Review and Claims Processing Audit Reports
initiated an exhaustive program of audits of claims processing
and decision making by both its own member companies and other
organizations, involving internationally recognized accounting
firms. These audits varied in type. Categories of those entities
companies that signed the Memorandum of Understanding (MoU);
Generali Trust Fund (subcontractor for processing Generali
claims from April 2001 to November 2004);
representative German insurance companies included in the
settlement agreement between ICHEIC, the German Foundation
"Remembrance, Responsibility and Future" and the German Insurance
Association (GDV), called the "BaFin Audits"; and
8A humanitarian claims process, subcontracted to the Conference
for Material Claims Against Germany, Inc. (Claims Conference).
stated that the Insurers which are a party to the MoU must
adhere to proscribed objectives and processing standards and
that these standards be subjected to audit by an internationally
recognized accounting firm.
which are parties to the MoU are Allianz AG of Germany, Assicurazioni
Generali S.p.A. ("Generali") of Italy, AXA S.A. of France,
Winterthur Life Insurance Company of Switzerland and Zurich
Insurance Company, also of Switzerland. Note that Winterthur
was acquired by AXA after the claims handling process was
developed five broad 'Audit Standards', or performance standards,
against which the Insurers' performance could be audited.
These Standards are as follows:
relevant archive sites
and secure relevant records
1 - 4 relate to finding, collecting, safeguarding and accessibility
of records from the relevant period of 1920 - 1945. Standard
5 relates to the companies' processes for receiving and recording
incoming claims and inquiries and searching their available
records for possible matches. Standard 5 also covers processing
the claims and issuing either a denial or offer letter to
the claimant, complete with proper notifications and relevant
documents supporting their conclusion.
take into account the particular circumstances of each Insurer
nearly 60 years after the end of the Holocaust era.
of the compliance process, the Insurers were required to prepare
a Management Report describing the work undertaken to comply
with the ICHEIC Standards 1 to 5. The establishment of accessible
records and formation of a processing system under these standards
were then audited as a "Stage 1" audit. The actual handling
of claims and inquiries using the records and processing procedures
approved under the Stage 1 audit was then audited under "Stage
2" of the audit process.
1 audits were carried out in the first instance by audit firms
appointed by the Insurers. These firms submitted a Compliance
Report, with an attached copy of the Management Report, relating
to each company or group. ICHEIC then appointed a second audit
firm to carry out a Peer Review audit of each Compliance audit.
The Peer Review auditors also carried out their own limited
additional testing of each Insurer's records. All of the audit
firms, Compliance and Peer Review, have extensive international
Compliance and Peer Review-were submitted in final draft form
to an ICHEIC committee empowered by the ICHEIC Commissioners
to oversee the audit process (the Audit Mandate Support Group,
or AMSG, which included representatives of regulators, Jewish
organizations, and companies) which considered the findings
at debrief meetings. At these meetings, the Insurers and audit
firms presented their reports for discussion and review by
the committee. Any additional work requested by the AMSG was
carried out by the companies and/or audit firms prior to the
finalization of their reports.
1 reports can be seen by clicking on Stage
1 Audits. There is a Peer Review Report related to
each company or group (1), to which are attached a Compliance
Report and Management Report (including any supplements or
addenda). The Peer Review Reports can be identified from their
1 reports relating to a company or group - Peer Review, Compliance
and Management - must be considered in their totality, not
read in isolation, in order to gain a complete and clear understanding
of the process.
2 audits have been carried out by firms appointed directly
by ICHEIC. Stage 2 audit reports are documents separate and
distinct from the Stage 1 reports, and are accessible as such.
There are no Management or Compliance reports in the Stage
2 process. Click on Stage 2 Audits
to see the Stage 2 audit reports.
Insurer, audits relate either to the entire company or group,
or to individual subsidiaries or sub-groups. In totality,
15 entities were subject to Stage 1 audits and 12 entities
subject to Stage 2 audits. Fewer entities were subject to
Stage 2 because (1) a sub-set of Belgian companies were eliminated
since their claims were handled by a government commission,
and (2) some company groupings changed between Stages 1 and
Trust Fund Audit
between ICHEIC, Assicurazioni Generali S.p.A. ("Generali")
and The Generali Fund in Memory of the Generali Insured in
East and Central Europe Who Perished in The Holocaust (the
"Generali Trust Fund" or "GTF"), the GTF carried out processing
of Generali claims between April 2001 and November 30, 2004.
ICHEIC terminated this agreement effective November 30, 2004.
Thereafter, claims were handled by Generali itself. ICHEIC
commissioned Deloitte to carry out an audit of GTF's claims
handling procedures and processing. A copy of the audit report
can be seen by clicking on GTF Audit
in the Audit Report menu.
Audits of German non-MoU Insurers
Federal Financial Supervisory Authority (Bundesanstalt für
Finanzdienstleistungsaufsicht, or "BaFin"), which regulates
insurance companies in Germany, with the assistance of ICHEIC
observers, carried out audits of ten German insurance companies,
selected by mutual consent, which were not members of ICHEIC,
in accordance with the terms of the agreement between the
Foundation "Remembrance, Responsibility and Future", ICHEIC
and the German Insurance Association (Gesamtverband der Deutschen
Versicherungswirtschaft e.V. or "GDV". German companies were
required to comply with the agreement (2) which incorporated
claims handling requirements similar to ICHEIC's five Standards.
The BaFin audits covered the companies' compliance with those
requirements. A copy of the BaFin audit report can be seen
by clicking on BaFin Audits in the
Audit Report menu.
of claims qualifying under Section 8A of ICHEIC's MoU was
carried out by ICHEIC, with the actual processing subcontracted
to the Conference on Jewish Material Claims against Germany,
Inc, (the "Claims Conference"). ICHEIC commissioned McGladrey
& Pullen, LLP to perform an audit of this process. A copy
of the audit report of 8A claims processing can be seen by
clicking on 8A Audits in the Audit Report menu.
the case of Zurich, there are two Compliance Reports, and
in the case of Generali, there are often supplemental reports,
depending on the relevant group or company.
copy of the agreement can be found under ICHEIC Agreements.