Whole life insurance quotes 2021

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    Whole life insurance quotes

    I was recently asked about handling domiciliary state approval for NY domiciled companies doing business in 50 states.

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    "Life Insurance Awareness Month - We put the LIFE back in life insurance." by State Farm is licensed under CC BY 2.0

    Whole life insurance quotes and policy - New York data

    In my experience, this was a bigger problem prior to the development of the certified (or "CL6") process in NY.  In those days, NY approval could take many months and NY-domiciled companies who needed approval in NY for those domiciliary states could be in a very difficult situation.  Back then, my recommendation was to develop a version to file under NY's out-of-state use statute - those were filed for informational purposes and were subject to a much less stringent set of review standards.  Those were typically processed within a couple of weeks and then that date could be used for domiciliary state approval.

    However, NY law has changed so that NY-domiciled companies no longer file most of their forms for out-of-state use.  Now the statute has an annual filing requirement for those forms.  They can be used immediately outside NY so long as they are reported on an annual basis, in a format not yet fully developed.   In addition, forms intended for use in NY are now often submitted under the expedited "CL6" process.

    In today's environment, a CL6 approval takes approximately 60 days.  While this is obviously a tremendous improvement over the old full prior approval timelines, it is still a long time to wait to file in domiciliary state approval  states.  An alternative for most types of products would seem to be a variation on the previous "filed for out of state use" approach.  If a form is developed for use solely outside NY, there are no additional regulatory requirements until the annual filing.  Therefore most, if not all of the domiciliary approval states would consider it "approved" by NY for use outside NY.

    Whole life insurance quotes: a great conversation [you know this]

    In a conversation with Cathlean Tnelligan of the NYSID this morning, she once again reiterated the need for specificity in SOVs.  While she concurred on the importance of guidance being published on the website, she also said that the Department needs to know now what is going to be on the form when it is issued.  They can't wait to enforce the standards until those standards are published.

    From the conversation, it is clear that if your company is in a position to fully define alternative text (including new addresses and phone numbers) that might appear, those should be included on the SOV up front.

    If however you thing something may change but you don't know what the new provision might be, e.g. where the service office might move to if it ever moves, you need to make clear on the SOV that your company will re-file the Memo prior to implementing any new text.   In some cases, failure to provide sufficient detail may get through the process and the SOV may be approved.  But take note that the NYSID is likely to consider it use of an unapproved policy form if there is any modification that they determine is outside the scope of the SOV's explanation.

    Whole life insurance quotes: end words about approval and costs

    This week I received approval of the oldest CL6 that I had pending for any company.  That filing was 5 months old and was a complicated one.  I have recently received several more recent approvals that indicate a much faster turnaround time.  My very recent experience is that complicated filings take 60-90 days and simpler filings take 1-2 weeks.

    The striking think about the position of the NY Department on this is that they don't say this benefit is not permitted in NY.  Instead, they interpret the law to require that  a company must design their product in a particular way.  The mandated design is one that requires embedding the cost in the interest rate credited (and that rate cannot then go below the guaranteed minimum stated in the contract).

    While that is certainly a valid approach and a common one in fixed annuities, it would seem to be equally valid to have a separately identified charge for this benefit.

    As the discussion of this issue progresses with the NYSID, it will be interesting to see if any room develops to look at this issue differently and to allow different methods of charging for this guarantee.  Once the guarantee is permitted, then that really becomes the issue - how does the charge for the benefit work?

    If the Department can see its way to a less restrictive interpretation of the non-forfeiture law,  then consumers will have the option in NY of selecting a product where their interest rate reflects the benefits they purchase or selecting a product where each optional benefit has its own charge identified.

    Source: lifeinsurancelawblog.com (External site - not affialate )

    Update: Jan/21

    Whole life insurance quotes over 50

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