Voya 2014 Annual Report Download - page 81

Other Laws and Regulations
USA Patriot Act
The Patriot Act contains anti-money laundering and financial transparency laws applicable to broker-dealers
and other financial services companies, including insurance companies. The Patriot Act seeks to promote
cooperation among financial institutions, regulators and law enforcement entities in identifying parties that may
be involved in terrorism or money laundering. Anti-money laundering laws outside of the United States contain
provisions that may be different, conflicting or more rigorous. Internal practices, procedures and controls are
required to meet the increased obligations of financial institutions to identify their customers, watch for and
report suspicious transactions, respond to requests for information by regulatory authorities and law enforcement
agencies and share information with other financial institutions.
We are also required to follow certain economic and trade sanctions programs administered by the Office of
Foreign Asset Control that prohibit or restrict transactions with suspected countries, their governments and, in
certain circumstances, their nationals. We are also subject to regulations governing bribery and other anti-
corruption measures.
Privacy Laws and Regulation
U.S. federal and state laws and regulations require financial institutions, including insurance companies, to
protect the security and confidentiality of personal information and to notify consumers about their policies and
practices relating to their collection and disclosure of consumer information and the protection of the security and
confidentiality of that information. The disclosure and security of protected health information is also governed
by federal and state laws. In particular, regulations promulgated by the U.S. Department of Health and Human
Services regulate the disclosure and use of protected health information by health insurers and others (including
life insurers), the physical and procedural safeguards employed to protect the security of that information and the
electronic transmission of such information. Federal and state laws require notice to affected individuals, law
enforcement, regulators and others if there is a breach of the security of certain personal information, including
social security numbers, and require holders of certain personal information to protect the security of the data.
Federal regulations require financial institutions to implement effective programs to detect, prevent and mitigate
identity theft. Federal and state laws and regulations regulate the ability of financial institutions to make
telemarketing calls and to send unsolicited e-mail or fax messages to consumers and customers. Federal laws and
regulations also regulate the permissible uses of certain types of personal information, including consumer report
information. Federal and state governments and regulatory bodies may consider additional or more detailed
regulation regarding these subjects.
Environmental Considerations
Our ownership and operation of real property and properties within our commercial mortgage loan portfolio
is subject to federal, state and local environmental laws and regulations. Risks of hidden environmental liabilities
and the costs of any required clean-up are inherent in owning and operating real property. Under the laws of
certain states, contamination of a property may give rise to a lien on the property to secure recovery of the costs
of clean-up, which could adversely affect the valuation of, and increase the liabilities associated with, the
commercial mortgage loans we hold. In several states, this lien has priority over the lien of an existing mortgage
against such property. In addition, we may be liable, in certain circumstances, as an “owner” or “operator,” for
costs of cleaning-up releases or threatened releases of hazardous substances at a property mortgaged to us under
the federal Comprehensive Environmental Response, Compensation and Liability Act of 1980 and the laws of
certain states. Application of various other federal and state environmental laws could also result in the
imposition of liability on us for costs associated with environmental hazards.
We routinely conduct environmental assessments prior to closing any new commercial mortgage loans or to
taking title to real estate. Although unexpected environmental liabilities can always arise, we seek to minimize
this risk by undertaking these environmental assessments and complying with our internal environmental policies
and procedures.
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