Post Year 2000 Reporting Requirements and Data Archiving

MIA BULLETIN NO. 99-21 To: President, All Domestic Insurance Companies, HMOs, Non-Profits, Dental Plans, MCOs, etc. From: Steven B. Larsen, Insurance Commissioner Date: December 1, 1999 Subject: Post Year 2000 Reporting Requirements and Data Archiving CC: Y2K Contact Person, All Domestic Insurance Companies, HMOs, Non-Profits, Dental Plans, MCOs, etc. This notice is to advise you of two new regulatory requirements regarding the year 2000-date change, specifically, post year 2000 reporting requirements and performing back-ups of critical computer files. Post Year 2000 Reporting Requirements In order to gain an early assessment of the effects of the year 2000-date change on insurance companies domiciled in this state, I, Steven B. Larsen, Insurance Commissioner of the State of Maryland, pursuant to the authority granted by The Annotated Code of Maryland, do hereby promulgate the following Y2K reporting requirements covering the period between December 31, 1999, and January 5, 2000, and subsequent periods. This information is considered confidential under the applicable provisions of this State’s examination statute. The National Association of Insurance Commissioners (“NAIC”) will provide services to facilitate the data collection effort. Reports are to be filed via the Internet in accordance with the following guidelines. • A completed version of the enclosed survey form shall be filed at the designated location on the NAIC website address at www.naic.org. • Completed survey forms shall be filed on the above NAIC website no later than 8:00 p.m. Eastern Standard Time on or before January 5, 2000, with subsequent updates to be filed on or before February 3 and April 5, 2000. The same survey form should be used for all three filings; please indicate the applicable date with each filing. • Insurance companies which are members of a holding company with at least one other insurance company, or an insurance group, shall complete the enclosed survey on a group basis or on an individual entity basis. • Insurance companies, which are not members of a holding company or an insurance group, shall complete the survey on an individual entity basis. • Entities not having an NAIC Company Code and/or entities that do not file with the NAIC (e.g., MCOs) should E-mail the survey to mkohler@mia.state.md.us and/or fax it to P. Sean O’Donnell at fax # 410-468-2101. The information provided to the NAIC will be quickly analyzed, summarized and provided to this department and will be kept confidential pursuant to applicable provisions of this State’s examination statute. NOTE: Companies experiencing failure(s) of mission critical systems and/or other Y2K-related problems that render the Company unable to process core business functions and/or provide certain services to policyholders are expected to immediately notify the Administration as soon as the failures/problems become evident, and should not wait until the January 5, 2000 reporting deadline. Please contact P. Sean O’Donnell, at (410) 468-2120 regarding any such failures or problems. This notification is in addition to the above reporting requirements to be filed at the NAIC website. Performing Data Archives As a matter of prudent management, many insurance companies have taken steps to ensure that data files critical to the on-going operations are archived before and after December 31, 1999. In the event this issue was not fully considered in your company’s Year 2000 contingency plan, and to ensure the recovery of mission critical data in the event of a Year 2000 failure, I am hereby directing the company to secure static data archives of all financial, claims, policy administration, sales and all other critical information beginning for the fourth quarter of 1999 and through the first quarter of the year 2000. If you have any questions regarding these two matters, please contact P. Sean O’Donnell, at (410) 468-2120.