Compliance and Risk Mitigation Assistance for Large Insurance Carriers
In today’s busy and ever changing regulatory environment, insurance carriers, both commercial and fraternal, are tasked with actively managing their risk exposure and protecting their reputation. Increased inquiries and actions by state insurance departments regarding life insurance and annuity sales practices require a solid understanding of the laws and regulations affecting the industry.
Currin Compliance Services, Inc. (CCS) has extensive, proven experience helping clients navigate the multitude of regulatory requirements. We help protect life insurance and annuity companies from regulatory actions and litigation by offering practical, customized compliance solutions.
Here are ways CCS can help you manage your risk:
Communicating with your employees and distribution partners regularly about company and policies and regulatory requirements is critical for any compliance program to be successful. CCS can build and deliver effective training programs on a variety of compliance topics. Whether you prefer web-based or live training, comprehensive in nature or targeted to select areas of risk, we can deliver training solutions that teach not only the “what,” but also the “why” and the “how.”
Some topics available include:
- Advertising compliance
- Suitability (including how to manage an effective process, perform oversight and testing, trending and analysis, and senior management reporting requirements)
- Rebating and Inducements
- Cross border sales
- Privacy and data security
- Compliance basics for new employees
- Source of funds
- Anti-Money laundering
- Developing and managing a field surveillance program
Ensuring that the sale of your company’s products is suitable to each individual consumer remains a key area of regulatory focus. Regulators expect carriers and their agents to comply with the applicable suitability standards and to protect customers, whether the function is performed in-house or is delegated to a third party. If the function is delegated to a third party, such as a broker/dealer partner, your company needs to perform additional due diligence and oversight to ensure your standards are being consistently applied and documented.
Managing an effective suitability program requires the successful coordination of a number of key components, such as written policies and procedures, oversight, testing, training, and reporting. CCS can help enhance and sustain your company’s suitability in a number ways including:
- Establishing or enhancing written suitability guidelines, policies & procedures, including supervisory and oversight policies & procedures
- Assisting carriers in the development and/or implementation of testing procedures by offering an objective, third party assessment, which may also include conducting audits of reviews that are delegated to third parties.
- Developing a suitability review trending and reporting platform to identify problem areas
- Assistance with the development or review of the suitability report to senior management to help your company’s leadership manage their regulatory exposure
- Performing suitability reviews, for companies who want to outsource this function to an industry expert, either in full or for overflow during heavy volume times.
CCS has extensive suitability expertise to assist you with this critical function!
Carriers are often held accountable for inappropriate or misleading sales practices used to sell their products, and the use of independent distribution poses unique compliance challenges for carriers. Many insurance producers work through Independent Marketing Organizations (IMOs) which continue to grow in both size and influence. Carriers must clearly understand these distribution risks, take reasonable steps to manage them, and utilize dedicated resources who understand the independent channel. We can help you manage compliance without significant disruption to the business by:
Managing producer risk – effective oversight requires more than resolving complaints and investigating fraud. CCS provides you with a holistic, risk-based approach to mitigating this exposure to sales practice risks such as undisclosed replacements, rebating, cross border sales, source of funds, and others.
Managing IMO risk –It is vital for you to have a plan to mitigate this increasing risk posed by the use of intermediaries. We have extensive experience working with IMOs and can customize a reasonable and achievable oversight program for you, which may include mitigating risks related to IMO marketing, suitability, data security and privacy, application processing and other back office operational processes.
Reviewing advertising – agents and IMOs create a significant amount of non-carrier specific materials to promote themselves, and the product types they offer. These materials can become your liability if their use results in the sale of one of your products. CCS can help you mitigate the risk of inappropriate or misleading advertising materials through a variety of approaches, from pre-reviewing materials, to post-review, sampling, advertising risk analysis and agent training on advertising regulations and best practices. Learn more (click here to link to the CCS advertising review page)
Conducting training – a foundational requirement for effective compliance, training needs must be considered for both your distribution partners and home office employees. CCS builds and delivers training to inform your distribution partners of compliance issues and also train your employees on things to look for when working with producers and IMOs.
Retaining producers while managing risk – an agent retention program can provide an attractive alternative to terminating an agent. CCS develops, and even conducts, customized programs to train and provide heightened oversight of a producer to reduce risk for you.
Tailored solutions to manage all your distribution risks.
With the myriad of regulatory requirements that insurance carriers need to comply with, it’s critical to have a trusted source of information. At CCS, we provide our clients with regular updates of changes to insurance law and regulation that is tailored to their business. We include a summary of the new law, and advice on how to implement changes, when needed.
Whatever your compliance needs, our staff will partner with you to enhance your compliance program to help sustain your long term success!