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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


Regardless, We Can Still Give Thanks

Happy Thanksgiving copy.png

We often struggle with understanding our past. Times when we erred in judgement; times when we were wronged by those we trusted; times when our differences made conflict inevitable. Of course, the hope is that we learn from the past, and embrace and give thanks for the present and future. Sometimes we wonder about whether we have learned anything at all. As it seems we continue to make the same errors, suffer from the same injustices. Still, even in the darkest times, there can and should be gratitude. Gratitude for being given the opportunity to make a difference, to do the right thing, and to pave the way for a brighter future. 

In 1863, during one of the darkest times in our country’s history, President Lincoln set in motion the national observance of Thanksgiving. His proclamation follows. Certainly, despite our current political and social divisiveness, we can find time to give thanks. Melody Beattie once said, “Gratitude makes sense of our past, brings peace for today, and creates a vision for tomorrow.” May we all feel that peace and have a most joyous Thanksgiving!

Washington, D.C.  - October 3, 1863  - By the President of the United States of America

A Proclamation.

The year that is drawing towards its close, has been filled with the blessings of fruitful fields and healthful skies. To these bounties, which are so constantly enjoyed that we are prone to forget the source from which they come, others have been added, which are of so extraordinary a nature, that they cannot fail to penetrate and soften even the heart which is habitually insensible to the ever watchful providence of Almighty God. In the midst of a civil war of unequalled magnitude and severity, which has sometimes seemed to foreign States to invite and to provoke their aggression, peace has been preserved with all nations, order has been maintained, the laws have been respected and obeyed, and harmony has prevailed everywhere except in the theatre of military conflict; while that theatre has been greatly contracted by the advancing armies and navies of the Union. Needful diversions of wealth and of strength from the fields of peaceful industry to the national defence, have not arrested the plough, the shuttle or the ship; the axe has enlarged the borders of our settlements, and the mines, as well of iron and coal as of the precious metals, have yielded even more abundantly than heretofore. Population has steadily increased, notwithstanding the waste that has been made in the camp, the siege and the battle-field; and the country, rejoicing in the consciousness of augmented strength and vigor, is permitted to expect continuance of years with large increase of freedom. No human counsel hath devised nor hath any mortal hand worked out these great things. They are the gracious gifts of the Most High God, who, while dealing with us in anger for our sins, hath nevertheless remembered mercy. It has seemed to me fit and proper that they should be solemnly, reverently and gratefully acknowledged as with one heart and one voice by the whole American People. I do therefore invite my fellow citizens in every part of the United States, and also those who are at sea and those who are sojourning in foreign lands, to set apart and observe the last Thursday of November next, as a day of Thanksgiving and Praise to our beneficent Father who dwelleth in the Heavens. And I recommend to them that while offering up the ascriptions justly due to Him for such singular deliverances and blessings, they do also, with humble penitence for our national perverseness and disobedience, commend to His tender care all those who have become widows, orphans, mourners or sufferers in the lamentable civil strife in which we are unavoidably engaged, and fervently implore the interposition of the Almighty Hand to heal the wounds of the nation and to restore it as soon as may be consistent with the Divine purposes to the full enjoyment of peace, harmony, tranquillity and Union.

In testimony whereof, I have hereunto set my hand and caused the Seal of the United States to be affixed.

Done at the City of Washington, this Third day of October, in the year of our Lord one thousand eight hundred and sixty-three, and of the Independence of the United States the Eighty-eighth. … By the President: Abraham Lincoln

Submitted by Pete Rock

Nevada Considers Best Interest Addition to Suitability Regulation

In a recent notice, Commissioner of Insurance Barbara D. Richardson announced a November 14 workshop designed to solicit comments on revisions to the state’s annuity suitability regulation. While there are other proposed changes to the regulation, of key interest is the addition of a definition of “best interest” and a corresponding change in the required standard of care.

The proposed change to the regulation includes the following definition of best interest:

“Best interest” means that, at the time an annuity is issued, a producer of insurance who is making a recommendation concerning the annuity acts with reasonable diligence, care, skill and prudence in a manner the producer of insurance believes will put the interest of the consumer first. The term does not mean that a resulting recommendation is:

  1. the least expensive annuity,

  2. the annuity with the highest stated interest rate or income payout rate, or

  3. the single best annuity,

which is available in the marketplace at the time of the annuity transaction.

That flows through to a proposed new standard of care. The insurer must have a reasonable basis to believe that, among other things:

The annuity as a whole, the underlying subaccounts to which funds are allocated at the time of purchase or exchange of the annuity and riders and similar product enhancements, if any, further the insurance needs and financial objectives, and are in the best interest, of that consumer based on his or her suitability information;

There would also be new disclosure mandates including disclosure of any “material conflicts of interest arising from financial incentives that are associated with the recommendation…”.

While there are many compliance issues raised by this proposal, one of those is that the operation of the two provisions excerpted above seems to require additional oversight of the field. An insurer, before issuing an annuity contract subject to the proposed regulation would have to determine that the producer acted with reasonable diligence, care, skill and prudence so that the producer acts in a way that he or she believes puts the best interest of the consumer first. I think many companies will be in a position of having to put new standards and controls in place to ensure that they can be comfortable making the determination that the producer has acted in the best interest of the consumer.

We recommend paying attention to this regulation in Nevada and tracking revisions and progress as it moves, potentially, toward promulgation.

Thanks to Alan Prochoroff for bringing this to our attention through his publication, Insurance Compliance Insight. If you have questions about this or other suitability regulations, you can reach me at or contact Pete Rock at


Did you know we have FREE resources available right on our home page and through our online education portal? WE DO!

There are tips and white papers and samples…oh my! Take a look at our FREE Downloads section and scroll down further to check out our online education and training courses. There are some freebies listed there, too. It’s quick and easy to explore our online education portal. Drop us a line at or call (518) 692-2494 if you have any questions or would like some help with your compliance needs.

How to gain compliance buy-in!

Currin Compliance Services, Inc.

Getting compliance buy-in isn’t always easy. Your company could have the highest compliance standards in the world, but if you can’t get the message heard effectively, then it won’t move your company ahead.

So what can you do? A lot, actually! Having a communication plan in place can help your company become raving fans of the compliance department. Here are six steps to help get you started:

  1. Determine Your Goal: Really think through what you’re trying to achieve – make it clear and specific. Defining your goal is the basis of determining your communication strategy.

  2. Understand Your Audience: Along with your goal, you need to understand who you’re speaking to. Often those in compliance aren’t “speaking the same language” as their audience and that contributes to the feeling that compliance isn’t in touch with others. Find out what motivates your audience and what their needs are. Connect your compliance message to how it helps them achieve their goals.

  3. Evaluate Readiness and Need: Next figure out how ready your audience is for the communication, and what the level of need is for the communication. The higher the readiness, the more easily you’ll get buy in. If readiness is lower, determine what the most important issues are to communicate and start there.

  4. Review Current Resources: Are there key individuals you can bring in to help get greater buy-in? Think of those with decision-making abilities or those who influence the decision makers. Leverage these individuals to help spread your message to others. Also, look for what’s already in place and working well – then build off that. Keep this motto in mind: “Grow the seeds, not the weeds!”

  5. Select Content: Use materials that speak to your company’s overall tone and culture. Continue to show how your compliance message is in line with your company’s goals. Don’t be afraid to be creative. Breaking down the information into bite-sized pieces, rather than a long, technical presentation, can help with engagement and retention. Think about using things like role-play scenarios, games, and cartoons/animation in the delivery of your message. Whenever possible, get face-to-face with your audience. While shooting off some e-mails may feel like it’s saving you time, or giving you some space from a difficult conversation, talking in person usually ends up being more productive.

  6. Develop Schedule: Chances are, your target audience is receiving messages from lots of different areas – both internally, and perhaps even externally. As you develop a communication plan, find out what your target audience is already receiving. Check to make sure there aren’t mixed messages or conflicting information. If possible, you may be able to synch up your communications with other information your target audience is receiving. This will help reduce information-overload, and help you be even more effective in your communication delivery.