Scroll down to the previous post and tell us which advertising compliance topic would be most valuable to you.
Another wonderful AICP National Conference is in the books! Seattle delivered with beautiful weather, and AICP delivered with great content, networking, and compliance insights.
I was honored to be a part of a panel featuring Maureen Perry, Product Reviewer with the Interstate Compact, and Ted Newton, Advertising Review with Mass Mutual. Together we selected what we saw as four overarching issues to be on the lookout for within the world of advertising review for life, health, and annuities.
- Consumer Confusion – Who is Offering What?
- Carrier Confusion – What is advertising?
- Electronic vs. Printed Advertising – Capabilities and Challenges
- Consumer Engagement – Plain Language, Disclosure, Engagement
Now, each of these topics could be broken down further and have their own dedicated sessions to really dig into how issues show up and how to tackle them. Still, we were able to discuss lots of ways to manage these hot topics and enjoyed an engaging conversation with the audience.
So how can you address these issues? Here are some of the key takeaways for each category:
- The issuing carrier must be made clear and prominent. Some states have more specific requirements about what this means than others, but there should be no question about who is issuing the policy.
- The definition of “advertising” is broad, and it’s best to cast a wide net to make sure your company is catching all the ads. If you don’t know if something is considered an ad or not, start with this question, “What is the intent of this flyer/tweet/brochure/tv commercial, etc.” Is it to promote insurance (generally, or specific products), your products, your services, your agents/agencies? If the answer is yes (and there’s a lot of times it’s going to be a yes) – then it’s an ad and needs to be handled as such.
- When it comes to electronic vs. printed ads, there are pros and cons on both sides. We talked a lot about space restrictions and how specific you can get in a limited space ad. Rule of thumb – less space, less specific.
- Finally, we rounded out our discussion with a big trend, which is the use of “plain language” or “plain English” in both insurance ads and in the contracts, themselves. We expect to see challenges to the traditional language and terminology that’s used in the insurance space for lots of reasons – target markets, selling products direct to consumer are just a couple of the drivers – while the idea of having language that’s familiar and understandable is certainly appealing from a compliance perspective (we want people to clearly understand how it works, what they’re buying). What that looks like while still having protection measures in place against litigation and/or regulatory violations is still very much up in the air. That said, it’s important for compliance professionals and regulators to keep an open mind here and work with others on what makes sense. There’s lots of room at the table to make insurance more accessible and understandable, it just needs open minds and discussions to make sure it stays reasonable and not simplified to the point it creates expectations that aren’t accurate.
If you’re interested in hearing more about these topics, drop us a line with any questions or comments you have or advertising issues you’re struggling with!!
IAdCA is an organization that’s near and dear to my heart because it’s an organization that focuses exclusively on advertising compliance for insurance compliance professionals. And next week I’ll be on my way to their annual conference at the gorgeous Omni Scottsdale Resort & Spa in Scottsdale, AZ.
When I first started with ad review, IAdCA was like a beacon of light where I could meet like-minded people and learn from those that had experience in this specific area. Don’t get me wrong, there are other great organizations for insurance compliance professionals, but to have an event solely focused on advertising compliance really makes IAdCA unique!
Over the years, I’ve had the opportunity to participate as a speaker, a volunteer on the education and planning committees, and now as a board member.
Another reason IAdCA is so great? A lot of thought that goes into the program and how to provide exceptional value for attendees. This year, I’ll be speaking on two important topics – both of which I would want to learn about from an attendee perspective. Here’s what I’ll be jamming on:
Effective Compliance Communications
In this session, we’ll be covering top tips to facilitate discussions around advertising compliance issues. It’s one thing to have substantive knowledge of what the issues, rules, and regulations are. Getting buy-in from others around what changes need to be made, and why, is a vital piece of the puzzle. We’re providing practical tips that can be implemented immediately to foster connections and improve buy-in for compliance needs.
Stories from the Trenches
No one wants to learn the hard way – fines, sanctions, consent orders. This session covers common themes that have come up in market conduct exams and consent orders directly related to advertising. I’ll be discussing specific takeaways for each of the real-life stories so that companies don’t have to wait until it’s too late to address an issue.
I’m looking forward to this event, the sunshine, and meeting up with industry colleagues. Will we see you there?
June 22-24, 2016 • Desmond Hotel • Albany, NY
The Currin Insurance Compliance Symposium (CICS) is coming up fast and we hope you will join us! This symposium will include discussions on important issues in our field, as well as general updates and trends that inform our daily work. We will talk about products and processes, management and communication of compliance information, and the use of metrics to evaluate compliance. There will be opportunities for small groups to engage in problem solving and to focus on improving ways to manage our jobs. We will look at some long-standing issues in new ways and also discuss how recent issues impact insurance compliance.
We are very excited to have Ann Johnston, PhD, PCC as our Keynote Speaker. She is a Global Learning Leader with 20+ years of experience and subject matter expertise in leadership, organizational design and development, and organizational change. Having heard Ms. Johnston as a keynote speaker first-hand, we are confident that you will not only benefit from her experience and expertise, but also enjoy her humor and personality!
CICS sessions will include:
- Indexed Product Advertising: Requirements and Risks
- Suitability: What should we be doing now?
- Carrier/Distribution Risk Assessments: Why and how?
- DOL Fiduciary Rule: Updates & Implementation
- Compliance Training: Why you need it & how to do it!
- Effective Compliance Officer Tips & Tricks
- Hot Compliance Issues in NY
- Accelerated Death Benefits: Filing challenges in CA, NY, and beyond!
- Variable Material: Is it me, or are the rules always changing?
- Hands-On Advertising Review
(sessions are subject to change)
We look forward to seeing you in June!
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.