Dear IMSA Friends:
September is on its way out, and
those autumn leaves are ready to fall. Its been
a great month for IMSA and many of our ongoing
efforts. Please read on:
Excelsior
Third
Quarter, 2007 Volume IX, Issue 3
Ethical Market
Conduct Issues for Presidents and Senior
Executives
.Excelsior
on Its Way
Our 3rd Quarter Excelsior newsletter is already
up on the web. You can check it by
clicking here, or wait for your hard copy
arriving next week. Be sure to check out these
items:
-
The CEO and IMSA:
An analysis of the role of CEOs in creating
and supporting IMSA.
-
Fighting those “Self-Assessment Blues”?:
Can you use IMSA to manage all your
self-assessments?
-
Annuity
Sales, Suitability and Seniors:
IMSA’s efforts in a key area.
-
Highlights from Atchinson Letter to Senate
Special Committee:
More detail on above.
-
Kalis IMSA AIMS: Announcing our 2007
company AIMS: Affordable, IMSA, Management
Services.
-
Excelsior Awards: Why
we give out our Excelsior Awards.
-
-
Best Practice Corner:
More ideas in this popular section.

Chicago is My Kind of Town!
This is the view each morning as
I walked to IMSA highly successful Suitability
Summit and Best Practices at Chicago’s Marriott
Courtyard on Ontario Street. I arrived on
Tuesday for the Summit and was impressed by the
great attendance and free exchange of ideas. Be
sure to read IMSA’s article on it following.
Regulators, Companies Wrestle with
Interpretation of Suitability Regulation -
Summit Offers Unique Opportunity for Dialogue
Chicago, IL (September 19, 2007) – Companies
selling annuities need guidance to interpret key
provisions of regulations in 30 states based on
the NAIC Suitability in Annuity Transaction
Model Regulation.
At a unique half-day forum in Chicago on
Tuesday, 12 insurance regulators and
representatives from FINRA and NAIC met with
more than 50 compliance professionals from life
insurance companies for the first time to
discuss the scope and interpretation of
regulation provisions such as periodic reviews,
delegation of supervision to a third-party, and
FINRA’s “safe harbor” as well as the needs of
companies and distributors for consistency and
predictability in regulatory oversight. Thus
far, it has been reported that some states are
taking widely divergent approaches to overseeing
companies’ compliance with the regulation that
is designed to ensure consumers’ annuity
purchases are “suitable.”
“This type of exchange brings regulators,
companies and broker-dealers face-to-face to
find the best ways to comply with this
regulation and meet the needs of consumers
considering annuity products,” said IMSA
President & CEO Brian Atchinson. “This is
important because ultimately, consumers will pay
the extra cost of the overlapping and
duplicative regulation that’s out there today.”
www.IMSAethics.org
Best Practice Workshop
Highlights
About 60 people attended this
year’s IMSA Best Practices Workshop. Many of
them thought this was the best one yet, The
Kenneth J. Kalis Company was a sponsor.

FINRA’s Larry Kosciulek speaks
and answered questions at the Workshop for IMSA
Companies.

Allstate’s Jo Reimers, AIG’s
Dianna Osmonson and ING’s Carol Stern give one
of the best-received presentations on Compliance
Reporting to Management.
If It’s Monday It Must Be
Washington
It was great to be in Washington
again for Jim Buddle’s retirement dinner and the
IMSA Standards Development Committee meeting.
Jim’s leadership on the committee will be
missed. We need another person of his stature
and commitment to step forward. Why not you?
IMSA belongs to the companies, and the more you
give, the more you will get out of the
experience.

Members of IMSA’s Standards
Development Committee honor retiring chairman
Jim Buddle for Genworth Financial at Ruth’s
Chris Steakhouse in Bethesda.

Familiar faces around the table. |

Jim Buddle chairs his final meeting as
chairman of the IMSA Standards
Development Committee. |
Wednesday? On to
Greenville, SC
We were also proud to be a
sponsor of the 87th meeting of the
Life & Health Compliance Association hosted by
RBC Insurance in Greenville. 105 people
attended from 73 companies; I was the only IMSA
QUI there. These are great and inexpensive
meetings. You can send in any question in
advance, and it is discussed by the group. You
can also sign up for a one-on one session with
the regulators attending, (this meeting’s folks
were from SCDOI, NCDOI and SERFF). I think they
are the best value in the industry. You can
sign up for the next one (in Tallahassee in
January) at www.lhca.net.

The real Ken Kalis next to his
picture at our table at the LHCA meeting in
South Carolina.
Best Practice of the Month
Compliance Part of Top
Executive Scorecard
Every company has a top line
scorecard that is used by the top executives to
manage the business. This report always
includes sales in terms of new business
premium. The other items shown vary by company
but usually are expense, conservation and
something. Sometimes recruitment is there or
number of producers. Less often you will see
renewal premiums. What is not there is
compliance, at least not for the vast majority
of companies. We noted a best practice in this
area back in 2005, and to date, that remains the
only instance we know of where compliance has
made it into this important document. The
company we gave an Excelsior award to for this,
simply had “Compliance” listed and gave a score
based on a number of factors, including
complaints, litigation expense, and meeting IMSA
monitoring standards. That’s a good starting
place. You may want to vary the ingredients but
the key is getting something having to do with
compliance into this top line report.
¨
Impact: Keeps Key
Compliance Concerns Visible
¨
Impact: Keeps
Processes on Schedule and Budget
¨
Impact: Compliance
Simply Part of Business Culture
At the Best Practice Workshop
in Chicago, everyone was very impressed with
the way that ING is reporting compliance
results to management. This is another best
practice, and its genius lies in creating
dramatic graphs that report compliance
information in terms that senior management
is interested in. It provides a number of
measure showing the savings good compliance
practice brings. This makes the value of
each element of ethical market conduct
evident and gives you the data you need to
support your goals when budget time comes.
Hope you’ve enjoyed this issue.
Please let us know if you have any questions or
would like some help in managing your IMSA
preparation or assessments. 386-462-1074 or
KenKalis@gmail.com.
Thanks for your continuing
interest in IMSA and in ethical market conduct.
Ken Kalis
Only Believe.
Mark 5:36