Predictive Analytics in Insurance

Chapter 12
Deployment, MLOps and Digital Transformation

Post Graduate Program in Insurance Management
Predictive Analytics in Insurance   •   Post Graduate

Deployment, MLOps and Digital Transformation

Introduction

Predictive analytics creates organisational value only when its outputs influence real decisions. A well-calibrated claims-severity model has little value if it remains in a notebook, cannot access current policy data, or produces scores that claims staff cannot interpret. Deployment is therefore the movement of an analytical model from development into a controlled operational environment. MLOps extends this idea by applying software engineering, data engineering, governance and operational monitoring to the entire machine-learning lifecycle.

In insurance, deployment is especially consequential. Models may influence underwriting eligibility, premium indications, claims triage, fraud investigation, reserving, customer retention and regulatory reporting. These decisions operate within legacy policy-administration systems, claims platforms, regulatory constraints, service-level agreements and human judgement. Digital transformation is consequently not equivalent to purchasing an artificial-intelligence platform. It is the coordinated redesign of processes, technology, governance, skills and accountability.

This chapter examines scoring pipelines, APIs, decision engines, cloud platforms, model governance, monitoring, retraining, cybersecurity, integration with core systems, and build-buy-partner choices. The emphasis is strategic and operational: the central question is not merely whether a model is accurate, but whether it is reliable, explainable, secure, economically justified and responsibly embedded in insurance operations.

Learning Objectives

By the end of this chapter, the learner should be able to:

  1. Distinguish batch scoring, real-time scoring, APIs and decision engines.
  2. Design a controlled model deployment and MLOps lifecycle.
  3. Select appropriate monitoring metrics for data, models, systems and business outcomes.
  4. Explain versioning, testing, retraining, cybersecurity and governance requirements.
  5. Evaluate cloud and hybrid architectures for insurance analytics.
  6. Integrate predictive services with policy, billing and claims systems.
  7. Formulate build-buy-partner decisions and a practical transformation roadmap.

1. From Model Development to Operational Decision

A predictive model estimates an outcome; an operational system converts that estimate into an action. For a claim, a model may estimate the probability of suspected fraud. A decision process then combines that probability with claim value, available investigation capacity, regulatory rules and human review. The distinction is important:

  • Prediction answers “What is likely to happen?”
  • Decisioning answers “What should the organisation do?”
  • Execution ensures that the chosen action is recorded and performed.

A typical deployment chain is:

Data sources → data preparation → feature computation → model scoring → business rules → human or automated action → outcome capture → monitoring and learning.

The model should not silently redefine a business process. Its scope, intended population, decision owner, input variables, limitations, override rules and acceptable use should be documented in a model card or equivalent governance record.

Batch and real-time scoring

Batch scoring evaluates many records on a schedule—for example, scoring an entire renewal portfolio overnight. It is efficient and appropriate where decisions do not require an immediate response. Real-time scoring evaluates a single case during an interaction, such as quoting a motor policy or routing a newly submitted claim.

Batch systems normally optimise throughput and reproducibility. Real-time systems prioritise latency, availability and graceful failure. A model that takes 800 milliseconds may be acceptable for overnight renewal scoring but unsuitable for a quote journey requiring a rapid response. The required service-level objective should therefore be defined before architecture is selected.

APIs and decision engines

An application programming interface (API) exposes model functionality to another system. A scoring API commonly receives validated features and returns a score, model version, timestamp, reason codes and status information. The API should not accept ungoverned arbitrary inputs; authentication, schema validation, rate limiting and audit logging are essential.

A decision engine usually combines predictive scores with deterministic rules, thresholds, eligibility constraints and referral logic. For example:

  • if a claim is outside coverage, refer for coverage review;
  • otherwise, if the fraud score exceeds a governed threshold, route to investigation;
  • otherwise, continue automated processing, subject to random quality sampling.

Separating the model from the decision policy is valuable because business rules may change more frequently than the model. It also makes accountability clearer: the model estimates risk, while the authorised business process determines how that estimate is used.

2. Deployment Architectures

Core components

A production architecture commonly contains:

ComponentMain responsibility
Source systemsSupply policy, customer, billing, claims and external data
Data platformStore, transform and govern historical and current data
Feature pipelineProduce model inputs consistently in training and production
Model registryRecord approved model artifacts, metadata and versions
Serving layerExecute batch jobs or real-time inference
Decision layerApply thresholds, rules, referrals and overrides
Workflow systemAssign work and record actions
Monitoring layerDetect technical, data, model and business problems
Governance repositoryPreserve approvals, evidence, documentation and audit trails

A major risk is training-serving skew: the feature calculated during development differs from the feature calculated during production. For instance, training may use a claim count measured at policy inception, while production accidentally uses a count updated after the claim event. Feature definitions, time windows and data lineage must therefore be shared or formally reconciled.

Cloud, on-premises and hybrid deployment

Cloud platforms provide elastic computing, managed storage, specialised machine-learning services and rapid experimentation. They can reduce infrastructure lead time, but they introduce questions concerning data residency, concentration risk, vendor dependence, identity management, cost control and exit planning. On-premises deployment may provide greater direct control and support existing systems, but capacity expansion, specialist skills and disaster recovery can be expensive.

A hybrid architecture is often practical for insurers. Sensitive systems may remain within controlled environments while model training, de-identified experimentation or elastic workloads use approved cloud services. The choice should be based on risk, latency, regulatory requirements, total cost of ownership and strategic capability—not on the assumption that cloud is automatically superior.

3. The MLOps Lifecycle

MLOps is a socio-technical operating model rather than a single tool. It joins data science with engineering, operations, security, actuarial practice, compliance and business ownership.

Lifecycle stages

  1. Problem definition: specify the decision, population, target, time horizon, action and success criteria.
  2. Data and feature preparation: establish data contracts, lineage, quality rules and reproducible transformations.
  3. Experimentation: record code, data snapshots, parameters, metrics and assumptions.
  4. Validation: test predictive performance, calibration, stability, fairness, leakage and business usefulness.
  5. Registration: store the candidate artifact and metadata in a controlled model registry.
  6. Approval: obtain technical, actuarial, risk, compliance and business approvals appropriate to materiality.
  7. Deployment: release through controlled environments, such as development, test, staging and production.
  8. Observation: monitor service health, input data, output behaviour, outcomes and controls.
  9. Change or retirement: retrain, roll back, replace or retire the model with documented rationale.

A production model is not simply a file containing coefficients. It includes the model artifact, preprocessing code, feature definitions, dependencies, environment specification, model version, training data reference, evaluation results, approval record and rollback procedure.

Versioning and reproducibility

At minimum, organisations should version:

  • source code and configuration;
  • training and validation datasets or immutable references;
  • feature definitions and transformations;
  • model parameters and artifacts;
  • container or runtime dependencies;
  • API schemas and decision rules;
  • documentation and approvals.

A useful release identifier links these items. Reproducibility means that an authorised team can reconstruct what was deployed, with which data and under which assumptions. It does not necessarily mean that every future run will produce bit-for-bit identical results; software libraries, hardware and random seeds can affect outcomes. Such differences should be understood and controlled.

4. Testing Before and After Release

Testing must cover more than predictive accuracy.

Data and feature tests

Data tests may check schema, data type, permitted ranges, missingness, uniqueness, referential integrity and timeliness. A policy premium should not be negative unless explicitly permitted; a date of loss should not precede the policy inception date without a documented explanation. Feature tests should verify calculation windows and prevent post-event information from entering a prediction.

Model tests

Model validation should include discrimination, calibration, stability and subgroup analysis. For a binary event, calibration concerns whether predicted probabilities correspond to observed frequencies. If a group of policies receives an average predicted probability of 0.20, approximately 20% should experience the event over a sufficiently large and relevant sample, subject to sampling variation and changing conditions.

A common discrimination measure is the area under the receiver operating characteristic curve (AUC), but AUC alone does not establish commercial value or fairness. For imbalanced fraud data, precision, recall and the precision-recall curve may be more informative. For continuous claim cost, mean absolute error and root mean squared error may be used, but the selected metric must reflect the decision’s cost structure.

System and integration tests

System tests should address latency, throughput, availability, authentication, failure handling, duplicate requests, timeouts and compatibility with core systems. A model service should return a controlled response when an external data provider is unavailable. Possible responses include a documented fallback model, manual referral or conservative rule; silently using stale or empty values is unsafe.

Deployment strategies

  • Shadow deployment: the new model scores live cases but does not affect decisions.
  • Canary release: the model serves a small, monitored proportion of traffic.
  • A/B or controlled testing: alternative treatments are compared where ethically and operationally appropriate.
  • Blue-green deployment: two production environments exist, allowing rapid switchback.
  • Champion-challenger: the approved champion remains operational while a challenger is evaluated.

The strategy should match the decision’s materiality. A claims triage model may support a controlled pilot; a pricing change may require actuarial, regulatory and governance approval before any customer-facing experiment.

5. Monitoring and Retraining

Monitoring should distinguish four dimensions.

DimensionExamples of indicatorsTypical response
SystemLatency, availability, error rate, throughputRepair service, scale capacity, fail over
DataMissingness, range violations, schema changes, driftInvestigate source or pipeline
ModelCalibration, discrimination, score distribution, stabilityReview model or population change
BusinessLoss ratio, claim handling time, conversion, complaints, referralsReassess decision policy and value

Drift

Data drift is a change in input distributions. Concept drift is a change in the relationship between inputs and the target. Performance drift is deterioration in observed predictive performance. These are related but distinct. A changing age distribution may be data drift without immediate performance deterioration; a new fraud pattern may cause concept drift even when input distributions appear stable.

For a numerical variable, a simple population stability index can be used as a screening measure:

PSI = ∑ᵢ (Aᵢ − Eᵢ) ln(Aᵢ / Eᵢ)

Here, categories or bins are indexed by i; Aᵢ is the current proportion in bin i; and Eᵢ is the reference or expected proportion. Both proportions must be positive. PSI is unitless and depends on binning; it is a signal for investigation, not a universal decision threshold or proof that a model is invalid.

Retraining should not be triggered solely by an arbitrary calendar schedule. A governed policy can combine time, volume, drift, performance, business change and regulatory events. Retraining also requires fresh labels. Claims outcomes may take months to mature, so a model can appear to have poor performance simply because recent cases are not yet fully developed.

Thresholds and operational capacity

Suppose a fraud model produces a probability p and investigation has a cost Cᵢ. If a missed fraud creates expected cost Cₘ, a simplified threshold rule refers a case when the expected benefit of investigation exceeds its cost. In a highly simplified binary setting, referral may be justified when:

p × Cₘ > Cᵢ

where p is the estimated probability of fraud, Cₘ is the avoided expected loss if fraud is detected, and Cᵢ is investigation cost. This expression assumes a reliable probability, a single avoidable loss estimate and no additional customer, legal or capacity effects. Real decisions require investigation yield, false-positive costs, severity variation, available capacity and fairness constraints. Thus a statistical threshold is not automatically an operational threshold.

6. Integration with Insurance Core Systems

Insurance environments commonly include policy administration, rating, billing, claims, document management, CRM, payment, reinsurance and regulatory-reporting systems. Integration patterns include:

  • synchronous APIs for immediate quotation or claim routing;
  • asynchronous events for claim creation, payment or policy changes;
  • scheduled files for legacy platforms;
  • data warehouses and lakehouses for analytical workloads;
  • robotic process automation only where APIs are unavailable and control risks are acceptable.

Integration design must specify the system of record, identifier standards, event timing, reconciliation process and ownership of corrections. For example, if a scoring service receives a policy version different from the billing system, the organisation must determine which version governs the decision and how inconsistency is logged.

A reliable decision record should preserve the input snapshot or references, model and rule versions, score, reason codes, decision, user or service identity, timestamp, override and subsequent outcome. Such records support customer service, complaints, audit, model validation and legal discovery.

7. Cybersecurity, Privacy and Responsible Use

Machine-learning systems enlarge the attack surface because they combine sensitive data, automated decisions and interconnected services. Key controls include:

  • least-privilege identity and access management;
  • encryption in transit and at rest;
  • secrets management rather than credentials in code;
  • network segmentation and endpoint protection;
  • vulnerability and dependency scanning;
  • secure software supply-chain controls;
  • input validation and rate limiting;
  • immutable audit logs and anomaly detection;
  • tested backup, recovery and incident-response procedures.

Threats include unauthorised data access, model theft, data poisoning, adversarial inputs, prompt or tool misuse in generative systems, compromised dependencies and denial of service. Model-extraction risk is relevant where repeated API queries can reveal model behaviour. Rate limits, monitoring and controlled outputs can reduce exposure.

Privacy governance requires purpose limitation, data minimisation, retention controls, access rights and lawful processing. Sensitive proxies may create discriminatory outcomes even when protected attributes are excluded. Fairness assessment should consider the relevant decision, legally protected groups, business justification, error trade-offs and the effect of human review. No single fairness metric is universally correct: equal selection rates, equal error rates and calibration can conflict under differing base rates. Governance therefore requires contextual judgement and documented rationale.

Explainability should be proportionate to the decision. A simple reason code such as “recent loss history increased referral likelihood” may assist a claims handler, but reason codes must be faithful to the model and not misleading. For high-impact decisions, human oversight, appeal routes and override monitoring are important. Human involvement is not a sufficient safeguard if staff merely approve automated outputs without meaningful review.

8. Operating Model and Accountability

Successful deployment requires clear roles. A practical model is:

  • Business owner: accountable for the decision, value and customer impact.
  • Data scientist: develops and validates the analytical method.
  • ML or data engineer: operationalises pipelines and services.
  • Platform or DevOps engineer: manages environments, reliability and release.
  • Model risk or validation team: independently challenges assumptions and results.
  • Security and privacy specialists: assess threats and controls.
  • Compliance and legal functions: interpret applicable obligations.
  • Actuarial and claims experts: evaluate insurance relevance and consequences.

The three-lines model can be useful: operational teams own and control the process; risk and compliance provide oversight and challenge; internal audit provides independent assurance. Small insurers may combine roles, but they should not eliminate independence for material models.

Model documentation should include purpose, population, target definition, data sources, exclusions, methodology, performance, limitations, fairness analysis, implementation details, monitoring plan, approval date and retirement criteria. Model inventory management prevents “shadow models” from operating without governance.

9. Build, Buy or Partner

The build-buy-partner decision is strategic rather than purely technical.

OptionStrengthsRisks and suitable conditions
BuildTailored capability, control, differentiationCost, skills shortages, maintenance burden
BuyFaster implementation, vendor expertise, product maturityVendor lock-in, opacity, integration and data concerns
PartnerShared investment and domain capabilityDependency, governance complexity, unclear accountability

A decision should assess total cost of ownership, including implementation, cloud consumption, licences, integration, validation, monitoring, retraining, cyber controls, staff and retirement. It should also consider strategic differentiation. Commodity capabilities such as generic document classification may be bought, while underwriting knowledge, proprietary data and distinctive decision logic may justify internal ownership.

Vendor due diligence should examine service-level commitments, incident notification, subcontractors, data location, model update practices, audit rights, portability, intellectual-property ownership, testing evidence and termination assistance. A vendor does not transfer the insurer’s accountability for customer outcomes or regulatory compliance.

10. Digital Transformation Roadmap

Transformation should proceed through controlled value delivery rather than a technology “big bang.” A staged roadmap may be:

Stage 1—Discover and govern: inventory processes and models; identify high-value use cases; define data ownership, risk tiers and target architecture.

Stage 2—Stabilise foundations: improve data quality, identifiers, APIs, observability, access management and model documentation.

Stage 3—Pilot: choose a bounded use case with measurable value and manageable risk, such as claims triage or renewal propensity. Use shadow or canary deployment.

Stage 4—Industrialise: establish reusable pipelines, registries, CI/CD controls, monitoring, validation and operating procedures.

Stage 5—Scale and redesign: integrate multiple decisions, redesign workflows, develop workforce capabilities and retire duplicative legacy processes.

Stage 6—Optimise responsibly: evaluate outcomes, customer impacts, resilience, cost and fairness; revise the portfolio and architecture.

Transformation metrics should include business value, customer outcomes, operational reliability, adoption, cycle time, control effectiveness and staff capability. A reduction in claim handling time is not a success if complaint rates or leakage rise. Balanced scorecards are therefore preferable to a single accuracy or savings metric.

Applied Case: Illustrative Claims-Triage Deployment

Background

Consider “Harbour Mutual,” a fictional mid-sized general insurer. Claims handlers manually review all motor claims. Management proposes a model that predicts the probability that a claim requires specialist investigation. The objective is to reduce avoidable delays while preserving fair access to claims service.

Problem

A prototype model performs well in historical testing but uses data assembled after claims registration, and its production features are not yet defined. The claims platform is an older system with limited API capability. Investigation capacity is fixed, and managers are concerned that a high referral rate will overwhelm the specialist team.

Analysis

The insurer first defines the decision point: scoring must occur within ten minutes of claim registration. It excludes information unavailable at that point. The target is a documented investigation outcome after claim maturation, with a separate treatment for unresolved cases. The team identifies three risks: training-serving skew, capacity-driven threshold failure and possible bias from geographic variables that act as socioeconomic proxies.

Approach

Harbour Mutual creates a feature contract specifying source, timestamp, transformation, missing-value treatment and owner for each feature. The service returns a score, model version, reason codes and a fallback status. A decision engine applies coverage rules first and then sends only the highest-priority eligible claims to investigation, subject to a daily capacity limit.

The model is initially deployed in shadow mode for four weeks. Monitoring covers API latency, missingness, score distributions, referral volume and subgroup outcomes. A champion-challenger arrangement compares the existing rules with the model. Human handlers can override referrals, but every override requires a coded reason.

Security controls include mutual service authentication, encrypted connections, restricted production access and immutable decision logs. A model validation team reviews calibration, leakage tests and fairness analysis before a canary release to 10% of claims. The rollback plan returns to the existing rules without changing the claims platform.

Outcome

After the pilot, Harbour Mutual finds that the model improves prioritisation but does not reduce total handling time until the investigation queue is redesigned. The company therefore scales the model only after increasing specialist scheduling flexibility and revising the decision threshold. It also removes one geographic feature after review shows that it added little predictive value but increased fairness concerns.

Learning points

  1. A technically accurate model can fail if workflow capacity is ignored.
  2. Target and feature timestamps are central to leakage prevention.
  3. Shadow and canary releases reduce operational risk.
  4. Decision rules, model scores and human overrides should be separately governed.
  5. Digital transformation requires process redesign, not only model deployment.

Challenges and Limitations

Deployment can expose limitations hidden during development. Historical data may encode past underwriting or claims practices rather than underlying risk. Labels may be delayed, incomplete or affected by human decisions. Models can deteriorate when regulation, climate, medical practice, fraud behaviour or economic conditions change. Cloud costs may grow unpredictably under poorly controlled experimentation. Legacy systems may prevent clean real-time integration. Finally, excessive automation can reduce professional judgement and make exceptional cases invisible.

These limitations justify proportional controls, not abandonment of analytics. High-impact applications need stronger validation, human oversight and monitoring than low-risk internal forecasting. A model should be retired when its data foundation, purpose, performance or governance is no longer defensible.

Chapter Summary

Operational value arises when predictive models are reliably connected to decisions, workflows and feedback. Batch and real-time scoring serve different latency and control requirements; APIs expose scoring services, while decision engines combine scores with rules, capacity and human review. MLOps provides a lifecycle for reproducible development, validation, registration, release, monitoring, retraining and retirement.

Effective deployment requires versioning of code, data, features, models, environments and rules. Testing must cover data quality, leakage, calibration, fairness, security, integration and resilience. Monitoring must distinguish system, data, model and business drift, and retraining must account for label maturity and changing conditions. Insurance integration demands careful treatment of system-of-record questions, event timing, audit trails and fallback procedures.

Cybersecurity, privacy, explainability and human accountability are integral to responsible deployment. Cloud, on-premises and hybrid architectures each involve trade-offs. Build-buy-partner choices should consider strategic differentiation, total cost, vendor risk and accountability. Finally, transformation is best managed through staged governance, foundation building, pilots, industrialisation and measured scaling.

Key Terms

MLOps: An operating discipline integrating machine learning, software engineering, data operations, governance and monitoring.

Batch scoring: Evaluating many records on a scheduled basis.

Real-time scoring: Producing a prediction during an active transaction or workflow.

API: A controlled interface through which systems exchange data or services.

Decision engine: A component that combines model outputs with rules, thresholds and referral logic.

Training-serving skew: A difference between feature computation during training and production scoring.

Model registry: A controlled repository of model artifacts, metadata and approval status.

Model card: Documentation describing a model’s purpose, performance, limitations and appropriate use.

Data drift: Change in the distribution of model inputs.

Concept drift: Change in the relationship between inputs and the target outcome.

Calibration: Agreement between predicted probabilities and observed frequencies.

Shadow deployment: Live scoring without allowing the new model to affect decisions.

Canary release: Gradual release to a small monitored share of users or cases.

Champion-challenger: A framework in which an incumbent model is compared with a candidate model.

Data contract: An explicit agreement defining data fields, types, quality and ownership.

Fallback: A controlled alternative used when the primary model or service is unavailable.

Model risk: The possibility that a model is unsuitable, incorrectly implemented or misused.

Digital transformation: Coordinated change in processes, technology, capabilities and governance.

Total cost of ownership: All direct and indirect costs over a capability’s lifecycle.

Review Questions

Short Answer Questions

  1. Distinguish prediction, decisioning and execution in an insurance process.
  2. What is training-serving skew, and why is it dangerous?
  3. State two differences between batch and real-time scoring.
  4. Why should model and decision-rule versions be recorded separately?
  5. Name the four major dimensions of production monitoring.

Long Answer Questions

  1. Explain the MLOps lifecycle from problem definition through model retirement.
  2. Discuss the advantages and risks of cloud, on-premises and hybrid deployment for insurers.
  3. Design a governance framework for a claims-triage model, including roles and documentation.
  4. Compare build, buy and partner strategies using cost, capability and accountability criteria.
  5. Explain how cybersecurity, privacy, fairness and human oversight should shape model deployment.

Analytical / Application Questions

  1. An insurer’s fraud model has stable input distributions but declining precision after a new fraud technique emerges. Identify the likely form of drift, propose monitoring evidence and recommend a response.
  2. Design a controlled release plan for a real-time underwriting model integrated with a legacy policy-administration system. Include fallback, audit and rollback requirements.
  3. A claims investigation team can process only 500 referrals daily. Explain why a probability threshold alone is insufficient and propose a capacity-aware decision process.

Multiple Choice Questions with Answers

Question 1

Which component primarily combines a predictive score with business rules and referral logic?

A. Data lake

B. Decision engine

C. Model registry

D. Source system

Correct Answer: B. Decision engine

Question 2

What is the main purpose of shadow deployment?

A. To delete the incumbent model

B. To score live cases without affecting decisions

C. To eliminate monitoring requirements

D. To guarantee improved profitability

Correct Answer: B. To score live cases without affecting decisions

Question 3

Which situation is an example of training-serving skew?

A. A model has too few parameters

B. A production feature uses a different time window from the training feature

C. A cloud service has high availability

D. A claims handler overrides a recommendation

Correct Answer: B. A production feature uses a different time window from the training feature

Question 4

Which measure is specifically concerned with agreement between predicted probabilities and observed frequencies?

A. Calibration

B. Latency

C. Throughput

D. Availability

Correct Answer: A. Calibration

Question 5

In the simplified rule p × Cₘ > Cᵢ, what does Cᵢ represent?

A. Estimated probability of fraud

B. Expected avoided loss

C. Investigation cost

D. Current premium

Correct Answer: C. Investigation cost

Question 6

Which type of drift describes a change in the relationship between inputs and the target?

A. Data drift

B. Concept drift

C. Schema drift only

D. Infrastructure drift

Correct Answer: B. Concept drift

Question 7

Which deployment method gradually exposes a new model to a small monitored proportion of traffic?

A. Canary release

B. Full replacement

C. Data archival

D. Batch extraction

Correct Answer: A. Canary release

Question 8

Why are immutable decision logs important in insurance model deployment?

A. They remove the need for testing

B. They support audit, complaints, validation and reconstruction of decisions

C. They guarantee that predictions are unbiased

D. They replace cybersecurity controls

Correct Answer: B. They support audit, complaints, validation and reconstruction of decisions

Question 9

Which is a principal risk of buying a machine-learning capability from a vendor?

A. The insurer automatically owns all source code

B. Vendor lock-in and limited transparency

C. The system cannot ever be integrated

D. Monitoring becomes unnecessary

Correct Answer: B. Vendor lock-in and limited transparency

Question 10

What is the most appropriate reason to use a fallback mechanism in a scoring service?

A. To conceal service failures

B. To provide a controlled response when the primary service is unavailable

C. To bypass authentication

D. To avoid recording model versions

Correct Answer: B. To provide a controlled response when the primary service is unavailable

Predictive Analytics in Insurance
Chapter 12 of 14