Death Master Report

6 (III. Examinations continued) • Non-forfeiture and contract maturity policies and procedures; • Systems data extracts of open individual annuity contracts, open retained asset accounts, and in-force life insurance policies, and related individual contract and policy file documentation for sample subsets of life insurance policies and annuity contracts; • Internal audit reports; • Board of Directors meeting minutes from periods of time relevant to the implementation of certain policies, procedures, and business activities; • Internal executive and management-level communications, including email communications, memos, and any records of any other written or verbal discussion relevant to the implementation of certain policies, procedures, and business activities. In addition to the six Lead States, additional states elected to participate in these examinations. Examination Results After examining insurers, the Lead States issued four examination reports that determined Massachusetts Mutual, USAA, American Equity and Citigroup insurance groups complied with state insurance regulations. Another 27 insurers entered into regulatory settlement agreements in which they agreed to use the Death Master File to identify deceased policyholders and to pay their beneficiaires.

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