Complaint Handling Policy for Administrators
1. Objective and Scope
1.1 Purpose
The purpose of this policy is to provide clear guidelines for program administrators, managing general agents, managing general underwriters, claims administrators and third party administrators (collectively “Administrators”) that write business or provide services on behalf of any company within the Ledgebrook, LLC (“Ledgebrook”) related to complaints received from Ledgebrook’s policyholders, claimants, regulators, or other third parties.
1.2 Scope
This policy applies to Administrators that receive a written complaint from a policyholder, consumer, regulator, or claimant pertaining to Ledgebrook’s business. This policy applies even when only the Administrator, and not the Ledgebrook carrier, is named in the complaint. This Policy supplements, but does not replace or supersede any requirements outlined in any contract between Ledgebrook and the Administrator; in the event of a direct conflict between the terms of this Policy and such contract, the terms of the contract shall govern.
1.3 Definition and Regulatory Considerations
A complaint is a communication primarily expressing a grievance and denoting customer dissatisfaction. Complaints are typically received from policyholders, claimants, and regulators (e.g., state insurance departments). Administrators will need to use common sense when determining whether a written communication received constitutes a complaint provided, however, that all written communication from a regulator should be considered a complaint for the purposes of this Policy. Requests for information, negotiations and other general inquiries are not considered complaints and are not subject to the requirements of this policy. Non-written complaints are also not subject to the requirements of this policy provided that Ledgebrook should be made aware of any such non written complaints if they are likely to lead to a written complaint or other exposure. Each state has adopted regulations regarding the handling of written complaints. Generally, these regulations require companies to respond to written complaints in a timely fashion (usually within a certain number of days) and impose fines and penalties when companies fail to comply.
2. Complaint Handling Procedure
Ledgebrook’s Administrators must conduct a fair and impartial review of all complaints and investigate customer concerns in good faith. Responses to complaints must address all issues raised by the complainant, clearly explaining the reasons for the company's position, include all requests supporting documents or information as specified in any request(s) from a state insurance department and be submitted on a timely basis Ledgebrook is required to submit information on its written complaints per state insurance department reporting requirements. In order for Ledgebrook to provide this information in an accurate and timely fashion, Administrators must:
a. Immediately forward any complaints received by the Administrator to the Ledgebrook complaint coordinator at complaints@ledgebrook.com;
b. Prepare a proposed response to each complaint which addresses each allegation therein;
c. Provide the Ledgebrook complaints coordinator with a draft response and all necessary supporting documents no later than 3 business days before the applicable deadline;
d. Work with Ledgebrook to finalize the response; and
e. Unless otherwise directed by Ledgebrook, submit the response and supporting documents to the appropriate regulatory body on or before the deadline specified in the complaint, or, provide the response and supporting documents to the Ledgebrook Complaint Coordinator at complaints@ledgebrook.com, on or before the deadline.
3. Contact
If you have questions regarding this policy or need assistance with any aspect of the complaint management process, please contact your respective Ledgebrook relationship manager or send an email to complaints@ledgebrook.com. This mailbox is monitored weekly.
Date Last Reviewed: 03/03/2023 Reviewed By: Nathan Hall