U.S. DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-81,565

THE TRAVELERS INDEMNITY COMPANY
PERSONAL INSURANCE REMITTANCE CENTER
HARTFORD, CONNECTICUT

Notice of Affirmative Determination
Regarding Application for Reconsideration

By application dated August 9, 2012, workers requested
administrative reconsideration of the negative determination
regarding workers’ eligibility to apply for Trade Adjustment
Assistance (TAA) applicable to workers and former workers of The
Travelers Indemnity Company, Personal Insurance Remittance Center,
Hartford, Connecticut (Travelers-PIRC). The determination was
issued on June 27, 2012 and the Notice of Determination was
published in the Federal Register on July 18, 2012 (77 FR 42337).
The subject workers are engaged in activities related to the supply
of remittance payment processing services related to premium
payments.
The initial investigation resulted in a negative determination
based on the findings that Travelers-PIRC did not shift the supply
of remittance payment processing services (or like or directly
competitive services) to a foreign country, or acquire the supply
of such services from a foreign country. Rather, the services
formerly supplied by Travelers-PIRC are being performed by a third-
party vendor in Texas which also provides a new service that is
supplied on a limited, intermittent basis by a resource in India.
The initial investigation also revealed that Travelers-PIRC
did not increase its reliance on imports of like or directly
competitive services.
In the request for reconsideration, the workers allege that
the “limited, intermittent . . . resource in India” is “an entire
unit in India, literally processing an integral and essential part
of the daily work flow, each and every day, and on a regularly
scheduled basis. Without this unit, the processing of the vendor
would fail in its ability to process an important part of the daily
work load.” The request included non-proprietary support material.
The Department has carefully reviewed the request for
reconsideration and the existing record, and will conduct further
investigation to determine if the workers meet the eligibility
requirements of the Trade Act of 1974, as amended.
Conclusion
After careful review of the application, I conclude that the
claim is of sufficient weight to justify reconsideration of the
U.S. Department of Labor's prior decision. The application is,
therefore, granted.
Signed at Washington, D.C., this 20th day of August, 2012
/s/ Del Min Amy Chen
_______________________________
DEL MIN AMY CHEN
Certifying Officer, Office of
Trade Adjustment Assistance
4510-FN-P


DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-81,565

THE TRAVELERS INDEMNITY COMPANY
PERSONAL INSURANCE REMITTANCE CENTER
HARTFORD, CONNECTICUT

Negative Determination Regarding Eligibility
To Apply for Worker Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974, as
amended (“Act”), 19 U.S.C. § 2273, the Department of Labor herein
presents the results of an investigation regarding certification of
eligibility to apply for worker adjustment assistance.
Workers of a firm may be eligible for worker adjustment
assistance if they satisfy the criteria of subsection (a), (b) or
(e) of Section 222 of the Act, 19 U.S.C. § 2272(a), (b) and (e).
For the Department of Labor to issue a certification for workers
under Section 222(a) of the Act, 19 U.S.C. § 2272(a), the following
criteria must be met:
(1) The first criterion (set forth in Section 222(a)(1) of the
Act, 19 U.S.C. § 2282(a)(1)) requires that a significant
number or proportion of the workers in the workers’ firm must
have become totally or partially separated or be threatened
with total or partial separation.

(2) The second criterion (set forth in Section 222(a)(2) of the
Act, 19 U.S.C. § 2272(a)(2)) may be satisfied in one of two
ways:
(A) Increased Imports Path:
(i) sales or production, or both, at the workers’ firm must
have decreased absolutely, AND
(ii) (I) imports of articles or services like or directly
competitive with articles or services produced or
supplied by the workers’ firm have increased, OR
(II)(aa) imports of articles like or directly
competitive with articles into which the component
part produced by the workers’ firm was directly
incorporated have increased; OR
(II)(bb) imports of articles like or directly
competitive with articles which are produced
directly using the services supplied by the
workers’ firm have increased; OR
(III) imports of articles directly incorporating
component parts not produced in the U.S. that are
like or directly competitive with the article into
which the component part produced by the workers’
firm was directly incorporated have increased.
(iii) the increase in imports described in clause (ii)
contributed importantly to such workers’ separation or
threat of separation and to the decline in the sales or
production of such firm.

(B) Shift in Production or Supply Path:
(i)(I) there has been a shift by the workers’ firm to a
foreign country in the production of articles or supply
of services like or directly competitive with those
produced/supplied by the workers’ firm; OR
(II) there has been an acquisition from a foreign country
by the workers’ firm of articles/services that are like
or directly competitive with those produced/supplied by
the workers’ firm; and
(ii) the shift described in clause (i)(I) or the acquisition
of articles or services described in clause (i)(II)
contributed importantly to such workers’ separation or
threat of separation.

For the Department to issue a secondary worker certification
under Section 222(b) of the Act, 19 U.S.C. § 2272(b), to workers of
a Supplier or a Downstream Producer, the following criteria must be
met:
(1) a significant number or proportion of the workers in the
workers’ firm or an appropriate subdivision of the firm
have become totally or partially separated, or are
threatened to become totally or partially separated;

(2) the workers’ firm is a Supplier or Downstream Producer to
a firm that employed a group of workers who received a
certification of eligibility under Section 222(a) of the
Act, 19 U.S.C. § 2272(a), and such supply or production
is related to the article or service that was the basis
for such certification; and

(3) either
(A) the workers’ firm is a supplier and the component
parts it supplied to the firm described in paragraph (2)
accounted for at least 20 percent of the production or
sales of the workers’ firm;
or
(B) a loss of business by the workers’ firm with the firm
described in paragraph (2) contributed importantly to
the workers’ separation or threat of separation.

Section 222(c) of the Act, 19 U.S.C. § 2272(c), defines the
terms “Supplier” and “Downstream Producer.”
Workers of a firm may also be considered eligible if they are
publicly identified by name by the International Trade Commission
as a member of a domestic industry in an investigation resulting in
a category of determination that is listed in Section 222(e) of the
Act, 19 U.S.C. § 2272(e).
The group eligibility requirements for workers of a firm under
Section 222(e) of the Act, 19 U.S.C. § 2272(e), can be satisfied if
the following criteria are met:
(1) the workers’ firm is publicly identified by name by the
International Trade Commission as a member of a domestic
industry in an investigation resulting in--
(A) an affirmative determination of serious injury or
threat thereof under section 202(b)(1);
(B) an affirmative determination of market disruption
or threat thereof under section 421(b)(1); or
(C) an affirmative final determination of material
injury or threat thereof under section 705(b)(1)(A)
or 735(b)(1)(A) of the Tariff Act of 1930 (19
U.S.C. 1671d(b)(1)(A) and 1673d(b)(1)(A));

(2) the petition is filed during the 1-year period beginning
on the date on which--
(A) a summary of the report submitted to the President
by the International Trade Commission under section
202(f)(1) with respect to the affirmative
determination described in paragraph (1)(A) is
published in the Federal Register under section
202(f)(3); or
(B) notice of an affirmative determination described in
subparagraph (1) is published in the Federal
Register; and

(3) the workers have become totally or partially
separated from the workers’ firm within--
(A) the 1-year period described in paragraph (2); or
(B) notwithstanding section 223(b)(1), the 1-year
period preceding the 1-year period described in
paragraph (2).

The investigation was initiated in response to a petition
filed on May 3, 2012 on behalf of workers of The Travelers
Indemnity Company, Personal Insurance Remittance Center, Hartford,
Connecticut (The Travelers Indemnity Company). The workers’ firm is
engaged in activities related to the supply of property-liability
insurance and reinsurance products and services. The subject worker
group is engaged in the supply of remittance payment processing
services related to the premium payments.
The petitioners alleged that a significant number of functions
(i.e. data entry, balancing, account lookup, verifications)
formerly performed by the subject worker group have been outsourced
to India.
During the course of the investigation, information was
collected from the petitioners and the workers’ firm.
With respect to Section 222(a)(2)(A)(ii) of the Act, the
investigation revealed that the firm did not import remittance
payment processing services or a service like or directly
competitive with the services supplied by The Travelers Indemnity
Company in 2010, 2011, or during the period of January through
April 2012.
With respect to Section 222(a)(2)(B) of the Act, the
investigation revealed that the firm did not shift the supply of
remittance payment processing services or a service like or
directly competitive with the services supplied by The Travelers
Indemnity Company to a foreign country or acquire remittance
payment processing services or a service like or directly
competitive with the services supplied by The Travelers Indemnity
Company from a foreign country. The investigation revealed that a
significant proportion of the remittance payment processing
services formerly performed by the subject worker group are now
supplied by a third-party provider in Texas, U.S.A. The third-party
vendor changed the work process to add a new service, which is
provided on a limited, intermittent basis by a resource in India.
However, the investigation revealed that the off-shore resource did
not directly replace any of the core work functions that were
previously performed by the subject worker group. The Department
did not survey The Travelers Indemnity Company’s customers based on
the internal nature of the service supplied.
With respect to Section 222(b)(2) of the Act, the
investigation revealed that The Travelers Indemnity Company is not
a Supplier to a firm that employed a group of workers who received
a certification of eligibility under Section 222(a) of the Act, 19
U.S.C. § 2272(a).
With respect to Section 222(b)(2) of the Act, the
investigation revealed that The Travelers Indemnity Company does
not act as a Downstream Producer to a firm (or subdivision,
whichever is applicable) that employed a group of workers who
received a certification of eligibility under Section 222(a) of the
Act, 19 U.S.C. § 2272(a).
Finally, the group eligibility requirements under Section
222(e) of the Act, have not been satisfied either because Criterion
(1) has not been met since the workers’ firm has not been
publically identified by name by the International Trade Commission
as a member of a domestic industry in an investigation resulting in
an affirmative finding of serious injury, market disruption, or
material injury, or threat thereof.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that the requirements of Section 222 of
the Act, 19 U.S.C. § 2272, have not been met and, therefore, deny
the petition for group eligibility of The Travelers Indemnity
Company, Personal Insurance Remittance Center, Hartford,
Connecticut engaged in activities related to the supply of
remittance payment processing services to apply for adjustment
assistance, in accordance with Section 223 of the Act, 19 U.S.C. §
2273.
Signed in Washington, D.C. this 27th day of June, 2012.


/s/Elliott S. Kushner
______________________________
ELLIOTT S. KUSHNER
Certifying Officer, Office of
Trade Adjustment Assistance







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