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March 24, 2008

Structured Settlement Wiki

S2KM has published a structured settlement wiki.

S2KM's objectives and purposes:

  • Publish a wiki for structured settlement professionals and stakeholders.
  • Feature industry issues and knowledge leaders in web 2.0 formats.
  • Encourage industry practice communities and networks to use wikis.
  • Better integrate S2KM's publications with other authors, publishers and publications.

S2KM will continue to publish S2KM's blog "Beyond Structured Settlements" including future posts announcing structured settlement wiki updates.

December 20, 2007

SSPA Non-Contravention Standards

State courts play an important "gatekeeper" role for structured settlement factoring transactions. IRC section 5891 imposes a 40 percent federal excise tax if a factoring transaction does not receive required state court approval. State structured settlement protection acts (SSPAs) make factoring transactions ineffective unless such transfers receive court approval.

When evaluating a proposed transfer, state courts must address these issues:

  • Payee's best interest - taking into account the welfare of the payee's dependents;
  • Compliance with SSPA requirements - including notice, disclosure and independent professional advice; and
  • Non-contravention of applicable laws - including other statutes and court orders.

In the lead article of its Fall 2007 edition of "Structured Settlement Insights", Pullman & Comley summarizes growing judicial authority for what constitutes non-contravention of a statute or order - as well as the related issue of what information is required for a court to make a non-contravention finding.  The article distinguishes these types of non-contravention issues from contractual anti-assignment restrictions.

The Pullman & Comley newsletter article highlights:

  • New Pennsylvania Rule 229.2.  Among other provisions, this judicial rule requires the "transferee" (factoring company attorney) to certify to the court "to the best of his or her knowledge, information and belief, formed after reasonable inquiry, that the transfer will comply with the requirements of the [Pennsylvania] Act and will not contravene any other applicable federal or state statute or regulation or the order of any court or administrative authority."
  • Different standards established by courts in other states including Connecticut, Illinois, Indiana and Florida.
  • Workers compensation laws.  Although most state workers compensation statutes prohibit or restrict assignments, both IRC sections 5891 and 130 reference and incorporate workers compensation cases.

For additional information:

October 28, 2007

Unauthorized Practice of Law - 1

Mark Wahlstrom has written a blog post titled "Structured settlement brokers drafting settlement documents. Are you guys nuts?" that highlights an important and controversial industry issue.

Mark's question: does a routine structured settlement business practice (life insurance agents drafting personal injury settlement documents) represent the unauthorized practice of law?

Mark, a life insurance agent and structured settlement commentator, answers yes: 

  • Current structured settlement business practices promote the unauthorized practice of law including non-lawyers drafting structured settlement legal documents. 
  • Some structured settlement intermediaries (aka "brokers" or "agents") regularly provide such legal services without appropriate licenses or qualifications for:
    • Plaintiff attorneys;
    • Liability insurers;
    • Defense attorneys.

Mark's blog post:

  • Describes how some liability insurer claim managers pressure structured settlement brokers to provide unauthorized legal services;
  • Does not address this corollary question: do these same structured settlement legal practices also represent malpractice by plaintiff and defense attorneys?

For additional information about structured settlements and the unauthorized practice of law, see:

  • Related S2KM blog posts:
    • NSSTA - NSSTA's 2007 Fall Meeting featured an educational program for NSSTA members about structured settlement documentation (subtitled: "an analysis of the legal and practical issues and problems") without any discussion concerning the unauthorized practice of law by life insurance agents and their employees.
    • AAJ - This author believes the American Association for Justice (plaintiff attorneys) has been negligent for not providing its members with updated education about:
      • Structured settlement laws and legal issues;
      • Related professional responsibilities and potential liabilities.
    • ASNP - This author also believes structured settlement recipients will benefit if and when special needs attorneys expand their professional knowledge to address structured settlement legal issues including the proper drafting of personal injury settlement documents.
  • Related S2KM wikis:
  • Related hardcopy resources - "Structured Settlements and Periodic Payment Judgments" including separate chapters for plaintiff and defense attorneys as well as updated information about structured settlements and:
    • The secondary annuity market - including IRC section 5891 and the state structured settlement protection statutes;
    • Government benefits and structured settlements - including the Medicare Secondary Payor statute; special needs trusts; and the Deficit Reduction Act of 2005.
  • John Darer's defense and explanation of traditional structured settlement business practices related to the unauthorized practice of law titled: "Nuts, Protein, Cholesterol, Fiber and your Settlement Documents." 

Postscript - October 30, 2007

This post was originally published Sunday evening October 28, 2007.  Additional edits were added Monday morning October 29, 2007. The original post appeared unedited for approximately eight hours Sunday night. S2KM's edits included changing S2KM’s interpretation of John Darer’s October 27, 2007 blog post titled “Nuts..Protein, Cholesterol, Fiber and Your Settlement Documents”.  S2KM’s original post characterized John’s post as promoting and condoning current structured settlement business practices.   S2KM’s edited post (above) substitutes the words “defense and explanation”.  Both the original and final versions include links to John Darer’s blog post and recommend that readers of S2KM's blog review Mark Wahlstrom's original post as well as John Darer's post.
 

October 20, 2007

NASP 2007 Annual Meeting - 1

The National Association of Settlement Purchasers (NASP) hosted its 2007 Annual Meeting October 18-19 at the Grand Hyatt in Washington, D.C.   This author was privileged to participate. 

S2KM's reporting about NASP's 2007 Annual Meeting begins with this blog post and this wiki which summarizes NASP's 2007 Educational Program -  a learning conversation about "The Structured Settlement Market". 

For prior S2KM commentary about NASP, see this S2KM blog post.

September 03, 2007

Structured Settlement Educational Programs - Fall 2007

Fall of 2007 features many association meetings and educational events that should interest structured settlement attorneys, other structured settlement professionals and stakeholders.

This S2KM blog post:

  • Highlights these Fall 2007 meetings and educational events; and
  • Features related commentary and analysis from S2KM and structured settlement knowledge leaders.

National Structured Settlement Trade Association (NSSTA)

Society of Settlement Planners (SSP)

National Association of Settlement Purchasers (NASP)

National Academy of Elder Law Attorneys (NAELA)

Special Needs Planners

National Alliance of Medicare Set-Aside Professionals (NAMSAP)

American Association for Justice (AAJ)

Additional Educational Resources - for structured settlement attorneys, other professionals and stakeholders:

August 17, 2007

Single Claimant 468B Settlement Funds

Robert W. Wood, the pre-eminent authority on "Taxation of Damage Awards and Settlement Payments", analyses Single Claimant 468B Settlement Funds in his first audio podcast interview  with Ned Arthur and S2KM Limited. Rob, a partner at Wood & Porter, is a prolific and highly-respected author and commentator whose specialties include structured settlements.

The Wood & Porter website features a comprehensive listing of Rob's publications - books and articles.

Rob's first audio podcast with S2KM Limited focuses on public policy arguments for and against Single Claimant 468B Settlement Funds. Rob's audio podcast is featured on S2KM's blog (Podcast Tape 8) and S2KM's Structured Settlement Public Policy Wiki.

IRC section 468B was enacted as part of the Tax Reform Act of 1986. IRC section 468B created important settlement funding options for plaintiffs and their attorneys.  The controversial issue is whether IRC section 468B applies to single claimant cases.  The U.S. Treasury Department is currently evaluating the Single Claimant 468B issue. 

What are the stakes for structured settlement stakeholders?  There are many including who (plaintiff or defendant) controls structured settlement decisions and who (plaintiff or defense annuity agent) controls annuity commissions.

Rob Wood is the expert on IRC section 468B Settlement Fund options and issues including Single Claimant 468B Settlement Funds.

Rob's audio podcast interview:

  • Outlines IRC section 468B's history and public policy;
  • Initiates a strategic online conversation about Single Claimant 468B Funds.

In a separate audio podcast interview with Ned Arthur (S2KM Podcast Tape 9), Rob analyzes structured attorney fees.

August 07, 2007

NAELA Annuity Policy White Paper

The National Academy of Elder Law Attorneys (NAELA) is an important trade association (for the structured settlement industry) of which this author is a relatively recent (2006) member. Among its strengths, NAELA sollicits and sponsors legal scholarship addressing a wide variety of topics.  This legal scholarship is primarily directed toward NAELA's approximately 5000 elder law attorney members nationally including hundreds of special needs attorneys.

Unfortunately for the structured settlement industry (and also NAELA members), NAELA's legal scholarship does not include structured settlements.

The most recent example of this scholarly omission (or at least neglect) is NAELA's Annuity Policy White Paper ("Annuity Policy: Consumer Protection Issues and Public Policy Recommendations") prepared by the NAELA Annuity Task Force and published in the hardcopy NAELA Journal Volume 3; 2007; Number 1.

Members of NAELA's Annuity Task Force are identified in the White Paper as: Michael A. Flory, Esq., Chairman, Michael J. McGuire, Esq., Donald M. McHugh, Esq., John B. Payne, Esq., and Shirley B. Whitenack, Esq. - "with special thanks to Donna Rainville".

NAELA's Annuity White Paper contains two references to structured settlements with no additional reference to or discussion of any structured settlement annuity laws or legal issues.

  • The first reference to "structured settlements" appears in a section titled "Immediate v. Deferred Annuities": "Immediate annuities (lifetime, fixed term and minimum term) are useful to supplement income and quite often settlements in lawsuits are annuitized, or 'structured' ".
  • The second reference to "structured settlements" appears in a section titled " 'Noncommutable' and 'Non-assignable' Annuities" related to a 2005 New Jersey Medicaid case, "Estate of F.K. v. Division of Medical Assistance and Health Services": "The appellate court held that the burden of proof of a secondary market is on the state agency, not the applicant, and the proofs submitted by state agency of a secondary market (i.e. internet websites advertising sales of structured settlements and lottery winnings) did not meet the burden of proof."

Otherwise, the NAELA Annuity White Paper (about public policy and consumer protection) makes no direct or indirect reference to structured settlement annuities or structured settlement laws - including the 46 state structured settlement protection statutes.

From a structured settlement perspective, here are recommendations for NAELA's Annuity Task Force related to specific sections of their current White Paper.

Purpose of the White Paper

  • Include references to structured settlements, personal injury settlement planning and special needs planning - all of which involve seniors and annuities.
  • Provide more thorough analysis of the secondary annuity markets including the secondary structured settlement annuity market.
  • Be more specific about identifying
    • the federal and state laws related to annuities - including structured settlement annuities and the structured settlement secondary market.
    • existing public policy related to annuities - including structured settlement annuities and the structured settlement secondary market.
  • Be more specific and expansive about the public policy and legal conflicts that currently exist between tax laws and public policy and government benefit laws and public policy
  • Address annuities (including structured settlement annuities) within the context of these laws and public policies:
    • Tax law;
    • Government benefit law;
    • Consumer protection law;
  • Include structured settlement annuities and the secondary annuity markets among the NAELA White Paper's recommendations.

Elements of the White Paper - Each of the following elements should address structured settlement annuities and the secondary annuity markets:

  • Understanding Annuities
  • Medicaid Planning with Annuities
  • Consumer Protection Issues

Understanding Annuities - This section should include additional specific subsections addressing:

  • Structured settlement annuities
  • Secondary market for annuities
  • Taxation of annuities - including structured settlement annuities
  • Lifetime annuities - including substandard age ratings and some discussion of "actuarially sound"  related to lifetime annuities.
  • Financial ratings and rating agencies - how can a White Paper about annuities not address financial ratings and financial rating agencies when discussing "The Risk Factor" of annuities?

Medicaid Planning with Annuities

  • Why not identify or equate this section with special needs planning and personal injury settlement planning.
  • Differentiate and define the two planning professions and, in that context, address structured settlement annuities and the secondary insurance markets.

Annuity Laws -include some reference to existing structured settlement annuity laws:

  • Federal tax laws
  • State structured settlement protection statutes
  • State periodic payment of judgment statutes

Consumer Protection Issues

  • Include some reference to federal structured settlement tax laws and state structured settlement protection statutes.
  • Identify structured settlement legislation as one example of existing consumer protection for annuities.

Structured settlement laws and legal issues have slipped between the intellectual cracks of elder law and special needs law. The NAELA Annuity Policy White Paper represents a continuing example of this unfortunate neglect. NAELA possesses incredible collaborative knowledge about annuities - some of that knowledge should be directed toward educating NAELA members about structured settlement annuities and the secondary insurance markets.

Contact NAELA for copies of NAELA's Annuity Policy White Paper.

For prior, related S2KM's blog posts, see:

June 29, 2007

S2KM Mid-2007 Structured Settlement Report

As Fourth of July 2007 quickly approaches, structured settlement stakeholder associations are re-organizing under their 2007 leadership.  These stakeholder associations include:

  • National Structured Settlement Trade Association (NSSTA).
  • Society of Settlement Planners (SSP)
  • American Association for Justice (AAJ)
  • National Association of Trial Lawyer Executives (NATLE)
  • National Academy of Elder Law Attorneys (NAELA)
  • Academy of Special Needs Planners (ASNP)
  • Special Needs Alliance (SNA)
  • National Alliance of Medicare Set-aside Professionals (NAMSAP)
  • National Association of Settlement Purchasers (NASP)

As  unsollicited input to these associations, S2KM offers this mid-year 2007 summary of important structured settlement legal developments. 

S2KM's Podcast 3 (accessible from S2KM's blog courtesy of Truffle Media Networks) provides a related audio summary.

Mid-2007 Structured Settlement Legal Developments

  • Potential $600 Million Shortfall at Executive Life of New York - "Drinker Biddle's Structured Settlement Update" provided an early Internet analysis of this story.  NSSTA has reacted swiftly by announcing an "ELNY Task Force".  In a June 29, 2007 written message to NSSTA members, President Henry Strong also announced:
    • Two-time NSSTA President Len Blonder will Chair NSSTA's ELNY Task Force;   
    • NSSTA has already met directly with the New York Liquidation Bureau; and   
    • NSSTA has initiated "productive discussions" with the American Counsel of Life Insurers (ACLI).
  • Social Security POMS to Address Structured Settlements - S2KM first reported this announcement by the SSA's Ken Brown in an April 9, 2007 blog post titled: "Academy of Special Needs Planners".  See these S2KM blog posts for additional background and analysis:
  • First Primary Market Disclosure Case - "Pullman & Comley's Structured Settlement Insights" provided the first Internet analysis of Joseph v. The City of New York which Pullman & Comley characterizes as ""the first court opinion to analyze the requirements in structured settlement protection acts that disclosures be made when negotiating a structured settlement."  
  • DOJ Sovereign Immunity Defense Voids Transfers - see "Drinker Biddle's Structured Settlement Update" for analysis of two DOJ sovereign immunity cases: Transamerica v. Settlement Capital and Continental Casualty v. United States.
  • New Pennsylvania Rule 229.2 - S2KM reported and analyzed this change to the Pennsylvania Structured Settlement Protection Act in a June 27, 2007 blog post.
  • Rapid v. Symetra - S2KM reported this case in a June 19, 2007 blog post.  The case confirms the general rule that, even following the enactment of IRC Section 5891, courts will enforce a clear and explicit anti-assignment provision in structured settlement agreements provided the interested parties timely object after having been given notice and an opportunity to be heard. For additional S2KM reporting about Rapid, see: CNA v. Rapid Settlements.

Check back for continuing S2KM blog and podcast reports and commentary covering important structured settlement issues and events - including exclusive S2KM reports from the 2007 AAJ Annual Convention July 13-18, 2007 in Chicago. 

For previous S2KM analysis of the structured settlement industry, see:

June 26, 2007

New Pennsylvania Rule 229.2

The Pennsylvania Supreme Court has promulgated a new state Rule of Civil Procedure 229.2 (New Rule 229.2) setting additional requirements under Pennsylvania's Structured Settlement Protection Act which was enacted in 2000. 

New Rule 229.2 is titled "Petition to Transfer Structured Settlement Payment Rights"

According to the New Rule 229.2 statement issued by R. Stanton Wettick, Jr., an Allegheny County Judge who serves as Chairman of the Pennsylvania Civil Procedural Rules Committee: "New Rule 229.2 is intended to provide the additional information necessary for a trial court to determine whether a petition to transfer structured settlement payment rights meets the best interest standard".

Highlights of New Rule 229.2:

  • The transfer petition must be filed in the county where the payee (original recipient) is domiciled.
  • Both the payee and the transferee (factoring company) are parties to the petition.
  • The transfer petition must be "verified" by the transferee and include:
    • Payment provisions and payment rights the payee wants to transfer;
    • Net amount payable;
    • Effective interest rate;
    • 4 attachments - in addition to any other documents required to support the findings:
      • Payee's Affidavit in Support of Petition - This affidavit requires information about the payee's income, dependents, prior transfers, and intended use of funds.
      • Initial Order of Court - In this order, the judge provides an initial review and either:
        • Sets a hearing date for the transfer petition; or
        • Denies the petition without a hearing in which case:
          • The judge must state reasons for the denial; and
          • The payee may file an amended petition.         
      • Certification by transferee attorney "representing to the best of his or her knowledge, information and belief, formed after reasonable inquiry, that the transfer will comply with the requirements of the Act and will not contravene any other applicable federal or state statute or regulation or order of any court or administrative authority."
      • A Final Order Granting the Petition
  • The transferee is required to give notice for final hearing date to:
    • Payees
    • Structured settlement obligor
    • Annuity issuer
    • Payee's spouse
    • Any person who receives alimony or child support from the payee

The initial reactions from industry experts to New Rule 229.2 generally have been positive.  The primary criticism from factoring companies appears to be that New Rule 229.2 does not require a hearing in every case.

For additional information about state protection laws, see Section 16.04 ("Structured Settlement Protections Acts") in "Structured Settlements and Periodic Payment Judgments".

June 19, 2007

Rapid v. Symetra

A recent, unpublished legal decision (Rapid Settlements v. Symetra Life Insurance Company) from the California Court of Appeals (Fourth Appellate District; Division Two) confirms the general rule that, even following the enactment of IRC Section 5891, courts will enforce a clear and explicit anti-assignment provision in structured settlement agreements provided the interested parties timely object after having been given notice and an opportunity to be heard. In this case, those interested parties were Symetra Assigned Benefits Service Company (SABSCO) and Symetra Life Insurance Company (Symetra Life) - collectively referred to as Symetra.

The decision over-ruled the trial court which had earlier approved the transfer to Rapid of $40,000, one-third of a $120,000 future periodic payment due to claimant Randy L. Griffin pursuant to a structured settlement agreement (SSA) signed in September 1993. In appealing the order approving the transfer, Symetra successfully contended the order should be reversed and the transfer declared void because the $40,000 payment was not assignable under the terms of the SSA. Based upon its ruling in favor of Symetra, the appellate court did not consider Symetra's additional contention that the transfer failed to comply with the requirements of California's structured settlement protection act.

When an interested party objects to the assignment of structured settlement payment rights, there are two basic legal questions: 1) does the structured settlement agreement clearly forbid assignment?  And if so, 2) does state law override a contractual anti-assignment provision?

The appellate ruling in this case is consistent with the majority of prior cases addressing these issues. It rejected the trial court's decision which "relied on the 'general policy favoring the free alienation of contract rights' to payment, as opposed to contractual duties, and indicated that the non-assignment provision appeared to be 'solely for tax purposes.' "

What makes this decision interesting, and controversial, is Rapid's argument that Symetra had itself actively solicited the assignment of Griffin's payment rights despite the anti-assignment language in the structured settlement agreement and that this "establishes that the practical interpretation of the contract, as evidenced by Symetra's words, acts and conduct, is that Griffin's payment rights are in fact assignable and Symetra has objected on a purely competitive basis."

The California appellate court disagreed with Rapid. It reasoned: "...under California law it is clear that non-assignment provisions are for the benefit of the obligor, and only the obligor has the right to waive the provisions...As the obligor, Symetra may choose to enforce or waive the non-assignment provisions of the SSA. That it chose not to waive the provisions in favor of Rapid does not mean Symetra may not waive the provision in favor of itself or an affiliate entity."

Therefore, at least in California, when structured settlement documentation includes clear and unambiguous anti-assignment provisions, an annuity provider such as Symetra appears to have the power: 1) to prevent a proposed transfer; and 2) to restrict a transfer to a specific factoring company including an affiliated factoring company.

This result is similar to a defense insurance company conditioning a structured settlement upon the selection of its affiliated annuity provider.

Both practices are anti-competitive and should be avoided.

For current and future cases, all structured settlement participants should review the settlement language in NSSTA's revised Model Qualified Assignment (MQA) Agreement - paragraph 7 (Acceleration, Transfer of Payment Rights) and the related footnote.

For additional information about anti-assignment language in structured settlements, see "Structured Settlements and Periodic Payment Judgments" - Chapter 16 ("Transfers of Structured Settlement Payment Rights").

For additional S2KM blog posts about factoring, see: