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For employees who died while in petitioner's employ,
petitioner filed an Employer's Statement through its plan
administrator, Coventry, who would then present the claim to AIG.
Coventry, as plan administrator, was responsible for ascertaining
employee deaths for those employees that died while no longer in
petitioner's employ.
Westport Management, an organization that performs
administrative services for life insurance companies, was engaged
by AIG and WJ/Coventry to administer petitioner's COLI policies.
In order to ascertain deaths of former employees, Coventry would
ask Westport to perform "Social Security sweeps", by checking
data base files to determine whether any covered former employee
had died. After the purchase of the policies and input of the
COLI policy data on its computer system, Westport began its
administrative duties, regularly preparing performance and
accounting reports, which were provided to Coventry and AIG. On
every policy anniversary, Westport calculated all values on a
monthly basis for all policies for the coming year. On
petitioner's behalf, Coventry administered the COLI plan, acted
as an intermediary with AIG, and checked reports and other
information provided by AIG and Westport to ensure correctness.
Every month and on request, Coventry received reports from
Westport on past and expected performance of the policies and
policy loans. From these reports, Coventry generated annual and
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