Regulatory Commentary

#257 | The Section 7702 Christmas Miracle

This is the closest thing to breaking news in our industry and, as such, it’s still very much evolving. Current updates to the post are at the very bottom. For all of the buzz and lead-up to the creation and…

#251 | The AG 49-A Loan Loophole

Back in June of this year, I wrote an article entitled “The Impacts of AG 49-A” that went through six points of how AG 49-A would impact illustrations. My 6th point was about policy loan arbitrage and the fact that,…

#229 | The Impacts of AG 49-A

At last, it appears as though the process to make edits to AG 49 is coming to an end and has coalesced around the proposal crafted by life insurers and put forth by their industry group, the ACLI, and now…

#222 | An Independent View of AG 49

One of the funny things about regulatory proceedings is that nothing happens – and then everything happens very, very quickly. The process to update AG 49 in light of growing market for Leveraged IUL has certainly followed this pattern. Back…

#189 | Getting Involved in the AG49 Discussions

So, you clicked on the LinkedIn article because you want to get involved in the AG 49 discussions at the NAIC? Great. Here’s how to listen in, understand what’s going on in the debate and contribute. First, how to access…

#187 | The NAIC IUL Multiplier Vote

James and I recorded a podcast on 10/18, the day after the NAIC vote, but have yet to release it because James has been unexpectedly out of the office for personal reasons. As a result, I’m writing this Quick Take…

#177 | The Real Problem with AG49 – Part 2

When I say “numerical average,” what picture pops into your head? If you’re into statistics, you imagine a standard normal distribution – a bell curve. We were all taught about the bell curve in school and it applies nearly universally…

#176 | The Real Problem with AG49 – Part 1

From its earliest days, AG49 was surrounded by controversy. The fight at the ACLI to even make a recommendation to the NAIC was fierce and, ultimately, resulted in some companies publicly lobbying against other life insurers and the ACLI. At…

#169 | The AG49 Menu

After a rather contentious IUL Illustrations Subcommittee call where regulators sparred with a lawyer representing a coalition of life insurers who are using charge-funded multipliers over a menu of possible changes to AG49, Chair Fred Andersen made the motion to…

#163 | IBTs and Corporate Division Laws

In the wake of GE’s massive $15B hit from its legacy Long-Term Care insurance block and continued struggles in the broader LTCi market, the NAIC has taken up the charge in 2019 to examine a national framework for insurance business…

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