Protective Life is dedicated to providing quality service, building trust and simplifying everything for you and our mutual customers. Please review the following information about Protective Life’s Annuity Suitability Program.
Protective Life’s Annuity Suitability Program
Protective Life has created an Annuity Suitability Information webpage under Working With Protective, Doing Business with Us tab at MyProtective.com. This webpage is designed to be a central point of reference for Protective Life’s Annuity Suitability Program. The webpage currently contains information regarding many of the items described in this newsletter, including Protective Life’s Annuity Suitability Guidelines, Annuity Suitability Producer Guide, Point of Sale Marketing Material, National Association of Insurance Commissioners’ (NAIC’s) training requirements, Annuity Suitability Review Desk Frequently Asked Questions.
In recommending an Annuity Transaction, a producer must have reasonable grounds for believing that the recommendation is in the consumer’s best interest and effectively addresses their individual insurance needs and financial objectives. Protective has developed Annuity Suitability and Best Interest Guidelines and an Annuity Suitability Producer Guide to help ensure producers comply with applicable annuity suitability laws and regulations. The Guidelines provide important information about the NAIC’s Suitability in Annuity Transactions Model Regulation (the Model Regulation), as well as annuity suitability regulations in states that have adopted the Model Regulation. Producers should refer to the Guidelines in order to understand more about Protective Life’s Annuity Suitability Program.
NAIC updates to Model Regulation
In February 2020, the NAIC approved an update to its Suitability in Annuity Transactions Model Regulation. The update includes a consumer-focused set of standards and practices to ensure the producer is acting in the consumers “best interest”. The changes have been incorporated into our Suitability Program documents including the Annuity Suitability Producer Guide.
We have updated our Suitability Questionnaire (Consumer Profile and Suitability Questionnaire for Fixed Annuities – LAD-1243R) with the additional information required and have included Appendix B – Consumer Refusal to Provide Information and Appendix C – Consumer Decision to Purchase an Annuity Not Based on a Recommendation.
The additional information required by the update will be beneficial to Producers to determine whether a recommendation addresses the consumer’s financial situation, insurance needs and financial objectives and as a result, we are implementing the updated form in all states.
New requirements for adopted states only
States adopting the updated Model Regulation will require the completion of an updated 4-hour training course for new producers and a 1-hour supplemental course for producer’s who have already completed it. Please refer to our Producer Training document for further details.
In addition, producers will be required to complete Appendix A – Insurance Agent (Producer) Disclosure for Annuities describing the types of products the producer can sell, whose annuities the producer can sell and how the producer is compensated.
Consumer education materials
The Point of Sale Marketing Material section is a helpful reminder to producers that Protective Life has made available product specific marketing material to be used with consumers at the point of sale. Protective Life encourages you to use these materials to help educate consumers about how our products work, and includes information on available riders, endorsements, restrictions, withdrawals, annuitization, expenses, surrender charges, and other important features.
Product training is available for all Protective Life’s annuity products. Some states require producers to complete a training course before selling or soliciting clients for annuity products. Protective Life provides online training courses that will allow producers to complete all product specific training requirements. Training modules for all annuity products have been made available utilizing the online platform RegEd. Certificates of completion are required to validate that training requirements have been met.
Suitability Review Desk
Protective Life has an Annuity Suitability Review Desk that is available to answer general questions concerning annuity suitability or the Annuity Suitability Questionnaire. Additionally, refer to the Annuity Suitability Frequently Asked Questions guide located on MyProtective.com which includes answers to the most common questions presented to our Annuity Suitability Review Desk. The Annuity Suitability Review Desk can be reached at AnnuitySuitabilityReview@protective.com.
Guidance on completing the Suitability Questionnaire
In order for the suitability team to conduct a thorough review, it’s important all questions on the Suitability Questionnaire be completed with accurate data. Questions 5 – 10 of the form identify the client’s financial information, including liquid assets, non-liquid assets, debt, and total net worth. Based on questions received from producers, we are providing additional guidance regarding what data to include, and how to accurately complete this section. Questions 5 – 10 ask for specific account types and balances therefore, it would be beneficial to gather this data when profiling a potential client. Also, the parenthetical instructions are included to assist producers and clarifying what specific information is being requested. Please ensure you are providing the requested information when completing this section so an accurate determination regarding suitability can be made.
Suitability refresher course
We encourage you to visit the Annuity and Life Insurance Suitability Information page under Working With Protective, Doing Business with Us tab at MyProtective.com for more information. This is where you will find the refresher course for the Suitability training that includes the updated NAIC model regulation.
New York Regulation 60
For replacements in New York, Regulation 60 requires a Disclosure Statement to be completed in order to make available full and clear information on which an applicant for life insurance or annuities can make a decision in his or her on best interest. As the agent, when you receive a partially completed Disclosure Statement from Protective, you are responsible for reviewing the information provided on the Disclosure Statement to ensure its accuracy and complete the questions under the Agent/Broker Statement section. In addition to identifying the primary reason(s) for recommending the new policy or contract, please carefully consider both the advantages and disadvantages of continuing the current policy or contract when responding. Please note, indicating ‘None’ or ‘N/A’ in response to the advantages of continuing the existing policy or contract is not acceptable.
Please contact us for additional support:
- Allstate: 877-905-3078
- Annuity IMO: 800-421-5614
- Bank/Broker-Dealer: 888-340-3428
Let’s deliver on our promises. Together.