BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2264
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          Date of Hearing:   May 2, 2012

                           ASSEMBLY COMMITTEE ON INSURANCE
                                 Jose Solorio, Chair
                    AB 2264 (Knight) - As Amended:  April 26, 2012
           
          SUBJECT  :   Insurance Fraud Investigators

           SUMMARY  :   Provides civil immunity for private insurance fraud 
          investigators when they report unlawful activity not related to 
          insurance fraud in the course of an investigation.  
          Specifically,  this bill  :  

          1)Requires insurers, and agents authorized to act on the 
            insurer's behalf, to provide, upon request of peace officers 
            employed by specified agencies, any and all useful information 
            regarding unlawful activity unrelated to insurance fraud that 
            is uncovered in the course of an insurance fraud 
            investigation.  

          2)Specifies that insurers, employees of insurers, and agents of 
            an insurer are not subject to civil liability for providing 
            information to an authorized government agency regarding 
            unlawful activity discovered in the course of an insurance 
            fraud investigation.
             
           EXISTING LAW  :

          1)Requires insurers and their agents to provide, upon request of 
            peace officers employed by specified agencies, any and all 
            relevant information regarding insurance fraud including: 
            insurance policy information, payment records, claims history, 
            and information gathered in the course of a fraud 
            investigation.  

          2)Specifies that insurers, employees of insurers, and agents of 
            an insurer are not subject to civil liability for providing 
            information regarding insurance fraud when the information is 
            requested by an authorized government agency.

           FISCAL EFFECT :   Unknown.

           COMMENTS  :   

           1)Purpose  .  According to the author, insurers employ special 








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            investigation units (SIU) to investigate suspected fraud.  
            These individuals collect information and research cases 
            through interviews with all those involved and make a 
            determination if fraud has been committed.  In the course of 
            completing these investigations, SIU personnel may encounter 
            evidence of other types of unlawful activity on the part of 
            the insured or related parties.  Because this activity is not 
            directly related to the potential insurance fraud, SIU's face 
            the threat of lawsuits from defendants in fraud cases alleging 
            defamation of character and other malicious intent if they 
            choose to report these activities to the appropriate 
            authorities.  Although significant and substantive evidence of 
            unlawful activity may be revealed, SIU's often do not report 
            this information to the authorities as a result.

           2)Right of Access.   Policyholders are required by their 
            insurance policy to cooperate with SIU investigators and 
            cannot deny access to SIU investigators in the same fashion 
            they may deny access to peace officers who seek entry without 
            a search warrant.  The bill would have the effect of allowing 
            SIU investigators to gather evidence of suspected unlawful 
            activity that would not be legally accessible by a peace 
            officer.   
                 
            3)Amendments  .  The amendments adopted on April 26, 2012 expand 
            the scope of immunity from civil litigation which the author 
            adopted to address insurer opposition.   

          4)Prior Legislation  .  Assembly Bill 802 (Duvall), introduced in 
            2009 with similar provisions (not the immunity language), 
            passed this committee on a 10-0 vote.  While the bill passed 
            the Assembly, it was never heard in the Senate.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California District Attorneys Association
          San Bernardino County Sheriffs Department

           Opposition 
           
          Consumer Attorneys of California
          Association of California Insurance Companies (unless amended, 
          prior version)








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          Analysis Prepared by  :    Paul Riches / INS. / (916) 319-2086