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New Standard of Care Center

Compliance with annuity and life insurance standard-of-care regulations (e.g., suitability,best interest, fiduciary issues) just got A LOT easier!

Currin Compliance Services is excited to announce our new Standard of Care Center (SCC) — an online collection of materials on the various fiduciary standards and suitability regulations, including NY’s new Reg 187. We will be following and creating materials about the NAIC’s efforts to revise and adopt a new suitability model regulation as well.

We are looking at suitability and standard of care issues in small, manageable chunks due to the size and scope of those issues. Our expectation is that this will be an evolving field for a long time and many of us will be dealing with these issues well into the future. We are launching the SCC as a monthly subscription service. As a subscriber, you will continue to receive updates, new information, reference documents, and analysis about developments in this area with unlimited access as long as your membership is current. The lessons are short and to the point. The titles are descriptive so you can find the appropriate lesson quickly. You’ll be able to scan the list of lessons and pick the exact one that you need. Each lesson focuses on a single topic.

We invite you to take a look at the SCC Introduction and Free Sample lesson as a preview into our vision — a one-stop repository for audio/visual lessons with downloadable scripts, reference documents, and other resources on this important topic. If you don't already have an account on our education and training platform (CICEd), you'll need to create one (it is free and without obligation). A CICEd account gives you access to all of our free materials and resources, plus the opportunity to register for paid courses and subscriptions. 

If you're ready to subscribe to the SCC now, use code 10OFFMEMBER and receive 10% off your monthly subscription price. Instead of $950/month your member subscription price will be $855/month — but only if you subscribe BEFORE April 1st. As of April 1st, the subscription price will be $950/month.

Questions? Email or call (518) 692-2494.

“1035 exchanges are about to get easier. Is that a good thing?”

This title is not original. It is the title of an article written by Greg Iacurci in InvestmentNews’ January 21, 2019 edition. It is an interesting piece about the effort to use technology to speed up the 1035 annuity-to-annuity transfer on a tax-free basis. Whenever I see 1035, I think replacement and when I think replacement, I think about Regulation 60 in NY. When I read this article, I kept thinking how likely it is to lead to Reg 60 violations and fines.

While not mentioned in the article, I am hopeful that those working on this streamlining effort are familiar with Reg 60 and its mandates. The article states “Annuity products are often derided as being expensive, complicated products, a criticism that’s compounded by cumbersome industry infrastructure that often creates a month-long exchange process. Technology can reduce the time line substantially, executives said, likely to within a week, start to finish.” That does not appear to be enough for all that is required by Reg 60.

Sheryl Moore, CEO of Moore Market Intelligence does point out that it is possible that “more bad actors would get missed” due to the streamlined process, and that is certainly true, but my concern is a compliance one. I do not see how it will be possible to comply with the disclosure requirements of Reg 60 within that process. So perhaps NY is outside the scope of these efforts? Perhaps once the rest of the country has successfully expedited the replacement process, pressure can be brought to bear on the NY DFS to revise Reg 60 to increase the speed of these transactions.


However, that seems a long shot given recent experience with Reg 60 procedures filings. In most cases, if not all, an expedited process for replacements requires revisions to a company’s DFS-filed procedures. Those filings are reviewed in granular detail and changes are often requested along with every screen shot of an electronic process. If changes are also required to the application to accommodate a new process, the slowdown at DFS is dramatically increased. Both the policy form reviewers and Reg 60 reviewers hold these types of changes to an extremely rigorous scope of review, far in excess of anything that exists in the review of paper processes. The chance that 1035 exchanges will get easier in NY seems remote.

It’s the most wonderful time of the year, except for . . .

Andy Williams had it right all those years ago. It is a wonderful time of the year. Great times and memories with family and friends, parties, presents, blessed and cherished holiday celebrations. Indeed, a most wonderful time. Except . . .


‘Tis also the time of the year for year-end planning and budget meetings. Looking ahead to next year and determining your goals, your team’s goals, and just how you’re going to get there. Nothing like adding a bit of stress to your holiday shopping, eh? 

And if you’re in the compliance side of the insurance business, even more stress. Just how are you to keep up with the latest changes in suitability and other state driven regulations that are popping up across the country? How can you possibly submit all of those new product and form filings you’re expecting in 2019!? And what about advertising reviews!?! How can they possibly expect you to stay on top of all of those agents and their social media activities?!?! And with inadequate resources!?!?! Your answer:  Need to hire . . . need to hire . . . need to hire! But perhaps not. 

Why saddle yourself with the hiring process? The reviewing of countless resumes, interviewing potential candidates, choosing which one MIGHT be the right fit for you and your team. Senior management isn’t giving you enough money to hire someone with the right amount of experience. You’re trying to find that budding superstar. That diamond in the rough that you can pay as little as possible, and who will excel at every task you give them. The problem is, they aren’t easy to find.

What about instead of a new full time employee, you bring on a consulting firm that will be there when you need them? One with a team that has extensive compliance experience. Former regulators, actuaries, CCO’s, COO’s, years of extensive form filing and advertising review experience. Essentially everything you need to address your regulatory and operational compliance needs and right there when you need them without all of the hiring paperwork and hassles. And likely for less than you would spend hiring that elusive diamond in the rough. That’s precisely what you get when you engage with Currin Compliance Services (CCS). We hope you consider us your partner as you plan for 2019. Why not check the need to hire box off your holiday list? Turn to CCS instead. 

Wishing you the very best for this most wonderful time of the year, and for a happy and successful 2019!

Author: Pete Rock