Structured Settlements: The Department of Justice's Selection and Use of
Annuity Brokers (Letter Report, 02/16/2000, GAO/GGD-00-45).
Pursuant to a congressional request, GAO provided information on the
Department of Justice's (DOJ) policy and guidance for selecting
structured settlement brokers, focusing on: (1) discussing the policies
and guidance for selecting structured settlement brokers used by DOJ and
six selected agencies; and (2) providing a list of the structured
settlement brokerage companies used by DOJ and the number of settlements
awarded to each company since May 1997.
GAO noted that: (1) in 1993 and 1997, DOJ issued policies and guidance
on the selection of structured settlement brokers to promote fairness
and to avoid the appearance of favoritism; (2) DOJ officials told GAO
that its policies and guidelines permit some discretion and that when
selecting a particular broker, they generally relied on such factors as
reputation, past experience, knowledge, and location; (3) however, DOJ
officials also told GAO they were unable to specify reasons why
attorneys selected particular brokers to settle specific cases, because
DOJ did not require documentation of these decisions; (4) without an
internal control requiring the reasons for selecting a particular
settlement broker be documented and readily available for examination,
it is more difficult to verify that selection policies and guidelines
were followed and, in turn, to avoid the appearance of favoritism and
preferential treatment; (5) overall, the six federal agencies surveyed
described policies and guidance in selecting structured settlement
brokers that were similar to DOJ's; (6) none of the agencies had
internal controls requiring their attorneys to document their reasons
for selecting a specific broker; (7) one agency had a written
supplemental policy governing the use of structured settlements, but it
did not require documentation of decisions; (8) officials at the other
five federal agencies said they also generally relied on such factors as
reputation, past experience, knowledge, and location for selecting a
particular structured settlement broker; (9) however, the reasons why
particular brokers were selected for specific cases were not documented;
(10) GAO's review of the list of structured settlement brokerage
companies used by DOJ and the number of settlements assigned to each
company showed that DOJ selected a few companies to handle most of its
structured settlement business; (11) according to DOJ, the companies
frequently have multiple offices and brokers that compete with each
other within the same company; (12) thus, a simple count of the number
of companies could be misleading; (13) although DOJ used 27 different
structured settlement companies to settle 242 claims for about $236
million between May 1, 1997, and May 1, 1999, 70 percent (169 cases)
were awarded to 4 brokerage companies; and (14) of the remaining 23
companies, none were awarded more than 17 cases each.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: GGD-00-45
TITLE: Structured Settlements: The Department of Justice's
Selection and Use of Annuity Brokers
DATE: 02/16/2000
SUBJECT: Damage claims
Torts
Internal controls
Claims settlement
Litigation
Government liability (legal)
Malpractice (medical)
IDENTIFIER: PHS National Vaccine Injury Compensation Program
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United States General Accounting Office
GAO
Report to the Honorable
James M. Inhofe, U.S. Senate
February 2000
GAO/GGD-00-45
STRUCTURED SETTLEMENTS
The Department of Justice's Selection and Use of
Annuity Brokers
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Contents
Page 121GAO/GGD-00-45 Selection and Use of Annuity Brokers
Letter 1
Appendix 14
Comments From the
Department of Justice
Tables Table 1: Annuity Settlements for DOJ 8
(May1997 to May 1999)
Abbreviations
AUSA Assistant United States Attorney
DOJ Department of Justice
EOUSA Executive Office for United States
Attorneys
FTCA Federal Tort Claims Act
HHS Department of Health and Human Services
NSSTA National Structured Settlement
Association
VA Department of Veterans Affairs
VICP National Vaccine Injury Compensation
Program
B-283058
Page 11GAO/GGD-00-45 Selection and Use of Annuity
Brokers
B-283058
February 16, 2000
The Honorable James M. Inhofe
United States Senate
Dear Senator Inhofe:
The federal government solicits the services of
private brokers to assist in structuring
settlements with claimants in lawsuits against
federal agencies. Because private brokers can earn
lucrative commissions from insurance companies, it
is important that the Department of Justice (DOJ)
has criteria and a system of controls to promote
fairness and avoid the appearance of favoritism in
selecting these brokers. This report responds to
your request that we review DOJ's policy and
guidance for selecting structured settlement
brokers. As agreed with your office, this report
(1) discusses the policies and guidance for
selecting structured settlement brokers used by
DOJ and six selected agencies1 and (2) provides a
list of the structured settlement brokerage
companies used by DOJ and the number of
settlements awarded to each company since May
1997.
Results in Brief
In 1993 and 1997, DOJ issued policies and guidance
on the selection of structured settlement brokers
to promote fairness and to avoid the appearance of
favoritism. DOJ officials told us that its
policies and guidelines permit some discretion and
that when selecting a particular broker, they
generally relied on such factors as reputation,
past experience, knowledge, and location. However,
DOJ officials also told us they were unable to
specify reasons why attorneys selected particular
brokers to settle specific cases, because DOJ did
not require documentation of these decisions.
Without an internal control2 requiring that the
reasons for selecting a particular settlement
broker be documented and readily available for
examination, it is more difficult to verify that
selection policies and guidelines were followed
and, in turn, to avoid the appearance of
favoritism and preferential treatment.
Overall, the six federal agencies we surveyed
described policies and guidance in selecting
structured settlement brokers that were similar to
DOJ's. Also, like DOJ, none of the agencies had
internal controls requiring their attorneys to
document their reasons for selecting a specific
broker. One agency had a written supplemental
policy governing the use of structured
settlements, but it did not require documentation
of decisions. Officials at the other five federal
agencies said they also generally relied on such
factors as reputation, past experience, knowledge,
and location for selecting a particular structured
settlement broker. However, as was the case with
DOJ, the reasons why particular brokers were
selected for specific cases were not documented.
Our review of the list of structured settlement
brokerage companies used by DOJ and the number of
settlements assigned to each company showed that
DOJ selected a few companies to handle most of its
structured settlement business. 3 According to
DOJ, the companies frequently have multiple
offices and brokers that compete with each other
within the same company. Thus, a simple count of
the number of companies could be misleading.
Although DOJ used 27 different structured
settlement companies to settle 242 claims for
about $236 million between May 1, 1997, and May 1,
1999, 70 percent (169 cases) were awarded to 4
brokerage companies. Of the remaining 23
companies, none were awarded more than 17 cases
each.
We are recommending that DOJ (1) establish
internal controls that require its officials to
document the reasons for selecting a particular
broker or brokerage company to settle a case and
(2) disseminate this guidance to federal agencies
responsible for handling structured settlement
claims.
Background
A structured settlement is the payment of money
for a personal injury claim in which at least part
of the settlement calls for future payment. The
payments may be scheduled for any length of time,
even as long as the claimant's lifetime, and may
consist of installment payments and/or future lump
sums. Payments can be in fixed amounts, or they
can vary. The schedule is structured to meet the
financial needs of the claimant.
For years, structured settlements have been widely
used in the tort area4 to compensate severely
injured, often profoundly disabled, tort victims.
Cases generally involve medical malpractice and
other personal injury. The Federal Tort Claims Act
(FTCA)5 is the statute by which the United States
authorizes tort suits to be brought against
itself. With certain exceptions,6 it makes the
United States liable for injuries caused by the
negligent or wrongful act or omission of any
federal employee acting within the scope of his or
her employment, in accordance with the law of the
state where the act or omission occurred.
Generally, a tort claim against the United States
is barred unless it is presented in writing to the
appropriate federal agency within 2 years after
the claim accrues.
In addition, the National Childhood Vaccine Injury
Act of 1986, as amended, created a mechanism for
compensating persons injured by certain
pharmaceutical products. The act established the
National Vaccine Injury Compensation Program
(VICP)7 as an alternative to traditional product
liability and/or medical malpractice litigation
for persons injured by their receipt of one or
more of the standard childhood vaccines required
for admission to schools and by certain employers.8
VICP is "no-fault." That is, claimants need not
establish that the vaccine was defective, or that
any degree of negligence was involved in its
administration. The only liability-related
question is causation-did the vaccine cause the
injury for which compensation is sought?
The industry standard of practice requires the use
of a licensed broker or insurance agent to obtain
a settlement annuity. DOJ's Civil Division9
estimated that structured settlements constitute
between 1 and 2 percent of all settlements in
litigated tort cases. Brokers receive no direct
compensation from the government; rather, they are
compensated by the insurance company from whom the
annuity is purchased. The insurance company
typically pays the brokers' commissions, which
amount to 3 or 4 percent of the annuity premium.
The government attorney negotiating the case is
responsible for selecting the broker.
Structured settlements for the federal government
are negotiated by the Civil Division's torts
attorneys, Assistant United States Attorneys
(AUSAs), or agency attorneys. AUSAs are authorized
to settle certain cases. An agency may not settle
a tort claim for more than $25,000 without the
prior written approval of the Attorney General or
her designee, unless the Attorney General has
delegated to the head of the agency the authority
to do so.10
Objectives, Scope, and Methodology
To ascertain DOJ's policies and guidance for the
selection of settlement brokers, we reviewed the
Torts Branch handbook, Damages Under the Federal
Tort Claim Act (section V: Settlements), and other
relevant documents pertaining to broker selection
policies. In addition, to obtain information about
the procedures used to select brokers, we
interviewed attorneys in DOJ's Civil Division and
representatives from the Executive Office for
United States Attorneys (EOUSA).
To obtain information on broker selection policies
and guidance used by federal agencies, we asked
DOJ to identify other federal agencies that
handled structured settlement claims. DOJ
identified six agencies-HHS and VA; the Air Force,
Army, and Navy; and the U.S. Postal Service. At
each of the six agencies, we met with officials
who were responsible for negotiating structured
settlement claims. We discussed their policies and
procedures for selecting structured settlement
brokers and asked them what factors they
considered during the selection process. In
addition, we obtained and reviewed a copy of the
Army's standard operating procedures pertaining to
structured settlements. Also, we asked the six
agencies to supply information pertaining to the
number of structured settlements since May 1997.
To provide the list of DOJ's structured settlement
annuities between May 1, 1997, and May 1, 1999, we
used data DOJ collected from the Civil Division
and the United States Attorneys Offices. The Civil
Division's data came from the Torts Branch, which
routinely handles structured settlements. The
United States Attorneys' data were collected by
EOUSA and include all the data received by EOUSA
as of August 12, 1999. As of that date, 34 of the
94 United States Attorneys offices had reported
annuity settlements during the relevant time
period.11 We did not verify the accuracy of the
information collected from the Torts Branch or
EOUSA.
To gain a broader understanding of structured
settlements, we met with the Executive Vice
President of the National Structured Settlement
Trade Association (NSSTA).12 We obtained
information concerning brokers working with
federal structured settlements.
We did our audit work between June and December
1999 in accordance with generally accepted
government auditing standards. We requested
comments on a draft of this report from the United
States Attorney General or her designee. Also, in
January we discussed the contents of this report
with VA's Assistant General Counsel; U.S. Postal
Service' Claims Division Counsel; and the Army's
Torts Claims Division Chief. Also, we obtain
comments for the Air Force and Navy from DoD's
Senior Report Analysis for the GAO Affairs
Directorate. In addition, we spoke with HHS'
Associate General Counsel. The written and oral
comments we received are discussed near the end of
the report.
Federal Policies for Selecting Structured
Settlement Brokers Lacked Adequate Internal
Control
Although DOJ had established policies and guidance
for the selection of structured settlement
brokers, the policies and guidance did not include
an internal control requiring attorneys to
document their reasons for selecting a specific
broker. Similarly, although the six agencies we
reviewed said they generally followed DOJ's policy
guidance for selecting a structured settlement
broker, they were not required to document their
reasons for selecting a particular broker. None of
these agencies documented the reasons why they
selected particular brokers.
DOJ Did Not Document Reasons for Selecting Brokers
DOJ had established policies and guidance
governing the selection of structured settlement
brokers, but it did not require that the reasons
for selecting a specific broker be documented. On
July 16, 1993, the Director of the Civil
Division's Torts Branch, which is responsible for
FTCA claims and litigation, issued a memorandum
that was intended to supplement the guidance on
structured settlements in the Damages Handbook and
to codify previous informal guidance on the
selection of structured settlement brokers.
Neither the Damages Handbook nor the memorandum
addressed documenting the reasons for selecting a
specific broker.
On June 30, 1997, the Acting Associate Attorney
General expanded the policy guidance by issuing a
memorandum to United States Attorneys. However,
the new guidance did not address documenting the
reasons for broker selections. Generally, the 1997
policy guidance outlined procedures concerning the
selection of structured settlement brokers. These
included:
� Every broker was to be given an opportunity
to promote its services.
� No lists of "approved," "preferred," or
"disapproved" brokers were to be maintained.
� Brokers who performed well in the past were
to be appropriately considered for repeated use:
however, such use could not be to the exclusion of
new brokers.
� Attorneys were expected to look to
supervisory attorneys for assistance; however,
final broker selection was the responsibility of
the attorney negotiating the settlement.
� When a structured settlement in an FTCA case
included a reversionary interest13 in favor of the
United States, the Torts Branch's FTCA staff was
to be consulted to maintain appropriate records
and ensure consistency.
� Any activity tending toward an appearance of
favoritism, any action contrary to any of the
above rules, or any activity incongruent with the
spirit of the memorandum was to be scrupulously
avoided.
According to agency officials, attorneys sometimes
asked each other about their experiences with a
particular broker, but the attorney negotiating
the case is responsible for making the final
broker selection, and is not required to consult
with the FTCA staff. DOJ officials told us that in
the absence of a requirement to do so, they did
not document the reasons for selecting particular
settlement brokers.
The Comptroller General's guidance on internal
controls in the federal government, Standards for
Internal Control in the Federal Government
(GAO/AIMD-00-21.3.1), requires that all
transactions and significant events are to be
clearly documented and that the documentation is
to be readily available for examination. The
documentation should appear in management
directives, administrative policies, or operating
manuals and may be in paper or electronic form.
All documentation and records should be properly
managed and maintained.
Selected Agencies Did Not Document Reasons for
Selecting Brokers
During 1999, DOJ provided its policy guidance14 to
the six selected agencies in our review-HHS and
VA; the Air Force, Army, and Navy; and the Postal
Service. Generally, the selection processes the
agencies said they had were similar to DOJ's,
(e.g., the attorney negotiating a case made the
final decision, no list of approved or disapproved
structured settlement brokers was maintained).
Five agencies in our review identified various
factors they considered when selecting a
structured settlement broker. For example:
� HHS, Postal Service, and VA officials told us
that they tended to select brokers with offices in
the Washington, D.C., area. According to VA
officials, the use of distantly located brokers
created problems because of (1) differences in
time zones and (2) the inability of nonlocal
brokers to physically conduct work on short
notice.
� Air Force, Navy, and VA officials told us
that they put considerable weight on an impressive
presentation given by the broker's firm.
� HHS, Navy, Postal Service, and VA officials
said they looked at the broker's knowledge and
experience in handling structured settlement cases
for the federal government and based their
selections on positive past experiences.
� Navy and Postal Service officials said they
looked for brokers with a reputation for being
dependable and responsible.
In addition, the Army had established supplemental
policies governing the selection of structured
settlement brokers. According to the Army's
standard operating procedures, brokers were to be
selected on a case-by-case basis according to the
following criteria: (1) the broker's ability to
become a member of the negotiating team,
participate in negotiations, and travel at his or
her own expense; (2) the selecting administrative
officer's previous interviews with or knowledge of
the broker; (3) the broker's ability to present
his views verbally (if the case requires in-person
negotiations); and (4) the broker's experience if
the administrative officer is inexperienced. In
certain more specialized cases, the selecting
administrative officer's choice of a specific
broker must be approved by a higher authority.
Even though federal agencies we surveyed said they
provided policy guidance on broker selection, none
of them required documentation of the reasons for
selecting a structured settlement broker. In the
absence of this requirement, none documented the
reason for selection.
DOJ Selected a Few Brokers to Handle Most
Settlements Claims
DOJ has selected several structured settlement
brokerage companies to handle most of the
structured settlement claims. Between May 1,
1997, and May 1, 1999, DOJ used 27 different
structured settlement brokerage companies to
settle 242 claims for $236 million. (See table 1
for the number and total annuity costs of annuity
settlements handled by brokers.) Of the 242 claims
awarded, 70 percent (169 cases) were awarded to 4
brokerage companies. One of the four companies
was awarded 30 percent (72 cases) of the total
number of cases. The remaining 23 companies were
awarded 30 percent of the total number of cases.
Table 1: Annuity Settlements for DOJ (May1997 to
May 1999)
Brokerage a Number of Total annuity
settlements cost
AIG Life Insurance 1 $97,000
Company
Allstate Life 1 99,333
Insurance Company
Brant Hickey & 10 4,894,998
Associates
Canada Life 1 100,000
Assurance Company
Creative 8 8,249,758
Settlement
Consultants
Delta Group 26 33,800,720
Garrett Wong & 1 1,000,000
Associates
GE Capital 1 150,000
Assurance
Halpern Group 1 484,505
Huver & 7 3,550,800
Associates, Inc.
JMW Settlements, 35 29,235,685
Inc.
Joe Huver, Amicus 3 760,000
Group
Kenneth H. Wells & 1 16,430
Associates
Legal Economic 1 156,500
Evaluations, Inc.
Minet Settlement 1 171,719
Services, Inc.
Near North 2 406,946
Financial Group
Near North 2 700,129
Insurance
Brokerage, Inc.
Pension Company 2 1,351,381
Ringler 36 24,039,764
Associates, Inc.
Settlement 17 21,691,697
Associates, Inc.
Settlement 5 3,339,803
Planning
Associates
Settlement 1 500,000
Professionals,
Inc.
Sheerin 2 689,810
Corporation
Structured 72 99,283,574
Financial
Associates
Structured Funding 2 600,000
Group
Structured 2 380,000
Settlement Company
Summit Settlement 1 250,000
Services
Total 242 $236,000,552
Note 1: DOJ settlements may Include annuity
settlements for the Torts Branch, Civil Division
and the U.S. Attorney Offices.
Note 2: Thirteen U.S. Attorney offices did not
provide structured settlement data.
a Includes four insurance carriers (AIG Life
Insurance Company, Allstate Life Insurance
Company, GE Capital Assurance, and Canada Life
Assurance Company) because the name of the
structured settlement broker was not included in
the data.
Source: DOJ data.
Because DOJ did not document the reasons for
selecting a particular broker, DOJ officials could
not specifically say why certain companies
received more business than others. However, as
noted previously, DOJ officials cited a variety of
reasons for selecting a specific structured
settlement broker, such as experience,
dependability, and knowledge of federal structured
claims.
According to DOJ, the companies frequently have
multiple offices and brokers that compete with
each other within the same company. Thus, a
simple count of the number of companies could be
misleading.
Conclusions
DOJ has developed policies and guidance for
selecting structured settlement brokers and
disseminated this information to the six other
federal agencies with authority to handle
structured settlement claims that we contacted.
However, the policies and guidance lacked an
internal control requiring that the reasons for
selecting a broker be documented and readily
available for examination. This is important
because without documentation of transactions or
other significant events, DOJ can not be certain
that its policies and guidance on selecting
structured settlement brokers are being followed.
Further, without documentation on the reasons
settlement brokers were selected, it is more
difficult to avoid the appearance of favoritism
and preferential treatment in a situation where
some brokers get significantly more business than
others.
Recommendations
We recommend that the Attorney General of the
United States direct the Director of the Torts
Branch responsible for FTCA claims and litigation,
Civil Division, to
� develop an adequate internal control to
ensure that the reasons for selecting structured
settlement brokers are always fully documented and
readily available for examination; and
� disseminate this guidance to federal
agencies, including those in our survey,
responsible for handling structured settlement
claims.
Agency Comments
We requested comments on a draft of this report
from the Attorney General or her designee. On
January 18, 2000, the Acting Assistant Attorney
General, Civil Division provided us with written
comments, which are printed in full in appendix I.
The Justice Department expressed appreciation that
the report "outlines the many steps undertaken by
the Department to ensure fairness in the broker
selection process."
DOJ said its existing policies and guidance to
ensure that the selection of brokers is fair are
effective. Therefore, it disagreed with our
recommendation that DOJ implement an adequate
internal control to ensure that the reasons for
selecting a specific structured settlement broker
are always fully documented and readily available
for examination. DOJ noted that the Comptroller
General's Standards for Internal Control in the
Federal Government specify that management should
design and implement internal controls based on
the related costs and benefits. It stated that it
was DOJ's belief that the costs of implementing
the recommendation, in terms of diversion of
attention from substantive issues and generation
of extra paperwork, would substantially outweigh
any benefits.
We recognize that determining whether to implement
a particular internal control involves a judgment
about whether the benefits outweigh the costs. We
believe that the benefits of implementing our
recommendation would outweigh any associated costs
and paperwork. As stated in this report, these
benefits are twofold: requiring documentation
would help enable DOJ to (1) determine if its
policies and guidance on selecting brokers are
being followed and (2) protect DOJ from charges of
favoritism towards a specific broker or brokers.
Further, noting the reasons for selecting a
specific broker in the case file at the time the
selection is made would appear to require only
minimal paperwork or cost. For example, a concise
memo to the file stating the rationale for the
selection would suffice.
DOJ also expressed concern that, although we
observed that most structured settlements have
been awarded to a relatively small number of
companies, we did not mention that many of the
selected companies had multiple offices and
brokers that competed for the same work.
According to DOJ, by "treating as a monolith all
brokers affiliated with the major companies, the
draft report ignores the actual way those
businesses are run and runs the risk of
significantly understating the actual number of
brokers competing to handle DOJ structured
settlements."
In response, we have noted that according to DOJ,
because structured settlement companies may have
multiple offices and brokers, the number of
companies could be misleading. Data were not
readily available for us to determine the extent
to which multiple brokers within a single company
competed for the same settlement. Nevertheless,
the number and cost of settlements by brokerage
company show that DOJ placed the majority of its
settlement work with a relatively small number of
companies-a situation that still could open it up
to charges of favoritism towards these companies.
Cognizant officials at HHS, VA, Air Force, Army,
Navy, and the Postal Service said they generally
agreed with the information presented in the
report. The Army provided additional information
to clarify its policy for selecting structured
settlement brokers, and we incorporated this
information in the report where appropriate.
We are sending copies of this report to Senator
Orrin G Hatch, Chairman, and Senator Patrick J.
Leahy, Ranking Minority Member, Senate Committee
on the Judiciary; Representative Henry J. Hyde,
Chairman, and Representative John Conyers, Jr.,
Ranking Minority Member, House Committee on the
Judiciary; and the Honorable Janet Reno, the
Attorney General. We are also sending copies to
other interested congressional parties. Copies
will also be made available to others upon
request.
If you or your staff have any questions, please
call me or Weldon McPhail on (202) 512- 8777. Key
contributors to this assignment were Mary Hall and
Jan Montgomery.
Sincerely yours,
Richard M. Stana
Associate Director, Administration
of Justice Issues
_______________________________
1The six selected agencies were the Departments of
Health and Human Services (HHS) and Veterans
Affairs (VA); the Air Force, Army, and Navy; and
the United States Postal Service.
2The Comptroller General's Standards for Internal
Control in the Federal Government (GAO/AIMD-00-
21.3.1) requires that all transactions and
significant events are to be clearly documented
and that the documentation is to be readily
available for examination.
3 Thirteen of the 94 U.S. Attorneys offices did
not provide structured settlement data.
4A tort is a civil wrong, not including a breach
of contract, for which the injured party is
entitled to damages.
528 U.S.C. 1346(b), 2671-2680.
6Three major exceptions under which the United
States may not be held liable, even in
circumstances where a private person could be held
liable under state law, are the Feres doctrine,
which prohibits suits by military personnel for
injuries sustained incident to service; the
discretionary function exception, which immunizes
the United States for acts or omissions of its
employees that involve policy judgments; and the
intentional tort exception, which precludes suits
against the United States for assault and battery,
and certain other intentional torts, unless they
are committed by federal law enforcement or
investigative officials.
7 42 U.S.C. 300aa-10 et seq.
8 Currently, the vaccines covered under the
Program are those administered to protect against
diphtheria, tetanus, pertussis (whooping cough),
measles, mumps, rubella (German measles), polio,
hepatitis B, varicella (chicken pox), Haemophilus
influenzae type b, and rotavirus.
9The responsibilities of DOJ's Civil Division
include representing the United States, its
agencies, and its employees in suits where
monetary judgments are sought for damages
resulting from negligent or wrongful acts.
10 For example, the Attorney General has delegated
the authority to settle tort claims of up to
$200,000 to the Secretary of Defense.
11Thirteen offices did not respond to EOUSA's
request for information.
12NSSTA is an organization composed of more than
500 members who negotiate and fund structured
settlements of tort and worker's compensation
claims involving persons with serious, long-term
physical injuries. Founded in 1986, NSSTA's stated
mission is to advance the use of structured
settlements as a means of resolving physical
injury claims.
13Reversionary interest is the interest that a
person has in the reversion of lands or other
property.
14This guidance was contained in a June 30, 1997,
memorandum from the Acting Associate Attorney
General to the United States Attorneys regarding
the selection of structured settlement brokers.
Comments From the Department of Justice
Page 16GAO/GGD-00-45 Selection and Use of Annuity
Brokers
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