DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-81,815

HARTFORD FINANCIAL SERVICES GROUP, INC.
COMMERCIAL/ACTUARIAL/
INFORMATION DELIVERY SERVICES (IDS)/CORPORATE & FINANCIAL REPORTING
GROUP
HARTFORD, CONNECTICUT


Notice of Negative Determination
on Reconsideration

On December 4, 2012, the Department of Labor issued an
Affirmative Determination Regarding Application for Reconsideration
for the workers and former workers of Hartford Financial Services
Group, Inc., Commercial/Actuarial/Information Delivery Services
(IDS)/Corporate & Financial Reporting group, Hartford, Connecticut
(The Hartford-IDS Group). The Department’s Notice of determination
was published in the Federal Register on January 4, 2013 (78 FR 773).
The Hartford-IDS Group is engaged in activities related to the
supply of financial services. The Hartford-IDS Group develops
databases for creating reports for corporate, regulatory, and
financial services. The Hartford-IDS Group is separately identifiable
from other groups within Hartford Financial Services Group, Inc.
Workers within the Hartford-IDS Group provide business and
information technology applications for corporate, regulatory, and
financial reporting.
Pursuant to 29 CFR 90.18(c), reconsideration may be granted
under the following circumstances:
(1) If it appears on the basis of facts not previously
considered that the determination complained of
was erroneous;
(2) If it appears that the determination complained of
was based on a mistake in the determination of facts
not previously considered; or
(3) If in the opinion of the Certifying Officer, a mis-
interpretation of facts or of the law justified
reconsideration of the decision.
The initial investigation resulted in a negative determination
based on the findings that, with respect to Section 222(a) and
Section 222(b) of the Trade Act of 1974, as amended (the Act),
Criterion (1) has not been met because a significant number or
proportion of the workers in such workers’ firm have not become
totally or partially separated, nor are they threatened to become
totally or partially separated.
The request for reconsideration states that “The Hartford
Financial Services employs nearly 10,000 employees in Connecticut.
The majority work full-time hours and are employed at the 690 Asylum
Ave, Hartford, Connecticut site, the location of the petition in
question . . . According to a former employee . . . his Unit was an
independent unit isolated from others, but the information prepared
by his unit, the database, was used by many units within The
Hartford. His particular Unit encompassed roughly 75 employees. While
only a few workers have been laid off to date in the specific unit,
the database was used by . . . units that have been TAA-certified.”
Information obtained during the reconsideration investigation
confirmed that with respect to Section 222(a) and Section 222(b) of
the Act, Criterion (1) has not been met because a significant number
or proportion of the workers in such workers’ firm have not become
totally or partially separated, nor are they threatened to become
totally or partially separated.
Significant number or proportion of the workers means that: (a)
In most cases the total or partial separations, or both, in a firm or
appropriate subdivision thereof, are the equivalent to a total
unemployment of five percent (5 percent) of the workers or 50
workers, whichever is less; or (b) At least three workers in a firm
(or appropriate subdivision thereof) with a work force of fewer than
50 workers would ordinarily have to be affected (29 CFR 90.2).
A careful review of previously-submitted information and
information obtained during the reconsideration investigation
revealed that the worker group consisting of Hartford-IDS Group did
not meet this requirement.
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.
Therefore, after careful review of the request for
reconsideration, the Department determines that 29 CFR 90.18(c) has
not been met.


Conclusion
After careful review, 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 Hartford
Financial Services Group, Inc., Commercial/Actuarial/Information
Delivery Services (IDS)/Corporate & Financial Reporting group,
Hartford, Connecticut, to apply for adjustment assistance, in
accordance with Section 223 of the Act, 19 U.S.C. § 2273.
Signed in Washington, D.C. on this 11th day of January, 2013
/s/ Del Min Amy Chen
_______________________________
DEL MIN AMY CHEN
Certifying Officer, Office of
Trade Adjustment Assistance
4510-FN-P


CORRECTED: SEPTEMBER 19, 2012

DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-81,815

HARTFORD FINANCIAL SERVICES GROUP, INC.
COMMERCIAL/ACTUARIAL/
INFORMATION DELIVERY SERVICES (IDS)/CORPORATE & FINANCIAL REPORTING
GROUP
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 three
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.

Section 222(c) of the Act, 19 U.S.C. § 2272(c), defines the
terms “Supplier” and “Downstream Producer.” 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.

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 July 19, 2012 by a state workforce office on behalf of workers of
Hartford Financial Services Group, Inc.,
Commercial/Actuarial/Information Delivery Services (IDS)/Corporate &
Financial Reporting group, Hartford, Connecticut (The Hartford). The
workers’ firm is engaged in activities related to the supply of
financial services. Specifically, the workers provide business and IT
applications for corporate, regulatory, and financial reporting. The
group develops databases for creating reports for corporate,
regulatory, and financial services. The group is separately
identifiable from other groups at the firm.
The petitioner alleges that the database activities were shifted
to a foreign country. Workers were required to train other workers
not located in the United States.
During the course of the investigation, information was
collected from the workers’ firm and the petitioners.
With respect to Section 222(a) and Section 222(b) of the Act,
the investigation revealed that Criterion (1) has not been met
because a significant number or proportion of the workers in such
workers’ firm, have not become totally or partially separated, nor
are they threatened to become totally or partially separated.
Significant number or proportion of the workers means that: (a)
In most cases the total or partial separations, or both, in a firm or
appropriate subdivision thereof, are the equivalent to a total
unemployment of five percent (5 percent) of the workers or 50
workers, whichever is less; or (b) At least three workers in a firm
(or appropriate subdivision thereof) with a work force of fewer than
50 workers would ordinarily have to be affected (29 CFR 90.2).



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 Hartford Financial Services Group, Inc.,
Commercial/Actuarial/Information Delivery Services (IDS)/Corporate &
Financial Reporting group, Hartford, Connecticut engaged in
activities related to the supply of financial services, specifically
providing business and IT applications (databases) for corporate,
regulatory, and financial reporting, to apply for adjustment
assistance, in accordance with Section 223 of the Act, 19 U.S.C. §
2273.
Signed in Washington, D.C. this 2nd day of August, 2012

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





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