Military Personnel: DOD Needs Better Controls over Supplemental Life Insurance Solicitation Policies Involving Servicemembers
Published: 2005-06-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Servicemembers are engaged overseas in hostile actions that threaten their lives and possibly the future financial security of their families, should they die. To address their financial security needs, some servicemembers have purchased additional life insurance to supplement that offered by the government. Concerns have been raised, though, about solicitation violations, as well as problems in the system for setting up payroll allotments for such insurance. The Department of Defense (DOD) recently published a revised draft directive on solicitation but will not implement the directive until at least 90 days following this GAO report. GAO addressed three primary issues: (1) the extent to which DOD solicitation regulations are being violated; (2) the extent to which DOD personnel are adhering to allotment regulations for the purchase of supplemental life insurance; and (3) the extent to which the new directive addresses ongoing problems in supplemental life insurance solicitation policies.
section_title: What GAO Found
paragraphs: DOD does not know the extent to which life insurance agents violate on-installation commercial solicitation regulations and does not actively disseminate information on all confirmed violations to other parts of DOD or to state insurance regulators. GAO found that violations are occurring. For example, in responses to GAO's 2004 survey of personal financial management program managers, one-quarter said prohibited practices such as misleading sales presentations had occurred occasionally or routinely on their installations in the prior 12 months. Also, between October 2001 and October 2004, DOD revoked agents' on-installation solicitation approval at least 26 times. The reason DOD does not have complete data on violations is that it does not have adequate mechanisms for ensuring the systematic tracking of violations. The dissemination problem is attributable to a lack of oversight by the DOD policy office and an ambiguity in its guidance. DOD cannot develop an effective and efficient process for curbing violations without maintaining accurate data on the number, types, and severity of violations and disseminating confirmed violation data to relevant parties. DOD cannot determine the extent to which DOD personnel adhere to allotment regulations because of problems with DOD's payroll databases and the different ways in which regulations are implemented. DOD's Financial Management Regulations, among other things, restrict who can submit an allotment form for supplemental life insurance. GAO could not determine the number of servicemembers with supplemental life insurance allotments due to database limitations, such as all insurance allotments (for example, for life and automobile) sharing the same code. Contrary to regulations, GAO found finance personnel accepting allotment forms without confirming they came from authorized sources. Some said they did this to ensure that policies started promptly. Database problems limit DOD's visibility over prohibited practices, such as those for group solicitation and the acceptance of allotment forms without proper authorization. In addition, GAO could not substantiate the assertion that servicemembers are prevented from using allotments to purchase supplemental life insurance and has identified reasons why this is probably not a widespread problem. DOD's revised directive on commercial insurance solicitation practices on DOD installations adds new requirements, but does not fully address oversight deficiencies. The revised directive will incorporate the interim policy and practices now in place and, to partially address the problems cited above, will add requirements for gathering and disseminating information on confirmed violations. Those requirements, however, will focus on banned agents only, rather than all confirmed violations. The result will be DOD's continuing inability to identify the number, types, and severity of all violations, or to recognize patterns of violations. The directive will also add requirements that installation commanders inquire into alleged violations of the solicitation regulation.

section_title: Letter
paragraphs: Military personnel are engaged overseas in hostile actions that threaten  their lives and possibly the future financial security of their families, should  they die. As a result, some servicemembers purchase additional life  insurance to supplement the benefits available through the government- offered Servicemembers’ Group Life Insurance (SGLI) and other programs.  In July 2004, we reported on the lump sum benefits and annuities available  to servicemembers’ survivors as well as the survivors of personnel  employed by federal, state, and large municipal governments. Recently,  legislation was enacted to increase the maximum SGLI coverage to  $400,000 and the death gratuity payment from $12,420 to $100,000. With  the enactment of this legislation, the number of policies and amounts of  supplemental life insurance sold to servicemembers could change from  current levels.
The Department of Defense (DOD) and the services have regulations to  govern on-installation solicitation for supplemental life insurance, as well  as other types of commercial products. Among other things, an installation  must approve agents before they are allowed to solicit, and the agents must  agree to abide by regulations that include prohibitions of 14 types of  practices. Violation of the regulations can result in the denial, suspension,  or revocation of agents’ or companies’ approvals to solicit on the  installation. Hereafter such agents are referred to as banned agents.
Servicemembers who elect to supplement SGLI’s coverage may purchase  their additional coverage using payroll allotments or other types of  payments such as checks or electronic transfers from checking or savings  accounts. An important feature of the allotment process is a DOD-wide  regulation that requires either the servicemembers or their representatives  with a special power of attorney to submit the allotment form for  supplemental life insurance.
Some servicemembers have reported experiencing problems when  purchasing supplemental life insurance. For example, a soldier described  misleading sales presentations and other concerns during congressional  hearings in 2004. Similarly, DOD reports in 1999 and 2000 cited problems  that included deceptive sales practices, violations of DOD policies  regarding on-installation insurance solicitation, ineffective state insurance  regulation programs, and inadequate safeguards in the allotment system  used to pay for the supplemental life insurance. Negative effects  associated with activities such as misleading sales presentations could  include servicemembers’ purchasing a product that either can be bought  elsewhere more cheaply or does not meet their life insurance needs.
Recently, a different type of life insurance-related concern has also been  voiced. Some life insurance officials have asserted that servicemembers’  chains of command have prevented personnel who wanted additional life  insurance from actually purchasing it when they attempted to set up a  payroll allotment. If servicemembers who truly want supplemental life  insurance are prevented from obtaining it, they may have less than their  desired level of coverage.
The Office of the Under Secretary of Defense for Personnel and Readiness  is responsible for developing the policies and procedures governing  personal commercial solicitation; and the heads of DOD components, or  their designees, are responsible for ensuring implementation of the  regulations and compliance with their provisions. The Defense Finance and  Accounting Service (DFAS) oversees the financial management regulations  and the payroll computer systems and databases.
In response to earlier problems and recommendations for change, the  Office of Morale, Welfare, and Recreation Policy—within the Office of the  Under Secretary of Defense for Personnel and Readiness—has been  revising the DOD directive that governs the marketing and sale of life  insurance and other commercial products on DOD installations. The  Department of Defense Appropriations Act for Fiscal Year 2005 contained  provisions indicating that the revised directive cannot be implemented  until at least 90 days after we issue the present report.
As agreed with your offices, this report addresses three issues: (1) the  extent to which agents are violating DOD’s policies governing the  solicitation of supplemental life insurance to active duty servicemembers  on domestic installations; (2) the extent to which DOD personnel are  adhering to regulations that govern how active duty servicemembers  establish payroll allotments to purchase supplemental life insurance; and  (3) the extent to which the new directive addresses ongoing problems in  supplemental life insurance solicitation policies.
In conducting this review, we limited the scope of our work to  supplemental life insurance solicitations occurring on installations in the  United States and to active duty servicemembers. Additional emphasis  was given to findings pertaining to junior enlisted servicemembers because  DOD and insurance officials have indicated that this subgroup is more  likely to encounter problems with the marketing and sale of supplemental  life insurance as well as with establishing payroll allotments for such  purchases. Numerous methods were used to gather and assess information  for this review. We examined DOD, service, and selected installation  policies on personal commercial solicitation on installations and the  establishment of allotments for supplemental life insurance, as well as  oversight management principles identified in the Government  Performance and Results Act of 1993. We also reviewed GAO, DOD, life  insurance industry, and other reports. We interviewed officials from DOD,  life insurance companies and associations, and other organizations such as  the Consumer Federation of America to identify the many perspectives on  the issues being studied. In conjunction with our work on another report,  we sent a survey to all 175 managers of DOD’s personal financial  management programs on installations in the United States. We also  surveyed the insurance commissioners for the 50 states, the District of  Columbia, and four territories: American Samoa, Guam, Puerto Rico, and  the Virgin Islands. In addition, we interviewed personnel from the state  insurance commissioner’s office for 4 of the 6 states in which we conducted  site visits to military installations, as well as personnel from the state  insurance commissioner’s office in Georgia. We also asked insurance  companies and two national insurance associations to identify agents and  company representatives who could be interviewed about solicitation and  allotment practices at locations near the six installations we visited.
During our six site visits, we requested materials related to the marketing  and sale of supplemental life insurance and the establishment of allotments  for that purpose. Those materials included a list of life insurance agents  approved for on-installation solicitation, handouts distributed to assist  servicemembers in determining their need for supplemental life insurance,  documentation of violations of personal commercial solicitation and  insurance-related policies, and complaints related to insurance solicitation  and allotment processing. While on site visits, we conducted interviews or  focus groups with installation leaders; the coordinator for the installation’s  personal commercial solicitation program; servicemembers; legal  assistance attorneys from the Judge Advocate General corps; finance  department personnel who managed and processed allotments; family  support center staff responsible for personal financial management  training and counseling activities; staff from morale, welfare, and  recreation; and representatives of on-installation banks and credit unions.  We observed the methods used to process and enter allotments for  supplemental life insurance into the pay system. We assessed the reliability  of allotment databases, and we later note in this report, limitations  associated with the databases that prevented us from accurately estimating  the number of allotments or amount of payments for supplemental life  insurance. We performed our work from May 2004 through May 2005 in  accordance with generally accepted governmental auditing standards.  Additional information on our scope and methodology can be found in  appendix I.
subsections: section_title: Background
paragraphs: DOD’s directive on personal commercial solicitation establishes the  policies and practices governing supplemental life insurance sales on  installations in the United States and overseas. Each service provides  additional policies and practices regarding on-installation commercial  solicitation, and some installations further specify how these DOD and  service policies and practices will be implemented locally. Importantly,  DOD and the service policies do not cover supplemental life insurance  solicitation that occurs off an installation. For example, servicemembers  can obtain life insurance through the Internet or from companies that  advertise in private-sector publications aimed at military personnel. Also,  some life insurance agents might sell supplemental life insurance off the  installation after (1) the agents initially generated leads on potential  customers through on-installation efforts such as sponsorship of morale,  welfare, and recreation events; or (2) other types of initial contacts that  include offering servicemembers a free meal at a local restaurant.
Although the steps used to obtain permission to solicit on an installation  may vary, the DOD directive notes that solicitors must meet the following  requirements: be duly licensed, have the permission of the installation  commander, and have made a specific appointment with a servicemember  and conduct it in family quarters or other areas designated by the  installation commander. The supplemental life insurance products offered  on installations in the United States must comply with the insurance laws  for the applicable state, contain no restrictions by reason of military  service or occupation unless the restrictions are clearly stated on the face  of the contract, plainly indicate any extra premium charges if they are  imposed for reasons of military service or occupation, and contain no  variation in the amount of death benefit or premium based on the length of  time the contract has been in force unless the variations are clearly  described therein.
In addition to specifying requirements for the solicitors and the life  insurance products, the DOD directive identifies the 14 prohibited  practices, shown in table 1. Committing any of the prohibited practices  can result in an agent or an agent’s affiliated insurance company being  banned. Among the other grounds for banning agents are failure to be duly  licensed to sell insurance products under applicable federal, state, or local  municipal laws; personal misconduct while on the installation; possession  or attempted possession of allotment forms or their facsimiles; and  substantiated complaints or adverse reports regarding goods or services  and the manner in which they are offered.
During the past decade, DOD issued two reports that addressed problems  with on-installation supplemental life insurance solicitation. In March 1999,  the DOD Inspector General (DODIG) found that improper solicitation  practices occurred at all 11 of the sampled installations. The improper  practices included presentations by unauthorized personnel, presentations  to captive audiences, solicitation during duty hours, solicitation in the  barracks, and subjecting servicemembers to sales pressure and misleading  sales presentations. The DODIG noted that the personal commercial  solicitation directive was adequate but that additional controls were  needed to administer and enforce the solicitation process. Among other  things, the DODIG suggested there was a need for improved oversight at  the installation level, stricter enforcement procedures when improper  solicitation practices are substantiated, and additional interface with state  regulatory authorities. In May 2000, a report commissioned by the Office of  the Under Secretary of Defense for Personnel and Readiness reviewed  insurance solicitation practices on DOD installations and identified many  of the same concerns and recommendations contained in the DODIG  report. In September 2000, DOD’s Office of Force Management Policy  established an insurance solicitation oversight working group to develop a  strategy for eliminating prohibited life insurance solicitation practices on  DOD installations. The working group’s recommended improvements were  included in a draft revision of the directive on personal commercial  solicitation, and this draft revision was published for public comment in  August 2003.
An important step in purchasing supplemental life insurance is making the  arrangement to pay for it. Some servicemembers pay for the insurance with  a payroll allotment, a process that is governed by the DOD’s Financial  Management Regulation and individual service policies and is under the  responsibility of DFAS. While the process for starting an allotment for  supplemental life insurance varies across services and installations, it can  be summarized in three steps: 1. Servicemembers or their representatives with a special power of  attorney complete an allotment form and submit it either directly to the  installation finance office or to the finance office through the  servicemembers’ unit administrative office. 2. The installation finance office processes the allotment requests and  electronically submits them to DFAS. 3. The first monthly payments are made to vendors more than a month  after the forms are submitted, because the processing of the allotment  requests takes time and the once-a-month payments result in the need  to wait for half of the payments to be taken out of each of the  servicemembers’ next two payroll deposits.
The allotments for all types of commercial insurance are supposed to be  coded as an AI discretionary allotment when they are entered into a DFAS  database. The procedure for purchasing SGLI with an allotment is  different from that used to purchase private supplemental life insurance  with an allotment. One reason is active duty servicemembers are  automatically insured for the maximum SGLI coverage. Servicemembers  may subsequently elect to reduce their SGLI coverage, or to cancel it  entirely.
DOD’s effort to revise the directive began in 2002 after reports in 1999 and  2000 documented problems with supplemental life insurance solicitation  on installations and made recommendations for improvement. In 2003,  DOD obtained public comments on a draft directive during a public forum  available to interested parties. Those comments and other input from  sources such as DOD’s general counsel served as the basis for a draft  directive published in the Federal Register on April 19, 2005, and discussed  during a public hearing held on May 6, 2005, to obtain additional comments.
section_title: DOD Does Not Know the Extent of Solicitation Violations and Does Not Disseminate Information on All Confirmed Violations
paragraphs: DOD does not know the extent to which life insurance agents are violating  regulations pertaining to on-installation personal commercial solicitation,  and it does not actively disseminate information about all confirmed  violations to other portions of DOD and state insurance regulators.  Although many of the sources that we contacted for our review identified  violations, DOD does not know how widespread the violations are because  it has not collected information on the number, types, and severity of the  violations. Even when violations have been severe enough to result in  commanders banning agents from their installation, DOD did not actively  provide that information to other installations or to state insurance  regulators. The absence of evaluative and reporting requirements in the  solicitation directive, as well as ambiguity in the directive about the  dissemination of information, are some of the reasons for these situations  that limit DOD’s ability to provide oversight of supplemental life insurance  solicitation on installations and prevent violators from having access to  servicemembers on installations.
subsections: section_title: DOD Does Not Know the Extent to Which Life Insurance Agents Have Violated Solicitation Policies on Domestic Installations
paragraphs: Because of the absence of evaluation and reporting requirements, DOD has  not collected the data that it needs to monitor the number, types, and  severity of life insurance agents’ violations of DOD’s regulations regarding  on-installation solicitation. But data from our review suggest that the  violations are not restricted to a few installations. Our data regarding  alleged violations of the 14 prohibited practices identified in DOD’s  commercial solicitation directive came from multiple sources: perceptions  expressed in a DOD-wide survey and numerous interviews at six  installations; information on the number and geographical dispersion of  cases where installation commanders had banned agents during the past  3 years because of violations; and a review of in-depth documentation for  four of the cases serious enough to result in banning agents.
A survey of personal financial management program managers on  installations in the United States indicated that six types of prohibited  solicitation practices were perceived to have occurred with varying  frequency on their installations during the prior 12 months. More than  one-third of the managers indicated that misleading sales presentations  regarding supplemental life insurance had occurred occasionally or  routinely on their installations, and more than one-quarter said that four of  the other five prohibited practices had occurred at least occasionally (see  fig. 1). In interviews conducted during our visits to six installations,  multiple sources—for example, solicitation coordinators, legal assistance  attorneys, servicemembers, and insurance agents—indicated that the types  of violations shown in figure 1 had occurred on their installations. For  three or more of the six installations, multiple sources told us of agents  inappropriately using their military retiree credentials to gain access to  servicemembers for life insurance solicitation purposes, life insurance  agents possessing or processing allotment forms, and life insurance agents  participating in military-sponsored training. The installations had little or  no documentation to show that the violations identified in the interviews  had been reported or investigated.
After we asked DOD if it had a list of insurance agents and companies  whose solicitation privileges had been withdrawn, DOD requested the  information from the services and installations. As of April 2005, DOD’s  request for information identified 51 cases that occurred on installations in  the United States from April 1998 through October 2004. Some installations  supplied information on enforcement actions that did not result in the  banishment of agents or companies. Table 2 provides information on 26  cases in which commanders banned agents—25 from DOD’s list and one  additional case we later identified—from October 2001 through October  2004. Examining only the more recent cases minimizes the possibility that  a case would have been the basis for findings in the 1999 and 2000 DOD  reports on supplemental life insurance. Table 2 shows that the 26 cases  occurred on 11 installations in eight states. Our analysis additionally  revealed that agents from one life insurance company were involved in 9  (about 35 percent) of the 26 cases, and agents from another company were  involved in 6 (about 23 percent) of the cases.
Our review also examined the in-depth documentation for two cases from  Camp Pendleton, California, and two cases at Fort Benning, Georgia, both  of which are listed in table 2. The documentation, sometimes more than 200  pages, illustrates the situations that led to the violations, the types of  violations occurring, and the amount of effort required to conduct the  investigations. The cases are summarized as follows, and additional details  on each are provided in appendix II.
Camp Pendleton: In 2003, an insurance agent requested and obtained  authorization to teach a class on veterans’ affairs benefits and financial  planning to Marines. During the class, the agent said very little about  veterans’ benefits but spoke at length about investments. The agent  distributed cards for Marines to provide contact information. Using this  information, the agent later sold Marines insurance policies at their  homes and on duty, sometimes without appointments. During the  meetings, Marines were given the impression that the agent represented  the Department of Veterans Affairs. This agent’s solicitation privileges  were suspended for 2 years by the installation.
Camp Pendleton: In 2003, insurance agents requested and obtained  permission to teach veterans’ affairs classes to Marines fresh from boot  camp. The classes, with required attendance, started as veterans’  benefits discussions but shifted to investment sales pitches after non- commissioned officers left the classrooms. Agents distributed  applications, allotment forms, and statements of understanding,  encouraging participants to sign quickly, not read the forms, leave the  dollar amount lines blank, and provide signed photocopies of their  identification cards. The Marines were not allowed to take any  paperwork with them and were told that copies would be sent to their  home of record. The agents, including at least one retired Marine, were  fired by their employer. Refunds were offered to those who purchased  policies.
Fort Benning: In 2003 and 2004, agents accessed soldiers in a basic  combat training brigade through unit non-commissioned officers for the  express purpose of providing financial planning classes. In unit  classrooms, the agents discussed the value of investing. At the end of  the presentations, soldiers who desired additional information  completed a form. Weeks later, the agents met with soldiers individually  or in small groups in the unit’s area. The agents were fired from the  companies they represented, and several officers and enlisted personnel  involved in arranging the presentations were reprimanded. The manager  for DOD’s personal commercial solicitation program said that he was  unaware of any other instance where enforcement included punishment  of installation personnel, but added that his office does not track such  information.
Fort Benning: In 2002, two agents accessed soldiers in the infantry  training brigade through unit non-commissioned officers for the express  purpose of providing financial management classes. The classes were  included on the training scheduled in conjunction with other personal  financial affairs presentations and were conducted in unit classrooms.  Non-commissioned officers escorted the soldiers to the classrooms.  According to the investigation, some of the non-commissioned officers  had knowledge of the solicitation actions taking place. These agents  later had their solicitation privileges revoked by the installation, and  refunds were provided to those who purchased policies.
DOD-wide, service-specific, and installation-level factors contribute to the  lack of information on violations. The absence of evaluation and reporting  requirements in DOD’s directive on personal commercial solicitation is a  primary reason why the services and installations do not emphasize  assessment and why DOD cannot estimate the extent to which life  insurance agents are violating the 14 proscribed practices and other parts  of the directive. The absence at the installation level of documentation of  confirmed violations by life insurance agents is also caused by several  other factors, including: (1) the time it takes for personnel to lodge a  complaint and other personnel to investigate it; (2) reluctance to get either  the agents or installation personnel in trouble, especially when the agents  appear to have the support of someone in the chain of command; and  (3) the lack of knowledge about permitted and prohibited practices by both  individuals being solicited and other servicemembers who allow life  insurance agents to conduct financial training or perform other prohibited  practices.
The lack of documentation on confirmed violations can result in negative  outcomes for both DOD and the life insurance industry. For instance, DOD  is unable to identify the extent of specific types or patterns of problems,  such as multiple instances of the same violation for agents from a single  insurance company. Furthermore, DOD cannot determine whether there  are many agents violating the regulations on a few occasions; a small  number of agents violating the regulations on many occasions; or many  people talking about a relatively few, well-publicized violations. Without  knowing the extent of the problem, DOD cannot develop an effective and  efficient strategy for curbing the violations. The lack of documentation  could also negatively affect the life insurance industry and its agents.  “Broad brush” complaints create a negative image of the industry. Some of  the agents we interviewed were concerned that the highly publicized cases  are painting a negative picture of them and their profession, even though  they said they had not violated the regulations on personal commercial  solicitation.
section_title: DOD Does Not Disseminate Information about All Confirmed Violations and Enforcement Actions to Other Parts of DOD or to State Life Insurance Regulators
paragraphs: The DOD policy office responsible for oversight of supplemental life  insurance solicitation on installations does not routinely disseminate  information on all confirmed violations to installations, to the services, or  to state life insurance regulators. Although the DOD solicitation directive  provides installation commanders with discretionary authority to report  banned agents to their military department, they are not obliged to do so.  Specifically, if installation commanders believe it is warranted, they can  recommend extending or lifting actions taken against life insurance agents  on other installations to their respective military departments. Additionally,  the Office of the Secretary of Defense for Personnel and Readiness could,  when appropriate, extend or lift the actions for other military  departments. Notably, the current solicitation directive does not require  the installation commander to routinely report information on all  confirmed violations to state insurance regulators. It merely requires  installations to notify appropriate state licensing authorities if the grounds  for withdrawing solicitation privileges involve the eligibility of the agent or  company to hold a state license or meet other regulatory requirements.
One indication that installation commanders and DOD policy officials have  had only limited communications about violations was the absence of a  DOD list of cases where agents had been banned from installations for  violating the personal commercial solicitation directive. The DOD policy  office did not generate its list of cases until we requested the information  for this review. This lack of information sharing occurred even when policy  violations were severe enough to warrant the banning of agents. These  communications-related problems continued despite three  recommendations in the 1999 DODIG report: (1) require that all  installations in the local area and the services’ higher commands be  notified of “any adverse actions” taken against an insurance agent; (2)  require the services to track such actions and report the information to the  office with oversight responsibility; and (3) increase the interaction with  state life insurance regulators. During our visits to six installations,  solicitation coordinators told us that they did not routinely interact with  their counterparts on other installations, but several of the insurance  agents that we interviewed said they were approved to solicit on multiple  bases in multiple states.
We found a similar lack of communication between the various parts of  DOD and state insurance regulators. In our December 2004 survey of all  state insurance commissioners’ offices, only one state reported that DOD  had notified it of disciplinary actions taken against a life insurance agent  during the prior 12 months, even though several of the 26 cases in table 2  occurred during the same period. Our survey also revealed that 100 percent  of the life insurance commissioners’ offices responding to our survey said it  would be a good practice if DOD were to notify their offices whenever it  took a disciplinary action against a life insurance agent, and 68 percent said  they would like more communications with the military.
Figure 2 shows the states where installation commanders took 26  enforcement actions to ban agents from October 2001 through October  2004; states where regulators indicated on our survey that the office had an  ongoing investigation involving life insurance sales to servicemembers; and  the number of active duty servicemembers in the states. State regulators  reported in our survey that they had ongoing investigations in nine states:  Alaska, California, Colorado, Georgia, Illinois, Iowa, Kentucky, New York,  and Texas. Regulators’ investigations were occurring in four states  (California, Georgia, Kentucky, and Texas) that have at least 30,000  servicemembers in them. Four states (California, Georgia, Illinois, and  Texas) had both an ongoing investigation by the state insurance regulators  in December 2004 and an installation where an agent had been banned  between October 2001 and October 2004.
Since the DODIG made recommendations to improve information sharing  6 years earlier that were not implemented, the absence of oversight by the  DOD policy office appears to be the primary reason for the past lack of  DOD-wide information sharing on banned agents and the continued lack of  information sharing on lesser confirmed violations. Ambiguity in the  solicitation directive about who should disseminate violations-related  information to state regulators and the types of information that should be  disseminated may have contributed to a lack of information sharing.  Another reason for the lack of contact relates to uncertainty regarding the  states’ ability to govern what occurs on an installation. Several state  regulatory officials stated that they were uncertain about whether they had  jurisdiction over life insurance sales on military installations. DOD officials  informed us that they began meeting with the National Association of  Insurance Commissioners in May 2005 to address some of these issues, and  legislation has been introduced in Congress to require greater  communication between DOD and the association. Additionally, several  installation officials stated that their office considered the involvement of  state regulators only for serious complaints or problems that involved life  insurance products.
The failure to disseminate information to other parts of DOD or to state  insurance regulators about agents and companies who violate the  solicitation policy—especially when the violations were serious enough to  ban agents—can enable violators to continue operating on other  installations. State insurance regulators in North Carolina told us that by  not reporting violations to state regulators, installations prevent the state  regulators from determining whether further actions, such as revocation of  licenses, are warranted. Maintaining a list only of banned agents does not  allow DOD or state regulators to spot patterns of violations by agents or  companies that may have committed multiple lesser violations on multiple  installations. If present, such patterns would be detectable only when  solicitation coordinators are able (1) to identify the other installations  where the agents or companies are approved to operate and (2) to  communicate with their peers on the other installations about violations  committed there by the agents or companies. Limited communications  between installations also hinders the promotion of best practices. For  example, other installations might be interested in Camp Pendleton’s  testing of agents before approving them for on-installation solicitation.  When determining whether to ban some agents from Camp Pendleton,  investigators were able to show that the agents correctly answered test  questions about prohibited practices— yet still committed the prohibited  practices.
section_title: Data on Payroll Allotments for Supplemental Life Insurance Unreliable and Procedures for Submitting Such Allotments Are Not Always Being Followed
paragraphs: We could not determine the extent to which servicemembers follow DOD’s  and the services’ allotment processing policies when purchasing  supplemental life insurance because of limitations in the allotment  databases and the different ways that finance offices were accepting forms  to start the allotments. Even with DFAS assistance, we could not generate  reliable monthly estimates of the number of servicemembers with, or the  amount of money allotted for, supplemental life insurance. The unreliability  of estimates stemmed from longstanding database and computer system  constraints, such as the coding used when gathering and entering the life  insurance allotments into the databases and computer problems that we  have documented in prior reports. Another problem area with  supplemental life insurance allotments is the lack of certification that  occurred when allotment forms were submitted to and processed by some  finance offices. Contrary to financial management regulations, some  finance personnel were accepting allotment forms through the mail or from  individuals without verifying that the submitter was either the  servicemember or that person’s representative with a special power of  attorney. We could not substantiate insurance officials’ and agents’  assertion that servicemembers were being prevented from using allotments  to purchase life insurance. Several factors suggest that all servicemembers  who want to obtain supplemental life insurance can do so.
subsections: section_title: Databases of Allotment Information Cannot Be Utilized to Monitor Servicemembers’ Use of or Perceived Need for Supplemental Life Insurance
paragraphs: We, with assistance from DFAS, attempted but could not determine with  sufficient reliability either the number of servicemembers who have  allotments for supplemental life insurance products or the number of  dollars that servicemembers pay as allotments to life insurance companies  each month. Although DOD’s Financial Management Regulation supplies  the primary guidance governing the procedures used to gather allotment  information and then electronically enter and store the information, each  service has a policy and procedures directing how to implement the DOD  regulations. Among other things, the military services’ policies and  procedures specify how allotments for supplemental life insurance and  other products or services are to be coded, the number of discretionary  allotments that each servicemember is allowed, and which forms can be  used to initiate allotments. Allotments to purchase life insurance are also  governed by the DOD directive on personal commercial solicitation. The  directive requires a 7-day cooling-off period between the time when E1s  through E3s sign a supplemental life insurance application and the time the  allotment is certified.
A variety of DFAS database-related constraints limit the visibility that the  DOD solicitation policy office, the services, and installations have over  servicemembers’ use of and perceived need for supplemental life  insurance. These constraints include the following:  Although the databases can be used to identify servicemembers with an  insurance allotment (an AI code), the allotment could be for  servicemembers’ or family members’ life, health, automobile, or other  insurance. Conversely, other servicemembers’ insurance allotments are  not detectable if they are coded for savings (an AS code) or other types  of accounts that the servicemembers also have with the company  providing supplemental life insurance.
Servicemembers are limited to six allotments in total and one  discretionary allotment per company, even if they have multiple  accounts (supplemental life insurance, savings, and so forth) with a  company.
DOD and service regulations permit the use of at least seven different  allotment forms, but forms such as the government-wide Standard Form  1199A or DOD-wide DD Form 2558 do not ask whether the allotment is  for supplemental life insurance. (See app. III for a copy of each form.)
The payroll databases cannot tell how many servicemembers pay  insurance companies directly by checks, electronic withdrawals from  personal accounts, and so forth.
DFAS maintains separate databases for the different military services,  and the code used to identify an insurance company is not the same for  all services. Creating a DOD-wide list requires additional work to merge  the resulting information.
DOD was informed about some of these database constraints in the 1999  DODIG report, in which analysts noted that they could not determine what  portion of the allotments were made specifically for life insurance.
A major cause of these database-related problems is DOD’s systems  supporting servicemembers’ pay. In our earlier reports, we documented  serious problems with these systems, noting that they were prone to error  and required manual data reconciliation, correction, and entry across  nonintegrated systems. While a significant system enhancement project is  under way to improve the administration of military pay, DOD is likely to  continue operating with existing system constraints for several years. The  continued use of forms that do not require information and coding specific  to life insurance could cause allotment data to continue to be unreliable for  oversight purposes, even when the new computer system becomes  operational. Information obtained during interviews indicated another  cause for data unreliability. Some interviewees suggested that  servicemembers might use codes other than AI to avoid the additional  requirements encountered when starting allotments for supplemental life  insurance. The additional requirements include the cooling-off period and   the requirement to submit a paper form for all supplemental life insurance  allotments, rather than using the electronic MyPay system.
The absence of data regarding which servicemembers do or do not carry  supplemental life insurance limits the oversight that DOD policy officials  and installation solicitation coordinators can exert. For example, the  inability to obtain accurate data prevents the DOD policy office from  monitoring increased or decreased perceived needs for supplemental life  insurance, an important issue now that new legislation has been enacted to  almost double the lump sum death benefits offered through the  government. Also, the lack of accurate data prevents the solicitation  coordinators from easily checking whether servicemembers on an  installation submitted an unusually large number of new allotments for  supplemental life insurance during a short period, a possible sign of mass  solicitation to recruits or trainees or other prohibited practices.
section_title: Allotments for Supplemental Life Insurance Have Been Started without Verifying Required Authorization and the Elapse of the Cooling-Off Period
paragraphs: Contrary to regulations, some finance personnel have accepted allotment  forms to start supplemental life insurance without verifying that the person  submitting the form is authorized to do so or, if applicable, that a  cooling-off period has occurred. According to DOD’s Financial  Management Regulation, establishment of, discontinuance of, or changes  to existing allotments for supplemental life insurance are to be based on a  written request by a servicemember or someone with a special power of  attorney on behalf of the servicemember. For junior enlisted  servicemembers, the DOD directive on personal commercial solicitation  provides an additional requirement: “For personnel in pay grades E-1, E-2,  and E-3, at least seven days shall elapse for counseling between the signing  of a life insurance application and the certification of an allotment. The  purchaser’s commanding officer may grant a waiver of this requirement for  good cause, such as the purchaser’s imminent permanent change of  station.”
Nonetheless, DOD personnel and insurance agents indicated that some  offices accepted allotment forms personally submitted by insurance agents  or through the mail with only the signature on the form serving as proof  that the servicemember wanted to start an allotment for supplemental life  insurance. For example:  A life insurance agent is alleged to have submitted allotment forms at  Fort Bragg for servicemembers who later said they had not wanted the  policies for which they were paying.
Finance office personnel at Naval Station Great Lakes said that about  half of all insurance allotment forms submitted to and processed by  their office came from insurance agents.
DFAS representatives who process allotments for Marines stated that  they accepted and processed allotment forms submitted directly from  Marines through the mail without the required certification.
Finance office personnel at Lackland Air Force Base were concerned  about the high number of mailed allotment forms from insurance  companies or otherwise on behalf of servicemembers and requested  DFAS guidance on processing such forms.
Several reasons were suggested for DOD personnel’s acceptance of  allotment forms that were not submitted personally by the servicemembers  or their representatives with a special power of attorney. DFAS personnel  representing the Marines said that they accepted and processed mailed  insurance allotment forms from Marines who, due to their transitional  status, were unable to properly certify the forms, but wished to promptly  initiate policies or to keep policies from lapsing. In addition, Air Force  personnel said that servicemembers have tight training schedules that  make it more convenient to mail the forms than to hand carry them to the  finance office. The Air Force has recently clarified its policies to require  contacting servicemembers and verifying the request when allotment forms  are received by mail.
The causes are different for noncompliance with the requirement to have  7 days elapse between the time junior enlisted servicemembers sign a life  insurance application and the time an allotment is certified. On allotment  forms such as the governmentwide Standard Form 1199A or the DOD-wide  DD Form 2558, no one is asked to certify that the required cooling-off  period and, possibly, counseling have occurred. Therefore, these forms do  not require finance personnel to determine whether the full 7 days have  elapsed before they certify the allotment. Other causes for noncompliance  with the required cooling-off period are ambiguities in the directive. First,  the requirement for a cooling-off period may be for all life insurance  allotments started by junior enlisted servicemembers, but its inclusion in a  directive governing only on-installation solicitation could cause finance  officials to interpret the requirement as applying only to those allotments  for supplemental life insurance sold on an installation to junior enlisted  servicemembers. Second, it is unclear whether the counseling is required  or optional during the cooling-off period. Further, the directive and the  standard allotment forms do not contain procedures for documenting  whether the counseling took place. Third, it is unclear when the  commanding officer must sign a waiver for the cooling-off period and/or  counseling.
Starting a supplemental life insurance allotment for servicemembers who  do not want one or were not required to allow the cooling-off period to  elapse can result in extra expenses for servicemembers who may already  be financially challenged. Even if servicemembers receive premium  reimbursements like those promised by insurance companies following the  incidents at Fort Benning, Fort Bragg, Camp Pendleton, and possibly other  places, months can pass between the paying for the allotments and the  reimbursements. During that time, servicemembers are without a portion  of their income, and this decreased income could result in budgeting  difficulties and fees for such things as bounced checks and late payments.  As we pointed out in our April 2005 report on the financial conditions of  servicemembers and their families, pressure from creditors, falling behind  in paying bills, and bouncing two or more checks were negative financial  events reported by approximately one-eighth to one-fifth of  servicemembers on a 2003 DOD-wide survey. In addition, more than 10  percent of servicemembers answered “in over your head” or “tough to  make ends meet but keep your head above water” when the survey asked  them to characterize their financial condition. For servicemembers who  were already having financial difficulties, unplanned allotments and any  extra expenses could result in debt and bad credit histories for  servicemembers, as well as adversely affect unit readiness and morale as  the chain of command attempts to address any resulting financial  problems.
section_title: Assertion That Servicemembers Are Prevented from Purchasing Supplemental Life Insurance Could Not Be Substantiated
paragraphs: Some insurance officials and agents asserted that chains of command  prevent servicemembers from purchasing supplemental life insurance, but  we were unable to substantiate the assertion. As we have previously  mentioned, DOD’s Financial Management Regulation requires that  servicemembers or their representative with a special power of attorney  complete and submit an allotment form if the supplemental life insurance is  to be purchased with a payroll deduction. Also, the previously discussed  requirement for a cooling-off period and possibly counseling for junior  enlisted personnel is important to examining the life insurance officials’  and agents’ assertion.
During a meeting at the start of our review, officials from insurance  companies and national insurance associations asserted that some  servicemembers were being prevented from purchasing supplemental life  insurance. Also, a firm that sells supplemental life insurance on and off  multiple installations supplied us with documents on 1,344  servicemembers who completed insurance applications from October 2002  through September 2004 but did not subsequently start a policy through the  firm. During site visits to two of the installations where the majority of the  1,344 servicemembers were based at the time of completing their  applications, we attempted to conduct focus groups with subgroups of  those servicemembers. Our points of contact on the installations indicated  that many of the servicemembers had rotated to other installations or were  in training that could not be missed.
Although we could not determine how representative these 1,344  applications were of all applications completed without a purchase being  made, this case study of the experiences at one firm provides some insight  into the viability of cost-related alternative reasons why servicemembers  might not follow through with the purchase of supplemental life insurance  coverage. Our analysis of the 1,344 cases showed that 831 applications  were for E1 through E3 servicemembers, and the per person average  monthly cost of the products in the applications was $92. For those 831  junior enlisted personnel, 3 percent of the cases contained only an  application for life insurance, 52 percent contained only an application for  what an official from the firm characterized as “a life insurance product  with an accumulation fund,” and 45 percent included both types of  applications.
Military officials, servicemembers, and insurance officials and agents  identified reasons—in addition to being actively prevented from processing  a supplemental life insurance allotment form—why servicemembers might  not start a policy after completing an application. These other reasons  included:  The counseling supplied during the 7-day cooling-off period could have  been misinterpreted as an implicit order from the chain of command not  to purchase the insurance, rather than as advice about the advantages  and disadvantages of purchasing supplemental life insurance or a  particular type of coverage.
The counseling could have resulted in the servicemember’s following  through on purchasing a supplemental policy but obtaining it from  another vendor, and possibly at a lower price.
Some servicemembers may have developed buyers’ remorse when they  later considered the competing demands on their compensation.
Servicemembers may have completed the application because of high  pressure sales practices, knowing they would not later file an allotment  form.
An allotment may not get started because of a lost or missing allotment  form.
Although we were not able to determine whether chains of command were  intentionally preventing servicemembers from purchasing supplemental  life insurance, information of four types suggests that the inability to  purchase supplemental life insurance coverage is probably not a  widespread problem. First, 85 percent of the state insurance regulators in  our survey indicated that no insurance company had filed a complaint  regarding the sale of life insurance to servicemembers on installations from  October 2003 through December 2004, and the other 15 percent said they  did not know. Second, most of the insurance agents identified by the  national insurance associations and interviewed during our six installation  visits indicated that they had not experienced a problem with the allotment  process. In contrast, agents for two life insurance companies typically  reported a problem, and the concerns related primarily to the processing of  allotments on two installations that were served by the firm that supplied  us with the more than 1,000 cases. Third, when we were able to talk with  servicemembers identified as having completed insurance applications  without starting allotments, they indicated that they did not purchase the  supplemental life insurance for reasons other than prevention by the chain  of command. Finally, if servicemembers wanted life insurance and were  actively prevented by the chain of command from filing allotment forms to  make the purchase, they could pay the premiums by check, electronic  withdrawals from other financial accounts, or some other means, without  further chain of command intervention.
section_title: DOD’s Revised Directive Adds New Requirements, but Does Not Fully Address Oversight Deficiencies
paragraphs: DOD’s revised directive on personal commercial solicitation practices on  DOD installations incorporates new requirements, but does not address all  oversight problems. Numerous changes have been proposed. Some  interim policy and practices that are currently in place have been  incorporated into the draft revision. Also, requirements for gathering and  disseminating information have been proposed, but they do not fully  address oversight deficiencies. Still other proposed requirements address  issues such as the type of information that life insurance agents will  provide to servicemembers to describe the product being offered by the  agent.
subsections: section_title: Draft Directive Proposes to Incorporate Existing Interim Policy and Formalized Practices Already in Place
paragraphs: One of the larger sets of additions to the draft directive proposes to  incorporate interim policy that DOD issued in 2002 about on-installation  financial education presentations. Those additions generally prohibit  representatives of commercial loan, finance, insurance, or investment  companies from providing such presentations. With certain restrictions, the  presentations may, however, be provided by representatives of the  following types of organizations: credit unions and banks located on  military installations, nongovernmental, noncommercial organizations  expert in the field of personal financial affairs, and those that are either tax- exempt (under 26 U.S.C. 501(c)(3) or (c)(23)) or under a contract with the  government. Among other things, restrictions require that the presenter  and educational materials use disclaimers to indicate clearly that they do  not endorse or favor any commercial supplier, product, or service. Also, the  installation commander shall consider the company’s history of complying  with on-installation commercial sales instructions if the presenting  organization is affiliated with a company that sells or markets insurance or  other financial products.
An additional change to the draft solicitation directive incorporates  procedures pertaining to advertising and commercial sponsorship that  were already in place at some of the installations we visited. For example,  the draft directive notes that solicitors are allowed to provide commercial  sponsorship of DOD morale, welfare, and recreation programs or events on  installations but are not to contact participants without their written  permission. Interviews with insurance agents and installation personnel  during our site visits indicated that agents were already generating lists of  future contacts through the use of forms that program or event participants  completed, indicating their permission for the future contact.
section_title: Proposed Evaluation, Reporting, and Dissemination Requirements Do Not Fully Address Oversight Deficiencies
paragraphs: DOD has taken some positive steps to improve its oversight of personal  commercial solicitation on installations by proposing to add four new sets  of requirements that pertain to gathering and disseminating evaluative  data. Each of the requirements has associated problems that could limit the  usefulness of the gathered and disseminated data.
Two sets of proposed changes add requirements for gathering and  disseminating information about violations on banned agents. As we noted  earlier, continued gathering and disseminating information on only those  violations severe enough to result in banning an agent will result in DOD’s  continuing to be unable to (1) identify the number, types, and severity of all  violations and (2) recognize patterns of violations. Failure to disseminate  information on all confirmed violations to all parts of DOD and to state  regulators can allow violators to continue operating on installations.
As the result of another proposed addition to the draft directive,  installation commanders will be required to inquire into any alleged  violations of the solicitation regulation or questionable solicitation  practices. This step could increase the DOD’s oversight of the number,  types, and severity of confirmed violations occurring throughout all  military installations if there were also an additional requirement to report  all confirmed violations to higher-level commands. Some factors that could  keep the number of inquiries into potential violations artificially low are the  lack of knowledge about which solicitation practices are prohibited, the  steps required to report a violation, and whom to contact when a suspected  violation occurs. We reported in April 2005 that only the Army is  monitoring the completion of required personal financial management  training for junior enlisted personnel, and it estimated that about 18  percent of that group had not received the required training. Our earlier  review did not assess the amount or the types of life insurance-related  training provided, but we noted that each service administered its personal  financial training differently. When we recommended additional DOD  oversight by requiring the services to develop and implement plans to  monitor the training, the Under Secretary of Defense for Personnel and  Readiness partially concurred with our recommendation but noted that the  DOD instruction governing personal financial management training had  sufficient procedures to let the military departments accomplish their  responsibilities.
Another proposed addition to the draft directive would require an  insurance agent to provide a servicemember with a new DOD-wide  questionnaire that would contain questions about the servicemember’s  experiences during the prearranged appointment with the agent for  solicitation. The value of information obtained from this assessment  instrument may be very limited, and might even create an erroneous  impression of what has occurred during the typical solicitation  appointments. The questionnaire will document interactions that were not  described as problem areas during our visits to six installations—that is,  life insurance agents who were complying with the requirement to  prearrange one-on-one solicitation meetings. Also, the voluntary  completion of the forms will result in a lack of transparency, since some  forms may not be turned in for a variety of reasons: For example, they were  never distributed by an agent, or the servicemembers did not want to take  the time to fill in and drop off the form. In addition, the directive includes  no requirement to submit the data to higher levels so that service-wide and  DOD-wide information can be developed.
section_title: Other Changes Will Result in Better Explanation or Clarification of Existing Requirements
paragraphs: Another change merits special mention because it could result in  servicemembers’ having better information for making decisions about  whether or not to purchase a specific amount or type of supplemental life  insurance coverage. All financial products that contain insurance features  must clearly explain the insurance features of those products. The draft  regulation elaborates further about insurance products, stating that if there  is a savings component to an insurance product, the agent shall provide the  customer written documentation, which clearly explains how much of the  premium goes to the savings component per year, broken down over the  life of the policy. This document must also show the total amount per year  allocated to insurance premiums. The customer must be provided a copy of  this document that is signed by the insurance agent. One problem that  might be encountered in implementing this proposed requirement is the  absence of any guidance about what types of information must be  contained in the written description and who (for example, the  installation’s solicitation coordinator or the National Association of  Insurance Commissioners) would judge whether the information is  conveyed clearly.
Three other changes in the draft also merit mention. First, solicitors are  prohibited from contacting DOD personnel by calling a government  telephone or by sending an e-mail to a government computer unless the  parties have a pre-existing relationship. Second, solicitors with military  identification cards and/or vehicle decals must present documentation  issued by the installation authorizing solicitation when entering the  installation for that purpose. Third, commercial sponsors may not use  sponsorship to advertise products and/or services not specifically agreed to  in the sponsorship agreement.
A DOD official informed us that DOD plans to review the findings and  recommendations of our report and then request more public comments  after our report is issued. He also indicated DOD will not publish a final  revised directive until at least 90 days after the issuance of our report,  consistent with the provisions of Section 8133 of the Department of  Defense Appropriations Act for Fiscal Year 2005.
section_title: Conclusions
paragraphs: DOD cannot identify the extent to which life insurance agents are violating  solicitation policies or procedures, the types, severity, or patterns of  violations. A proposed new provision in the draft directive would require  DOD to maintain and disseminate a master file on banned agents, but this  new provision will still not provide DOD with a full picture of the important  but missing data outlined in the prior sentence. For example, DOD’s  current list (1) is not searchable to help solicitation coordinators quickly  check on agents who want to be approved or re-approved for on- installation solicitation, (2) does not provide the same information on every  case as is evidenced by the absence of dates for 6 of the 51 cases, (3) does  not identify the specific types of violations that occurred—data critical for  identifying patterns of violations, and (4) probably does not contain  information on all agents who installation commanders have determined  violated regulations but have not done something severe enough to be  banned. The continued absence of these important data will force DOD, the  services, and installations to take actions based on isolated incidents,  anecdotes, and other possibly insightful, but non-optimum information.  DOD has, however, taken a positive step by including a requirement in the  draft directive to maintain a list of contacts for state insurance regulators,  but it does not require installation commanders to keep state regulators  generally informed about all confirmed solicitation violations occurring on  their installation. This ambiguity could result in some relevant violations  not getting reported to state regulators. Similarly, ambiguity is present in  the wording of the requirement for the cooling-off period for junior enlisted  servicemembers who want to purchase supplemental life insurance. While  DOD’s draft directive clarified that the period is 7 calendar days, other  ambiguities were identified earlier in this report. Failure to address these  issues during the current revision could result in inconsistent enforcement  of that requirement.
The quality of the information in the DFAS payroll databases limits the  ability of other parts of DOD in their efforts to (1) monitor servicemembers’  perceived need for supplemental life insurance and (2) detect prohibited  group presentations as evidenced by large numbers of new allotments for  supplemental life insurance. Continued reliance on multiple generic  allotment forms and a generic data entry code that does not distinguish  different types of insurance products (for example, life versus automobile)  will perpetuate existing data reliability problems. Furthermore, the  continued use of generic forms to start a supplemental life insurance  allotment results in a missed opportunity for DOD to institute steps to  address solicitation requirements whose enforcement has not been  assessable. For example, DOD has no current forms or other assessment  methods for documenting that the required cooling-off period for junior  enlisted personnel occurred, servicemembers received required documents  from life insurance agents, and the finance or administrative staff who  accepted the allotment form for supplemental life insurance also verified  that the person submitting it was either the purchaser or the  servicemember’s representative with a special power of attorney. With  regard to this last enforcement and documentation issue, our review found  some noncompliance with the requirement that only servicemembers or  their representatives with special power of attorney could start  supplemental life insurance allotments. Even though some of the reasons  for the noncompliance may be well-meaning, some of the instances where  finance officials have accepted such allotment forms from unauthorized  persons have resulted in banning agents, diverting valuable resources away  from the military mission to conduct investigations, and possibly placing  servicemembers and their families at financial risk when unanticipated  allotments begin for unwanted products. Adherence to existing regulations  would go far to eliminating these negative effects.
section_title: Recommendations for Executive Action
paragraphs: We are making five recommendations. We recommend that the Secretary of  Defense direct the Under Secretary of Defense for Personnel and  Readiness to take the following actions in revising DOD’s solicitation  regulation:  Develop and implement, with the services, a DOD-wide searchable  violations database that uses consistent data elements and coding  across services. Solicitation coordinators or others at the installation  would then be required to enter the installation name, violating agent’s  name, insurance company supplying the product, type(s) of violation(s),  date and type of action taken, and other information important for  identifying patterns of violations and facilitating efficient data collection  and dissemination of information on confirmed violators to all  installations and state insurance regulators.
Specify in the revised directive that the installation commander is  responsible for notifying state insurance regulators, the service  secretariat, and DOD, when the commander has determined that agents  or companies have violated DOD, service, or installation policies.  Requiring installation commanders to contact appropriate state officials  regarding all confirmed violations of DOD’s commercial solicitation  directive increases the likelihood that state insurance officials will be  provided an opportunity to determine if further action such as  revocation of a state license is warranted.
Clarify the portion of the revised directive that pertains to the  cooling-off period that must elapse before junior enlisted personnel can  start an allotment to purchase supplemental life insurance. Addressing  and eliminating the ambiguities that we have identified about what is  required versus optional could result in better compliance with the  directive.
We recommend that the Secretary of Defense direct the Defense Finance  and Accounting Service to take the following actions:  Determine what current and future modifications should be made to the  regulations, forms, and procedures used to initiate and electronically  capture supplemental life insurance allotments so that more useable  data are available to the DOD, service, and installation offices  responsible for overseeing supplemental life insurance solicitation. This  step might include developing and implementing a single code and form  that would be used for supplemental life insurance allotments and to  document compliance with requirements that DOD has previously had  little visibility over.
Issue a message to all finance offices and the Defense Finance and  Accounting Service offices that process allotments for supplemental life  insurance to remind personnel that DOD’s Financial Management  Regulation indicates that only servicemembers or their designated  representatives with special power of attorney for the prescribed  purpose are authorized to start, stop, or modify financial allotments. If  deviations from the policy are warranted to allow mailed allotment  forms, the Defense Finance and Accounting Service should specify the  additional verification required in those situations.
section_title: Agency Comments and Our Evaluation
paragraphs: DOD’s comments are included in this report as appendix IV. DOD partially  concurred with our first two recommendations and fully concurred with  the three remaining recommendations.
In commenting for DOD, the Principal Deputy for Personnel and Readiness  raised three issues concerning the thoroughness and accuracy of our  review.
First, DOD incorrectly stated that our review was only to look at the  complaints of the insurance industry and that after we did not substantiate  these complaints, we instead looked at DOD’s oversight of commercial  insurance solicitation on DOD installations. While we were aware of the  industry’s complaints, we focused our review on broader systemic issues,  like the implementation of DOD and service poliies, procedures, and  regulations governing the marketing and sale of supplemental life  insurance on domestic military installations. Focusing on these systemic  issues, however, allowed us to determine whether the complaints had  merit. At every stage during our review, we emphasized that we were asked  to review compliance with DOD’s regulations and policies on both the  marketing and sale of life insurance on installations and the processing of  financial allotments for such products. For example, in the letter notifying  the Secretary of Defense that we were beginning our review and at our first  meeting with DOD and service representatives, we listed the following  three researchable questions: 1. What are DOD’s and the services’ policies and procedures for the  marketing and sale of life insurance policies to military personnel and  the processing of financial allotments for military personnel? 2. How do DOD and service regulations affect the marketing and sale of  life insurance policies and the processing of financial allotments to  military personnel? 3. How are the processes and procedures for the marketing and sale of  life insurance policies and the handling of financial allotments,  especially for commercial products like life insurance policies,  implemented at Fort Bragg, Fort Lewis, and other military installations?
Our report fully addressed solicitation and allotment issues in addition to  providing our congressional requesters with an update on the revision of  DOD’s personal commercial solicitation directive, as they also requested.  Further, DOD stated that our report makes only minor mention of the fact  that we did not substantiate the insurance industry’s assertions that  servicemembers were being prevented from using allotments to obtain life  insurance. To the contrary, we devoted a section of our report to the issue,  but that issue was only one of many allotment-related concerns that we  addressed in that portion of the report.
Second, DOD expressed concern about our use of survey data in examining  the extent to which insurance solicitation violations were occurring on  installations. The most significant reason for using the survey was the  incompleteness and other problems associated with the data that DOD  maintains on violations. The problems with those data are addressed more  fully in our later response to DOD’s partial concurrence with our first  recommendation. Because we were aware that survey data are  unsubstantiated, we supplemented that information with data gathered  from other sources such as DOD’s list of banned agents and information  gathered from a wide variety of individuals during our six visits to military  installations. DOD similarly conduits surveys to monitor other personnel  issues. For example, the Office of the Under Secretary of Defense for  Personnel and Readiness conducted a survey of over 75,000  servicemembers asking for unsubstantiated perceptions about racial/ethnic  discrimination and harassment and these data could be combined with  compliance-related information from DOD’s investigations of alleged  violations to give the department a more complete view of the issue. DOD  also stated that we should have disclosed the wording used in the survey.  The information that DOD reviewed in our figure 1 is the exact wording of  our survey items. Although the wording for the overall question, “During  the past 12 months, how often have the following practices concerning  supplemental life insurance taken place on the installation?” was changed  to a declarative sentence to increase readability, our paraphrasing is a true  representation of what we asked. Finally, the response rate of 75 percent  for our survey of all personal financial management program managers on  U.S. installations is higher than the rate obtained on recent DOD-wide  surveys such as the August 2004 survey which had a response rate of  40 percent. Given these facts, we believe that our discussion about the  extent of solicitation policy violations was appropriate, especially since  DOD had information on only the subset of violations serious enough to  merit banning an agent from an installation.
Lastly, DOD maintained that we made a false statement about the  department not knowing the extent of personal solicitation policy  violations. DOD’s point is incorrect on several grounds. First, early in our  review in May 2004, we asked DOD officials whether a DOD-wide database  existed that the services could use to report to DOD insurance agents or  companies that have had their solicitation privileges withdrawn. DOD  officials told us that while there was such a system, it was up to the  services to provide updated information. DOD officials said at the time  there was no comprehensive information available to document such  actions. In October 2004—approximately 5 months after we asked for a list  of all banned agents—DOD provided us with information similar to that  provided on its Commanders Page Web site as of April 2005. At the time we  received this information, the Director of the program that oversees  personal commercial solicitation told us that the list may not be complete  and accurate—which we found to be true—but that it provided all of the  information that the services had reported. Second, DOD’s list of banned  agents did not include all cases where insurance agents or companies were  banned. As we reported, personnel at Fort Bliss, Texas, indicated that the  installation commander had banned an agent who was not included on  DOD’s Commanders Page Web site as of April 2005. Third, unless DOD bans  every agent who violates in any way the solicitation policy regardless of the  severity of the violation, its data on banned agents are not equivalent to  knowing the extent of all confirmed violations.
Regarding DOD’s comments about our recommendations, DOD partially  concurred with our first recommendation to develop and implement a  searchable violations database, but DOD’s explanation of its partial  concurrence does not identify any additional steps to address the  deficiencies that we identified with their current procedures. As we noted  in our report, the monitoring system should focus on all confirmed  violations of solicitation policies and not just on those severe enough to  result in agents being banned. By establishing a database on all confirmed  violations, DOD would have a more complete picture of solicitation  violation activities to better identify patterns, types, and severity of  confirmed violations. If patterns are found, they could serve as the basis for  identifying actions to eliminate the recurring or systemic problems. Our  proposed database would also provide installation solicitation officers with  a resource to check whether agents requesting solicitation approval or  re-approval at their installations were involved in prior violations at other  locations.
DOD partially concurred with our second recommendation that installation  commanders notify state insurance regulators of confirmed violations of  solicitation policies. DOD’s position is that such reporting by installation  commanders should only be required when the violations involve the  eligibility of the agent to hold a state license and to meet other regulatory  requirements. We believe that DOD should report all confirmed violations  to state regulators. Installation commanders and their legal advisers may  not have the expertise needed to determine whether a solicitation violation  involved license-eligibility or regulatory requirements. Having installation  commanders report all confirmed violations to state regulators would  allow the regulators to decide whether further action is appropriate. As we  pointed out in our report, state insurance officials from North Carolina  were concerned that DOD’s lack of reporting violations prevented them  from determining whether further actions, such as revocation of licenses,  are warranted.
DOD concurred with our third recommendation and stated that it had  identified an additional ambiguity in the current revised directive regarding  who is responsible for monitoring and enforcing the cooling-off period for  supplemental life insurance purchases. DOD’s proposed revision addresses  the concerns that we raised.
DOD concurred with our fourth recommendation and stated that they will  consider our proposed changes for a future enhancement of their pay  system. In addition, DOD said that it will review its regulations and forms  to determine what current and future modifications should be made.
DOD concurred with our fifth recommendation and stated that it will issue  a message identifying who can start, stop, or modify allotments to all  finance offices and Defense Finance and Accounting Service offices that  process allotments.
As agreed with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days after its  issue date. At that time, we will provide copies of this report to interested  congressional committees and the Secretary of Defense. We will also make  copies available to others upon request. This report will be available at no  charge on GAO’s Web site at http://www.gao.gov.
If you or your staff have any questions regarding this report, please contact  me at (202) 512-5559 or stewartd@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff members who made major contributions to  this report are listed in appendix V.
section_title: Scope and Methodology
paragraphs: In addressing the objectives of our engagement, we reviewed reports that  had been issued by GAO, DOD, and others, including the life insurance  industry. We interviewed officials from DOD, life insurance companies and  associations, and other organizations, such as the Consumer Federation of  America, to identify the many perspectives on the issues being studied. In  connection with another report, we constructed, pre-tested, and  administered insurance- and allotment-related survey questions to all 175  installation-level managers of DOD’s personal financial management  programs located in the United States. We received completed surveys  from 131 installations, yielding an overall response rate of 75 percent,  which ranged from a low of 62 percent for the Air Force to 93 percent for  the Marine Corps. We also constructed, pre-tested, and administered an  e-mail survey to the insurance commissioners for the 50 states, the District  of Columbia, and four territories: American Samoa, Guam, Puerto Rico,  and the Virgin Islands. We received completed surveys from 46 states, the  District of Columbia, and one U.S. Territory, yielding an overall response  rate of 87 percent. We did not receive surveys from four states (California,  Delaware, Florida, and Idaho) and three territories (American Samoa,  Guam, and the Virgin Islands). We later contacted the four non-responding  states to verify if they had any investigations on insurance sales practices  on military installations, and only California responded to our inquiries. In  addition, we interviewed personnel from the state insurance  commissioner’s office for four of the six states where we conducted site  visits to military installations, as well as personnel for the commissioner’s  office in Georgia. We also asked insurance companies and two national  insurance associations to identify agents and company representatives who  could be interviewed about solicitation and allotment practices at the six  installations. During site visits, we requested materials related to the  marketing and sale of supplemental life insurance and the establishment of  allotments for that purpose. Those materials included a list of life  insurance agents approved for on-installation solicitation, handouts  distributed to assist servicemembers in determining their need for  supplemental life insurance, documentation for violations of personal  commercial solicitation and insurance-related policies, and complaints  related to insurance solicitation and allotments. While on the site visit, we  conducted individual interviews or focus groups with the following types of  individuals: installation leaders; the coordinator for the installation’s  commercial solicitation program; servicemembers; legal assistance  attorneys from the Judge Advocate General corps; finance department  personnel who managed and processed allotments; family support center  staff responsible for personal financial management training and  counseling activities; staff from morale, welfare, and recreation; and  representatives of on-installation banks and credit unions.
We limited our scope to the sale—marketing, solicitation, and purchase— of life insurance to active duty servicemembers on installations in the  United States. Emphasis was given to findings pertaining to junior enlisted  servicemembers since DOD and insurance officials have indicated that this  subgroup is more likely to encounter problems with the marketing and sale  of supplemental life insurance and establishment of an allotment for such a  purchase. During the course of our work, we visited six installations (see  table 3). We selected the installations based on inputs from DOD and  insurance officials, and with due consideration for the large number of  Army personnel deployed to Iraq and Afghanistan. We did obtain additional  information on completed and ongoing large-scale investigations of  violations that occurred on other installations: Fort Benning, Georgia, and  Fort Stewart, Georgia, although we did not conduct site visits to these  installations.
To address the extent to which agents were violating DOD’s policies  governing the solicitation of supplemental life insurance to active duty  servicemembers on domestic installations, we reviewed and analyzed  DOD, service, and selected installations’ policies and directives governing  personal commercial solicitation, primary among these was the DOD  directive on personal commercial solicitation on DOD installations. We  also reviewed DOD reports on commercial life insurance sales; materials  provided by insurance association and company officials, as well as  insurance agents; and state government announcements such as those  from the office of the Georgia state insurance commissioner about  investigations of and enforcement actions against some companies and  agents who sold supplemental life insurance to servicemembers. We  contacted the Federal Trade Commission to ascertain whether its Military  Sentinel system contained any information on complaints or investigations  on supplemental life insurance sales to servicemembers. We obtained a  wide range of perspectives about the sale of supplemental life insurance to  servicemembers during meetings with DOD and service headquarters  officials, officials from companies and two life insurance associations (the  American Council of Life Insurers and the National Association of  Insurance and Financial Advisors), and a representative of the Consumer  Federation of America. In addition to interviewing staff from the insurance  commissioners’ offices in four of the six states where we visited  installations and in the state of Georgia, we constructed, pre-tested, and  administered an e-mail survey to the insurance commissioners for the 50  states, the District of Columbia, and four territories. We also used  responses about supplemental life insurance-related issues from a survey  of all DOD personal financial management program managers, professional  staff employed on most installations who were responsible for  coordinating the financial management training, counseling, and other  assistance provided to servicemembers. During our site visits, we asked  that the command point of contact provide us with the following types of  materials: a list of life insurance agents approved for on-installation  solicitation, handouts distributed to assist servicemembers in determining  the need for supplemental life insurance, documentation for violations of  personal commercial solicitation and insurance-related policies, and  complaints related to insurance solicitation. While on the installation, we  conducted individual or focus group interviews with the following types of  installation personnel or offices: installation leadership, the coordinator for  the installation’s commercial solicitation program, legal assistance  attorneys from the Judge Advocate General corps, and family support  center staff responsible for financial training and counseling activities. We  also asked the life insurance associations and company officials for the  names of agents that we could interview while on our site visits. As part of  our site visits, we conducted interviews with on-installation bank and  credit union officials, asking about current and planned efforts to offer  supplemental life insurance through their financial institution.
To address how effectively DOD personnel are adhering to DOD’s  regulations that govern how active duty servicemembers establish payroll  allotments to purchase supplemental life insurance, we interviewed  officials from DFAS at their headquarters and field offices associated with  each service. We also reviewed and analyzed guidance documents  governing servicemembers’ use of allotments that DFAS, the services, and  selected installations provided to us. We interviewed finance officials at the  installations we visited and observed the data entry process used to  electronically transmit data from the installation to the payroll accounting  system maintained by DFAS. At several installations, we also interviewed  officials at administrative units that serve as intermediaries in the  processing of servicemembers’ allotments and asked questions as  personnel demonstrated the procedures used in submitting, processing,  and confirming allotment transactions.
To assess the extent to which the draft revision of DOD’s directive will  address ongoing problems with supplemental life insurance policies on  DOD installations, we reviewed the Department of Defense Appropriations  Act for Fiscal Year 2005 to determine the restrictions on when the draft  directive could be issued. We conducted interviews with DOD program  officials to discuss proposed changes, the reasons for the proposed  changes, and other issues related to the draft directive. Also, DOD provided  us with a copy of the draft directive as of January 2005 so that we could  compare and contrast it to the current version of the directive. We  compared that version to the one printed in the April 19, 2005, Federal  Register announcement. We subsequently contacted DOD policy officials  to determine whether DOD intended to again request comments after our  report was issued.
We performed our work from May 2004 through May 2005 in accordance  with generally accepted government auditing standards.
section_title: Details on Selected Recent In-Depth Investigations
paragraphs: We are providing synopses of the reports that investigators prepared after  they completed gathering data on alleged violations. We did not  independently attempt to verify the allegations or the weight of the  evidence supporting decisions reached by installation commanders.  Instead, we merely summarize the information provided in the investigative  reports.
Installation: Camp Pendleton, California Period when the violations occurred: October through November 2003 Description of the violations: An insurance agent approached an officer  requesting authorization to teach a class on veterans’ affairs benefits and  financial planning to squadron Marines. The officer believed the class  would benefit Marines and included the agent on the training schedule.  During the class, the agent spoke little about veterans’ benefits, focusing  more on investments. The agent distributed cards to obtain contact  information and later met with Marines while they were on duty or in their  homes to sell them policies. The agent described the policy as an  investment plan, rather than an insurance policy, guaranteed, as stated by  the agent, to provide Marines “$500,000 to $1,000,000 by the time they  reached their sixties.” The agent also tried to sell the investment plan to  Marines without appointments. During the meetings, Marines were given  the impression that the agent was a representative of the Department of  Veterans’ Affairs and was able to assist them in obtaining their benefits. On  one occasion, the agent tried to obtain a MyPay personal identification  number from a Marine.
Investigators determined that these actions violated prohibited solicitation  practices including providing financial planning and insurance classes  without prior approval; attempting to solicit or sell insurance without an  appointment; attempting to sell insurance in an unauthorized area; using  unfair, deceptive, misleading, or fraudulent schemes to encourage sales;  and soliciting to trainees.
Documentation to assess the scope of the problem: The investigation  report included sworn statements from 12 Marines who met with the agent  as well as two other Marines approached by the agent.
Estimated number of affected servicemembers: The initial class  included 15 to 25 Marines, and the agent conducted the class at least one  other time.
By the installation: Solicitation privileges for the agent were  suspended for two years for all Western area Marine Corps installations.
By the insurance company: The insurance company returned the  agent’s solicitation pass and ceased all operations on the installation  with no plans of reopening.
Installation’s interaction with state insurance commissioner’s  office: The installation recently provided copies of the investigation to the  state insurance commissioner.
Installation: Camp Pendleton, California Period when the violations occurred: May through September 2003 Description of the violations: Under the guise of presenting information  on veterans’ affairs benefits, two insurance agents obtained permission  from a commanding officer to provide the classes to Marines arriving from  boot camp, at which attendance was required. Four people conducted the  classes, including three insurance agents and the wife of one agent.  According to participants, the classes started with normal veterans’ benefit  discussions, but shifted into an investment and life insurance sales pitch  after non-commissioned officers left the room. The product was identified  as a “can’t lose proposition” and participants were told that participation  would earn them about $500,000 in just over 21 years. During the sales  pitch, agents distributed paperwork, including applications, allotment  forms, and statements of understanding, to the Marines. Participants were  encouraged not to read the forms and sign them quickly, leave the amounts  on the allotment forms blank, provide the insurance company  representatives access to MyPay personal identification numbers, and  provide signed photocopies of their identification cards. The agents  brought portable printers to the meetings to obtain the necessary  information. The Marines were not allowed to take paperwork with them,  being told that copies would be sent to their home of record.
Investigators determined that these actions violated prohibited solicitation  practices including soliciting military personnel who are in an on-duty  status; soliciting without appointment in areas utilized for the housing and  processing of transient personnel and in unit areas; using manipulative,  deceptive, or fraudulent devices, including misleading advertising and sales  literature; soliciting recruits, trainees, and other personnel while in a  “mass” or “captive” audience; and violating the requirement that at least  seven days elapse between the signing of a life insurance application and  the certification of an allotment for personnel in pay grades E1 through E3.
Documentation to assess the scope of the problem: The investigation  report included interviews from 26 Marines in the five classes. Additional  information, such as direct deposit forms and statements of understanding,  was also included.
Estimated number of affected servicemembers: 345  By the installation: Solicitation privileges for the agents were revoked  for Camp Pendleton and all Western region Navy and Marine Corps  installations.
By the insurance company: The insurance company shut down its  operations at Camp Pendleton and has no plans to reopen. The company  terminated the three agents involved, at least one of whom was a retired  Marine. Refunds were provided to 110 Marines before the June 8, 2004  cutoff date.
Installation’s interaction with state insurance commissioner’s  office: The investigation report recommended the California Department  of Insurance be notified of the report results. The installation recently  provided copies of the report to the state insurance commissioner.
Installation: Fort Benning, Georgia Period when the violations occurred: December 2003 through July 2004 Description of the violations: Four agents, two who were on Fort  Benning’s list of authorized insurance and investment agents, gained access  to soldiers in the Basic Combat Training Brigade through unit non- commissioned officers under the pretext of providing financial planning or  financial management classes. The agents conducted their briefings in unit  classrooms, discussing the value of investing and providing examples of  wealth accumulation. At the end of these presentations, soldiers wanting  additional information were asked to complete an informational form.  Following up on leads generated from the forms, the agents returned to the  unit area a few weeks later and met individually or in a small group with  soldiers. These follow-on meetings, involving the use of laptop computers  and direct deposit forms, took place in unit classrooms or unit dayrooms.  Fort Benning officials found that officers and non-commissioned officers  contributed to the solicitations and a number of drill sergeants knew of the  insurance presentations in the unit area.
Investigators determined that these actions violated prohibited solicitation  practices including soliciting during enlistment or induction processing or  during basic combat training; soliciting to mass, group, or captive  audiences; and misusing the allotment of pay system.
Documentation used to assess the scope of the problem: The  investigation report included sworn statements from a number of soldiers  who met with the agents. Additional information, such as direct deposit  forms, was also obtained.
Estimated number of affected servicemembers: 377  By the installation: Installation solicitation privileges for the agents  were revoked. Three officers and seven enlisted personnel involved  were reprimanded for failing to adequately safeguard the soldiers for  whom they had responsibility.
By the insurance company: The agents involved were fired from the  insurance companies they represented. The insurance company from  which most of the policies appear to have been sold has agreed to  provide refunds to soldiers.
Installation’s interaction with state insurance commissioner’s  office: The investigation report recommended that findings be shared with  the state licensing agencies. Installation officials have provided  information to the state of Georgia regarding these incidents.
Installation: Fort Benning, Georgia Period when the violations occurred: July 2002 through October 2002 Description of the violations: Two agents conducted financial  management briefings to soldiers in the infantry training brigade. The  agents gained access to soldiers through unit non-commissioned officers  under the pretext of providing financial management classes. The classes  were imbedded into the training schedule with other personal and financial  affairs presentations and were conducted in unit classrooms on the  installation. The soldiers were escorted to the classrooms by non- commissioned officers, and according to the investigation, some of the  non-commissioned officers had knowledge of the solicitation actions  taking place. In addition to the financial management classes, one of the  agents allegedly made insurance presentations in training areas to non- commissioned officers. During these presentations, some trainees met with  the agent and subsequently purchased life insurance policies.
Investigators determined that these actions violated prohibited solicitation  practices including soliciting during enlistment or induction processing or  during basic combat training; soliciting to mass, group, or captive  audiences; making appointments with or soliciting military personnel who  are in an “on duty” status; and using manipulative, deceptive, or fraudulent  devices or schemes to sell products, including misleading advertising and  sales literature.
Documentation used to assess the scope of the problem: The  investigation report included sworn statements from involved non- commissioned officers, soldiers who attended the briefings, and Army  community affairs officials who received complaints from two of the  soldiers involved.
Estimated number of affected servicemembers: 906  By the installation: Installation solicitation privileges for the two  agents were revoked.
By the insurance company: The agents involved were fired from the  insurance company they represented. The insurance company offered  refunds to affected persons, and as of May 2005, about 20 percent of the  soldiers received refunds.
Installation’s interaction with state insurance commissioner’s  office: Installation officials have provided information to the state of  Georgia regarding these incidents.
section_title: Allotment Forms
section_title: Comments from the Department of Defense
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the individual named above, James Cook, Jack Edwards,  Lynn Johnson, David Mayfield, Terry Richardson, Arnett Sanders, Cheryl  Weissman, and Kristy Williams made key contributions to this report.
section_title: Related GAO Products
paragraphs: Military Personnel: DOD Comments on GAO’s Report on More DOD  Actions Needed to Address Servicemembers’ Personal Financial  Management Issues. GAO-05-638R. Washington, D.C.: May 11, 2005.
Defense Base Act Insurance: Review Needed of Cost and Implementation  Issues. GAO-05-280R. Washington, D.C.: April 29, 2005.
Military Personnel: More DOD Actions Needed to Address  Servicemembers’ Personal Financial Management Issues. GAO-05-348.  Washington, D.C.: April 26, 2005.
Military Personnel: DOD’s Tools for Curbing the Use and Effects of  Predatory Lending Not Fully Utilized. GAO-05-349. Washington, D.C.:  April 26, 2005.
Credit Reporting Literacy: Consumers Understood the Basics but Could  Benefit from Targeted Educational Efforts. GAO-05-223. Washington, D.C.:  March 16, 2005.
DOD Systems Modernization: Management of Integrated Military  Human Capital Program Needs Additional Improvements. GAO-05-189.  Washington, D.C.: February 11, 2005.
Highlights of a GAO Forum: The Federal Government’s Role in  Improving Financial Literacy. GAO-05-93SP. Washington, D.C.:  November 15, 2004.
Military Personnel: Survivor Benefits for Servicemembers and Federal,  State, and City Government Employees. GAO-04-814. Washington, D.C.:  July 15, 2004.
Military Personnel: Active Duty Benefits Reflect Changing  Demographics, but Opportunities Exist to Improve. GAO-02-935.  Washington, D.C.: September 18, 2002.
Military Banking: Solicitations, Fees, and Revenue Potential.  GAO/NSIAD-99-72. Washington, D.C.: April 15, 1999.