Talk:New York Life Insurance Company

Edit request: Criticism and controversy

Hi again! Following my requests so far to update this article, I'd like to make a request to remove the Criticism and controversy section from the article. This entire section is rather poorly sourced, verges on original research, and consists of seemingly not notable events that were not covered in independent, third-party sources. This section was discussed a while back by 2*6 and Jusdafax, and I think it's worth revisiting since there has been no change since then in terms of improved sourcing.

Sources This section contains eight sources.

• Reference #19 is to the New York Life entry on the Better Business Bureau website, which does not mention "allegedly unethical sales practices and refusal to remit death benefits, notably in the State of California."
• Reference #20 is a legal summary on FindLaw
• Reference #21 is a court document
• Reference #22 is Top Class Actions, whose stated goal is "connecting consumers to settlements, lawsuits & attorneys"

The section also includes a number of details lauding New York Life, the source material of which I feel are of equally poor quality. These include bestliferates.org, a New York Life press release, and a dead link to Top Work Places. The only info here with a secondary source is NYL's best-places-to-work listing in Boston, which cites Business Insider. Regardless, I propose that this information be removed, too.

My take is that important, notable events and issues belong on Wikipedia—whether positive or negative—if it has generated coverage in reliable, independent sources, is relevant to the subject, and given WP:DUE weight. In this case I tend to agree with 2*6 that the sources used here are not compelling, and are borderline spammy. Interested to hear others thoughts on this and whether this section might be updated or removed! Just to quickly note again, I do have a financial COI here as I'm here on behalf of NYL as part of my work with Beutler Ink, so will not make this edit myself and would like to discuss with others. 16912 Rhiannon (Talk · COI) 21:29, 22 December 2017 (UTC)

 Implemented The Criticism and Controversy section was renamed 'New Jersey investigation', as this was the only reliable reference provided in the section. I have expanded upon the New Jersey report's findings, and offered its results, in order to provide contextual understanding of the contents. The other references were for online database results, and no contextual understanding of those findings was provided, so they were removed.

Those removed "complaints" ought not to have been mentioned in passing — as they were here — since the failure to provide a deeper understanding does the reader a great disservice. If, in the future, individual pertinent lawsuits are described along with contextual understanding of what the lawsuits/complaints entailed — including the results that arose from them — the section may be expanded further. Regards, Spintendo ᔦᔭ 22:27, 22 December 2017 (UTC)

Thanks, Spintendo. Appreciate your input here and agree in general with your approach. I'll admit, I felt that without secondary sourcing the New Jersey investigation didn't seem especially noteworthy but I'll take a close look at what you've added here and think some more about it. Thanks, 16912 Rhiannon (Talk · COI) 22:46, 22 December 2017 (UTC)

Hi again! After some more thought, I still wasn't sure about the level of detail here considering the primary source, so I posted a note to WikiProject Law for some more input on this type of section. If editors are generally unconcerned, then I'll leave this be, it just seems like a lot of detail / weight given to this for something with no secondary coverage. 16912 Rhiannon (Talk · COI) 21:57, 12 January 2018 (UTC)

Hi yet again, Spintendo! After receiving no responses on WikiProject Law, I have posted a request for a third opinion at WP:3O. I don't feel that the New Jersey investigation should be covered in so much detail (if at all) considering the lack of secondary sources. It's clear from your original reply that you feel it should be given this detail to allow for the right level of context, but it seems unencyclopedic to focus on this one investigation out of the whole company history. 16912 Rhiannon (Talk · COI) 22:22, 8 February 2018 (UTC)

Response to third opinion request:

To be honest, I'm not quite sure why that section exists to begin with. The cited report doesn't seem to be as much an investigation or criticism as routine review and the results, lacking comparative context as they are, look like nothing unusual. So we have two possible cases here: Either it's a routine review, which should be filed under "New Jersey State review" or "Case statistics", rather than "criticisms" or "investigation"; or it's indeed an investigation - a non-routine event based on some outside derogatory information (client complaints, media reports and the like) - in which case you should provide the context and outcomes of the investigation in addition to its conclusions. François Robere (talk) 23:03, 9 February 2018 (UTC)

Thanks for your thoughts here, François Robere. So far as I'm aware (and based also on what my contact at NYL has been able to find out), there is no particular significance to this report/investigation other than someone at some time added it to the article and Spintendo felt that it was the one piece from the previously existing Criticism and controversy section that had sourcing good enough to expand and retain. The report/investigation was originally added to the article by an IP editor in August 2016. I have searched for secondary, reliable sources that might offer context or describe this report/investigation in further detail, but I have not uncovered anything. On this basis, and WP:DUE, does it seem reasonable to simply remove the section? (A quick note of disclosure, in case you didn't see above: I'm here on behalf of New York Life as part of my work at Beutler Ink so will not edit the article directly.) Thanks in advance, 16912 Rhiannon (Talk · COI) 02:13, 13 February 2018 (UTC)

As a measure of caution I've done my own research, and only found two interesting items that aren't already mentioned in the article ([1][2]), neither of which is related to the so-called investigation. As far as I'm concerned, unless we have new sources as per my previous remarks, the New Jersey section can be removed; whether or not it is is up to the other editors involved. François Robere (talk) 15:55, 13 February 2018 (UTC)

François Robere: I understand. I appreciate your willingness to review the issue and offer an opinion.

Pinging Spintendo: In light of the WP:3O reviewer's input, what do you think is the best way to proceed? If you're still not inclined to remove the New Jersey investigation content, would you be comfortable with me asking folks from WikiProject Companies (or similar) in order to build consensus one way or the other?

I appreciate everyone's time in this issue. Thanks, 16912 Rhiannon (Talk · COI) 16:21, 15 February 2018 (UTC)

As it appears that the editors may not have fully read the report, all I can add here is what I discovered in it's stated purposes and conclusions, and address concerns according to that knowledge.

1. The cited report doesn't seem to be as much an investigation or criticism as routine review. The report was conducted by the Commissioner for Banking and Insurance of the state of New Jersey, officially called a "Market Conduct Examination", as authorized by N.J.S.A. 17B:30-13.2 (Complaint handling procedures) and N.J.A.C. 11:2-17.6 (Rules for replying to pertinent communications). These were not part of any type of regular or routine examination, and were triggered by reports from consumers.
2. Lacking comparative context as they are, look(s) like nothing unusual. The examination revealed certain instances where company practices did not accord fully with various provisions of New Jersey insurance statutes and regulations. On the contrary, these are unusual occurances.
3. So we have two possible cases here: Either it's a routine review, which should be filed under "New Jersey State review" or "Case statistics", rather than "criticisms" or "investigation"; or it's indeed an investigation - a non-routine event based on some outside derogatory information (client complaints, media reports and the like) This was not outside information. According to the report, these findings were based on information provided by the New York Life Insurance Company itself (e.g., "Based on the documentation and information submitted by the Companies").
4. in which case you should provide the context and outcomes of the investigation in addition to its conclusions. Notwithstanding the fact that outcomes and conclusions are often the same thing, both are to be found in the report under "Examiner's findings". A summary of those findings is what I placed in the Wikipedia article in place of the poorly formed claim statements which were originally placed there. As these "outcomes/conclusions" exist in two locations for editors to read on their own, I wont expound upon them further. Suffice it to say, they do not speak poorly of NY life Ins. Indeed, the findings exonerated the company in the majority of areas where complaints were filed, with the majority of errors being committed in policyholder services.
5. As far as the need for additional context, the report has been made a part of the official state of New Jersey record, and its conclusions were signed off by both the Commissioner of the Department of Banking and Insurance as well as the SVP and Chief Compliance Officer of NYLife. I'm not sure what additional coverage is needed here. Not wishing to make a WP:POINT of the matter, it goes without saying that the policy repeated here (WP:DUE) does not take into consideration the other references already existing in the article which, as they originate from only one source, would certainly fail that requirement. If anything, removing it would seem to violate WP:BALASP and WP:PROPORTION. Regards, Spintendo      17:04, 27 February 2018 (UTC)

References

The section in question has been rewritten:

All of the information remains the same. Its presentation is the only thing altered. Let me know if this works.Spintendo      18:54, 27 February 2018 (UTC)

Hi Spintendo, thanks for your patience while I mulled this over. To start with, I want to say I see and appreciate the time and attention that you've given this section. What I'm struggling with is the "why". Both from a Wikipedia perspective (bearing in mind NPOV, and WP:PRIMARY, as well as thinking about what information is considered of encyclopedic importance), and from your individual perspective, I'm at a loss as to why this particular report is so important that it deserves its own section in the article, despite there being only the primary source document and no secondary coverage. It's not that I'm opposed to any mention of it and it's not even negative to NYL, but I'm puzzled why this report that has no secondary coverage needs this much detail and its own standalone section. Typically you've tended to be opposed to including a lot of "minutiae" in company articles, so I've been surprised at your take on this. Can you explain so I can understand the "why" from your perspective? 16912 Rhiannon (Talk · COI) 21:37, 2 March 2018 (UTC)

I'm not the individual who first added the information, so I cannot speak to their motivations. What I can speak to is how the editor community has treated this information since it was first appended in August 2016.

1. 23-AUG-2016 First appearance of the information
2. 14-JAN-2017 First attempted removal of the information
3. 14-JAN-2017 The information is restored by Darylgolden whose edit summary states "Revert removal of well-sourced criticism"
4. 14-JAN-2017 Second attempted removal of the information.
5. 14-JAN-2017 Second restoration by Jusdafax whose edit summary states "Revert removal of correctly sourced content please do not edit war."
6. 16-MAY-2017 A qualification is added stating that the information critical to the company ought to be viewed with suspicion.
7. 22-DEC-2017 The beginning of my edits which altered the allegations to be based off of the complaint language as it was shown in the report, basing it upon the page numbers which I included. I also included for the first time the actual numbers used in the findings (percentage-wise) which the original wording did not use. I also removed the spurious references to unreliable sources which the claim had included, narrowing the source to be only the report itself.

All of this time since August 2016 the main bulk of the information from the New Jersey report has described either the report's intentions (from AUG 2016 to DEC 2017) or its actual findings (from DEC 2017 to the present) and attempts at removing it have failed. Based on this history it appears that the information has community consensus to remain in one form or another. Regards, Spintendo      20:38, 8 March 2018 (UTC)

Ok, if I'm understanding right, since the information has been in the article for eighteen months and a couple of attempted removals have been reversed, your view is it has community consensus to remain. I don't agree with that. The reasons given by the two editors who reverted weren't specific to this detail (since both were reverting wholesale removal of the Criticism and controversy section. This material isn't well sourced, as both of the editors reverting the edits said in their summaries, it's just the one primary source, the report itself. Per the 3O editor above, "unless we have new sources as per my previous remarks, the New Jersey section can be removed"; given there's no secondary sourcing will you remove it? (As a side note: even if there was consensus for a mention of this report, it doesn't necessarily relate to it having its own section of the article.16912 Rhiannon (Talk · COI) 21:00, 8 March 2018 (UTC)

I've re-emplaced it under the "Recent history" subheading. I will not remove it without a broader consensus. The report was signed off by, and contains the signatures of, both Commissioner Considine and Barbara McInerney, Senior Vice President and Chief Compliance Officer of New York Life Insurance Company, and the document itself resides on New Jersey government servers (nj.gov) so I'm not sure which part is supposed to be unreliable here.Spintendo      21:28, 8 March 2018 (UTC)

Definitely not saying it isn't reliable, what I am saying is that it's a primary source with no secondary coverage that would show this is a key fact we should know about NYL as part of an encyclopedic overview of the company. Anyway, I'll leave this here for today and see if the editors who'd reverted removals previously chime in. If not, I'll consider how we might get some other folks to offer their 2c here to form broader consensus. open to your thoughts on that too, if you have any suggestions for good venues to get input as the relevant WikiProjects can be very quiet. 16912 Rhiannon (Talk · COI) 21:47, 8 March 2018 (UTC)

With no-one else weighing in here, I think the best bet to form broad consensus is to open an RfC. I'm not very experienced with them, but I've had a go at writing up what I hope is a neutral description of the situation and hope editors can offer some informed thoughts. 16912 Rhiannon (Talk · COI) 20:22, 12 March 2018 (UTC)

Spintendo, WP:PRIMARY includes this definition (my bold): "Duke University, Libraries offers this definition: "A primary source is a first-hand account of an event. Primary sources may include newspaper articles, letters, diaries, interviews, laws, reports of government commissions, and many other types of documents."

As well, I would say that a government report like this could be a secondary source, say if we were using it to support say, the number of claims made on New York Life policies in a certain year. But that's not how it's being used: it's being used to support inclusion of details that 1. a market conduct investigation was undertaken, 2. the findings of that investigation. Your rubric above supposes that the report is being used to include details about the company, that were provided by NYL and summarized by the government commission. But it is not. It is being used to summarize the investigation itself. In that way, as well as in terms of a straightforward reading of WP:PRIMARY, it is a primary source. 16912 Rhiannon (Talk · COI) 13:36, 15 March 2018 (UTC)

That's ok, I wont hold it against you that you have difficulty counting. All you need to do is count the number of steps from the center: The customer, the employee, and the regulators = One, two, three...that is a third party. It's a secondary source because they are two steps removed from the original people involved, those being NYLIC and their customers...one, two. By your own definition a Primary source features original materials from people close to an event who are directly involved. How exactly does a group of lawyers and regulators writing about events which occurred years before, involving people they've never met and circumstances they never witnessed, make them a primary source? Spintendo      13:58, 15 March 2018 (UTC)

Ok, I'm going to try restating this. It is being used to support inclusion of a mention of the investigation itself and the investigation's findings, so you have a group of lawyers and regulators as a source for their own findings about NYL and the importance of that to NYL. It is primary. The government have their job to do in undertaking this type of investigation and publishing a report with findings, but we need journalistic coverage to show why it's important. 16912 Rhiannon (Talk · COI) 17:33, 15 March 2018 (UTC)

RfC on Policyholder service improvements section

Is the Policyholder service improvements subsection of the company History appropriate, or should it be removed or reduced in length? The current content is based on a market conduct examination report from the State of New Jersey Department of Banking and Insurance and there is no coverage of this from independent, secondary sources, however a mention of the report has been retained in the article for a couple of years in one form or another. Thanks in advance, 16912 Rhiannon (Talk · COI) 20:25, 12 March 2018 (UTC) Please note: I have a conflict of interest as I am here on behalf of New York Life as part of my work with Beutler Ink. 16912 Rhiannon (Talk · COI) 17:49, 15 March 2018 (UTC)

This is incorrect. While these are court documents, they are not primary source court documents, in the sense that they are not akin to trial transcipts of individuals speaking in a crowded courtroom. That kind of trial transcript would be a primary source document because the transcriptionist was sitting there, in the courtroom when the words were spoken. The court record in this case from New Jersey contains information from files kept by a first group of people, the NYLIC employees. These files contained descriptions of actions and events which occurred to a second group of people, their customers. These documents, after being handed over, were examined by a third group of people, the NJ Banking and Insurance regulators. These three groups of people only contained one immediate connection - the NYLIC employees and its customers. The report itself was written by the third group who had nothing to do with the other two. This makes the document a third-party secondary-source document, as shown in the table below highlighted in yellow.

	First party	Third party
Primary source	A NYLIC employee fills out paperwork regarding a life insurance claims process they are undergoing with a customer.	Friends and family members of that customer who were present to witness the claims process share their observations of the family member's experience of that process by publishing it on Facebook.
Secondary source	A NYLIC employee gathers documents which discuss other customer's life insurance claims processes.	NJ Banking and Insurance regulators examine these documents and write a report of findings based on conclusions drawn from their examination, publishing their findings through the NJ Courts.
Tertiary source	A NYLIC employee incorporates the findings of other non-life insurance insurance examiners outside of the company who have been asked to consult on these claims and offer their opinions.	A database on insurance claim processes with data on hundreds of different cases in all realms of insurance is set up by consumer advocates for the public to examine, which is published online through the LexisNexis database.

If you look closely, in each box you have different individuals all creating a story based on information as they receive it at their level. In the first person primary source box you have one person creating a document based on their interaction with one other person. One over in the third person primary source column you have people telling a story from their perspective, and so on and so forth. At each level, the distance from the center expands one box at a time, and the information changes slightly from box to box while remaining true to the overall narrative. So much so that when you come to the yellow highlighted box you will see the story from the position that our contested document tells it from: the third party secondary source position, as that is the exact number removed from the center that the people who are telling the story — the individuals from the New Jersey Banking and Insurance regulations office — come from. This claim that there needs to be secondary sourcing is already met. Those attorneys from the Banking and insurance committee independently checked the findings initially made by NYLIC. Using the regulators own understanding of NJ banking and insurance statutes, they came to their own conclusions regarding the closing of certain insurance policies. Just as the Hillsborough Independent Panel would do back in 2013 when it reviewed older documents for an event which occurred in 1989, in order to reach new conclusions, this government action represents sourcing which goes beyond that of primary, at least in 13% of the findings. The requirement you speak of is to have the primary documents and then the secondary analysis of those documents independent of those who first prepared the documents. This document is the analysis, while the records were provided by NYLIC and signed off by their own SVP. They're both already here, in the report and in the appendix.

Regards, Spintendo      13:48, 15 March 2018 (UTC)

Notes

References

Per my RfC summary, the investigation report is the only source for the investigation itself and its outcomes. There is no journalistic coverage. The question here is whether editors feel that the material is appropriate based on that source alone. Hopefully other editors can review the content and source and let us know what they think, too. 16912 Rhiannon (Talk · COI) 17:45, 15 March 2018 (UTC)

Let's use an example here. If there was a plane crash and the NTSB wrote a report about their investigation of it, you wouldn't accept their report because — according to you — the NTSB would be the only source. But I bet you would qualify that stance by saying something like "But in that case the news media would have also reported on the crash, and that would make it legitimate." So my question would be How is it made legitimate? The NTSB report would not have been based on input from any one of those news reports. But your requirement would seem to suggest that for the NTSB report to become legitimate, the media has to report on it as well, as if a mere mention of something by the media has some magical way of making a government source become legitimate. Is that a correct view of your stance on this issue? Please advise. Spintendo      04:38, 19 March 2018 (UTC)

It is not a question of "legitimacy" but whether the information is significant enough to be included in the article, and that is what WP:SECONDARY sources are for. From the policy: Wikipedia articles usually rely on material from reliable secondary sources. Articles may make an analytic, evaluative, interpretive, or synthetic claim only if that has been published by a reliable secondary source. In any case, you had suggested building broader consensus, so let's let others weigh in to do that otherwise it's just us going back and forth on this. 16912 Rhiannon (Talk · COI) 14:02, 19 March 2018 (UTC)

That policy says Do not analyze, evaluate, interpret, or synthesize material found in a primary source yourself." You still need to describe in what way and with which passages I am taking material from a primary source and analysing it. We need to see specific passages where material from the report has been taken and used in analysis in anything I have placed into the article. Also, the policy states "Wikipedia articles usually rely on material from reliable secondary sources. Articles may make an analytic, evaluative, interpretive, or synthetic claim only if that has been published by a reliable secondary source." In which case, what is the claim that is being erroneously made here? Is the entire report "the claim"? Correct me if I'm wrong, but if I had to guess I'd say that's what you thought it was, the entire report is the claim. However, a secondary source provides an author's own thinking based on primary sources, generally at least one step removed from an event. Describe for me how these regulators, looking at primary source documents from NYLIC — some of them covering events as many as two years prior to the report being made — are not the secondary source (the regulators)? And finally, if the regulators are the primary source, then what is the analysis they are doing? I see that they are reporting on data, the number of files which failed to be resolved. The determination of a failure in resolution—is that the analysis? If that is the analysis, then what documents are they basing this analysis on? I think what would be helpful here would be to take a quick informational survey. A survey is a great way of guaging participants levels of understanding of a particular incident, in order to make sure they are all on the same page. Otherwise, discussion would have an added sense of difficulty. Rhiannon and I will both answer these ten questions. There are six multiple choice, three true or false and one fill in the blank. Rhiannons questions are below, and mine are in the extended section below that (don't peak at my answers).

Q: What relationship to the event do these items have? NYLIC employees. Which kind of a source are they?

1. Primary
2. Secondary
3. Tertiary

Q: What relationship to the event do these items have? NYLIC customers. Which kind of a source are they?

1. Primary
2. Secondary
3. Tertiary

Q: What relationship to the event do these items have? NYLIC policyholder records. Which kind of a source is this?

1. Primary
2. Secondary
3. Tertiary

Q: What relationship to the event do these items have? NJ DOBI (division of banking and insurance) employees. Which kind of source are they?

1. Primary
2. Secondary
3. Tertiary

Q: What relationship to the event do these items have? NJ DOBI's documents (the report). Which kind of a source is this?

1. Primary
2. Secondary
3. Tertiary

Q: Who or what was present at the event to witness it? Mark all that apply:

1. NJ DOBI's documents
2. NYLIC employees
3. NYLIC customers
4. NJ DOBI employees
5. NYLIC policyholder records

Q: What was the event, and when did it occur?
_________________________
__________________________ (fill in the blanks)

Final questions:

Q: True or false. If you were to call this individual on the day the event occurred and ask them how the event turned out, they would have no problem giving you the correct answer.

• NYLIC employees - Is this claim true or false for them?

1. True
2. False

• NYLIC customers - Is this claim true or false for them?

1. True
2. Falso

• NJ DOBI employees - Is this claim true or false for them?

1. True
2. False

Extended content

Q: What relationship to the event do these items have? NYLIC employees. Which kind of a source are they? Primary (The answer would be # 1, they are a primary source. Now you answer the next questions.) Secondary Tertiary Q: What relationship to the event do these items have? NYLIC customers. Which kind of a source are they? Primary Secondary Tertiary Q: What relationship to the event do these items have? NYLIC policyholder records. Which kind of a source is this? Primary Secondary Tertiary Q: What relationship to the event do these items have? NJ DOBI (division of banking and insurance) employees. Which kind of source are they? Primary Secondary Tertiary Q: What relationship to the event do these items have? NJ DOBI's documents (the report). Which kind of a source is this? Primary Secondary Tertiary Q: Who or what was present at the event to witness it? Mark all that apply: NJ DOBI's documents NYLIC employees NYLIC customers NJ DOBI employees NYLIC policyholder records Q: What was the event, and when did it occur? A: The event was the end-result handling of certain insurance policies and how those policies were paid out to policyholders. When the event occurred was whenever a policy came to be closed, either through the specific actions on the part of the policyholders (closing the account, death) or through the actions of NYLIC employees who closed the policies and filled out their paperwork. Q: True or false. If you were to call this individual on the day the event occurred and ask them how the event turned out, they would have no problem giving you the correct answer. NYLIC employees True False NYLIC customers True Falso NJ DOBI employees True False

We can discuss the answers when everyone is completed. Spintendo      02:28, 20 March 2018 (UTC)

This survey is not a productive way forward. It is very apparent that you and I disagree about the inclusion of the material and have differing understandings of the guidelines. What is needed here is for others to weigh in with fresh eyes and their own understanding of the guidelines. All this does is make it far less likely anyone will choose to weigh in. Please will you collapse this section of the discussion and allow the RfC to run its course? 16912 Rhiannon (Talk · COI) 17:53, 20 March 2018 (UTC)

The way to move forward is by having a greater understanding of the particulars of this dispute. A survey is a perfectly good way to gauge prior knowledge, and I put it forward as a way of exploring the concepts that you and I continue to speak about, such as primary sources, secondary sources, etc. We can continue to mention these terms, but they wont mean anything unless we can demonstrate our understanding of what these terms actually mean. We need to show that our individual understandings of these terms are concordant with each other. If you're unwilling to answer a ten question survey, just as I did, in order for others to understand your thought processes on the subject better, then I understand. But that is not the way to attain a resolution you'll agree with. And please dont put all your eggs in the RfC basket. An RfC can never be a complete replacement for discussions on the talk page because, ultimately, you and I are the only two interested parties in this matter, and likely will ever be. I do hope you change you mind and engage on this subject in the manner indicated. Regards, Spintendo      05:49, 21 March 2018 (UTC)

(Reworded) RfC on Policyholder service improvements section

Should this article contain a subsection on a 2009 market conduct examination undertaken by a New Jersey state government office, sourced entirely to the investigation report? The current section is as follows:

In 2009, examiners from the New Jersey Department of Banking and Insurance, in full cooperation with NYLIC, worked to identify areas where improvements could be made in policyholder services. In other areas such as complaints, replacement file review, underwriting, claims review, and advertising and forms, the Department examiners found no errors in the NYLIC reviewed files. The complete findings were as follows:

• Claims, Marketing and Sales: 0% error ratio
• Policyholder services: 13% error ratio
  • According to the report, "The examiners found four complaints where New York Life failed to provide a written response to the complainant within a reasonable period of 10 working days."
• Replacement file review: No problems
• Underwriting: 0% error ratio
• Claims review: 0% error ratio
• Advertising and forms: 0% error ratio

In addition to those areas, a review was also conducted regarding the disciplinary actions performed on agents of the company. The review found that of 11 agents disciplined, none were for "activities related to the replacement of annuities or life insurance policies". With regards to improving policyholder services, the examiners noted they were "satisfied that the Companies (NYLIC) have taken or will take corrective measures pursuant to the recommendations of the Report."

References

Is this appropriate? 16912 Rhiannon (Talk · COI) 15:10, 21 March 2018 (UTC) Please note: I have a conflict of interest as I am here on behalf of NYL as part of my work with Beutler Ink. 16912 Rhiannon (Talk · COI) 15:11, 21 March 2018 (UTC)