Wednesday, May 27, 2020

No. 374: Time Insurance Company—Another Long-Term Care Insurer Heads for Rehabilitation

On May 18, 2020, the Wisconsin Office of the Insurance Commissioner (OIC) issued a press release about its petition to a state court for permission to place Time Insurance Company (Time) in rehabilitation. Because Time is a long-term care (LTC) insurance company, this is a significant development in view of similar actions relating to two other LTC insurance companies: the liquidation of Penn Treaty Network America Insurance Company (Penn Treaty) and the rehabilitation of Senior Health Insurance Company of Pennsylvania (SHIP). The first sentence and the second paragraph of the OIC press release read as follows (the full press release is in the complimentary package offered at the end of this post):
Insurance Commissioner Mark Afable took measures today to help protect nearly 200,000 individuals who have long-term care insurance or other insurance policies with Time Insurance Company....
"Our filing with the court today protects nearly 200,000 consumers across the country," said Commissioner Afable. "State law requires me to act when our office believes an insurer is in financial trouble and that is what we have done today."
The Petition
The "Notice of Verified Petition and Verified Petition for Order for Rehabilitation" of Time consists of an eleven-page text and a five-page attachment. The text describes the background, lists the grounds for rehabilitation, and explains why the OIC determined that "rehabilitation is the only remaining option." The petition also states: "The Commissioner intends to file a plan of rehabilitation within 60 days of the Court's entry of the Order for Rehabilitation."

The petition provides details of a change of Time's ownership, Time's redomestication to Puerto Rico and its later redomestication back to Wisconsin, OIC's concerns about Time's risk-based capital (RBC) levels, OIC's cease and desist orders, and other significant matters. The petition is in the complimentary package offered at the end of this post.

The Statutory Statement
The petition says Time filed its statutory annual statement for the year ended December 31, 2019 on April 3, 2020. The statement shows total admitted assets of $16.2 million, total liabilities of $12.7 million, and statutory net worth of $3.5 million. On page 19.1 of the statement, there is a discussion of whether the company will be able to continue as a going concern. Selected pages of the statutory statement are in the complimentary package offered at the end of this post.

The RBC Ratios
RBC data for the past five years are shown on page 22 of Time's statutory statement for 2019. The RBC ratio at the end of each year, with company action level as the denominator of each ratio, are as follows (the RBC ratios with authorized control level as the denominator are twice the ratios shown here): 238 percent in 2015, 431 percent in 2016, 273 percent in 2017, 152 percent in 2018, and 210 percent in 2019.

An Omission
In The Insurance Forum (my monthly newsletter published from January 1974 through December 2013) and later on this blog site, I have written extensively about LTC insurance for 32 years. Recently a reader brought to my attention an important item on which I have not written.

My first article about LTC insurance was in the February 1988 issue of the Forum. It grew out of a solicitation I had received in the mail concerning a new LTC insurance product then being offered by Union Fidelity Life Insurance Company.

My second article about LTC insurance was in the August 1991 issue of the Forum. It grew out of an article in the June 1991 issue of Consumer Reports, the magazine of Consumers Union (CU). The CU article was entitled "An Empty Promise to the Elderly?" It described a CU study of 46 LTC insurance policies. None of the policies was rated "excellent" or "very good," but CU did not discuss the reason for those findings. In my August 1991 issue, I said "excellent" or "very good" LTC insurance policies would never be found because the problem of financing the LTC exposure violates insurance principles and therefore cannot be solved through private insurance.

In the July 2008 issue of the Forum, I elaborated on the discussion in my August 1991 issue. The July 2008 article is in the complimentary package offered at the end of this post.

What I have never discussed, because I have no recollection of ever having seen it, is a 16-page "Special Report" on LTC insurance published in the October 1997 issue of CU's magazine. The report included two pages of "ratings and recommendations" of 67 "comprehensive" LTC insurance policies and 47 "nursing home only" policies. The 67 "comprehensive" policies were ranked by "overall score." Six of them were rated as "very good," and none as "excellent." The top two policies on the list were "very good" Penn Treaty policies. My reader asserted that CU's October 1997 report created a huge demand for Penn Treaty's LTC insurance policies. I do not know whether his assertion is correct, but he may be right.

General Observations
I am not aware of anyone who has formally and publicly agreed with me that private LTC insurance cannot solve the problem of financing the LTC exposure. Nor am I aware of anyone who has formally and publicly disagreed with me. My views on the matter remain unchanged.

The previously mentioned July 2008 Forum article, entitled "Shortcomings of Private Insurance in Financing Long-Term Care," ends with this sentence: "I think many of those who try to address the problem [of financing long-term care] by purchasing private long-term care insurance will encounter disappointment."

Since October 2013, when I began this blog, I have received hundreds of emails from disgruntled owners of LTC insurance policies. For the most part, the complaints are about substantial premium increases or difficulties encountered in the handling of claims. Often the policyholders ask for my advice on what to do. In response, I have always said I am neither an attorney nor a consultant, and am not in a position to comment beyond what I have written. I then tell each person how to obtain, through the search box in the extreme upper left corner of the home page of my blog site, my posts relating to his or her company or about LTC insurance generally. I also sometimes suggest that the person contact the state insurance department in the person's home state. Each email from a disappointed LTC insurance policyholder has been a painful experience.

Available Material
I am offering a complimentary 30-page package consisting of the OIC press release (1 page), the OIC petition (16 pages), selected pages from Time's 2019 statutory statement (8 pages), and the July 2008 Forum article (5 pages). Email and ask for the May 2020 package about the rehabilitation of Time.


Thursday, May 21, 2020

No. 373: Texas Securities Commissioner Iles Issues an Emergency Order Directed At an Out-of-State Promoter

On May 15, 2020, Texas Securities Commissioner Travis J. Iles issued an Emergency Cease and Desist Order (Order) directed at Nickolas Steele (aka Nick Vop Steele aka Nick Steele). The Order shows addresses for Steele in Bellwood, Illinois, in Elmhurst, Illinois, and in Franklin, Wisconsin.

The Order relates to cryptocurrency trading during the COVID-19 pandemic. I reached out to the securities departments in Illinois and Wisconsin to see if they know of Steele. I was not able to contact Illinois; the department may be closed due to the pandemic. I received this email from a spokesperson in Wisconsin:
Our research since you contacted us indicates that Nickolas Steele may have resided in an apartment in Wisconsin from approximately 2016 to early 2018. The rest of his residential history is largely in Illinois. In August 2016, he was charged in Racine County with operating a vehicle while suspended, and he provided an Illinois address at that time. The Texas order does not allege any activities occurring in Wisconsin or any investors here. We have not located any Craigslist advertisements targeting Wisconsin investors by Steele. However, we will record this inquiry in our database and be on the alert for any Wisconsin activity past or future.
I contacted the North American Securities Administrators Association to see if they know of Steele. I am awaiting a reply.

According to the Order, Steele has 31 days to request a hearing. Any knowing violation of the Order is a criminal offense punishable by a fine of not more than $10,000, or imprisonment for two to ten years, or by both such fine and imprisonment. The nine-page Order is here.


Monday, May 18, 2020

No. 372: The Age 100 Problem—Another Update on the Lebbin Lawsuit Against Transamerica

As regular readers know, I have written extensively about what I call "the age 100 problem" in general, and in particular about the Lebbin lawsuit against Transamerica Life Insurance Company. The most recent update on the case is in No. 341 (November 15, 2019). Here I provide another update. (See Lebbin v. Transamerica, U.S. District Court, Southern District of Florida, Case No. 9:18-cv-80558.)

Gary Lebbin was born in September 1917 in Germany, came to the U.S. in 1938 to escape Nazi persecution, and married in 1944. His wife died in 2015 at age 97. In 1990 he created the Lebbin-Spector Family Trust (Trust), whose trustees are his two children. At the time, the Trust bought two second-to-die universal life policies on Gary and his wife from Transamerica with a total face amount of $3.2 million. When his wife died, the policies became single-life policies on Gary.

In July 2017, when Gary was almost 100 years old, he and the Trust filed an individual lawsuit in federal court in Maryland against Transamerica. The complaint alleged the company had falsely represented the policies as "permanent insurance" for his "whole life," and had refused his request to extend the policies beyond their terminal age of 100. The complaint included a breach-of-contract count and several other counts. In October 2017, at Transamerica's request, the lawsuit was transferred to federal court in Florida, where the policies were originally sold and several potential witnesses were located.

Recent Developments
In February 2019, by which time Gary was afflicted with dementia, Transamerica settled with him for $10,000. The Trust then filed an amended complaint omitting Gary as a plaintiff, leaving the Trust as the only plaintiff. The amended complaint included several counts, including a breach-of-contract count.

In July 2019, the judge granted the Trust's claim for breach of contract. The other counts were denied by the judge or withdrawn by the Trust. The judge canceled the trial, which had been set for early August 2019. The parties said they had agreed to resolve the case, but had not agreed on the damages for the Trust's breach-of-contract claim. Those damages thus became the only remaining issue in the case. The judge set a briefing schedule on the issue of damages.

The Trust requested a return of all premiums paid to Transamerica—a total of $1,670,141 plus prejudgment interest. The prejudgment interest rates the Trust suggested were the Florida statutory rates at the time of each premium payment. The Trust said it would provide the interest figure prior to the entry of final judgment.

Transamerica strongly opposed the amount of the Trust's claim for damages. The Trust replied to Transamerica's opposition. The parties made several further filings, eventually ended their briefings, and awaited the judge's ruling on the damages.

The Judge's Ruling
On April 7, 2020, the judge issued a "Final Order on Damages." For the two policies combined, he awarded the Trust a total of $2,530,154, including interest. He described his reasoning, showed his calculations, and said "Final Judgment will be entered separately." On April 9, the judge issued a "Final Judgment." On April 10, he issued an "Order Closing Case." The three documents are in the complimentary package offered at the end of this post.

The Appeal
On May 7, Transamerica filed a notice of appeal and posted a bond in the amount of $2,783,169. I think the difference between the amount of the bond and the amount of the judgment represents interest and costs of appeal. Transamerica's appellant brief is due June 17. Two court documents relating to the appeal are in the complimentary package offered at the end of this post. (See Transamerica v. Lebbin, U.S. Court of Appeals, Eleventh Circuit, Case No. 20-11756.)

General Observations
I had hoped Transamerica would pay the amount awarded and end this three-year-old lawsuit. However, we now have to wait and see what happens in the appeal. I plan to report developments.

Available Material
I am offering a complimentary 14-page package consisting of the judge's final order on damages (7 pages), his final judgment (1 page), his order closing the case (1 page), and two court documents relating to the appeal (5 pages). Email and ask for the May 2020 package about Lebbin v. Transamerica.


Wednesday, May 13, 2020

No. 371: Long-Term Care Insurance—An Update on the Skochin Class Action Lawsuit Against Genworth

In No. 334 (September 26, 2019), I discussed a class action lawsuit against Genworth Financial, Inc. (Genworth) relating to premium increases on long-term care (LTC) insurance policies. Here I provide an update on the case. (See Skochin v. Genworth, U.S. District Court, Eastern District of Virginia, Case No. 3:19-cv-49.)

Developments Reported in No. 334
On January 18, 2019, three individuals filed a class action lawsuit against Genworth and Genworth Life Insurance Company (GLIC). The plaintiffs are Pennsylvania residents Jerome and Susan Skochin, and Maryland resident Larry Huber. They purchased their policies in 2003 and 2004 from General Electric Capital Assurance Company, a predecessor of Genworth and GLIC. The original complaint included four claims for relief: Count 1 for breach of the implied covenant of good faith and fair dealing, Count 2 for fraudulent inducement, Count 3 for fraudulent omission, and Count 4 for violation of the Pennsylvania Unfair Trade Practices and Consumer Protection Law (CPL).

The lawsuit is one of many involving premium increases on LTC insurance policies. Unlike other cases, however, the plaintiffs do not challenge the increases. Rather, they allege the defendants failed to disclose material information to assist policyholders in making decisions about their policies. Thus Skochin may be thought of as a disclosure (or nondisclosure) case.

On March 12, 2019, the defendants filed a motion to dismiss the complaint. The judge denied the motion. On April 29, the plaintiffs filed an amended complaint that included four claims for relief: Count 1 for breach of contract, Count 2 for fraudulent inducement, Count 3 for fraudulent omission, and Count 4 for violation of the CPL.

On May 13, the defendants filed a motion to dismiss the amended complaint. On June 28, the judge ordered the defendants to complete production of documents by July 19. On July 3, the plaintiffs filed a stipulation of dismissal of Genworth, leaving GLIC as the only defendant.

On August 7, the judge set November 14 for a class certification hearing, and March 3, 2020 for the jury trial to begin. On August 29, the judge granted GLIC's motion to dismiss Count 1 (breach of contract) in the amended complaint, and denied GLIC's motion to dismiss the other three counts. He ordered the plaintiffs to file a second amended complaint by September 20, and GLIC to file its answer by October 4. On September 20, the plaintiffs filed a second amended complaint that included two claims for relief: Count 1 for fraudulent inducement by omission, and Count 2 for violation of the CPL.

Developments Subsequent to No. 334
On October 30, the plaintiffs filed a notice of settlement. On November 1, the judge ordered the plaintiffs to file a third amended complaint, and stayed the defendant's answer pending approval of the settlement. He also ordered the plaintiffs to file a motion to notify the class and a proposed settlement agreement. On November 22, the plaintiffs filed a third amended complaint. On December 20, the plaintiffs filed a motion to notify the class and a proposed settlement agreement.

On January 15, 2020, the judge held a hearing, granted preliminary approval of the proposed settlement, directed that the class notice be mailed to class members, and set the final approval hearing for July 10. On March 31, in response to requests by Genworth, the judge granted an amendment to the preliminary approval, and directed that the notice be mailed to class members. The class notice is in the complimentary package offered at the end of this post.

The Proposed Settlement
According to the proposed settlement and the class notice, policyholders will be offered certain options. Some policyholders will be offered options that include cash benefits. However, I found no estimate of the aggregate cash benefits to policyholders, other than a wide range of figures in the ambiguous paragraph (b) of the following description of the compensation of the plaintiffs' attorneys:
As part of the request for Final Approval of the Settlement Agreement, Class Counsel will file a request seeking to be paid the following:
(a) $2,000,000 relating to the injunctive relief that is in the form of the Disclosures.
(b) An additional contingent payment of 15% of certain amounts related to Special Election Options selected by the Settlement Class, which shall be no less than $10,000,000 and no greater than $24,500,000. None of the attorneys' fees will be deducted from payments made by Genworth to Settlement Class members
The plaintiffs' attorneys will also request an award of litigation expenses of not more than $75,000. With regard to the three named class representatives, the plaintiffs' attorneys will request approval of service payments of up to $25,000 for each of them for the time, work, and risk they undertook. None of the service payments will be deducted from payments made by Genworth to class members.

The Indiana Motion to Intervene
On April 10, after the settlement administrator mailed the class notices, the Indiana Department of Insurance (IDOI) moved to intervene to seek a temporary stay. Here is the first sentence of the motion:
Pursuant to Federal Rule of Civil Procedure 24, the Indiana Department of Insurance moves to intervene for the purpose of seeking a temporary stay of the proceedings in this case due to the on-going national emergency resulting from the COVID-19 virus.
On the same day, IDOI moved for a temporary stay and filed briefs in support of both motions. On April 17, the plaintiffs opposed the IDOI motions. On April 23, IDOI responded to the opposition. The judge has not yet ruled on the matter. Court documents relating to the IDOI effort are in the complimentary package offered at the end of this post.

Seven Policyholder Objections
Seven policyholders filed objections with the court. On April 20, a Florida policyholder objected. On April 22, a Colorado policyholder objected. On April 28, a Michigan couple objected. On May 1, a New York policyholder objected. On May 1, an Idaho policyholder objected. On May 5, a California policyholder objected. On May 5, a North Carolina couple objected. Court documents relating to the seven objections are in the complimentary package offered at the end of this post.

Excerpt from Genworth 10-Q
On May 6, Genworth filed its 10-Q report for the quarter ended March 31, 2020. On page 63, the report describes the Skochin case. Here are the last two sentences of the description (the full description is in the complimentary package offered at the end of this post):
Based on the Court's preliminary approval of the settlement, we do not anticipate the outcome of this matter to have a material adverse impact on our results of operations or financial position. If the court does not approve the final settlement, we intend to continue to vigorously defend this action.
General Observations
In other posts of mine about settlements of lawsuits involving premium increases on LTC insurance policies, there have sometimes been references to the size of a "settlement fund." Such a figure helps to evaluate the reasonableness of the proposed compensation of the plaintiffs' attorneys. Without a "settlement fund" figure, an evaluation is difficult.

It seems strange that the plaintiffs' attorneys oppose the eminently reasonable IDOI request for a temporary stay due to the pandemic. I hope the judge will grant the IDOI motions and will order a temporary stay.

I am an Indiana resident. I am impressed by and grateful for my home state department's effort. At the same time, I an disappointed that no other state insurance regulators have sought a temporary stay—not even Genworth's home state of Virginia, where the case is being tried. Also, the Virginia commissioner chairs an LTC Insurance Task Force that was created by the National Association of Insurance Commissioners and that hopes to get its arms around the problems of the LTC insurance business.

Available Material
I am offering a complimentary 81-page PDF consisting of the class notice (9 pages), court documents relating to IDOI's effort to obtain a temporary stay (54 pages), court documents relating to seven policyholder objections (17 pages), and the 10-Q description of the Skochin case (1 page). Email and ask for the May 2020 package about the Skochin lawsuit against Genworth.


Friday, May 8, 2020

No. 370: UNUM's Long-Term Care Insurance Statutory Reserves Take a Hit

As readers of this blog site are aware, I have written often about long-term care (LTC) insurance policies. I have also written about premium increases and reserve deficiencies relating to those policies.

The Unum Disclosure
On May 4, 2020, Unum Group (NYSE: UNM) filed with the Securities and Exchange Commission (SEC) an 8-K (significant event) report. Unum disclosed an important aspect of an ongoing financial examination of Maine-domiciled Unum Life Insurance Company of America by the Maine Bureau of Insurance (MBOI). Here are the key disclosures:
MBOI has concluded that Unum America's long-term care statutory reserves are deficient by $2.1 billion as of December 31, 2018. As permitted by MBOI, Unum America will phase in the additional statutory reserves over seven years beginning with year-end 2020 and ending with year-end 2026. The 2020 phase-in amount is estimated to be between $200 million and $250 million. This strengthening will be accomplished by the Company's actuaries incorporating explicitly agreed upon margins into its existing assumptions for annual statutory reserve adequacy testing. These actions will add margins to Unum America's best estimate assumptions. The Company plans to fund the additional statutory reserves with expected cash flows. The Company's long-term care reserves and financial results reported under generally accepted accounting principles are not affected by the MBOI's examination conclusion.
The Company has suspended its current share purchase authorization and will not repurchase shares in 2020. Additionally, the Company intends to continue to pay its common stock dividend at the current rate.
General Observations
Language similar to that quoted above is in Unum's 10-Q report for the quarter ended March 31, 2020, as filed with the SEC on May 5, 2020. The MBOI examination of Unum is scheduled to close at the end of the second quarter of 2020. Therefore, the examination report is not yet publicly available. In the meantime, I felt that readers would be interested in this development relating to Unum's LTC insurance reserves.

Available Material
I am offering a complimentary three-page PDF containing Unum's 8-K report. Email and ask for the May 2020 package about the Unum 8-K report.


Wednesday, May 6, 2020

No. 369: Scott Witt's Views on Indexed Universal Life—A Follow-Up

Scott Witt, FSA, MAAA, is a fee-only insurance advisor and a Financial Services Affiliate member of the National Association of Personal Financial Advisors. In No. 363 (April 8, 2020), I discussed briefly his views on indexed universal life policies and offered a complimentary copy of his seven-page article. Witt received many comments on his article, and decided to write a five-page follow-up. His original article and his follow-up are available here.


Friday, May 1, 2020

No. 368: Senior Health Insurance Company of Pennsylvania—The Proposed Plan of Rehabilitation

Senior Health Insurance Company of Pennsylvania (SHIP) has been running off the long-term care (LTC) insurance business of Conseco Senior Health Insurance Company (CSHI) since 2008. At that time, CSHI transferred the assets and liabilities of its LTC insurance business to create SHIP. CSHI had been running off its LTC insurance business (not selling any new LTC insurance policies) for five years prior to the transfer.

For many years after 2008, SHIP's financial condition worsened, often showing risk-based capital (RBC) levels calling for formal actions by the Pennsylvania Insurance Department (Department), SHIP's primary regulator. The Department took no formal regulatory actions.

In its statutory financial statement for the year ended December 31, 2018, SHIP reported a deficit (negative surplus). Its liabilities exceeded its assets by $447 million. Still the Department took no formal regulatory action. The deficit grew to $462 million at the end of the first quarter of 2019, to $477 million at the end of the second quarter, and to $524 million at the end of the third quarter. Still the Department took no formal regulatory action.

I believe that SHIP did not file a statutory financial statement for the year ended December 31, 2019. However, according to the preliminary plan of rehabilitation (Plan) discussed in this post, SHIP's deficit at the end of 2019 was $916 million.

The Application
On January 23, 2020, Jessica E. Altman, the Pennsylvania Insurance Commissioner (Commissioner), applied to the Commonwealth Court of Pennsylvania for an order placing SHIP in rehabilitation. Here, without citations, is part of the introduction to the application:
SHIP has committed one or more acts which constitute grounds for rehabilitation. Specifically, SHIP's most recent annual statement demonstrates that the company is statutorily insolvent. Additionally, SHIP's most recent risk-based capital ("RBC") report indicates that the company's total adjusted capital is substantially below its mandatory control level RBC, therefore triggering a "mandatory control level event." Finally, the Trustees of the Senior Health Care Oversight Trust [which oversees SHIP] and SHIP's directors have consented in a signed writing to the company being placed in rehabilitation and have waived a hearing.
The Order
On January 29, President Judge Mary Hannah Leavitt of the Commonwealth Court of Pennsylvania issued an order approving the application because "rehabilitation has been requested by and consented to by SHIP's board of directors and the trustees of the Senior Health Care Oversight Trust." The judge appointed the Commissioner as rehabilitator, said the Commissioner may appoint a special deputy rehabilitator, and ordered the filing of a Plan on or before April 22, 2020. The Commissioner appointed Patrick H. Cantillo as special deputy rehabilitator, and engaged a group of consultants to develop the Plan. I wrote about these developments in No. 352 (January 29, 2020) and No. 354 (February 10, 2020). (IN RE: Senior Health Insurance Company of Pennsylvania In Rehabilitation, Commonwealth Court of Pennsylvania, No. 1 SHIP 2020.)

The Plan
On April 22, Cantillo filed in court a single-spaced 108-page Plan. Here are the components of the Plan, with the number of pages shown in parentheses (the full Plan is in the complimentary May 2020 package offered at the end of this post):
Table of Contents (5)
How to Provide Comments and Objections (1)
Important Notice (3)
Basic Information about the Plan (6 pages)
General Plan Details (18)
Details of Phase One of the Plan (16)
Details of Phase Two of the Plan (22)
Phase Three (1)
Other Matters (22)
Glossary (14)
The "Basic Information about the Plan" includes a "Summary Description of the Plan." Here is the first paragraph of the description:
The following description of the Plan is intended to provide policyholders the basic information required for them to make the required election(s) if the Plan is implemented as proposed. To that extent, it should also enable policyholders to decide what if any comments or formal objections they may offer in response to the request for approval of the Plan. Much more detail about the Plan and related matters is provided in the sections that follow.
The Plan has three phases. In Phase One, policies not in nonforfeiture status will be evaluated and policyholders will be offered options. In Phase Two, policyholders may be offered additional options. In Phase Three, SHIP will complete the run-off of policies. Policyholders are divided into various active and disabled categories, and are offered various options. The Plan provides some illustrations, but each of them carries this warning language:
This illustration is provided solely for the purpose of demonstrating how premiums and benefits under each option in the proposed rehabilitation plan compare to each other. Every policy is different and produces different results.
General Observations
The Plan is incredibly complex. Cantillo and those working with him obviously poured an enormous amount of effort into its preparation.

The Plan involves options under which policyholders may choose to pay increased premiums and/or receive reduced benefits, and those already on claim may choose to receive reduced benefits. Some of those premium increases and benefit reductions are likely to be large.

I do not know how Judge Leavitt will handle the Plan. However, I think the Plan will fail. Premium-paying policyholders may drop out in droves when they see the magnitude of the premium increases and benefit reductions. I hope the judge will reject the Plan and order SHIP into liquidation. That action would bring the state guaranty associations into the picture, along with assessments paid by other insurance companies. In short, I think liquidation would make it possible to lower the size of the premium increases and lower the size of the benefit reductions.

The Pandemic
While the Plan was being prepared, the COVID-19 pandemic was and still is wreaking havoc on the United States and the rest of the world. Moreover, the pandemic is having its greatest impact on the elderly. Many of them are in nursing homes, assisted living facilities, homes for the aged, retirement communities, facilities for elderly veterans, and other facilities offering long-term care services.

A paragraph entitled "Timeline" appears on page 15 of the 108-page PDF of the Plan. The paragraph talks about affording policyholders and other interested parties an opportunity to comment on the Plan. In that paragraph is the following sentence, which alludes to the pandemic:
Because of the extraordinary circumstances facing our nation, the Rehabilitator will ask the Court to provide policyholders and others a prolonged period of time to review the Plan before such comments are due.
To my knowledge, that is the only comment in the Plan about the pandemic. However, it is possible that I missed other comments.

It is morbid to contemplate how the impact of surging numbers of deaths among the elderly may affect the LTC insurance business. Such a surge would eliminate many claim payments, and therefore might improve the financial condition of SHIP and other LTC insurance companies.

Available Material
In No. 352 I offered a 27-page complimentary January 2020 package about SHIP. In No. 354 I offered a 23-page complimentary February 2020 package about SHIP. Those packages remain available.

Now I am offering a 108-page complimentary May 2020 package containing the full Plan. Email and ask for the May 2020 package about the SHIP Rehabilitation Plan.