anti-fraud plan

Ashar Group takes a proactive approach to preventing insurance fraud when related to the Life Settlement market. Employees of the Ashar Group are trained to detect possible fraud in both the application for the original policy issuance and for the Life Settlement. We strongly support the need for an effective anti-fraud program and encourage others to join in our efforts.

The purpose of the Ashar Group, LLC’s Anti-Fraud Plan is to establish procedures to detect, investigate, and report suspected fraudulent activity in compliance with Section 626.99278 of the Florida Statutes.

Section 1. PROCEDURES FOR DETECTING AND INVESTIGATING POSSIBLE FRAUDULENT INSURANCE ACTS AND PROCEDURES FOR RESOLVING MATERIAL INCONSISTENCIES BETWEEN MEDICAL RECORDS AND INSURANCE APPLICATIONS

Ashar Group, LLC requires its applicants to provide a completed Viatical settlement application. This application has been approved by the State of Florida Office Of Insurance Regulation on April 7, 2005, file #VIA 05-03392; updated February 3, 2010, file # VIA 09-23849.

The following anti-fraud statement is prominently displayed on the application:

Fraud Warning: Any person who knowingly presents false information in an application for insurance or a viatical/life settlement contract is guilty of a crime & may be subject to fines & confinement in prison.

The Ashar Group, LLC application is then reviewed for possible inconsistencies. This review will include but not be limited to comparing the diagnosis date of the primary illness to the effective date of the life insurance coverage.

The following information is then requested for those potential/viable viatical/life settlement client’s files:

  • A copy of the client’s medical records.
  • A verification of coverage detailing insurance information.

Upon reviewing these items, Ashar Group, LLC will then compare and review them for possible inconsistencies. In the event any of these procedures seems to suggest fraudulent activity, Ashar Group, LLC will then report such activity to the Division of Insurance Fraud, Florida Department of Financial Services, 200 East Gaines Street, Tallahassee, FL 32399-0324.

Section 2.PROCEDURES FOR MANDATORY REPORTING OF POSSIBLE FRAUDULENT ACTS TO THE DIVISION OF INSURANCE FRAUD

In the event a material inconsistency cannot be resolved, the President, Executive Vice President and/or Senior Vice President shall determine if the file should be reported to the Division of Fraud.

Suspected fraudulent activity in connection with a Florida Viatical settlement transaction will be reported to the Division of Insurance Fraud, Florida Department of Financial Services, 200 East Gaines Street, Tallahassee, Fl 32399-0324.

Upon request, Ashar Group, LLC will provide copies of documents that support the belief that fraud may have taken place or attach copies of those documents to the Department of Insurance Suspected Fraud Referral Form.

Section 3.

All of Ashar Group LLC’s brokers will be instructed by the President, Executive Vice President and/or Senior Vice President on the importance of detecting, eliminating and reporting insurance fraud.

As a method of prevention, brokers will provide an approved application that informs potential new clients of the legal consequences of committing fraudulent acts.

Ashar Group, LLC will provide an approved application to inform each potential new client that their file will be thoroughly reviewed by both Ashar Group, LLC and any other provider that Ashar Group, LLC may send the file to, and that false information in an application for a life insurance policy constitutes fraud and will be reported to the Department of Financial Services.

Each broker will receive a copy of this document and verify its receipt by signature.

Brokers will receive and review bulletins and publications dealing with fraud as they are made available from the Department of Financial Services and other relevant industry organizations.

Section 4.

The individual processors are responsible for reviewing the files submitted by their respective clients for indications of fraud.

If a broker or processor suspects fraud in any particular file, then they are to report it to the company’s designated employees who are responsible for reviewing the files and reporting instances of suspected fraud to the Division of Insurance Fraud. These designated employees under the Immunity Provision include:

Jon B. Mendelsohn — CEO

Jason T. Mendelsohn — President