Several InsureReinsure.com bloggers are attending the ALI-ABA Conference on Insurance and Financial Services Litigation in Chicago.   Earlier today, one of the panels addressed recent developments in the area of class action certification, particularly in life insurance and annuities litigation.   The discussion focused on cases involving fraud claims, which have been seen as difficult to prosecute as a class action due to individual issues of reliance and causation.  However, courts in recent cases have granted certification, applying surprisingly lenient standards.  Most notably, in In re National Western Life Ins. Deferred Annuities Litig. (S.D. Cal.) (click here to read the decision), the court on Monday granted certification of a fraud claim under RICO related to the sale of deferred annuities nationwide.  The court found that reliance is a question “common” to the class, because “consumers are nearly certain to rely on prominent (and prominently marketed) features of a product which they purchase.”  The speaker pointed out that this analysis is very close to “presumed causation.”  This and other recent cases, particularly out of California and the Ninth Circuit, have threatened to greatly liberalize the standard for obtaining class certification in fraud cases.