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.

DOL Fiduciary Discussion RE: Use of Term Advisor

In a recent article about the DOL fiduciary rule proposal on, Michael Kitces, a partner at Pinnacle Advisory Group, brings up a very interesting point: the multitude of ways that financial professionals represent themselves to clients and prospects, particularly in the titles they use, and the description of services they claim to offer.

In the article, Mr. Kitces is quoted saying, “How often do you see ‘stockbroker’ on a business card anymore? You don’t. You see ‘advisor.’ We’ve allowed the sales people to communicate to the public that they are in the business of giving advice. And then we have not held them accountable for doing so.”

Gone are the good old days when an insurance agent calls himself or herself just that – an agent. The term “advisor” is used indiscriminately by so many professionals, very often in an inappropriate manner. Individuals who sell insurance products for commission, who are not registered as an investment or financial advisor, do not provide “advice” (at least, they shouldn’t, unless it is incidental to the sale of the insurance product they are recommending).

In fact, the NAIC advertising model regulation for life insurance and annuities, in an attempt to draw the distinction between insurance agents and financial advisors, specifically includes language in the regulation, which reads, “….No insurance producer may use the terms, such as “financial planner”, “investment adviser”, “financial consultant”, or “financial counseling” in such a way as to imply that he or she is generally engaged in an advisory business in which compensation is unrelated to sales unless that is actually the case.”

Have we, as an industry, helped create our own mess here? It’s hard to say for sure, since, as Mr. Kitces calls out in the article, this point has not been raised by the DOL as part of the proposed rule discussion. The article states, “While no fan of the DOL’s proposal, Kitces shares a perspective with those lobbying hardest on Labor’s behalf: after years of the SEC’s failure to adequately enforce the ’40 Act, consumers can no longer tell the difference between broker and advisor.”

But it certainly begs the question. Had the SEC and the state insurance divisions better enforced this issue, had the industry done a better job of self-regulating ourselves in this regard, what would the DOL proposal look like today? Or would there even be one?

Read the full article here... “DOL fiduciary rule puts broker-dealers in Catch 22”