Don’t Forget the Source

Glenda K. Bean and I just returned from a two-day compliance training session at a large Insurance Marketing Organization (IMO). I really enjoy training and I am happy to have the opportunity to do quite a bit of it these days. However, I have been doing 1-2 day trainings on life and annuity advertising compliance for quite a while now and I was feeling as though my presentation was getting stale. So for this most recent trip, I decided to completely re-vamp it and I was very pleased with the outcome.

One surprisingly successful element was in the afternoon of the first day when the group of about eight of us read aloud both the NAIC model advertising regulation and the unfair trade practices act model. Section by section we went around the room and read it aloud. As we went around we had the opportunity to talk about specific historical issues that led to certain provisions as well as current applications for sections drafted years ago. We had very interesting discussions about what individuals with various licenses could do and not do. We talked about the differences between guaranteed and non-guaranteed elements, as well as the difference between determinable and guaranteed. All of these issues have been part of my previous presentations, but they arose differently when based on reading the models directly.

We spent much of the second day reviewing ads together in a variety of ways. The comments were good and the participants had clearly learned a lot. I don’t think every topic is suited to this approach for training, but it did reinforce for everyone how important it is to continually go back to the primary source documents. Memories are good and secondary materials can help, but there is nothing like going back to the law itself or the regulation itself for a clear understanding of the requirements for advertising materials, whether created by carriers, marketing organizations, agencies or individual producers. I think that’s what the group we trained this week learned. That feels like good progress.

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Compliance With or Without Enforcement