Insurance Underwriting Vetting Report
How a 500-credit Insurance Underwriting Vetting Report is produced. The frameworks we adopt, the state-regulator boundary we will not pretend to overcome, and the corrections process if we get something wrong.
Overview
An Insurance Underwriting Vetting Report is a paginated, twelve-section due-diligence document on a person (D&O / Key Person / E&O insured) or an entity (Cyber / Property / Liability insured) being underwritten for insurance. It is generated on demand from public registry filings, SEC filings, regulator enforcement records, sanctions lists, breach-notification databases, and the applicant’s own enriched profile. It takes three to five minutes to produce, costs 50 credits (about $20 USD), and is delivered as a shareable HTML report with a printable PDF view.
It is intended for an underwriter at a carrier, MGA, or insurance broker deciding whether to bind, refer to senior underwriter, request additional information, or decline.
The report is not a binding decision. It is a structured presentation of the public record across four NAIC-aligned underwriting axes — identity verification, financial integrity, loss-history signal, governance/control posture — for the underwriter to evaluate themselves in the context of carrier-internal underwriting guidelines.
The Six Frameworks We Adopt
NAIC Underwriting Standards
The U.S. National Association of Insurance Commissioners (NAIC) is the standard-setting body for state insurance regulation. The NAIC’s underwriting model standards inform the four axes that anchor every Insurance Underwriting Vetting Report: identity verification (knowing the applicant), financial integrity (capacity to pay premium + capacity to be a stable insured), loss-history signal (claims experience), and governance / control posture (signals of operational risk). State-level rules layer additional jurisdiction-specific requirements on top of the NAIC baseline.
ICD 203 — Analytic Standards (Office of the Director of National Intelligence)
The U.S. Intelligence Community’s Directive 203 defines nine tradecraft standards: properly described sources, proper expression of uncertainty, distinction between intelligence and assumptions, incorporation of alternative analysis, judgement of consequences, customer-relevant focus, logical argumentation, accurate reflection of source content, and clear language. We treat these as binding for every Insurance Underwriting Vetting Report.
D&O Underwriter Risk Framework
Directors-and-officers liability insurance underwriters at Chubb, AIG, Allianz, Travelers, and the major reinsurers evaluate executives along a multi-axis risk framework before binding policies. The framework emphasises: tenure pattern, Form 4 stock-sale timing relative to material announcements, related-party transactions disclosed in 10-K and proxy filings, prior litigation naming the executive personally, regulatory enforcement actions, board-resignation patterns under stress. Section 5 (Governance / Control Posture) of every Insurance Underwriting Vetting Report applies this framework directly when the line is D&O or Key Person.
UK PHIA Probability Yardstick (UK Defence Intelligence)
The Professional Head of Intelligence Assessment publishes a seven-band probability yardstick — Remote chance (under 5%) / Highly unlikely (10-20%) / Unlikely (25-35%) / Realistic possibility (40-50%) / Likely (55-75%) / Highly likely (80-90%) / Almost certain (over 95%). Every probabilistic claim — loss-frequency inferences, sanctions-exposure projections, stability claims — is expressed using these seven bands paired with an analytical-confidence rating (High / Moderate / Low).
AML/KYC + OFAC Sanctions Compliance
Anti-Money-Laundering and Know-Your-Customer compliance plus OFAC sanctions screening. Section 9 (Sanctions Screening) screens the applicant against publicly-available portions of OFAC SDN, UN Consolidated, EU Financial Sanctions, and UK HMT lists. Sanctions exposure is typically a hard-decline trigger for most carriers; we surface it as such with PHIA confidence.
NIST CSF 2.0 (Cybersecurity Framework)
The National Institute of Standards and Technology Cybersecurity Framework version 2.0 (2024) defines six functions for organisational cybersecurity: GOVERN, IDENTIFY, PROTECT, DETECT, RESPOND, RECOVER. Section 6 (Cyber Security Posture) of every Insurance Underwriting Vetting Report maps the applicant’s observable posture to these six functions when the underwritten line is Cyber, Tech E&O, or any liability with material cyber-component. Where the line is non-cyber-relevant on an individual subject, the section is retained for completeness with a notice.
The Twelve Sections of an Insurance Underwriting Vetting Report
| # | Section | Purpose |
|---|---|---|
| 1 | Executive Summary | Built last. Bind / refer / additional-info / decline recommendation, three "why underwrite" bullets, three "premium-loading factors" bullets. |
| 2 | Underwriting Risk Assessment | Score out of 100 with four sub-scores: identity verification, financial integrity, loss-history signal, governance / control posture. |
| 3 | Identity Verification & Jurisdiction | Entity: legal name, jurisdiction, registered address, regulatory licensing footprint. Individual: full name, residences, professional licensing. |
| 4 | Financial Stability Signals | Entity: revenue stability, capital adequacy, restructurings. Individual: bankruptcies, judgments, liens, license suspensions. |
| 5 | Governance / Control Posture | Entity: board independence, D&O underwriter framework. Individual: track record of decisions in fiduciary roles. |
| 6 | Cyber Security Posture (NIST CSF 2.0) | Six-function mapping. Material on Cyber + Tech-E&O lines; retained-with-notice on non-cyber lines. |
| 7 | Loss History & Claims Pattern | SEC 8-K cybersecurity-incident filings, breach notifications, mass-tort exposure, prior settlements, prior liability events. |
| 8 | Litigation Exposure | Active + closed material litigation, regulatory enforcement actions. |
| 9 | Sanctions Screening | OFAC SDN / UN Consolidated / EU / UK HMT — each cited primary source, PHIA confidence. |
| 10 | Industry-Specific Risk Signals | D&O: securities-class-action history. E&O: malpractice. Cyber: prior breach disclosures. Property/Liability: premises + product-liability + environmental. |
| 11 | Red Flags — Severity-Ranked | HIGH / MEDIUM / LOW aggregate from prior sections. |
| 12 | References & Source Citations | Aggregated audit trail of every URL cited above, deduplicated, grouped by source class (Primary / Authoritative-Secondary / Aggregator / Unverified) per ICD 206 sourcing standards. |
D&O Underwriter Risk Framework — How We Apply It
Directors-and-officers liability insurance pricing is one of the most demanding executive risk-evaluation processes in the U.S. economy. Underwriters at Chubb, AIG, Allianz, Travelers, and the major reinsurance markets evaluate every named officer against a multi-axis framework before binding new D&O policies, raising premiums, or excluding individuals from coverage.
Section 5 (Governance / Control Posture) of every Insurance Underwriting Vetting Report applies this framework along five axes when the underwritten line is D&O or Key Person:
- Compensation pattern. Cash-vs-equity mix where disclosed in proxy filings. Repricing events. Golden-parachute trigger structure. Perks materially above peer median.
- Form 4 timing. Stock sales within the 30-day window before negative material announcements. Cluster patterns of executive selling around predictable events. Pledging or hedging of company stock where company policy bans it.
- Related-party transactions. 10-K and proxy disclosures of business arrangements between the named officer (or their family / affiliated entities) and the company.
- Litigation exposure. Civil suits naming the officer personally as defendant. Securities class actions where the officer is named.
- Regulatory enforcement. SEC, FTC, DOJ, FINRA, state-AG enforcement actions. Wells notices. Consent decrees.
NIST CSF 2.0 — How We Apply It
The NIST Cybersecurity Framework version 2.0 (2024) defines six high-level functions:
- GOVERN — cybersecurity risk-management programme, board-level oversight, written policies, role accountability.
- IDENTIFY — asset and data inventory, third-party-risk programme, regulatory-context mapping.
- PROTECT — access control, encryption, data-at-rest + data-in-motion protections, security training programme.
- DETECT — continuous monitoring, anomaly detection, log-analytics capability.
- RESPOND — incident-response capability, breach playbooks, communications plan.
- RECOVER — business continuity, disaster recovery, post-incident hardening.
Section 6 (Cyber Security Posture) maps the applicant’s observable posture to these six functions, citing public evidence: SOC 2 Type II reports, ISO 27001 certifications, prior breach disclosures (SEC 8-K material-cybersecurity-incident filings since 2023, state-AG breach-notification databases), public bug-bounty programme posture, security-team size signals from LinkedIn, public security blog or RFC publication.
Where data is thin: "Cyber posture not assessable from public record; recommend underwriter request SOC 2 Type II / ISO 27001 / pen-test attestations directly from applicant."
AML/KYC + OFAC Sanctions Compliance
Section 9 (Sanctions Screening) of every Insurance Underwriting Vetting Report screens against four publicly-available consolidated lists:
- OFAC Specially Designated Nationals (SDN) list — U.S. Treasury / OFAC.
- UN Security Council Consolidated Sanctions List.
- EU Financial Sanctions consolidated list.
- UK HMT Consolidated List of financial sanctions targets.
Sanctions exposure is typically a HARD-DECLINE trigger for most carriers; we surface it as such with PHIA confidence. We do not access subscription consolidated-screening tools (World-Check, LexisNexis WorldCompliance, Dow Jones Risk & Compliance, ComplyAdvantage). When binding requires CRA-tier sanctions screening, the carrier should commission that separately.
Honest Limits — what we do not do
What we DO do
- Synthesis-tier output: 12-section narrative Due Diligence report with cited evidence, four-axis NAIC scoring, PHIA-banded probabilities.
- Public methodology: this page. Frameworks auditable by carriers, MGAs, brokers, and state regulators.
- Asymmetric pricing: 50 credits (about $20) for a full vetting report. Comparable depth at incumbent risk-Due Diligence firms (Kroll, Mintz, K2) typically costs $5K-$50K per investigation.
- Adopted U.S. insurance-regulator + intelligence-community + cybersecurity + AML/KYC frameworks (NAIC, ICD 203, ICD 206, UK PHIA, D&O Underwriter Framework, OFAC, NIST CSF 2.0, ALCOA) in writing, openly.
What we DO NOT do
- We do not satisfy state-mandated underwriting documentation requirements. Carriers must supplement this report with state-DOI-compliant documentation per their internal underwriting guidelines.
- We do not access subscription PEP / sanctions databases (World-Check, LexisNexis WorldCompliance, Dow Jones, ComplyAdvantage).
- We do not access carrier-internal claims databases (ISO ClaimSearch, NICB, equivalents) — those require licensed-carrier access.
- We do not access sealed legal records, juvenile records, or expunged records.
- We do not run credit reports or FCRA-compliant background checks.
- We do not invent claims to fill thin sections.
Corrections Policy
Three commitments modeled on the BBC editorial corrections process:
- Identification window. Errors flagged within thirty days of report generation are corrected on the canonical view URL within five business days.
- Re-publication, not silent edit. Corrections preserve a redline diff between the original and corrected text, time-stamped, with a one-line explanation.
- Subject right of reply. The applicant named in any Vetting Report may submit a one-paragraph factual rebuttal to corrections@mentionfox.com. Verifiable rebuttals attach to the report alongside the original section.
Data integrity floor — ALCOA. Every Insurance Underwriting Vetting Report carries an ALCOA Methodology footer: each factual claim is Attributable to a cited source, presented in Legible plain language, marked with the date it was Contemporaneously verified, sourced from the Original primary record where available, and Accurately reflects the underlying evidence.
References
- NAIC — National Association of Insurance Commissioners.
- ICD 203 — Analytic Standards — Office of the Director of National Intelligence (2015).
- ICD 206 — Sourcing Requirements for Disseminated Analytic Products.
- UK PHIA Probability Yardstick.
- NIST Cybersecurity Framework 2.0 — National Institute of Standards and Technology.
- Bank Secrecy Act — U.S. Treasury / FinCEN.
- FATF Recommendations — Financial Action Task Force.
- OFAC SDN list — U.S. Treasury.
- UN Security Council Consolidated Sanctions List.
- UK HMT Consolidated List.
- FDA Data Integrity and Compliance With Drug CGMP — ALCOA principles.
Methodology v1.0 · Published 2026-05-03 · Verifierce / MentionFox · Vertical 11 of the Due Diligence PlatformWealth Advisor methodology →