CEJ - Birnbaum - Documents
- 1999 - Report - CEJ - A consumer advocate's guide to getting, understanding, and using insurance data, by Birny Birnbaum - 40p
- Birnbaum, B., 2005. “Producer Compensation Disclosure,” Comments
of the Center for Economic Justice to the National Association
of Insurance Commissioners, March 22, Austin, TX: Center for
Economic Justice.
- Center for Economic Justice, 2005. “Producer Compensation Disclosure,” Comments of the Center for Economic Justice to the National Association of Insurance Commissioners, January 19, Austin, TX: Center for Economic Justice.
- 2005 - JIR / NAIC - The Critical Role of Insurance Class Actions, by D.J. Powers, former general counsel of the Texas Department of Insurance; founder of the Center for Economic Justice - 20p
- 2008 0915 - Letter - CEJ, Public Citizen, U.S. PIRG * Center for Economic Justice, Consumer Federation of California - re HR 5840 - 3p
- 2008 1226 - Letter - CEJ / CFA to NAIC Surplus Relief Working Group - re Proposals to Weaken Life Insurers Capital and Reserve Requirements - 21p
- 2019 0830 - Letter - CEJ / Birney Birnbaum to NAIC (LIIIWG) Life Insurance Illustrations Issues Working Group - 12p
- 2015 1012 - NAIC consumer representatives to NAIC (LIAC) - 1p
- comments from stakeholders on their issues and concerns with life insurance illustrations and the Life Insurance Illustrations Model Regulation
- 2017 0313 - CEJ (Birnbaum) to NAIC (LIBGWG) - CEJ Comments to Life Insurance Buyer’s Guide Working Group 170313 - [3p-link]
- 2017 0217 - CEJ (Birnbaum) to NAIC (LIBGWG) - CEJ Comments to NAIC Life Insurance Buyers Guide Working Group 170217 - [2p-link]
- 2018 1107 - CEJ (Birnbaum) to NAIC (LIIIWG) - 4p
- 2019 0227 - Letter - CFA to SEC - re File No. S7-23-18, Updated Disclosure Requirements and Summary Prospectus for Variable Annuity and Variable Life Insurance Contracts - 13p
- As a group of consumer representatives wrote in an earlier letter to the National Association of Insurance Commissioners (NAIC):
- “Disclosures tend to be written, reviewed and approved by insurance subject matter experts – typically regulator or industry lawyers, actuaries and market regulation staff.
- Few of these people have subject matter expertise in consumer readability, cognition, information biases or learning. Few have expertise in testing of consumer information and disclosures or training in these fields.
- The results have often been a disclosure that is unhelpful to a consumer, but provides a liability shield for insurers.”17
- 17 [2018 1107] - Letter from NAIC Consumer Representatives Brenda Cude, Birny Birnbaum, and Silvia Ye to members of the NAIC Executive Committee Task Force on Consumer Information, Education and Disclosure, Nov. 7, 2018. - <WishList>
- Substitute securities for insurance in the above quote, and the same could be said for securities disclosures, such as the current proposal, that are designed for the retail market.
- 2019 - CEJ (Birny Birnbaum) to NAIC (LIOG) -
- Ms. Mealer reminded the Working Group that a draft outline (Attachment Four-A) submitted by Birny Birnbaum (Center for
Economic Justice—CEJ) serves as a starting point for a list of topics that the online guide should address.
- She said an additional outline of topics (Attachment Four-B) submitted by Brenda Cude (University of Georgia) had been posted on the Working Group’s web page.
- 2019 0826 - CEJ (Birny Birnbaum) to NAIC (MAPWG) -
- 2019 1126 - CEJ (Birny Birnbaum) to NAIC (LIAC) - Annuity Suitability Model Regulation - 16p
- 2021 0811 - Letter - CEJ (Birny Birnbaum) to NAIC (LIAC) - Response to Questions Regarding the Work of the Life Insurance Illustrations WG - 16p
- 2019 0826 - CEJ (Birny Birnbaum) to NAIC (MAPWG) -
- 2022 0408 - Presentation - CEJ (Birny Birnbaum) - Presentation to NAIC Consumer Liaison Committee Modernizing Market Regulation Data Collection and Analysis - 29p
- 2023 0906 - Letter - CEJ (Birny Birnbaum) to NAIC (Market Conduct Examination Guidelines Working Group) - 6p