LIIIWG - Life Insurance Illustration Issues Working Group - NAIC - Documents

2015

  • 2015 0311 - AAA to NAIC (LATF) - re IUL - 4p
  • 2015 0811 - AAA to NAIC (IULWG) - Paper- 5p
  • 2015 1120 - (LIAC) - Life Insurance and Annuities (A) Committee National Harbor, Maryland - (6-3)
    • the Committee set a 30-day public comment period to receive comments from stakeholders on their issues and concerns with life insurance illustrations and the Life Insurance Illustrations Model Regulation (#582). In response, she said the Committee received comments from:
      • American Academy of Actuaries (Academy) - 3p
      • American Council of Life Insurers (ACLI) - 2p
      • California Department of Insurance - 1p
      • Massachusetts Mutual Life Insurance Company (MassMutual) - 1p
      • 2015 1012 - NAIC consumer representatives - 1p
      • State Farm - 1p

2016

  • 2016 - Spring
    • Commissioner Gerhart explained that the American Academy of Actuaries (Academy) wrote a letter - 1p (2016 0128) suggesting expansion of the Working Group’s charge to include a review of the Life Insurance Buyer’s Guide (Buyer’s Guide).
    • He said the American Council of Life Insurers (ACLI) followed up with a letter stating that it did not oppose the addition, but pointed out that the Committee itself already has an existing charge to revise the Buyer’s Guide, and the addition of this task to the Working Group might slow down its ability to accomplish the current charge.
  • 2016 0920 – LIIIWG - Conference Call
    • Agenda Compilation of Subgroup
    • Suggestions Policy Overview
  • 2016 1016 – LIIIWG - Conference Call
    • Agenda Compilation Document
    • Feedback on Compilation Document
    • ACLI Feedback
  • 2016 1115 – LIIIWG – Conference Call
    • Agenda
    • Compilation for Discussion
    • ACLI Comments
    • BB TW Comments

2017

  • 2017 0109 - LIIIWG - Conference Call
    • Materials
    • LIIIWG minutes 1-9-17
  • 2017 0208 - LIIIWG - Conference Call
    • Call Canceled
  • 2017 0313 - LIIIWG - Conference Call
    • MLR 580
    • MLR 582
    • 3-6-17 ACLI Letter
    • LIIIWG Agenda 3-13-17
  • 2017 0614 - LIIIWG - Conference Call
    • Agenda
    • Discussion Draft Revisions #582
  • 2017 0628 - LIIIWG - Conference Call
    • Agenda
    • ACLI Comments
    • 06/26/17 Draft Template
    • RW Life Illustration Draft
  • 2017 0731 – LIIIWG – Conference Call
    • Agenda
    • CA. suggested disclaimer
    • Proposed changes to Policy Overview
    • Discussion Draft
  • 2017 0914 - LIIIWG - Conference Call
    • 9/14 Agenda
    • 7/31 Conference Call Minutes
    • 7/28 #580 Revisions
    • 9/12 Draft Sample Overview
    • CEJ Glossary
    • CEJ Comments on Sample Overview
  • 2017 1017 - LIIIWG - Conference Call
    • Agenda
    • October draft policy overview template sample
    • CEJ Draft policy overview template
    • CEJ Draft policy overview template glossary
    • Draft Revisions #580
    • ACLI Comment Letter
  • 2017 1116 - LIIIWG - Conference Call
    • Agenda
    • CEJ policy overview proposal 11/13/17
    • CEJ glossary proposal 11/13/17
    • B Cude edits CEJ Glossary proposal V1
    • B Cude edits CEJ Glossary proposal V2
    • Outstanding Issues table 11/16/17
    • 11/16/17 Draft #580
    • 11 /16/17 Draft #582

2018

  • 2018 0213 - LIIIWG - Conference Call
    • Agenda
    • Outstanding issues table 11-16-17 (rbw)
    • 11-16-17 Proposed changes to Model #580 RW
    • LIIIWG conf call 11-16-17
    • 11-16-17 Life Illustrations Model # 582 Draft
    • 10-17-17 Draft-Overview Term Life (sample)
  • 2018 0314 - LIIIWG - Conference Call
    • Agenda
    • Draft changes to Model #580
    • Draft changes to Model #582
    • Outstanding issues table
  • 2018 0501 - LIIIWG - Conference Call
    • Agenda
    • Outstanding Issues Chart
      Academy IWG Comment Letter
  • 2018 0514 - LIIIWG - Conference Call
    • THIS CALL HAS BEEN MOVED TO MAY 18TH AT 1 PM ET
    • Outstanding issues table

2019

  • [  ]  - 2019 0830 - Letter - CEJ / Birnbaum to NAIC (LIIIWG) - Response to Recent Comments by the ACLI and NAIFA - 
    • 2021 0811 - LIAC - NAIC - Summer National Meeting, Proceedings - 43p
  • 2019 1115 - ACLI to NAIC - RE: Revisions Considered for Life Insurance Policy & Narrative Summaries - 8p
  • [  ]  - 2019 1115 - LIIIWG - CEJ, Birny Birnbaum -
    • 2021 0811 - LIAC - NAIC - Summer National Meeting, Proceedings - 43p

2020s

  • 2020 0827 - ACLI to NAIC (LIIIWG) -  Re: Term Life Insurance Sample Policy Overviews - [Automatic-Dowload-2p]
  • 2020 1104 - ACLI to NAIC (LIAC) -  RE: Life Insurance Illustrations Issues (A) Working Group - 2p
  • 2021 0811 - LIIIWG - NAIC - Life Insurance Illustrations Working Group - Next Steps Summary Comment Chart,  (p8-43) - 43p
  • 2021?? Proceedings - Wicka Report - Should we move on?
    • 2021 - Jennifer Cook e-mail to Participants
    • 2021 0805 - LIAC - NAIC - ACLI - RE: Life Insurance Illustrations Issues (A) Working Group - 3p
      • As a result, the Working Group tried to address an unknown problem, which is impossible to do. 
    • 2021 0808 - Cude to NAIC (Jennifer Cook) - 1p 
    • 2021 0809 - NAIFA to NAIC (LIAC) - RE: Life Insurance Illustrations Issues (A) Working Group - 2p
    • 2021 0811 - CEJ (Birnbaum) to NAIC (LIAC) - Response to Questions Regarding the Work of the Life Insurance Illustrations WG - 16p
  • 2021 1119 - LIIIWG NAIC - Richard Wicka (Chair) - Life Insurance and Annuities (A) Committee Requested Chair Report - 26p  ---  [BonkNote]
  • 2021 0811 - LIIIWG - NAIC - Life Insurance Illustrations Working Group - Next Steps Summary Comment Chart,  (p8-43) - 43p
    • LIIIWG Next Steps Summary Comment Chart
      • Question 1 - Do you support the development of a short policy overview document for the working group to achieve its charge? Yes or No.
      • ACLI - NO - The working group has fulfilled its charge.
        • The Working Group was created from concerns raised when the Indexed Universal Life (IUL) Illustrations (A) Subgroup under the Life Actuarial (A) Task Force was working on guidance for IUL policy illustrations that would result in consumers being better able to understand the product performance and interest variability of IUL products.
        • A review of sample disclosures for all types of life insurance policies revealed that additional disclosures to those now required are likely to confuse consumers, which would be the opposite of the Working Group’s goal.
        • Moreover, the additional disclosures could create liability traps for insurers regarding required versus supplementary disclosures and undermine well respected NAIC models enabling the availability of affordable insurance protection to millions of Americans.
      • NAIFA - Without the involvement of an agent—if the consumer relies solely on the written materials provided—it is unlikely that he or she will have the necessary information and guidance needed to make the right decision considering the consumer's unique circumstances, regardless of when the policy overview document is provided 
      • NALC - Additionally, there is little doubt that significant litigation will arise around the manner in which the supplemental disclosures were provided. Ultimately, these factors will lead to less conversation between agents and consumers about insurance needs, and more focus on reading the contents of a checklist of documents.
      • Utah - NO - We do not support the development of the policy overview. The WG charge is to explore “how the narrative summary […] and the policy summary […] can be enhanced.” Improving readability of the already required documents would be preferable to an additional document.
    • Additional Comments 
      • ACLI - Should the Committee believe that further consideration be given to promoting consumer readability and understandability of life insurance policies, the ACLI recommends that the NAIC undertake its traditional approach to alleged systemic problems, namely, an objective fact-finding and study.4 
        • It is not clear that there is a problem with consumer disclosures and, if so, what precisely the problem is and the extent of the alleged problem. The ACLI would welcome the opportunity to review objectively evidence that an alleged problem might be extensive and evaluate it against the manifest success of life insurance policy disclosures based upon the existing, successful model regulations.
      • Finseca - We would also like to recommend that the (A) Committee provide additional support documentation as to why the LIIIWG found it necessary to augment the current policy summaries issued by insurers with the new overview document.
        • The record of the LIIIWG’s proceedings does not provide a detailed justification of why the overview is necessary.
      • CEJ, Birny Birnbaum - The working group long ago reviewed illustrations and disclosures provided by insurers for a variety of products and found these documents with great variation among insurers regarding lengthy and presentation – for the same products – as well as difficult to navigate and impractical to use for the comparison shopping purposes set out in the model regulation.

Illustration Guidelines for Variable Life Insurance - 1986-2 NAIC Proc. 16 

Rules Governing the Use of Illustrations in Connection With the Sale of Life Insurance. 

ATTACHMENT THREE-A

Guide to Understanding of Ledger Illustrations, 1993-2 NAIC Proc. 1000

Analysis of Illustration Proposals, 1994-3 NAIC Proc. 515

Life Disclosure Standards Draft, ATTACHMENT FOUR-A, September 17, 1994

 

Questions & Answers Life Illustrations Model Regulation as of Dec. 17, 1996, ATTACHMENT ONE-A

August 1993 Position Paper on Life Insurance Illustrations.

1994-3 NAIC Proc. 515

2. Discussion of Draft of Working Group Position Paper

Commissioner Robert Wilcox (Utah) said that the working group had drafted a list of standards that they wish to see included in a model law and regulation eventually adopted (Attachment Four-A).

 

1994-3 NAIC Proc. 515

 

1993-2 NAIC Proc. 1000

ATTACHMENT ONE-H

ARTICLE 9. REQUIREMENTS FOR LEDGER ILLUSTRATIONS USED IN

THE SALE OF LIFE INSURANCE AN ANNUITY POLICIES DRAFT COPY

FOR DISCUSSION ONLY


1993-1 NAIC Proc. 249

ATTACHMENT ONE-A

Summary of NAIC Activity

Life Insurance Disclosure/Illustrations

NALU
1994-1 NAIC Proc 352
13. The Cover Page for any illustration should contain the annual premium necessary to maintain the policy to maturity based solely upon the guarantees in the policy. This will assist the policyowner in understanding the differences between guaranteed and non-guaranteed policy features.
 

1994-1

Mr. Barkacs suggested the illustration concentrate on concept disclosure. He said many consumers can not distinguish between universal life and whole life. He said a narrative explanation was needed because many did not understand the numbers or the fact that a universal life policy might drain the cash value until there was no coverage left.

 

1994-3 NAIC Proc. 515, Technical Resource Committee's Draft Suggestions Concerning the Life Insurance Illustrations Model Regulation

 

ACTUARIAL ANALYSIS OF PROPOSED ILLUSTRATION REGULATIONS, Compiled by Technical Resource Advisors,, 1994-3 NAIC Proc. 515

,

1996-1006
7.10 If the guideline level premium will not provide coverage to the end of the term of the contract, does the illustration have to display the annual term charges allowed by § 7702 or can the illustration explain that the coverage will terminate?
See Question 7.9. Either may be illustrated as long as the insurer discloses the effect of what is illustrated.

 

IV. RECOMMENDATIONS CONCERNING THE NAIC LIFE INSURANCE

ILLUSTRATIONS MODEL REGULATION, 1997-4 NAIC Proc. 1232