* This bulletin was repealed by 08-05

To:           Notice to all Missouri domiciled insurance companies and other insurance entities

From:      Keith A. Wenzel, Director, Missouri Department of Insurance

Re:          Y2K Compliance Issues

Date:       November 23, 1999

The Missouri Department of Insurance (referred to hereinafter as "Department") is an agency of the State of Missouri created and established for administering and enforcing all laws in relation to insurance and insurance companies transacting business in the State of Missouri. The general purpose of the Year 2000 compliance bulletin is to assure that the insurance company has taken reasonable measures to identify, assess and plan for potential problems which may occur with computer systems due to the year 2000. The Year 2000 problem is the result of years of abbreviating the year in computer programs to just the last two digits in order to save computer memory. With the year 2000 approaching, there is a concern that computer systems will not correctly recognize "00" as the year 2000, thereby creating mistakes or causing a shut down of computer systems and may cause the loss of mission critical data.

Mandated Year 2000 Records Archiving Strategy

In order to maintain mission critical data prior to the effects of the Year 2000 date change on insurance companies (or other regulated insurance entities) domiciled in this state, I, Keith Wenzel, do hereby promulgate the following Year 2000 Records Archiving Strategy requirements:

As part of their Year 2000 compliance activities all companies are required to have in place either:

• a data archiving process that on no less than a quarterly basis stores mission critical data for the fourth quarter of 1999 through the second quarter of the Year 2000; or
• a defined, formal archiving strategy that permits the recovery of mission critical data from any discovered Year 2000 failures.

The records from the data archiving process or the formal archiving strategy shall be maintained through December 31, 2003.

"Mission critical data" includes material financial, claims, policy administration, sales information, or other critical information maintained by the company. The preferred method for storing data archiving records is in the form of tapes, disks, or other generally accepted electronic storage forms. However, if necessary and at a minimum, hard copy materials should be maintained in the event electronic storage media is not available.

Post Year 2000 Reporting Requirements

In order to gain an early assessment of the effects of the Year 2000 date change on insurance companies (or other regulated insurance entities) domiciled in this state, I, Keith Wenzel, do hereby promulgate the following Year 2000 reporting requirements covering the period between December 31, 1999 and January 5, 2000, and subsequent periods.  Each domestic insurer shall via the Internet:

• File a completed version of the survey form located on the NAIC website.
• File the completed survey forms no later than 8:00pm 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, indicating 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.

This information is ordered pursuant to the applicable provisions of the examination of insurers including but not limited to Section 374.190 and 374.205 of the Revised Statutes of Missouri. The information gathered pursuant to this bulletin is considered of a confidential nature as provided for in Missouri Statutes and the NAIC Year 2000 Information Sharing and Confidentiality Agreement. The National Association of Insurance Commissioners ("NAIC") will provide the necessary services to facilitate the data collection effort. The NAIC will analyze and summarize this information and make it available to the Missouri Department of Insurance and other state regulators for post Year 2000 efforts. The data will be developed into summary statistics and shared with federal and international regulators on the general state of the U.S. insurance industry and to respond to media inquiries and communications.

Statutory authority for this Year 2000 bulletin includes, but is not limited to, Sections 374.190 and 374.205, Revised Statutes of Missouri which permits the Department to inquire into the business and affairs of any insurance company which transacts the business of insurance in the State of Missouri.