Dear IMSA Friends; 

The first quarter of 2008 is history.  Look for our Excelsior spring newsletter shortly.  As usual, there is a lot going on. 

Please read on!

Congratulations to Allstate Companies Renewing IMSA Membership  Allstate Companies:     American Heritage Life Insurance Co., Jacksonville, FL;     Allstate Life Insurance Co., Northbrook, IL;     Allstate Life Insurance Co. of New York, Farmingville, NY and;     Lincoln Benefit Life Insurance Co., Lincoln, NE. Annuity Suitability Summit Explores How To Best Serve Consumers In A Well-Regulated Marketplace   On March 12, 2008 a Summit Meeting in Washington, D.C. of state and federal regulators, consumer advocacy groups, life insurance companies, and those who sell and distribute products gathered to address the critical issues regarding the suitability of annuity sales to consumers and the challenges of coordinating regulatory approaches to best serve consumers. The Summit was convened by the Insurance Marketplace Standards Association (IMSA).     The topics discussed included how state and federal regulators can work collaboratively and efficiently to provide greater clarity and predictability for companies and producers who are expected to comply with an array of inconsistent and overlapping state and federal requirements.     “I applaud IMSA’s initiative and effort to address suitability,” said Roger Sevigny, New Hampshire Insurance Commissioner and National Association of Insurance Commissioners (NAIC) President-Elect. “This issue gains importance everyday, not only for baby boomers and other consumers, but also for the insurance and regulatory communities. My hope is that from this forum comes a uniform approach to suitability and suitability oversight.”     “AARP was pleased to participate in this unique forum that will hopefully lead to the development of concrete steps to promote greater consistency and predictability in the regulation and sales of annuity products,” said Ryan Wilson, AARP Strategic Policy Advisor. “These strides can benefit both the industry and the consumers who purchase annuities.”     “The time to address these issues is now, and the organization to help us get it done is IMSA,” said Doug Ommen, Missouri Insurance Commissioner. “In a well-regulated environment, consistency and uniformity is critical to protecting consumers."     “This important dialogue addressed suitable annuity sales for consumers throughout the United States, so that companies and distributors might better understand both state and federal regulations,” said James Mumford, First Deputy Insurance Commissioner of Iowa. “This Summit can effect positive change for not only consumers and regulators, but also for those that market and sell annuity products and their current policyholders.”

 Good Stories on IMSA Website

Check out the fine stories from BestWire and Insurance Compliance Insight at http://imsaethics.org.

IMSA Begins Complying Annuity Suitability Best Practices

IMSA Sees Ways to Improve Suitability Model Implementation

More on the IMSA Annuity Suitability Summit Meeting
The 2008 IMSA Annuity Suitability Summit Meeting was held on Wednesday, March 12 at the JW Marriott Hotel in Washington, DC.  The Summit Meeting attracted participation from over 65 attendees representing IMSA qualified companies, distributors, AARP, FINRA and 14 state insurance departments including NAIC President-Elect Commissioner Roger Sevigny of New Hampshire, Director Doug Ommen of the Missouri Department of Insurance and Commissioner Thomas Hampton of the District of Columbia.  The Summit Meeting was an excellent opportunity to convene an informal discussion among regulatory, distribution and industry leaders on key issues affecting the life insurance marketplace.

Suitability

The agenda was designed to focus the discussion on the challenges faced by life insurance companies in attempting to comply with suitability laws and regulations; especially, various elements of the NAIC Suitability in Annuity Transactions Model Regulation (the "Model Regulation") which has now been adopted in 32 states.  A primary purpose of the Summit Meeting was to provide a unique forum that would permit IMSA qualified company representatives to offer possible solutions to current suitability-related compliance challenges as a means to engender regulatory acceptance of these concepts.   

Uniformity and consistency were common discussion topics throughout the day.  Regulators, distributors and industry representatives agreed that pursuit of greater uniformity and consistency in the interpretation and enforcement of provisions of the Model Regulation would provide valuable benefits to all marketplace stakeholders including consumers. 

NAIC President-Elect Commissioner Roger Sevigny of New Hampshire confirmed the need for an expedited, timely solution to address some of the outstanding interpretation and enforcement issues associated with regulatory review of compliance with the Model Regulation.  While industry representatives identified a strong need for further guidance on how states may interpret and enforce various provisions of the Model Regulation, regulators asserted their desire to develop a consistent, uniform approach to regulating unsuitable sales as well as their need to gain a better understanding in the near future of the options for compliance available to companies to protect against questionable sales practices.  Commissioner Sevigny indicated he would bring these concerns to the attention of the NAIC leadership at the upcoming NAIC Spring National Meeting.  Further discussion of these issues identified several best practices that companies employ currently to identify inappropriate sales activity.  As a result of the discussions, IMSA will serve in a leadership role by working with its qualified companies to identify a series of best practices employed by life insurance companies to identify inappropriate sales activity that will be presented to the NAIC for review and comment as possible acceptable strategies to demonstrate compliance with the Model Regulation.

Clearinghouse

IMSA introduced its Clearinghouse as a means to establish a uniform practice with respect to obtaining the annual certifications of annuity suitability supervision compliance required under the Model Regulation.  IMSA continues to grow its Clearinghouse as more and more qualified companies provide IMSA with data to allow life insurance company distribution partners to enroll in and use the efficient capabilities of the Clearinghouse.

Periodic Review

The Summit Meeting participants were also introduced to the concept of allowing an independent third-party such as IMSA to conduct the periodic reviews required under the Model Regulation on behalf of life insurance companies.  This periodic review strategy would provide a more consistent means for life insurance companies to demonstrate a consistent method of confirming third-party distributor compliance with delegated supervisory responsibilities.

FINRA

Participants in the Summit Meeting also heard presentations from Larry Kosciulek of FINRA provided an update on recent developments with respect to final adoption of various elements of FINRA Rule 2821 pertaining to Deferred Variable Annuity Sales. 

 IMSA's 2007 Full Summit Meeting identified the need for better collaboration and coordination between FINRA and state insurance regulators.  As a result of these discussions, Jim Mumford of the Iowa Insurance Division and Tom Selman of FINRA offered comments on their recent presentation to the NAIC leadership on the need for better understanding between state insurance and FINRA regulators concerning their respective regulatory practices.  NAIC staff reported that, as a result of these discussions, a one hour session has been scheduled at the upcoming NAIC Spring National Meeting for FINRA to provide an overview of its regulatory review process for state insurance regulators.  In addition, FINRA and the NAIC will work collaboratively to conduct a joint training session for state insurance department regulators at the NAIC Fall National Meeting in Washington, DC.

 Finally, the Summit Meeting participants agreed to continue these forums on a regular basis in order to identify current compliance challenges and develop industry-based solutions for review and possible acceptance by regulatory authorities.

 For more information on IMSA's Summit Meeting, please contact Brian Atchinson at (240) 744-3020 or Donald Walters at (240) 744-3027.

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Upcoming Meetings from IMSA Today:

April 1                         In the Flow Distribution Working Group Conference Call

April 1                         Qualification Process Working Group Conference Call

April 9                         Standards Advisory Committee Meeting at IMSA Offices in
                                    Bethesda, MD

April 13-16                  IRES Foundation National Insurance School on Market Regulation in Summerlin, NV           

April 16                       (Tentative) United States House of Representatives Financial Services Committee hearing with Representative Paul Kanjorski regarding insurance regulation modernization options.

April 17                       Qualification Process Working Group Meeting at Allstate Offices in Northbrook, IL

April 18                       Communications & Outreach Working Group Conference Call

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SAVE THE DATES           April 9-11, 2008

Seventh Annual Insurance Advertising Compliance Association Conference

Practical Approaches to Advertising Topics and Issues for Insurance Marketing and Compliance Professionals

Chicago, Illinois
Crowne Plaza Chicago Metro
More information at:  http://www.iadca.org/conference.html

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LHCA May 14-16 in Omaha

DON'T FORGET DEADLINE DATES:
HOTEL - APRIL 13th is the deadline date for reserving your hotel room at the Embassy Suites to receive the special discounted rate of $129. Please call 1-800-EMBASSY (362-2779) to reserve your room now. When making your reservation, please identify yourself as a member of the Life and Health Compliance Association group in order to obtain the special rate. In addition to this special room rate, breakfast is made-to-order breakfast served in the Atrium. You can't beat this special deal.

EARLY REGISTRATION - APRIL 13th is the deadline date for the early registration fee for the conference. Please register online at www.lhca.net TODAY. Detailed information regarding our conference can be found on the website. Your quick response and registration fee submissions ensure we can provide you with the best meeting possible!

AGENDA QUESTIONS - April 28th is the deadline to submit agenda questions. The success of the meeting depends upon your questions and subsequent discussion. You'll receive responses and insight from some of the most knowledgeable individuals in the insurance industry. Questions should be submitted through the LHCA website. START SUBMITTING QUESTIONS NOW – THE SOONER THE BETTER – THE MORE THE MERRIER!

REGISTRATION FEES – Please make checks payable to Ameritas Life Insurance Corp. Be sure to send your check to the attention of Cindy Meyer along with a copy of your registration confirmation page from the website. This will ensure that I have all necessary information to process your fees correctly. If you have not heard from me within 2 weeks of mailing your fee, please let me know so I can track down the check.

EARLY ATTENDEES TUESDAY EVENING - In addition to having a hospitality suite available Tuesday evening, May 13th, the Creighton University Bluejays play the University of Nebraska Cornhuskers at historic Rosenblatt Stadium, home of the College World Series. This is a chance to see two of the best college baseball programs in the Midwest go head to head for state bragging rights. We have made arrangements with Creighton for 30 of these hard to get seats at the price of $12.00 per seat. The baseball game is a separate cost from the main meeting costs. Please contact Larry Gardner if you are interested in attending the baseball event. First Come - First Serve due to ticket availability.

GOLF OUTING – Don't forget to sign up for the Don Edde Memorial Golf Outing to be held Wednesday morning at Shoreline Golf Course. The fee is $60 per player (includes cart, green fees, lunch and great prizes). Shoreline's 18 hole, par 72 championship golf course is a scenic lakeside golf course bordering the shores of Carter Lake. Golfers of all skill levels are welcomed and encouraged!

GUEST SPEAKERS - We have invited Ann Frohman, the Nebraska Director of Insurance to speak at one of the sessions.

We have also invited Dave Morris, Examiner with the Interstate Insurance Product Regulation Commission (IIPRC), Interstate Compact. Dave will talk about filings from an Interstate Compact examiner's perspective. All Interstate Compact questions will be discussed during this session and Mr. Morris can provide answers to your questions.

THURSDAY EVENING RECEPTION – Explore. Discover. Remember. The Thursday evening reception will be a "don't miss" event. The reception will be held at the Durham Western Heritage Museum. This museum used to be known as the Union Station. It was built in classic art deco style by Union Pacific Railroad as a showpiece in the city of its headquarters. In its heyday, Union Station has 64 trains and 10,000 passengers pass through it daily. When passenger travel stopped in 1971, Union Pacific Railroad donated the building to the City of Omaha. Union Station was renamed in 1997 to Omaha Western Heritage Museum to honor the family instrumental in the building's comeback.

We have full access to all exhibits and galleries throughout our reception. Be sure to register for the conference and take advantage of this grant event.

If you are interested in becoming a sponsor for this meeting, please contact Cindy.

PLEASE DON'T DELAY – REGISTER NOW!

Cindy Meyer, FLMI, ACS
Supervisor, Contract Analysts
Ameritas Life Insurance Corp., A UNIFI Company
5900 O Street, P O Box 81889
Lincoln, NE 68501-1889
phone: 800-745-1112, ext. 87722
fax: 402-467-7956
email: cmeyer@ameritas.com

Larry Gardner
Pacific Life Insurance Company
phone: 402-574-3212
email: larry.gardner@pacificlife.com

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