Another effort that is underway is a 'how-to' guide that would offer regulators guidance on market conduct compliance by focusing on complaints, market share and supplemental pages filed with a company's annual statement.

The launch will include a Web site devoted to the data call project. Companies will be able to download documents and send data through the site. The NAIC site will also list contacts in nine states that are participating in the pilot.

Initially, there had been 10 states that were scheduled to participate in the pilot. However, the Arizona state insurance department said it could not guarantee that data companies submitted to it through the NAIC site could be kept confidential because of state laws on public information.

The issue of confidentiality was one of the major concerns of insurers as the details of the project were advanced. Insurers told regulators that they were concerned that trade secrets and other information could become public and that information could be used by class-action attorneys against companies.

Because of this concern, the data will be passed on through the site to individual state insurance departments which will analyze the data for market conduct by companies that fall outside the norm. Regulators have said that they are confident that in this way they can protect information and allay companies' concerns.

Letters will go out this week to insurance company presidents or the executive with the next ranking as listed on the last annual statement. The pilot will start with life insurance companies which will have 90 days to complete the request. A report is expected by early 2003.

The property-casualty industry will start the data gathering process from Jan.-June 2003, with a report due later in 2003.

The American Council of Life Insurers, Washington, and the Alliance of American Insurers, Downers Grove, Ill., have been in contact with members alerting them to the project and the data call, according to representatives for the trade organizations.

Life insurers have asked for clarification on certain points in the data call, according to Linda Lanam, ACLI vice president and deputy general counsel.

For instance, she said, a question on surrenders led to a request for clarification on whether a conversion of a term insurance contract would be considered a surrender.

A request for clarification, whether a replacement's question referred to groups, was answered by regulators who said the question was not directed to group contracts.

In general, life insurers have the data, she added. But in certain cases, it could require a need for reprogramming computer systems. For instance, Ms. Lanam explained, if data has been collected in the aggregate, and state specific data is requested, that could result in reprogramming. Companies have been asked to keep track of costs associated with reprogramming so that that information can be included when a report is prepared, she said.