The Regulatory Environment

MIB is subject to a myriad of laws governing the use of consumer reports and addressing the privacy of individually identifiable information (information that is associated with individuals). In addition, MIB is deeply committed to providing its services to member life and health insurance companies in a manner that allows their full compliance with applicable laws protecting the privacy and security of consumer information.  

By providing our Checking Service, MIB is a "nationwide specialty consumer reporting agency" subject to the federal Fair Credit Reporting Act ("FCRA"). This classification signifies that MIB is a "consumer reporting agency" that issues "consumer reports" that are not credit reports. Because MIB's operations are regulated as a consumer reporting agency under FCRA, it provides both Canadian and U.S. consumers with the rights, protections and privileges available under FCRA without any differentiation based on residence or, citizenship. However, to the extent MIB is subject to any of Canada’s provincial credit reporting laws and such laws differ from the requirements under the FCRA, MIB will provide Canadian residents with the additional rights, protections and privileges available under such laws.  In short, MIB conducts its operations throughout North America with a consistently high degree of confidentiality and security. 

Because MIB member companies are governed by the Gramm-Leach-Bliley Act ("GLBA"), the Health Insurance Portability and Accountability Act and Health Information Technology for Economic and Clinical Health Act (collectively, "HIPAA”), federal marketing-related laws (e.g., the Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM) and the Telephone Consumer Protection Act (TCPA)), and numerous state privacy laws, and Canadian members are governed by the Personal Information Protection and Electronic Documents Act ("PIPEDA") and equivalent provincial laws, MIB conducts its business in a manner that allows its members to comply with such laws. 

Under HIPAA, MIB is a Business Associate of members engaged in the business of certain types of health insurance (Covered or Hybrid Entities) and, accordingly, MIB has certain privacy and security obligations and restrictions regarding Protected Health Information. Under HIPAA, MIB has implemented administrative, physical and technical safeguards that meet the requirements of the HIPAA Security Rule, as well as written policies and procedures that meet the requirements of both the Privacy Rule and the Security Rule.