So, you’re thinking about pulling the plug on a market? Whether it’s a product line or an entire operation, leaving a market isn’t as simple as just walking away. There are a whole bunch of rules and regulations you need to consider, and ignoring them can lead to some serious headaches. This article is all about understanding that market withdrawal regulatory exposure, what it means for your business, and how to deal with it.
Key Takeaways
- Leaving a market means you still have to follow all the insurance rules that applied when you were active, especially concerning policyholders you’re leaving behind. This is a big part of your market withdrawal regulatory exposure.
- Regulators watch over insurer solvency, how companies treat customers, and the fairness of policy terms. When you withdraw, they’ll be checking to make sure you’re still meeting these obligations for any remaining policies.
- Handling claims properly, even after you’ve decided to leave, is super important. Rushing or messing up claims can lead to penalties and more regulatory trouble.
- Protecting customer data and keeping systems secure are major concerns. Even after you’re gone, you might still be responsible for data breaches or privacy issues related to your past operations.
- Getting out of a market requires a solid plan that includes how you’ll wrap up all regulatory duties. Staying in touch with regulators throughout the process is key to minimizing your market withdrawal regulatory exposure.
Understanding Market Withdrawal Regulatory Exposure
The Evolving Regulatory Landscape
When an insurer decides to exit a market, it’s not just a business decision; it’s a regulatory event. Regulators are always watching, and their focus intensifies when a company plans to pack up and leave. This isn’t new, but the landscape is definitely changing. We’re seeing more complex rules and a greater expectation for transparency from both state and federal bodies. The key is that regulators want to ensure policyholders are protected, even when an insurer is leaving. They’re looking at how you handle existing policies, claims, and any potential gaps in coverage that might pop up. It’s a delicate dance, and missteps can lead to significant headaches.
Key Areas of Regulatory Scrutiny
Regulators tend to zero in on a few critical areas when an insurer withdraws. First, there’s the solvency aspect – can the company still pay claims for policies still in force, even if it’s not writing new business? They’ll want to see proof of adequate reserves and financial stability. Then, there’s market conduct. This covers how you’re treating policyholders during the exit. Are you giving enough notice? Are you handling claims fairly and promptly? Are you complying with all the rules about policy cancellations or non-renewals? Finally, data privacy and cybersecurity are huge. As you wind down operations, you still have all that sensitive customer data. Regulators want to know it’s secure and that you’re following all notification requirements if there’s a breach. It’s a lot to keep track of.
Impact of Market Withdrawal on Compliance
Pulling out of a market doesn’t mean your compliance obligations disappear; in fact, they often become more intense. You have to keep up with all the existing regulations for policies that are still active. This means continuing to adhere to claims handling standards, like those for timeliness and communication. You also need to be mindful of data privacy rules, especially when you’re transitioning data or closing down systems. Think about it: if you’re shutting down servers, how are you ensuring data is securely archived or destroyed according to regulations? It’s also important to remember that even after you’ve stopped writing new business, you’re still subject to market conduct examinations. Regulators want to make sure that the exit itself is handled properly and doesn’t create new problems for consumers. It’s a period where vigilance is absolutely necessary.
When an insurer withdraws from a market, the regulatory focus shifts from growth and new business to the responsible wind-down of existing obligations. This involves a heightened scrutiny of financial reserves, claims handling practices, and consumer communication to prevent adverse impacts on policyholders and maintain market stability.
Foundations of Insurance Regulation
Solvency and Financial Stability Oversight
Insurance companies have to be financially sound. That’s the main idea behind solvency regulation. It’s all about making sure an insurer has enough money – capital and reserves – to pay out claims, not just today, but well into the future. Regulators keep a close eye on things like how much capital an insurer holds relative to the risks it’s taking on, how it invests its money, and how it manages its reinsurance arrangements. They do this through regular financial exams and reporting requirements. The goal is to catch any signs of trouble early, before it impacts policyholders. It’s a bit like a doctor monitoring a patient’s vital signs to prevent a serious health crisis.
Market Conduct and Consumer Protection
This part of regulation focuses on how insurers actually interact with people. Think about everything from how they sell policies and advertise their products to how they handle claims and deal with complaints. Regulators want to make sure insurers are being honest, transparent, and fair in all these dealings. They conduct market conduct exams to look for patterns of bad behavior or unfair treatment of consumers. If an insurer isn’t playing by the rules, they can face consequences like fines or orders to make things right for customers. It’s about ensuring a level playing field and protecting consumers from deceptive practices. The rules here are designed to ensure consumer clarity, fairness, and protection throughout the insurance lifecycle. Market conduct rules are a big part of this.
Policy Form and Rate Regulation
Insurers can’t just make up any policy language or charge whatever they want. Regulators review policy forms, including endorsements and exclusions, to make sure they are clear, fair, and comply with state laws. Sometimes, standard policy forms are used for certain types of insurance, like auto or home, to make things simpler for consumers and prevent tricky wording. Rates are also scrutinized to ensure they are not excessive, inadequate, or unfairly discriminatory. This oversight helps prevent insurers from taking advantage of policyholders through confusing contract terms or unfair pricing. It’s a way to keep the insurance products themselves honest and understandable.
Navigating Claims Handling Regulations
When an insurer decides to withdraw from a market, the claims handling process becomes a really big deal. It’s not just about paying out claims; it’s about doing it right, according to all the rules. Regulators pay close attention to this because it’s the moment policyholders really interact with the company, and how that goes can make or break trust.
Timeliness and Communication Standards
One of the most common areas regulators look at is how quickly claims are handled and how well the insurer communicates with the policyholder. There are usually specific timeframes for acknowledging a claim, starting an investigation, and providing updates. Failure to meet these deadlines can lead to penalties. It’s not enough to just process claims; you have to keep the customer informed every step of the way. This means clear, consistent communication, whether it’s about the status of their claim or explaining why more information is needed. For example, after a loss, insurers are often required to acknowledge the claim within a few days and provide a written response about coverage within a set period, like 15 or 30 days, depending on the state. This transparency is key to avoiding issues.
Investigation and Coverage Determination
After a claim is reported, the insurer has to figure out what happened and if the policy actually covers it. This involves a thorough investigation. Adjusters need to gather facts, review policy language, and determine if the loss falls within the policy’s scope. This can get complicated, especially with complex claims. Insurers must be careful to interpret policy language fairly. If there’s ambiguity, it’s often read in favor of the policyholder. When an insurer decides a claim isn’t covered, they have to explain why in writing, citing the specific policy provisions. This part of the process is where many disputes can start, so getting it right from the beginning is important. It’s about making sure the investigation is complete and the coverage decision is well-supported by the facts and the policy terms. This is a critical step in managing market conduct.
Bad Faith Claims and Regulatory Penalties
This is where things can get really serious. Handling claims in bad faith means an insurer didn’t act honestly, promptly, or fairly. This can happen if an insurer unreasonably delays payment, denies a claim without a good reason, or doesn’t properly investigate. The consequences can be severe, including fines, orders to pay restitution, and even punitive damages in court, which can go way beyond the original claim amount. Regulators actively monitor for these kinds of practices. During a market withdrawal, ensuring that all remaining claims are handled with the utmost good faith is not just a legal requirement but also a way to manage the company’s reputation and avoid further regulatory headaches. It’s about fulfilling the contract as promised and treating policyholders with respect, even as the company exits.
Here’s a quick look at what regulators often expect:
- Prompt Acknowledgment: Acknowledge receipt of a claim within a specified number of days (e.g., 3-10 business days).
- Reasonable Investigation: Conduct a thorough investigation within a reasonable timeframe.
- Timely Communication: Provide regular updates and respond to inquiries promptly.
- Clear Coverage Decisions: Issue written decisions explaining coverage or denial, citing policy language.
- Fair Valuation: Accurately assess damages based on policy terms and market conditions.
- Prompt Payment: Pay undisputed amounts without undue delay.
When an insurer withdraws from a market, the claims process becomes a focal point for regulatory scrutiny. Adhering strictly to established timelines, maintaining transparent communication, and conducting thorough, fair investigations are paramount. Any misstep in handling claims during this period can lead to significant financial penalties and reputational damage, making diligent claims management a critical component of a successful exit strategy.
Data Privacy and Cybersecurity Compliance
When an insurer decides to withdraw from a market, it’s not just about stopping sales and managing existing policies. There’s a whole layer of data privacy and cybersecurity compliance that needs careful handling. Think about all the personal information you’ve collected over the years – names, addresses, financial details, health records, maybe even more sensitive stuff. Regulations like the GDPR in Europe or various state-level laws in the U.S. put strict rules on how this data is handled, stored, and eventually, how it’s disposed of or transferred.
Data Breach Notification Requirements
If, during the withdrawal process, there’s any kind of data breach – meaning unauthorized access or disclosure of personal information – you’ve got specific notification duties. These aren’t suggestions; they’re legal obligations. The timeline for reporting these breaches is often very tight, sometimes as short as 72 hours from discovery, depending on the jurisdiction. You need to notify affected individuals and, in many cases, the relevant regulatory bodies. Failing to do so can lead to hefty fines and serious reputational damage. It’s a good idea to have a clear plan in place for what happens if a breach occurs, even when winding down operations. This plan should outline who is responsible for what, how notifications will be made, and what steps will be taken to mitigate the harm. It’s a complex area, and getting it wrong can be costly.
Consumer Privacy Rights and Protections
Even as you exit a market, consumers still have rights regarding their data. This includes the right to access their information, request corrections, or even ask for data deletion under certain circumstances. Your withdrawal plan needs to account for how you’ll continue to honor these rights for existing policyholders. This might involve setting up a dedicated point of contact or a process for handling these requests even after you’ve stopped writing new business. It’s about respecting the trust people placed in you with their personal details. Maintaining these protections is not just a legal requirement but also a matter of ethical business practice.
Third-Party Vendor Oversight
Often, insurers work with various third-party vendors for services like claims processing, IT support, or data storage. When withdrawing from a market, you need to ensure these vendors are also compliant with data privacy and security regulations. This means reviewing contracts, understanding how they handle your data, and making sure they have a plan for data destruction or secure transfer. If a vendor experiences a breach, it can still reflect on you. You’re generally responsible for the actions of your vendors when it comes to protecting customer data. This oversight is critical to avoid unexpected liabilities during your exit. It’s a good practice to get written assurances from vendors about their data handling procedures post-withdrawal. This is especially important if you’re transferring policyholder data to another entity as part of the withdrawal process. You can find more information on data privacy compliance for insurers here.
The process of exiting a market requires a thorough review of all data handling practices. This includes not only how data is secured during the withdrawal but also how it will be managed, retained, or destroyed in compliance with all applicable privacy laws. A failure in this area can lead to significant penalties and erode any goodwill built during the operational years.
Anti-Fraud Measures and Legal Frameworks
Insurer Duties in Fraud Detection
Insurance fraud is a persistent issue that affects everyone by driving up costs. Because of this, insurers have specific legal duties when it comes to detecting and preventing it. They’re expected to have programs in place to spot suspicious activity. This isn’t just about catching criminals; it’s about protecting the integrity of the insurance pool for honest policyholders. Think of it like a neighborhood watch, but for financial crimes. Insurers need to train their staff to recognize red flags and have clear procedures for reporting suspected fraud to the authorities. It’s a balancing act, though, as we’ll see.
Balancing Fraud Control with Consumer Rights
While insurers are tasked with fighting fraud, they can’t just accuse anyone without cause. There’s a fine line between investigating potential fraud and violating a customer’s rights. For instance, an insurer can’t just start digging through a policyholder’s private financial records without a good reason and proper legal grounds. They have to follow strict rules about data privacy and due process. If an insurer goes too far, they could face legal trouble themselves. It’s all about making sure that the fight against fraud doesn’t trample on the rights of innocent people. This is where clear policies and careful execution really matter.
Regulatory Enforcement Actions
When insurers don’t meet their obligations regarding fraud detection or when their anti-fraud efforts overstep boundaries, regulators step in. These enforcement actions can take many forms. They might involve fines, mandatory changes to an insurer’s procedures, or even suspension of licenses in severe cases. Regulators look at whether an insurer has adequate fraud prevention programs and whether they are complying with laws like the Bank Secrecy Act, which is important for combating money laundering. Failing to take fraud seriously or mishandling investigations can lead to significant penalties and damage an insurer’s reputation. It’s a reminder that compliance isn’t optional; it’s a core part of operating legally and responsibly. For more on how regulators monitor insurer practices, you can look into regulatory investigations into bad faith insurance practices.
Cross-Border Regulatory Complexities
Operating an insurance business across different countries means you’re not just dealing with one set of rules; you’re juggling many. When a market withdrawal happens, especially internationally, this complexity really comes to the forefront. Each country has its own insurance regulator, and they all have different ideas about how things should be done. This can make winding down operations a real headache.
International Sanctions and AML Compliance
Dealing with international sanctions and anti-money laundering (AML) rules is a big part of this. You have to make sure that as you pull out, you’re not violating any sanctions that might be in place against certain countries or entities. This involves careful checks on who you’re dealing with and where the money is going. It’s not just about avoiding fines; it’s about staying on the right side of the law globally. Failure to comply with sanctions can lead to severe penalties and reputational damage.
Harmonization Efforts and Localized Strategies
There have been efforts to make insurance regulations more similar across borders, but honestly, it’s still a long way off. You’ll find that while some principles are shared, the specifics can vary wildly. This means that a strategy that works in one country might not fly in another. You often need to develop localized strategies for compliance, especially when exiting a market. This requires a deep understanding of each local regulatory environment. For example, understanding how regulators respond to inquiries about rate filings in different jurisdictions is key [7172].
Managing Global Market Withdrawal
When you’re pulling out of multiple countries, you need a plan that accounts for all these differences. This means:
- Mapping out all relevant jurisdictions: Know which countries you’re operating in and what their specific regulatory requirements are for market exit.
- Engaging local legal and compliance experts: You can’t know everything about every country’s laws. Get advice from people on the ground.
- Developing a phased exit strategy: Sometimes, a gradual withdrawal is easier to manage from a regulatory perspective than a sudden one.
- Maintaining clear communication with all regulators: Transparency is key. Keep them informed about your plans and progress.
The sheer volume of differing regulations across jurisdictions can make a global market withdrawal feel like trying to solve a puzzle with pieces from a dozen different boxes. Each piece (regulation) has a specific shape and purpose, and forcing it into the wrong spot just won’t work. Careful planning and expert guidance are absolutely necessary to avoid creating more problems than you solve during the exit process.
Effectively managing a product recall, for instance, requires adherence to market conduct and consumer protection standards, which are often dictated by local regulations [5089]. This principle extends to market withdrawals, where clear communication and fair treatment of policyholders are paramount, regardless of the country.
The Role of Policy Language in Disputes
When an insurance claim happens, the policy document itself becomes the main point of reference. It’s not just a piece of paper; it’s the contract that lays out exactly what’s covered and what’s not. Because of this, the exact wording in an insurance policy is super important, especially when disagreements pop up. These disagreements, or disputes, often come down to how different parts of the policy are interpreted.
Interpreting Coverage Scope and Limitations
The core of any insurance policy is its promise to cover certain losses. But this promise isn’t unlimited. The policy will define the scope of coverage, meaning what types of events or damages are included. It also details limitations, which are specific boundaries on that coverage. For example, a property policy might cover fire damage but exclude damage from floods. Understanding these boundaries is key. When a loss occurs, the first step is always to see if the policy’s language clearly includes or excludes the situation. Sometimes, the language is straightforward, but other times, it can be pretty vague, leading to arguments about what was actually intended when the policy was written. This is where regulatory review of policy forms comes into play, aiming to make sure terms are clear and fair for consumers.
Exclusions, Conditions, and Endorsements
Beyond the main insuring agreement, policies have other sections that significantly shape coverage. Exclusions are specific situations or causes of loss that the policy will not cover. Conditions are requirements that the policyholder must meet for coverage to apply, like reporting a claim within a certain timeframe. Endorsements, on the other hand, are amendments that can add, remove, or change policy terms. They might broaden coverage in some ways or narrow it in others. For instance, an endorsement could add coverage for a specific piece of equipment or clarify a particular exclusion. Navigating these different parts of the policy is complex. A dispute might arise if an insurer tries to deny a claim based on an exclusion that the policyholder believes doesn’t apply or wasn’t clearly communicated. The way these clauses are written and applied can make a big difference in the outcome of a claim. It’s also important to consider how these elements interact, especially in specialized areas like surplus lines insurance where policy forms might be more customized and require careful review to meet regulatory standards for clarity and fairness [75b7].
Valuation Methods and Dispute Resolution
Even when coverage is agreed upon, disputes can still happen over how much the loss is actually worth. Policies will often specify methods for valuing damaged property or the extent of a liability loss. Common methods include Replacement Cost (RC) and Actual Cash Value (ACV). RC pays to replace the damaged item with a new one, while ACV pays the replacement cost minus depreciation. The difference between these two can be substantial. If there’s a disagreement on the valuation, policies usually have built-in dispute resolution mechanisms. These can include negotiation between the parties, appraisal processes where neutral third parties help determine value, or even arbitration or litigation if an agreement can’t be reached. The specific language in the policy dictates which of these methods must be used and in what order. The precise wording of these valuation clauses is critical for determining the financial outcome of a claim.
Market Structure and Regulatory Impact
Admitted vs. Surplus Lines Market Considerations
The insurance market isn’t a single entity; it’s a complex web with different layers. You’ve got the admitted market, which is where most standard insurance policies come from. These companies are licensed in a specific state and have to follow all the rules and regulations set by that state’s insurance department. This means they’re generally seen as safer bets for consumers because regulators keep a close eye on their finances and how they treat policyholders. Think of it as the main highway – well-trafficked and regulated.
Then there’s the surplus lines market. This is for specialized or hard-to-place risks that admitted insurers won’t cover. These companies aren’t licensed in every state, so they have more flexibility but also less direct regulatory oversight. It’s more like a back road – useful for specific journeys but with different rules. When an insurer withdraws from the market, it can put pressure on the admitted market, potentially pushing more business into the surplus lines space. This shift can affect pricing and coverage availability, and regulators will be watching to make sure consumers aren’t left unprotected or overcharged. Understanding these market dynamics is key when planning an exit strategy.
Reinsurance and Financial Stability
Reinsurance is basically insurance for insurance companies. It’s a way for insurers to transfer some of their risk to another company, called a reinsurer. This is super important for financial stability, especially for larger insurers or those dealing with big, unpredictable risks. By offloading some of that risk, an insurer can maintain healthier capital reserves and avoid being wiped out by a single catastrophic event. When an insurer plans to withdraw from a market, their reinsurance arrangements become a big focus. Regulators want to know how the withdrawal will affect existing reinsurance contracts and whether the insurer has made adequate provisions to cover claims that might still come in, even after they’ve stopped writing new business. It’s all about making sure policyholders are still protected, no matter what.
Intermediary Responsibilities and Oversight
Agents and brokers are the folks who connect insurance companies with customers. They play a pretty big role in how insurance gets sold and managed. Agents usually work for one or a few specific insurance companies, while brokers can shop around for the best coverage from various insurers. When an insurer decides to leave a market, these intermediaries have a responsibility to their clients. They need to make sure policyholders are informed about the withdrawal and helped to find new coverage if necessary. Regulators also keep an eye on intermediaries to make sure they’re acting in their clients’ best interests and not pushing unsuitable products, especially during times of market change. It’s a delicate balance, and getting it wrong can lead to regulatory trouble for both the intermediary and the withdrawing insurer.
The structure of the insurance market, encompassing admitted carriers, surplus lines, and the role of reinsurance, directly influences how regulatory exposure is managed during a market withdrawal. Each component has distinct oversight requirements and impacts policyholder protection differently. Understanding these interdependencies is vital for a compliant exit.
Strategic Risk Management During Withdrawal
Integrating Compliance into Exit Strategies
When a company decides to exit a market, it’s not just about stopping sales. There’s a whole regulatory side to consider, and if you mess that up, it can get messy. Think about all the policies you’ve sold and the promises made. You can’t just walk away from those obligations. Regulators want to see a clear plan for how you’ll handle existing policies, claims, and any ongoing customer service needs. This means your exit strategy needs to be built with compliance in mind from the start. It’s about making sure you’re not leaving a mess for customers or regulators to clean up. This often involves setting aside adequate reserves for future claims and ensuring there’s a responsible party to handle them, even after you’re gone. Failing to plan for this can lead to fines and a damaged reputation.
Maintaining Regulatory Engagement
Even though you’re leaving, you still need to talk to the regulators. They’re not going to forget about you just because you’re pulling out. It’s important to keep them in the loop about your withdrawal plans. This means providing them with updates on your timeline, how you’re handling policy run-offs, and who will be responsible for claims. Open communication can prevent misunderstandings and show that you’re taking your responsibilities seriously. Sometimes, regulators might have specific requirements for market exits, like needing approval for your wind-down plan. Ignoring them or being difficult to reach will only make things harder. It’s better to be proactive and build a cooperative relationship, even during a departure. This can help smooth out any bumps along the road and reduce the chances of unexpected penalties.
Mitigating Long-Term Market Withdrawal Regulatory Exposure
Pulling out of a market doesn’t mean all your regulatory worries disappear overnight. There can be lingering issues, especially with claims that might surface years later. You need a plan for how these will be managed. This might involve setting up a run-off carrier or a claims servicing agreement to handle claims that come in after your official exit. Also, consider data privacy and cybersecurity. Even after you’re gone, you might still have obligations regarding customer data. Making sure that data is securely handled or properly disposed of is key. Think about potential tail exposure, which is the risk of claims arising long after the policy period has ended or the market has been exited. Proper documentation and record-keeping are vital here. Having a clear process for managing these long-term liabilities can save a lot of trouble down the line and protect the company from future regulatory actions. It’s about closing the door cleanly, not leaving it ajar for problems to creep in.
Here are some key steps to consider:
- Develop a Comprehensive Wind-Down Plan: Outline every step of the exit process, including policy termination, claims handling, and customer communication. This plan should be reviewed by legal and compliance teams.
- Establish Adequate Reserves: Ensure sufficient financial reserves are set aside to cover all known and potential future claims and liabilities.
- Secure Run-Off or Claims Servicing Agreements: Arrange for a third party to manage existing policies and claims after the company’s withdrawal.
- Maintain Regulatory Communication: Keep all relevant regulatory bodies informed of the withdrawal progress and address any concerns promptly.
- Address Data Retention and Privacy: Comply with all data privacy laws regarding the secure storage, transfer, or destruction of customer data.
Planning for market withdrawal requires a forward-thinking approach to compliance. It’s not just about the immediate exit but also about managing the residual risks and obligations that can persist for years. A well-structured plan minimizes future regulatory entanglements and protects the company’s reputation.
Wrapping Up: Staying Ahead of Market Withdrawal Risks
So, we’ve talked a lot about why companies might pull products from the market and the regulatory headaches that can come with it. It’s not just about losing sales; it’s about facing scrutiny from regulators, potential fines, and even damage to your reputation. Keeping a close eye on policy language, making sure claims are handled fairly, and staying on top of data privacy rules are all big parts of this. Honestly, it seems like a lot to manage, but ignoring these areas can lead to some serious trouble down the road. The key is to be proactive, understand the rules, and build processes that help you avoid these kinds of problems in the first place. It’s better to get it right from the start than to deal with the fallout later.
Frequently Asked Questions
What does “market withdrawal” mean for an insurance company?
It means an insurance company decides to stop selling its products or offering its services in a specific area or altogether. Think of it like a store closing its doors in a town.
Why do insurance companies have to follow rules when they stop selling products?
Governments make rules to make sure insurance companies act fairly and don’t leave customers in the lurch. These rules protect people who have insurance and ensure the company handles everything properly before it leaves.
What kind of rules do regulators look at closely when a company leaves a market?
Regulators check if the company is still able to pay claims, if it’s treating customers fairly, and if it’s following all the laws about handling private information. They want to make sure everything is wrapped up correctly.
How does an insurance company’s policy wording affect leaving a market?
The words in the insurance policy are like a contract. When a company leaves, regulators and customers will look at these words to understand what promises the company still has to keep, like paying for ongoing claims.
What happens if an insurance company doesn’t handle claims properly when it’s leaving?
If a company doesn’t pay claims on time or fairly, it can face big fines and penalties from regulators. This is called “bad faith,” and it’s a serious issue that can damage the company’s reputation.
Does it matter if the insurance company operates in other countries when it leaves one market?
Yes, it can be more complicated. Companies have to follow the rules of each country they operate in, including laws about money laundering and international sanctions, which can make leaving a market tricky.
How does a company protect itself from problems when it decides to leave a market?
A smart company plans its exit carefully. This means talking to regulators early, making sure all paperwork is in order, and having a clear plan for how it will handle existing policies and claims.
What is “solvency” and why is it important when an insurance company leaves?
Solvency means an insurance company has enough money to pay its debts, especially future claims. Regulators make sure companies are solvent so that policyholders are protected, even after the company stops selling new policies.