on each work station.

When an employee of an agency terminates either voluntarily or involuntarily, they must be removed from access to Allstate Applications. Please indicate if the termination reason code is Voluntary or Involuntary. If you indicate Involuntary, notification is sent to the Licensing Department to ask for the reason for the involuntary termination. Provide the reason. Licensing will notify local HR to determine if the LSP should have their binding removed for best interest. Best interest terminations will be for actions that seriously damage the Allstate Brand. Local HR will work with the Agency to determine if the conduct supports removal of binding. When the Company makes this decision, the LSP will not be allowed to bind insurance for Allstate anywhere in the country.

Insurance is a highly regulated industry and someone transacting insurance without an active appointment or the proper license violates Florida Statues, as well as the EA Contractual Agreement. For complete information on Agency Staff refer to the EA Manual located on the Gateway.

The EA Manual can be found on the Gateway, search EA R3001 Program Materials and Agency Standards or input in the search field web ID number 13526

Understand the various licenses available for your staff to obtain. For example, do you understand the difference between the 2-20 and the 4-40 licenses? A 4-40 licensed staff must be a salaried employee. Salaried employee does not necessarily mean they are exempt from over time in the context of the word salaried, it means they cannot receive commissions based on the production of applications, insurance or premiums.

A 4-40 licensed staff person, who completes binding authority requirements, must be appointed by a 2-20, licensed person. The 2-20 must appoint the 4-40 license directly to their 2-20 via the Department of Financial Services. Once LSP’s 4-40 is appointed the 2-20 must supervise the activities of the LSP. Here is a scenario…you have an ESA or Satellite office and you have a 4-40 in the office. Staffs that have a 4-40 license must be appointed to a 2-20 person who will supervise them in the agency.

For complete guidelines on licenses and appointments refer to the Division of Insurance Agent and Agency Services web site.

The web address: http://www.myfloridacfo.com/Division/Agents/Licensure/default.htm

See Appendix – ASDT Job Aid

http://www.myfloridacfo.com/Division/Agents/Licensure/default.htm


New Business Checklist

Intended Use

Allows the agency to obtain and transmit complete and accurate information on every person whose consumer report will be ordered including but not limited to name, address, and date of birth and when provide the social security number.

Tips for Using

Staff can use any of the checklist examples in the appendix to document all information gathered on a prospective customer. We encourage you to customize one for your agency. It should include any agency notes to refer to when providing customized solutions for your customer, as well as, a tool for your compliance process for verification of information. It can also be used as an onboarding tool for new employees.

See Appendix – How to Use an Auto New Business Checklist, Auto New Business Checklist and/or Policy Checklist

Credit Report Ordering - No Hit Validation Form

Intended Use:

Implement the use of this No Hit Form to require your staff to document when there is a No Hit on a Credit Report. Agencies should only re-order credit reports if the first was returned as a no hit when additional/corrected information is required, and with the approval of the customer.

Tips for minimizing No Hit Credit Reports

1. Verify all information was complete and entered accurately (spelling of name, full current address, prior address, etc.) If the original order information matches the customer's information on the driver's license, then continue with new business quoting and processing as usual.

2. Credit re-orders after a No-Hit on the same control number: If there are changes made to key information to obtain a Hit, this is compliant with company guidelines. If a reorder takes place, and no key information is changed, the system will return the same historical result, which was a no hit.

3. Credit re-orders after a No-Hit on a different control number indicates a new quote was started and possibly the agency is not looking for the existing quotes or may believe beginning a new application would result in getting a Hit.

Tip: for the latest information on New Business and Credit Ordering on Renewal guidelines, use the Gateway search field and type: Credit Reporting or Credit Reporting Job Aid

See Appendix – No Hit Validation Form


PQB Reconciliation Form

Intended Use:

Use this to reconcile the Loss Information Summary of the PQB.

Tips for Using:

The PQB Reconciliation contains instructions on how to reconcile results of the loss information contained on the PQB. It provides what if scenarios and documentation/reason is required for:

At Fault is changed to a No Fault

Deleting/Reassigning matched Claims

Delete Declared Operator

Deleting Unmatched claim

Undisclosed operator not added

Changing MVR accident to a No Fault

Tip: additional resources regarding PQB can be found by visiting the RMBC website and clicking "Pre-Qualifying Business."

See Appendix – PQB Reconciliation Form

How to Prevent or Minimize Duplicate Credit Re-Orders

The Duplicate Credit Report Order POSIS category tracks multiple credit reports ordered for the same individual for the same line of business. It also tracks duplicate social security numbers used for different insured’s. Credit report re-orders are only appropriate when the initial result was a no-hit for one/both operators and the agency has input additional/corrected information that may result in a hit.

Why is it important to prevent/minimize duplicate credit orders?

1. To help ensure adherence to the Federal Credit Reporting Act and the Agency Ordering of Consumer Reports Agency Standard.

2. Expense issue: it costs money every time credit is ordered and re-ordered.

What are a few common drivers of preventable duplicate credit orders?

3. Neglecting to verify key information prior to ordering credit: Please make sure all key information entered is complete and accurate before ordering credit reports the first time. Key Information includes: Last Name, First Name, Middle Initial, address, previous address if moved within two years for auto and five years for property, date-of-birth, marital status, and Social Security Number.

https://agencygateway1.allstate.com/wps/myportal/id/50618



4. When ordering credit always ask “what is your name as it appears on your driver’s license”. This is especially helpful for those who do not take their spouse’s surname, or hyphenate their last name.

5. Not checking for existing quotes on the same individual(s) prior to starting a new quote: Please check for an existing quote in Gateway Household View prior to starting a new one, especially in agencies with multiple producers.

6. Lack of attention or education for new producers: please take the time to go over the correct process for verifying information prior to ordering credit and do not re-order for education purposes.

See Appendix – How to Prevent or Minimize Duplicate Credit Orders Job Aide

Gateway Additional Resources

Allstate University Home Page

In Allstate University there are significant resources for Point of Sale Compliance Education for new or tenured employees. These targeted topics provide short, specific education to address individual knowledge gaps, available online, anytime. Within each course, topics can be accessed and completed in any order as reinforcements are needed.

TIP: To access the Allstate University landing page, type: Allstate University Course Catalog on Gateway.


Risk Management Policy (RMP) Resource Web Page

RMP Guidelines for Auto lines and Resources for Supporting documents

RMP Guidelines for Property lines and Resources for Supporting documents

RMP Guidelines for Specialty Lines

In Gateway search field type: RMP to reach the landing page for the Risk Management Policy (RMP) Resource Page. (Click on Florida).

Type any of the words below in Gateway for links to Additional Resources

Rules and Rates

Ivantage Expanded Market Programs




ADHERENCE TO RULES AND RATES **also commonly referred to as a Rules and Rates Exception WSR

Tip: type in Gateway search field: Adherence to Rules and Rates and click on the job aide: How to Correctly Process Common Discounts.

The job aid lists the most common discounts applied at New Business and Renewal. The application of the discount at New Business, Renewal, as well as Agency Tips and Loss of Discount.

1. Full Pay

2. Easy Pay

3. Allstate eSmart

4. Responsible Payer

5. Allstate Drive Wise Program

Please note: WSR Exceptions to rules and rates cannot be submitted by the LSP. The LSP may gather the evidence but only the agent can submit the exception. This ensures the agent is double-checking to make sure the evidence substantiates the reason for the exception. Please remember that our filed Rules and Rates are regulated by the OIR; they are not an Allstate business decision. We are a heavily regulated industry, it is very important to remember, Alliance is programmed based on the rules we filed with the state to make sure we are compliant.

Documentation required to support agency / company errors

Based on the request type, the following are examples of documentation that should be attached to the Adherence to Rules and Rates WSR.

Copy of a customer email or eAgent call log (showing the date and call notes) that show the customer’s intent and support agency error.

Copy of remittance report showing the date and amount of the payment was collected.

Copy of the customer’s acknowledgement email showing the enrollment date for e-Smart

Copy of an endorsement that was delayed due to a version error or pended in error

Ticket number and detailed explanation if a system issue occurred.


Field Business Conduct Site

Intended Use:

The site illustrates Field Business Conduct’s focus on education, detection and governance, as well as governance and reporting. Only through a robust reporting metric, can we obtain the data necessary for early issue identification. We also provide tips and resources to agencies so that Agents, as small business owners, can better run their agencies. Supporting consistent and ethical practices will protect the Allstate Brand and your Agency reputation.

The Field Business Conduct Site provides tools and information to help protect your agency's reputation. Available on this site is information on:

Data Fundamentals - Invest just 25 minutes in the first annual FBC education to help prevent potential data privacy or data integrity issues in your agency. To access the course:

o Go to TalentConnection

o From the Home drop down, select Learning

o Search the catalog for Annual Agency Education: Data Fundamentals

Agency Staff and Business Practice Guide - A checklist of agency practices and procedures that agency owners should review to make sure certain activities are compliant.

Business Conduct in the Digital Age - A quick reference guide detailing appropriate business conduct and actions within the digital age.

Back to Basics - Fundamental tips to help protect your agency as you manage your business.

Unlicensed Agency Staff Guidelines - know what non-appointed activities staff may perform.

Cross Sell Do’s and Don'ts - achieve goals by doing things the right way at the right time and for the right reason.

In Gateway search field type: Field Business Conduct to reach the landing page.








Appendix

Agency Compliance Tool Kit

ASDT Job Aid to Add Staff in the Agency


ASDT Job Aid – Terminate Staff NT ID


Example of Auto New Business Checklist


Example of Auto New Business Checklist con’t


Agency Compliance Took Kit © 2013 Allstate Insurance Company. Proprietary and Confidential Information. 12/5/2016

Example of Auto New Business Checklist



No Hit Validation Form



PQB Reconciliation



How to Prevent or Minimize Duplicate Credit Orders

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