Commissioner Joel Ario
1209 Strawberry Square
Harrisburg, PA 17120
Dear Commissioner Ario:
In your approval of the trust to hold the Senior Health Insurance Company of Pennsylvania, you preempted any possibility of different opinions concerning the trust, through your decision to not hold a public hearing. Therefore, you, in effect, determined the validity of the trust by yourself. You may say, opinions were expressed within the comment period, but were they? considering ninety percent of policyholders hadn't a clue about the proposed trust to hold their LTC policies. To claim the comment period was announced in the Pennsylvania Bulletin was pure "Doublespeak." Would you reasonably suspect that a policyholder living in Florida would read the Pennsylvania Bulletin? You have in your possession the Milliman Actuarial 5 year projection for the trust, but have made it unavailable in the public domain, although it may give one a much clearer understanding of the future of the trust.
Bill Silverman
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Heidi B. Shakely
Eckert Seamans Cherin & Mellott
213 Market St., 8th floor
Harrisburg, PA 17101
RE: Senior Health Insurance Company of Pennsylvania: Milliman, Inc. Actuarial Report
In considering the approval of the above listed company in November, 2008, it appears to not be substantiated by anything other than the PA commissioner's order: no public hearing, no information to policyholders, other than the most vague allusion to change of company, vetting of interested parties during the comment period appearing as a mere formality with replies from the department vague and misdirected.
A darkness surrounds the Milliman document with the claim of privileged confidential information, making me dubious about the need for such secrecy.
That, combined with not being willing to hold an informational hearing, seems to further cloud the issue of motivation; of using authority improperly.
I request to have sent to me by letter, or email, the full Milliman Report. I feel the report will better enable me to understand the commissioner's justification for approving the trust.
Very Truly Yours,
Bill Silverman
Tuesday, March 10, 2009
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