Company Position on Suitability

Our Position

We have a strong commitment to adhere to the suitability guidelines set forth in the 2010 Suitability in Annuity Transactions Model Regulation. We have developed guidelines and forms for you to use to ensure that every sale and replacement of an annuity product is suitable. We rely on your insight and personal knowledge of your client’s financial situation to identify facts and information that may not be obvious to the individual reviewing the forms or application. We expect you to know and understand our products and our suitability standards and apply this knowledge in your every day practice of soliciting our products.

Producer Responsibilities

Training

  • Review and fully understand the features of the products you are selling.
  • Review and complete all product training materials available on the LIMRA PinPoint website prior to solicitation
  • Complete the State Continuing Education Annuity Training, where required, on the LIMRA PinPoint website.
  • Review the Suitability Frequently Asked Questions document to ensure you understand our expectations of your participation in the suitability process.

Maintaining Records

  • We request that written records of discussions held with your client be maintained for future reference.
  • Your records should include your client’s current financial circumstances and objectives.
  • Your records should include how the annuity you recommended meets your client’s needs and objectives based on the information gathered during your meeting(s) and disclosed on the Annuity Suitability Questionnaire.
  • It is recommended that these records be maintained for at least the length of the contract plus seven years (or longer if required by state law).

Solicitation

  • Review the applicable Buyer’s Guide, Product Disclosure, Rider Disclosure and Privacy Commitment Policy with your client.
  • If applicable, ensure that both you and your client sign the signature pages of the Product Disclosure and Rider Disclosure and return copies with the application.
  • Leave copies of the Buyer’s Guide, Privacy Commitment and applicable disclosure documents with your client.
  • Accurately complete the application, Annuity Suitability Questionnaire and Client Identification Form.
  • Make a reasonable effort to obtain your client’s suitability information.
  • Assess the various features of our annuities to make a reasonable determination if any product is suitable for your client based on the suitability information provided.
  • Fully explain to your client the various features, risks, benefits and charges of the annuity and any rider(s) you are recommending.
  • Fully document your rationale for recommending the purchase of the product and any rider(s) in your records as well as on the Annuity Suitability Questionnaire. Be specific.
  • If your client resides in a nursing home, has any form of cognitive impairment, or has been diagnosed with a terminal illness, do not continue with the sale.

Our Responsibilities

We will:

  • Provide you with the required training, forms and certifications.
  • Closely review your signed applications, Annuity Suitability Questionnaire, Client Identification Form and any other forms or information you submit with an application for completeness and to ensure the sale meets our suitability standards.
  • Contact clients to validate certain information provided on the Annuity Suitability Questionnaire.
  • Periodically contact clients to verify they received their contracts, are aware of relevant product information and are satisfied with their purchase.
  • We may conduct random reviews of your sales to verify the appropriateness of sales and/or sales practices.
  • Periodically review and revise our policies and procedures and keep you apprised of these revisions.

We will not:

  • Provide legal or tax advice to you or your client.
  • Issue a contract if you have not completed the required product and state training.
  • Issue a contract with an incomplete Annuity Suitability Questionnaire.
  • Issue a contract where the source of premium is from a mortgage, reverse mortgage or home equity line of credit, or personal loan.
  • Issue a contract that you have not recommended.
  • Issue a replacement contract where the existing contract has been in force for less than 24 months.
  • Issue a replacement contract where the existing contract being replaced is less than 36 months old and the same producer who sold the existing contract is also selling the replacement contract.
  • Accept any application for a deferred annuity if the purchase is intended to qualify an individual for Medicaid, VA benefits, or any other similar state or federal aid program.
  • Permit the sale of its products in connection with a Personal Service Contract.
  • Issue a contract to a client who resides in a nursing home, has any form of cognitive impairment or has been diagnosed with a terminal illness.
  • Issue a replacement contract where the client will incur excessive surrender charges.

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