Advisor Tells Regulators That Life Illustrations Are Just Too Simple

News March 23, 2023 at 03:24 PM
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The current illustrations for all kinds of universal life insurance policies are just too simple, and they fail to convey how much all kinds of changes could affect policy performance, a life insurance veteran told insurance regulators Tuesday.

Richard Weber, the principal at The Ethical Edge, a life insurance advisory firm in Pleasant Hill, California, made the case for updating permanent life policy illustration standards in a presentation to the National Association of Insurance Commissioners' NAIC/Consumer Liaison Committee.

Weber said in an email interview that he believes that life insurers are following the existing policy illustration regulations, "but illustrations are all unintentionally misleading."

Weber argued, in the interview and a slide deck he used for the meeting presentation, that graphics used in the illustrations often imply that policy factors that can change, such as interest crediting rates, expense fees and the limits on the percentage of index or investment gains flowing into the crediting rate, are fixed.

"The policy owner needs a better way of managing their policy than through the use of a constant rate sales illustration or in-force illustration," according to Weber's presentation.

In the presentation, Weber said insurers, agents and advisors should make more use of statistical modeling tools and talk more in terms of the probability that a given policy and premium payment strategy will meet the client's needs, rather than trying to show the policy might work in one particular scenario, or one small set of scenarios.

The Committee Background

The NAIC/Consumer Liaison Committee session was part of the NAIC's spring national meeting. The NAIC — a group for state insurance regulators — is gathering in Louisville, Kentucky, this week, and also streaming sessions online.

The Consumer Liaison Committee gives insurance researchers, consumer group leaders and others a chance to speak for consumers' interests in NAIC proceedings.

Weber serves on the committee in his capacity as the treasurer of the Life Insurance Consumer Advocacy Center.

Other NAIC News

• The NAIC's Big Data and Artificial Intelligence Working Group said it's about to send out a survey questionnaire asking life insurers are using artificial intelligence and machine learning systems to price, underwrite, market and administer life insurance policies. The questionnaire will go out to insurers with more than $250 million in 2021 individual life premiums, and to term life writers that cover more than 10,000 people. It will also go out to insurance technology firms.

• The NAIC's Valuation of Securities Task Force may update the rules that apply when a bank that has provided letter of credit guarantees for insurer fails. Silicon Valley Bank and Signature Bank of New York were taken over very quickly, without releasing bad financial statements or going through credit rating downgrades. Under current NAIC rules, an insurer can still use letters of credit from those banks. The task force wants to add regulator takeovers as a reason to remove a bank from the list of "qualified U.S. financial institutions" used to assess letter of credit providers.

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