Fair Canada

  • 2024 0209 – FAIR Canada – Jean-Paul Bureaud – [FSRA-2023-015] – 2024 0209 – 3p
  • 2008 1009 – FAIR Canada – Canadian Foundation for Advancement of Investor Rights – re: Product Suitability Consultation – 2p
    • We believe that the consultation would benefit from a clearer articulation of the reasons for and objectives of the consultation.
    • [Bonk: Q: What’s the Problem That We Are Trying to Solve?] 
    • As a general matter, based on feedback we have had from investors, investors need more action from regulators, not more public consultations.
      • Broad consultations in the guise of being able to say that the regulators are doing something diminish regulators credibility.
  • 2015 0821 – Fair Canada – Comment – re: Review of Mandate of FSCO – 11p
  • 2015 1214 – Fair Canada – Comment – re: Preliminary Position Paper on the Review of Mandate of FSCO – 8p
  • 2016 0531 – Fair Canada – Comment – re: FSCO’s Draft 2016 Statement of Priorities – 9p

Canada – Insurance – Overview

  • Ontario Insurance Act (the “Act”) and its regulations.
  • George Dinney
  • Lawsuits
    • Sun Life / MetLife / Fehr
    • Mosten
  • LLQP
  • MGAs
  • Universal Life Insurance
  • 2008 10 – CCIR – An Approach to Risk-Based Market Conduct Regulation – “The Approach” – Final Report  —  [BonkNote]  —  11p
  • 2014 09 – FSCO / FSRA – Report – Life Insurance Product Suitability Report  —  [BonkNote]  —  52p
  • 2014 – IMF – Canada – Report on the Observance of Standards and Codes – IMF Country Report No. 14/30 – 67p
  • [  ] – 2018 07 – CCIR – Comments – Fair Treatment of Customers Working Group  —  [BonkNote]  —  110p
  • 2021-2022 – CISRO – Principles of Conduct for Intermediaries Working Group – [link]
    • 2022 – CISRO – CISRO Principles of Conduct for Insurance Intermediaries – 3p
    • [  ] – 2021 07 – CISRO – Comments – Principles of Conduct for Intermediaries Working Group – Stakeholder Submissions  —  [BonkNote]  —  68p
  • 2022 04 – CCIR-CSRO – Comments – Incentives Management Guidance (IMG)  —  [BonkNote]  —  83p
  • [ – ] – 2022 – FSRA – Proposed Principles-Based Regulation Approach Guidance – No. GR0014APP —  —  [link]  — 8p
    • [ X] – 2022 – FSRA – [2022-006] – Comments – Principles-Based Regulation  —  [BonkNote]  — [Binder-50p]  —  [link]
      • Date: Comment Due Date: April 29, 2022
  • [ – ] – 2022 – FSRA – Principles of Conduct for Insurance Intermediaries – No. PC0044INT  —  [BonkNote]  —  [link]  —  21p
      • Appendix B: Examples of conduct contrary to the Principles of Conduct
      • The following is a non-exhaustive list of conduct FSRA has observed that would be considered failures in following the Principles of Conduct.
    • [ X ] – 2022 – FSRA – [2022-007] – Comments – Consultation on Proposed Principles of Conduct for Insurance Intermediaries  —  [BonkNote]  —  2xp
  • 2023 1003 – FSRA – Strengthening oversight and accountability of the life insurance sector – [link]
    • As part of FSRA’s enhanced sector supervisory approach, today FSRA is releasing two reports:
      1. 2023 10 – FSRA – Report – Market Conduct: Life and Health Insurance Agents – Life Agent Thematic Examinations: Tiered Recruitment Model MGAs  —  [BonkNote]  —  43p
      2. 2023 10 – FSRA – Report – Observed Practices in the Distribution and Sale of Universal Life Insurance  —  [BonkNote]  —  15p
  • x – 2023 1121 – FSRA – [2023-015] – Comments – Consultation for Proposed Guidance on Life Insurance Agent & MGA Licensing Suitability  —  [BonkNote]
  • [  ]  – 2024 0209 – FSRA – Consultation for Proposed Guidance on Life Insurance Agent & MGA Licensing Suitability – BonkNote Comment  —  [BonkNote]  

Grady Polcyn

2023

  • 2023 0328 – Grady Polcyn – FFL – IULs: What Are They and How Do You Find Them? – [VIDEO-YouTube-21:44]
    • Client Example – Mary – 79 yo woman – UL – 
    • UL History – BTID – Is this even Life Insurance – 
    • Target Premium – Minimum Premium
    • 6 – How to set up clients the right with IUL
    • Brad – ? 
    • Youtube Videos
    • Mutual of Omaha – Sales Tools – WinFlex – 
    • AMS Team – Illustrations
    • Reading definitions. – Tamra – Death Benefits – Level vs Increasing
    • Do the work
    • Americo
    •  
  • 2023 05 – Grady Polcyn – FFL – IULs Simplified with 4x Hall of Fame Producer, Spencer Faggioni – [VIDEO-YouTube-14:15]
    • 7 – Rich Man’s Roth
    • TikTok, Instagram – Financial Information 
    • 10 – Facts Tell, Stories Sell – Overfunding his 401k, Cash Value doesn’t go down. 
    • Grady – Should self-employed Insurance agents have an IUL? as a Retirement Plan? – Agents should have their own policy because it makes it easier to sell to other people.

  • 2023 0830 – Grady Polcyn – FFL – How To Sell IULs Virtually – [VIDEO-YouTube-50:03]

    • Description: Juan Franco, the #1 IUL producer at FFL, shares the secrets to selling IULs virtually. He protected over 1,300 families personally last year with this approach.

  • 2024 0123 – Grady Polcyn – FFL – IUL Bootcamp: Script, Illustration, Close – [VIDEO-YouTube-34:38]

    • Description: 3x Hall of Fame Producer and Integrity Partner, Calvin Wright, demonstrates how to successfully setup, present and close 20-30 IUL appointments per week.
    • Current Assumptions
    • Ameritas – Ethos –  IUL
    • 12 – returns – 5-15 – Conservative Estimate – 
  • 2024 0312 – Grady Polcyn – FFL – Insurance Sales Presentation of the #1 All Time Producer – [VIDEO-YouTube-21:45]
    • Steve Giordano
    • SG – Selling an IUL to a 26 yo. IUL is exploding right now. Sales Record last week.
  • 2024 0409 – Grady Polcyn – FFL – How To Protect 940 Families A Year (Personally) – [Easton Padden] –
    • 9 – Homeless, Broker, like most of us
  • 2024 0510 – Grady Polcyn – FFL – Americo IUL Sales Training with Madison Hill – [Jamie Chirio / Josh   – [VIDEO-YouTube-27:02]
    • Americo IUL Illustrations – 8.42% Illustrated Rate, 6.25% Alternate Rate
    • 9 – Madison Hill – Illustrated Rate, Illustrates Really well.
    •  – IUL 101 – Gibberish – Talk to us like we are kindegartners
    • 10 – Josh – We are used to selling Final Expense / Mortgage  – Not used to looking at Illustrations – Big Grid of Confusing numbers –  Illustrated Rate – Whole Life-4-5%. We love IUL’s.
      • 13 – Non-Guaranteed – Telling Clients – Close to Reality – Americo IUL Illustrations – 8.42% Illustrated Rate, – “Easy Solve”
    • 13 – Target Premium, Max Premium – Easy Solve Premium – 
    • 21 – Jamie Chirio – 

2022 – LLQP – Life Licence Qualification Program (LLQP) Exam Preparation Manual

  • 2022 – Life insurance: Life Licence Qualification Program (LLQP) Exam Preparation Manual E-311 – 9th Edition
  • Chapter 4 – Universal Life
  • (p53) – This Chapter explores the third type of permanent insurance, universal life (UL) insurance, which evolved after numerous modifications to whole life insurance.
  • (p261) – 11.6 Using illustrations
  • [Bonk – [1]]: Understand, Underwriters – Coverage, 
  • [Bonk – [2]]: Term vs Perm, Perm – Projections, Illustrations = Complex, 
  • [Bonk – [3]]: universal life policy outcomes – [Coverage Period], sensitive / investment performance – [], Projection, Future Performance, Signature (Understanding]
  • [Bonk – [4]]: Agent, Spreadsheets, Compare policies
  • [1] – Illustrations are commonly used to help the client understand the recommended policy, and they are often appended to the life insurance application so that the insurance company’s underwriters have a clear picture of the coverage being applied for.
  • [2] – In the case of a term policy, the illustration just shows the premiums payable and the death benefit in each policy year.
    • For permanent insurance policies, the illustrations are more complex, in that they also include projections of future policy dividends, mortality deductions, investment account values, and cash surrender values for each policy year.
      • [Bonk: [2]] +Coverage Period, What is the Purpose of Cash Value? – Why Should anybody care about any of this? LC-Blumenthal –  Look – CSV vs CV]
      • [Bonk: [2]] – Garret Gunderson = Why do they call UL Permanent?]
    • However, these projections are only intended to demonstrate how the policy works, and are not a prediction of guaranteed or expected performance.
    • [Bonk: 1) UL – Bobby Samuelson, LIFE180 – Missing COI Column, 2) UL – Any Plan, Coverage Period. 3) UL – Missing – Death Benefit in each policy year]
  • [3] – Participating whole life and universal life policy outcomes are very sensitive to even small changes in investment performance, particularly over the long life of these policies. To highlight this sensitivity, most policy illustrations now include projections for at least two investment return scenarios. Agents must ensure that policyholders understand that the projections are not predictions of future performance. In fact, the policyholder is typically required to sign the illustration, acknowledging that he understands the limitations of the illustration.
  • [4] – In addition to the official policy illustrations generated by the insurance company’s software, agents may find it useful to develop their own simple spreadsheets to compare products or insurance options, such as those provided earlier in the case study above.
  • (p261) – 11.6 Using illustrations
  • [Bonk – [1]]: Understand, Underwriters – Coverage, 
  • [Bonk – [2]]: Term vs Perm, Perm – Projections, Illustrations = Complex, 
  • [Bonk – [3]]: universal life policy outcomes – [Coverage Period], sensitive / investment performance – [], Projection, Future Performance, Signature (Understanding]
  • [Bonk – [4]]: Agent, Spreadsheets, Compare policies
  • [1] – Illustrations are commonly used to help the client understand the recommended policy, and they are often appended to the life insurance application so that the insurance company’s underwriters have a clear picture of the coverage being applied for.
  • [2] – In the case of a term policy, the illustration just shows the premiums payable and the death benefit in each policy year.
    • For permanent insurance policies, the illustrations are more complex, in that they also include projections of future policy dividends, mortality deductions, investment account values, and cash surrender values for each policy year.
      • [Bonk: [2]] +Coverage Period, What is the Purpose of Cash Value? – Why Should anybody care about any of this? LC-Blumenthal –  Look – CSV vs CV]
      • [Bonk: [2]] – Garret Gunderson = Why do they call UL Permanent?]
    • However, these projections are only intended to demonstrate how the policy works, and are not a prediction of guaranteed or expected performance.
    • [Bonk: 1) UL – Bobby Samuelson, LIFE180 – Missing COI Column, 2) UL – Any Plan, Coverage Period. 3) UL – Missing – Death Benefit in each policy year]
  • [3] – Participating whole life and universal life policy outcomes are very sensitive to even small changes in investment performance, particularly over the long life of these policies. To highlight this sensitivity, most policy illustrations now include projections for at least two investment return scenarios. Agents must ensure that policyholders understand that the projections are not predictions of future performance. In fact, the policyholder is typically required to sign the illustration, acknowledging that he understands the limitations of the illustration.
  • [4] – In addition to the official policy illustrations generated by the insurance company’s software, agents may find it useful to develop their own simple spreadsheets to compare products or insurance options, such as those provided earlier in the case study above.

Steve Leimberg

  • 2005 05 – Leimberg – Stranger-Owned Life Insurance: Killing the Goose That Lays Golden Eggs!, By Stephan R. Leimberg -10p
  • 2006 – The Journal of Gift Planning – Life Insurance and Charitable Planning: How to Stay on the Right Side of the Comfort Line
    in the (Quick) Sand, by Stephan R. Leimberg and Randy L. Zipse – 16p
  • 2007 0327 – LISI – Leimberg Newsletter – New York Best Interest Rule for Life Insurance – New Requirements for Life Insurance Producers and Ethical Considerations for Other Estate Planners, by Barry Flagg – 28p
  • 2018 1215 – LISI – Leimberg Newsletter – #2671 – Martin Shenkman’s Day 1 Notes from the 44th Annual Notre Dame Tax and Estate Planning Institute – 50p
  • 2020 0610 – LISI – Leimberg e-mail Newsletter Archive Message #17 – Subject: Jason Early & Permanent Life Insurance During Times of Uncertainty – 5p

Barry Flagg

2010s

  • 2017 0522 – Veralytic – Criticism of Hybrid Life Insurance Products – [Barry Flagg] – [VIDEO-YouTube-46:56]
    • SEC 151A, Harkin Amendment
    • Red Flags
      • 35 – HyperFunding –
        • [Bonk: Curtis Ray – MPI-?]
      • Indexed Loans
      • 46 – Premium Financing
        • [Bonk: 
      • Participation Rates / Cap Rates
        • [Bonk: 2012 0110 – BrokersAlliance – Introduction to Indexed Universal Life – [Sheryl Moore] – [YouTube-27:23]
          • 26 – Sheryl Moore: What your Agents need to know about. And that is what is the integrity of the renewal rates with the company that you are doing business with. Because some of these insurance companies have very high, inflated first year rates and they are subsidizing them with the rates in years two plus.
            • Steve Savant: That sounds so evil to me.
            • Sheryl Moore: eh… No Comment. I’ll just say it’s become a function of our independent agent distribution system unfortunately.
      • NAILBA – “
  • 2019 0327 – Leimberg – Subject: Barry Flagg: New York Best Interest Rule for Life Insurance – New Requirements for Life Insurance Producers and Ethical Considerations for Other Estate Planners, by Barry Flagg – 27p
    • This Base/Target Premium is set by actuaries and generally calculated using conservative assumptions as the amount necessary to cover COIs and expenses required to maintain life insurance death benefit.
      • As such, this Base/Target Premium can be thought of as the “insurance premium” (i.e. the premium paid to maintain life insurance coverage).
    • [Bonk: Overfund-?] – Premium amounts paid into the policy in excess of this Base/Target Premium can, therefore, be viewed as “excess premium” above and beyond that required to cover the costs of maintain the death benefit.
      • “Excess premiums” are typically intended to either create a cash value reserve as “pre-payment” of what would otherwise be future premiums and/or to grow the policy account for wealth accumulation, retirement planning, and/or asset protection

2020s

  • 2020 04 – Providing Life Insurance Advice under the New CFP Board Practice Standards, By Paul H. Auslander, Raymond Ferrara, and Barry Flagg  —  [link]  —  17p
  • 2020 0404 – Veralytic – Life Insurance Advice Under New CFP Practice Standards – [Barry Flagg] – [VIDEO-YouTube-01:36:01]
    • Nobody Know what they are getting charged, 
    • Expectations – Wall Street Journal, Forbes
  • 2023 0520 – Letter – Barry Flagg / Veralytic to Finseca – 2p
    • I regret to have to resign from Finseca … again, for the following reasons.
    • California Best Interest Rule for insurance products (i.e., CA SB 264). 
    • Lobbying against Client’s Best Interest rules is lobbying for preservation of current NAIC-based regulations that permit agents, brokers and insurers to “quote” low premiums while charging HIGH costs withOUT disclosing either those HIGH costs nor the HIGHer risks of future “premium calls” for more than the originally “quoted” premium or total loss due to policy lapse even when all originally “quoted” premiums were paid.
    • Such “bait-and-switch” sales and marketing practices foster DIS-trust blocking financial security for all, and continue to divide the financial security profession.
    • This current regulatory regime creates an environment where the reckless get rewarded and the prudent get punished.
    • I likewise believe Client’s Best Interests rules for life insurance are BOTH needed to protect consumers against “bait-and-switch” sales and marketing practices AND will lead to sales growth.
    • Insurance products are the last, largest, most-neglected and worst-performing assets on client’s balance sheets (e.g., WSJ: Universal Life Insurance, a 1980s Sensation, Has Backfired – [link]  —  [Bonk: by Leslie Scism]
    • Client’s Best Interest rules harmonize the operating principles necessary to enable more financial advisors to have more conversations like this with more customers, resulting in BOTH greater financial security for all AND growth in sales.
  • 2023 0609 – Veralytic – Insurance Illustration DECODED learn how to find the hidden costs the agents won’t tell you! – [Barry Flagg] – [VIDEO-YouTube-44:23]

Larry Rybka

  • 2005 07 – JFSP – Guesses, Projections, Promises and Guarantees, Journal of Financial Service Professionals, by Lawrence J. Rybka, J.D., CFP® – 11p
  • 2019 10 – NAEPC Journal – How to Retire in the Magical Retirement Income in the Clouds, Issue 32, by Lawrence J. Rybka, J.D., CFP® – 11p
  • 2020 02 – NAEPC Journal – Life Insurance In The Client’s Best Interest: Seeing More Clearly in 2020, by Lawrence J. Rybka, JD, CFP® – 11p
    • If there is a dispute on how a policy was supposed to work or the benefits that were to be provided, it is the policy contract language that controls it, not sales materials or representations by the agent
  • 2021 – Retirementincomejournal.com – Life Insurers face “The Great Call”, by Larry Rybka – [link]
    • 2021 0409 – Valmark Financial Group – The Great Call – [Larry Rybka] – [VIDEO-YouTube-15:26]
      • Description: It is no secret that the press of low yields is forcing additional restructuring moves on life insurance companies. In this video, I comment on both Allstate’s retreat from the U.S. life business and the demutualization and sale of Ohio National.
      • These recent transactions raise questions for the industry about which companies will put in enough “chips” to stay in the life insurance game…
  • 2022 1122 – Forbes – The Dirty Secret of Life Insurance Quotes, by Cameron Huddleston and Amy Danise – [link]
    • If you’re shopping for a cash value life insurance policy such as universal life or whole life insurance, buyer beware: The life insurance quote you get might be a lot lower than what you’ll actually have to pay. And what you must pay could dramatically increase over time.
    • In early 2020, Rybka, Flagg and 10 others sent a letter of support for a proposal to the NAIC to limit what they saw as abuse of AG 49 and create more realistic projections for indexed universal life insurance in order to protect consumers. But the response Rybka said he got was that the NAIC was too far along in crafting its own fix to make a change.
  • 2023 0814 – Not in Barbieland Anymore: Abusive Life Sales May Lead to Jail if Combined with Investment and Tax Advice, Larry J. Rybka, Chairman and CEO at Valmark Financial Group – [link]
    • <WishList?> – Today, Arthur Postal of Life Annuity Specialist published a story called “Rogue Agents Dubious Indexed Life Investment Schemes Spark Lawsuits” (which you can view if you subscribe) about how a few life-only insurance agents gave advice that had effectively wrecked the financial well-being of hundreds of clients and left hundreds of millions of dollars of damage in their wake.
    • The common thread was that agents-specifically those who had relinquished their FINRA registration and continued to offer financial advice-used “regulatory arbitrage”, which allowed these agents to keep active state insurance licenses and offer advice with little to no standard or supervision. 
    • The cases referenced in Postal’s article are not isolated. Postal also cites a recently published Stanford Law Review article, which examined data from over 1.2 million advisors with varying levels of regulatory oversight. See Colleen Honigsberg et al., Regulatory Arbitrage and the Persistence of Financial Misconduct., 74 Stan. L. Rev. 373, 792.  – 56p
      • The study shows that those who drop FINRA registration and continue as state-licensed insurance agents (e.g., life-only agents) are “disproportionately likely to proceed under more lenient state-level regulation, thereby exposing investors to harm in the future.”
    • Comment – Steven S. Zeiger – The IUL posts on LI would never get through compliance with phrases like tax free, no risk of loss, better than your 401k plan, 8% returns, etc.
      • Larry J. Rybka – Steve exactly the point. There is no compliance. Fixed only agents do not have any review of sales materials or suitability. The article only gave examples of bad producers whose deeds were uncovered by regulators, and litigation apart from insurance regulation. There were another 4 examples this year involving hundreds more clients that did not make this story.
  • 2024 0418 – The Granddaddy of All Premium Finance Litigation, by Larry J. Rybka, Chairman and CEO at Valmark Financial Group – [link]
  • 1989 08 – Best’s Review – The Ledge Lie, by Volume 90 No. 4, Life/Health Insurance Edition, by Lawrence S. Rybka –  4p

Curtis Ray

2020s

  • 2020 0806- Curtis Ray - What Actually Happens In A Down Market with MPI - [VIDEO-YouTube-08:52]
    • 8 - Reloc (known as a Participating Loan) in an IUL - [Bonk: bottom of screen in Video]
  • 2022 / 2024 0729 - BetterWealth - I Challenged Curtis Ray About MPI... Here's What Happened - [VIDEO-YouTube-01:01:34]
  • 2022 0506 - The Homeboys - LIFE INSURANCE & RETIREMENT PLANNING WITH CURTIS RAY | 🏠 Homeboys Podcast #45 - [VIDEO-YouTube-52:22]
  • 2024 0521 - Curtis Ray - OIC-WA - Order NO. - 24-0094 - Order To Cease and Desist and Notice of Intent to Impose Fine - 8p
  • 2024 1009 - BetterWealth - The Curtis Ray Interview: Legal Threats, MPI Strategy, & Industry Backlash - [VIDEO-YouTube-01:23:50]

Tax Shelters

  • 2003 0719 – NYT – Wealthy Family Is Suing Lawyer Over Tax Plan, By David Cay Johnston – [link]
    • Since the government began attacking tax shelters in earnest two years ago, a growing number of individuals and corporations who bought shelters that the I.R.S. has either demolished, or may demolish, have filed lawsuits against promoters and their lawyers.

2020 0818 – Garrett Gunderson – Universal Life Insurance Policy: Everything you need to know

  • 00:00 – Todd – Zero-sum Game. Accountants got a hold of it sometime in the 80s and made decisions based on fear. – [Bonk: Who is Todd referrring to?]
  • 00:00 – Todd – Accountants made a decision to come up with a product that was good for the company, but not necessarily good for the consumer. And that’s where they lost their purpose.
  • 02:00 – Garrett – Concepts vs Math, Math supports the concepts.
  • 02:00 – Garrett – IUL is sold as a no risk product.
  • 02:00 – Todd – IUL Upside, Downside,  UL built on the Term Chassis. 
  • 02:45 – 04:15 – [Bonk: Q: How Can Universal Life Insurance Be Classified? Permanent / Whole / Term / Other]
  • 02:45 – Todd – People Say that Universal Life is Whole Life for half the price. It can’t be half the price and be the same thing.
    • 03:00 – re: Norman Baker (?) – There are no deals in the insurance industry. Everything is a trade-off between cost and risk for the insurance company. 
    • 03:15 – Todd – Why are the premiums different for Term and Whole?
    • 03:30 – Todd – Universal Life is somewhere between the two. What does that mean?  What that means is that there’s less risk for the insurance company and that is why they can charge a lower price for it.
    • But yet it’s sold as the same thing as Whole Life.
    • In fact, part of it is in the Name. It is classified as Permanent Insurance. What does that mean? What does Permanent mean to you?
  • Garrett – That it will be around one day longer than me. For sure. 
  • Todd – Right. Permanent has to be there, right.? It has to be there. That’s what Permanent is. And, yet, Universal Life doesn’t fit that.  All it is is extended term insurance really.
  • 04:00– Garrett – It’s built upon this Term Insurance Chassis. Which is Annually Renewable. And it could go up every year as you get older. 
  • 04:00 – Todd – In the old days the only thing available was YRT.  Insurance companies then started Level Premium Term. Mortality Curve. 
  • 05:33 – Todd – UL undercharge – people – sad – people pay and then get a surprise. This thing is going
    • [Bonk: 1) UL – bigger and later surprise, 2) a) Blumenthal vs New York – Did it say $X was enough for permanent, b) GMP – Guaranteed Maturity Premium,  Expert Witness]
  • 0 – Garrett – Selling into a future that they don’t understand how it’s going to impact.
  • 07:00  – Todd – Seen what happens to families. Paid premiums, skipped Vacations.
    • Now that that spouse has died I find out that the Life Insurance doesn’t exist.
    • People say that insurance companies don’t pay claims. No, that’s not what happened. – What happened was that they bought a faulty product, because it was sold to them as something that is permanent, but it turns out not to be when they actually look at it.
  • 09:00 – Universal life is a zero-sum game, original purpose was…
  • 9:40 – Accountants made UL….-?
  • Insurance companies have a terrible reputation
  • 10:00 – Garrett / Todd – 2008 recession, Double Dip, Variable Life – Complexity of IUL – People don’t know how it works – Does taking money out of Policy affect your COI, NAV – Crediting has a lot of affects, Sequence of Returns, 
  • 12:50 – WL getting replaced by IUL. Guarantees vs NGE’s.
  • not to protect the consumer, it’s to protect the company
  • 6.81% max-? – Caps, Floors –
  • 14:45 – 
  • Garrett – alot of moving pieces, alot of things you are not being told, level of uncertainty, Tax Shelter
  • later people will think they have a different product
  • if somebody sold it, they may not know
  • 16:00 – Garrett / Todd – People think it’s simple, I can’t think of a more complicated product,
    • ⇒  They think they are buying a different version of an Indexed Annuity.
    • Maybe it’s easier to sell if you don’t explain it
  • Todd – Arbitrage – LIRP – Illustration – Marketing – Guarantees vs NGE’s
  • Think and ask better questions