2026 0331 - NAIC - LIAIWG - Call - Life Insurance and Annuities Illustrations Working Group - (A) 

  • 2026 0331 - NAIC - LIAIWG - Call - Life Insurance and Annuities Illustrations Working Group - (A)  ---  [BonkNote]
    • Agenda
    • Materials
    • 2026 0331 - NAIC - LIAIWG - Letters - Life Insurance and Annuities Illustrations Working Group - (A)  ---  [BonkNote]
  • 1- Ben Slutsker, Chair Minnesota
    • NAIC Spring National Meeting
      • Presentation / Observations - Annuity and Life Insurance Illustrations - LIAC - Life Insurance (A) Committee 
      • Double Digit Returns - 20+%
      • <WishList> - Presentation
  • 5 - Donna Megregian, AAA - American Academy of Actuaries - From Letter
    • The LPrC observed the lack of adoption of the amended Model 245 and would benefit from understanding why it has not been adopted by a majority of the states. We were also curious whether the variations in disclosures and illustrations gathered by the Working Group were observed within states that had adopted the amended Model 245 versus those that had not adopted the amended Model 245. If the adoption of the amended Model 245 mitigates the concerns raised regarding the amount and the range of annual returns disclosed or illustrated, we would suggest that the Working Group focus on education by encouraging nationwide adoption.
    • Illustrations are not predictions of performance and, based on our understanding, were never intended to be.
    • Recognizing that consumers learn in various ways, we encourage collaboration with consumer groups to explore how visuals and other media might be leveraged to understand the volatile and variable nature of returns from product features.
    • Can't call illustrations "projection"
  • Richard Weber, NAIC Consumer Rep, LICAC, Life Insurance Consumer Advocacy Center
    •  

2026 0331 - NAIC - LIAIWG - Comments - Life Insurance and Annuities Illustrations Working Group - (A) - ADD

  • Academy Comment Letter - Donna Megregian
    • The LPrC observed the lack of adoption of the amended Model 245 and would benefit from understanding why it has not been adopted by a majority of the states.
    • We also seek clarification of whether the 10%-25% return ranges were observed under Section 5 (disclosure) or Section 6 (illustration), or both?
    • ...  we would discourage illustrations being utilized as performance indicators or trying to modify illustrations to set expectations for consumers. Taking note of how life insurance illustrations were designed, and were meant to demonstrate how the product works, so too were annuity illustrations designed under the amended Model 245. Illustrations are not predictions of performance and, based on our understanding, were never intended to be. We suggest leveraging different means, such as the Annuity Buyer’s Guide or other supplemental sales tools to assist with demonstrating returns from indexed annuities.
    • Recognizing that consumers learn in various ways, we encourage collaboration with consumer groups to explore how visuals and other media might be leveraged to understand the volatile and variable nature of returns from product features. For example, the inclusion of graphs that show the returns of the index over a period of time may help consumers quickly identify volatility versus reading charts of numbers or disclosures .
    • We caution that providing consumers with any level of confidence in future returns for products in general, especially indexed and variable products, misrepresents the predictability and variability of the returns. We encourage focusing on the variability of past returns to highlight the nature of how the feature works. We also encourage diligent management and review of a policy by the policy holder to assess how actual returns have impacted the policy, and if adjustments are needed for the policy to continue meeting the needs of the policy holder.
  • Cannex Comment - 6p
    • p1 - The current illustration framework, as established in the NAIC Annuity Disclosure Model Regulation, provides a structured approach to presenting product performance to consumers. However, the interaction of three factors— (1) the renewal rate assumption, amplified by premium bonus designs; (2) the historical scenario selection methodology; and (3) the inconsistency between current strategy rates and the economic environment of the illustrated scenario— produces illustrated returns that can materially exceed reasonable consumer expectations.
    • In the short term, enhanced disclosures and supplemental reduced-rate scenarios can improve transparency within the existing framework.
    • In the long term, modernizing the scenario selection methodology toward standardized, forwardlooking representative scenarios, requiring economic consistency between strategy rates and illustrated scenarios, and strengthening standards for newly developed indices will be necessary to ensure the illustration framework keeps pace with evolving product designs and index innovations.
    • p3 - The Renewal Rate Assumption and Premium Bonus Interaction
      • Why this is misleading: In reality, initial-term strategy rates are not guaranteed to renew at the same level. Carriers routinely set more attractive rates for the initial term as a competitive marketing strategy, with the expectation and pricing intent that renewal-term rates will be lower. The current regulation does not distinguish between an introductory rate and a sustainable renewal rate.
      • [Bonk: ADD: Grading]
    • p4 - Inconsistency Between Current Strategy Rates and Historical Scenarios
    • p5 - Recommendations to the Working Group
      • Short-Term Approaches
        • 1. Require Disclosure of Renewal Rate Risk
        • 2. Require a "Reduced Rate" Supplemental Scenario
      • Long-Term Approaches
        • 1. Modernize Scenario Selection: Move Toward Standardized Representative Scenarios
        • 2. Require Consistency Between Strategy Rates and the Illustrated Scenario
        • 3. Strengthen Standards for Newly Developed and Bespoke Indices
  • Consumer Representatives Comment - 164p - Brenda Cude, Bonnie Burns, Brendan Bridgeland, Ken Klein, Erica Eversman, and Interested Party Birny Birnbaum
    • We have long been frustrated by the inadequacies of these illustrations.
    • Our comments, in the attachments listed below, address a number of issues.
    • p1 - A recommendation that the Working Group’s work take into consideration the knowledge gained from research about consumers and annuities (Best Practices for Annuity Disclosures, prepared by Brenda Cude)
      • p2-6 - 2026 03 - Best Practices for Annuity Disclosures, by Brenda J. Cude, Professor Emerita, University of Georgia NAIC Consumer Representative
      • p2 - Annuity disclosure design should be grounded in research-based knowledge about what consumers care about when choosing among annuities.
      • Several themes show up consistently across behavioral, marketing, and retirement-income studies.
      • p6 - High-Level Takeaway: Consumers care most about income amount, trust in the insurer, guarantees, and simplicity. I hope we can keep that in mind as we think about annuity disclosures.
    • p7 - 2026 03 - Life Insurance and Annuity Disclosures Must Address Long-Term Care Insurance Benefits, by Bonnie Burns, NAIC Consumer Representative
      • p7 - We ask that the Life Insurance and Annuities Working Group consider the impact of life and annuity LTC riders or benefits in its work.
      • [Bonk: ADD: 2025 0610 - NAIC - Seniors Issues Task Force - (B)
        • re: Life Insurance with LTC Benefits
        • Bonnie Burns, Consumer Representative - Can somebody show us how these policies work?
        • Steve-?
        • North Dakota Woman-? - Have people / States been getting Complaints about these products? Or are we going to get complaints 15 years down the road?
    • p8-18 - 2023 12 - to NAIC (LIAC) - Consumer Financial Literacy vs. Illustrations for Life Insurance and Annuities, Brenda J. Cude and CEJ / Birny Birnbaum
    • p19-34 - 2023 - CEJ / Birny Birnbaum - Re-Engineering Life and Annuity Illustrations and Disclosures for Consumer Protection and Fair 
    • p35-p45 - 
    • p46-50 - 
    • p51-70 - SILAC - 
    • p71-103 - F&G
    • p104-164 - Disclosure: Why it shouldn’t be the default, A joint report from the Australian Securities and Investments Commission (ASIC) and the Dutch Authority for the Financial Markets (AFM)
  • Joint Trades Comment - 3p - ACLI, CAI - COMMITTEE OF ANNUITY INSURERS, IRI - INSURED RETIREMENT INSTITUTE
    • We agree that in order to make an informed decision about the purchase of an index annuity consumers need to understand how the product operates and how it performs under various market conditions. The NAIC’s Annuity Disclosure Model Regulation (Model #245) seeks to address this through a buyer’s guide that describes the various deferred annuities available in the marketplace and with rules governing annuity illustrations.
    • ....  we encourage you to work closely with the Annuity Buyer’s Guide Working Group to ensure alignment between the two groups. 
    • The illustration rules set forth in Model #245 were intended to help consumers make informed decisions about annuities, but the Model has not been widely adopted by states.
    • ...  the Working Group can also explore whether Model #245 is performing as originally expected and whether it does in fact address the concerns raised by the Working Group in the states that have adopted the Model.
      • In connection with that review, we recommend conducting consumer focus group testing to better understand the information consumers want related to index annuities and the value of the existing illustration and disclosure framework would be helpful.
      • Any future work should be grounded in an understanding of how the current framework is, or is not, meeting the needs of regulators and consumers in states that have adopted the Model and states that have not adopted the Model.
    • While we appreciate the Working Group soliciting feedback on the general direction that it should move towards, we think more foundational work on the specific nature of any concerns, and the specific situations giving rise to those concerns, is needed to determine any next steps.
      • [Bonk: ADD: What's the Problem?]
        • ACLI - Birny - Tomasz
        • Lawsuits - Complaints
  • Steve Malerich - 2p - Actuary, Retired
    • p1 - I have two identified two areas where current practices appear to be inconsistent with the objective to “ensure … reasonable expectations regarding future performance” of index annuities. Both areas involve the disclosure of returns – likely unsustainable – that are based on past performance of an index.
      1. Price / Earnings Ratios
      2. Back-casting
    • p2 - Even if insurers begin with good intentions, I imagine that they build their proprietary indices from past winners in the market.
    • If, at first, just a few insurers deliberately build their proprietary indices to enhance historical returns, then they will lead the market in illustrated returns. Pressure will then be on other insurers to do the same; to not do so would likely mean to surrender their competitive position.
    • Lacking the ability to look inside today’s market leaders, I can’t say for certain that this explains the extraordinary returns that are being disclosed. But, “if it looks like a duck …”
    • It seems to me that the safest way to protect against such abuse would be to prohibit disclosure based on back-casting of proprietary indices. Any attempt to regulate it otherwise, I suspect, would allow some insurers to find ways around the regulation, eventually leading us into “too good to be true” territory.
  • Dick Weber Comment - 10p - LICAC - Life Insurance Consumer Advocacy Center, Gerard J. Vanderzanden
    • Attachments:
      • p4 1. F&G annuity illustration page
      • p5-10 - 2. “The Answer, Dear Brutus, Lies Not in the Life Insurance Products, But in Policy Illustrations” from the March 2026 edition of The Journal of Financial Service Professionals
    • LICAC is concerned that while annuity and life policy illustrations are intended to show how the policy dynamics (expenses and credits) WORK, illustrations are almost always perceived as a “projection” of policy values. In LICAC’s experience, policy illustrations are often used by agents to create and set buyer expectations.
    • Policy complexity is a problem for most consumers, but policy illustrations are the REAL problem. Even if the agent doesn’t specifically intend to use the illustration as a projection of outcome, the consumer will almost always interpret the illustration as a projection.
    • When the NAIC last broadly addressed the use of life insurance illustrations in 1995, it adopted Life Insurance Illustration Model Regulation #582. Variable universal life was explicitly excluded from that regulation, and Indexed products had not yet appeared in the marketplace and therefore could not be addressed in the Model. NAIC’s Model 245 attempts to similarly regulate annuity illustrations, but the Model has not been widely adopted.
      • [Bonk: ADD: 
    • 30 years ago, three-page policy illustrations were the norm before the 1995 Model Regulation, but 50+ page illustrations soon emerged to address the Model’s requirements, likely an unintended consequence. The consumer has not been well served by this explosion of data and narratives.
      • [Bonk: <WishList> - Examples of Illustrations from the 1970s, 1980s, 1990s]
    • In the short-term, we recommend:
      • Incorporate graphic images of accumulating value into illustrations in place of streams of numbers.
      • Determine the 5 scenario criteria and require consistency in use for all carriers and products.
    • In the long-term:
      • Incorporate into such a display user controls that allow the consumer to consider the “what ifs?” of premium/accumulation scenarios for annuities, and as it relates to life insurance illustrations, adjustable for age/rate class/death benefit/premium/withdrawals/loan variations.
    • Attachments:
      • p4 - 1. F&G annuity illustration page
      • p5-10 - 2. “The Answer, Dear Brutus, Lies Not in the Life Insurance Products, But in Policy Illustrations” from the March 2026 edition of The Journal of Financial Service Professionals
        • [Bonk: ADD: 
  • Utah Department of Insurance - 1p  
    • Past performance is not an indication of future performance.
    • Hypothetical returns should be round numbers, like 0%, 5%, 10% and should be capped by regulators. Showing hypothetical return of 20% serves no purpose, creates unrealistic expectations, and is very likely misleading. Using an illustrated return like 7.83% creates a false perception of precision and knowledge. If an insurance company illustrates a return of 7.83%, consumer is more likely to assume that the return is supported by research and not just a guess.
      • One potential solution would be to limit illustrated returns to whole percentages not exceeding 10%, and to illustrate at a rate selected by a consumer.
    • Regarding past performance, only the actual historical performance should be shown
  • Michigan Department of Insurance and Financial Services - 2p - Danielle M. Torres, Company Market Regulation Manager, Department of Insurance and Financial Services
    • ...  index annuity disclosures short-term and long-term approaches that may ensure consumers receive reasonable expectations for index annuity concerns at the point-of-sale.
    • Short-term solutions
      o Educational materials and/or alerts could be updated or drafted for consumers. The consumer representatives could be consulted to determine the most effective ways to communicate this information to consumers.
    • Long-term solutions
      • Prior to revising Model Law 245, review existing state and federal regulations for similar products including but not limited to:
      • Current NAIC model laws related to disclosures of life and annuity products
        o Model Law 250 – Variable Annuity Model Regulation
        o Model Law 270 – Variable Life Insurance Model Regulation
        o Model Law 570 – Advertisements of Life Insurance and Annuities Model Regulation
        o Model Law 582 Life Insurance Illustrations Model Regulation

      • FINRA rules for variable annuities and RILAs
        o FINRA Rule 2211. Communications with the Public About Variable Life Insurance and Variable Annuities.
      • Individual state statutory requirements 
      • Investigate tools or other resources that regulators could use to proactively assess the market and identify products that are failing to meet projections. This work could complement the technical work focusing on how consumers perceive and use illustrations.

2026 0331 - NAIC - LIAIWG - Comment Letters - Life Insurance and Annuities Illustrations Working Group - (A)

  • Academy Comment Letter - Donna Megregian
    • The LPrC observed the lack of adoption of the amended Model 245 and would benefit from understanding why it has not been adopted by a majority of the states.
    • We also seek clarification of whether the 10%-25% return ranges were observed under Section 5 (disclosure) or Section 6 (illustration), or both?
    • we would discourage illustrations being utilized as performance indicators or trying to modify illustrations to set expectations for consumers. Taking note of how life insurance illustrations were designed, and were meant to demonstrate how the product works, so too were annuity illustrations designed under the amended Model 245. Illustrations are not predictions of performance and, based on our understanding, were never intended to be. We suggest leveraging different means, such as the Annuity Buyer’s Guide or other supplemental sales tools to assist with demonstrating returns from indexed annuities.
    • Recognizing that consumers learn in various ways, we encourage collaboration with consumer groups to explore how visuals and other media might be leveraged to understand the volatile and variable nature of returns from product features. For example, the inclusion of graphs that show the returns of the index over a period of time may help consumers quickly identify volatility versus reading charts of numbers or disclosures .
    • We caution that providing consumers with any level of confidence in future returns for products in general, especially indexed and variable products, misrepresents the predictability and variability of the returns. We encourage focusing on the variability of past returns to highlight the nature of how the feature works. We also encourage diligent management and review of a policy by the policy holder to assess how actual returns have impacted the policy, and if adjustments are needed for the policy to continue meeting the needs of the policy holder.
  • Cannex Comment - 6p
    • p1 - The current illustration framework, as established in the NAIC Annuity Disclosure Model Regulation, provides a structured approach to presenting product performance to consumers. However, the interaction of three factors— (1) the renewal rate assumption, amplified by premium bonus designs; (2) the historical scenario selection methodology; and (3) the inconsistency between current strategy rates and the economic environment of the illustrated scenario— produces illustrated returns that can materially exceed reasonable consumer expectations.
    • In the short term, enhanced disclosures and supplemental reduced-rate scenarios can improve transparency within the existing framework.
    • In the long term, modernizing the scenario selection methodology toward standardized, forwardlooking representative scenarios, requiring economic consistency between strategy rates and illustrated scenarios, and strengthening standards for newly developed indices will be necessary to ensure the illustration framework keeps pace with evolving product designs and index innovations.
    • p3 - The Renewal Rate Assumption and Premium Bonus Interaction
      • Why this is misleading: In reality, initial-term strategy rates are not guaranteed to renew at the same level. Carriers routinely set more attractive rates for the initial term as a competitive marketing strategy, with the expectation and pricing intent that renewal-term rates will be lower. The current regulation does not distinguish between an introductory rate and a sustainable renewal rate.
    • p4 - Inconsistency Between Current Strategy Rates and Historical Scenarios
    • p5 - Recommendations to the Working Group
      • Short-Term Approaches
        • 1. Require Disclosure of Renewal Rate Risk
        • 2. Require a "Reduced Rate" Supplemental Scenario
      • Long-Term Approaches
        • 1. Modernize Scenario Selection: Move Toward Standardized Representative Scenarios
        • 2. Require Consistency Between Strategy Rates and the Illustrated Scenario
        • 3. Strengthen Standards for Newly Developed and Bespoke Indices
  • Consumer Representatives Comment - 164p - Brenda Cude, Bonnie Burns, Brendan Bridgeland, Ken Klein, Erica Eversman, and Interested Party Birny Birnbaum
    • We have long been frustrated by the inadequacies of these illustrations.
    • Our comments, in the attachments listed below, address a number of issues.
    • p1 - A recommendation that the Working Group’s work take into consideration the knowledge gained from research about consumers and annuities (Best Practices for Annuity Disclosures, prepared by Brenda Cude)
      • p2-6 - 2026 03 - Best Practices for Annuity Disclosures, by Brenda J. Cude, Professor Emerita, University of Georgia, NAIC Consumer Representative
      • p2 - Annuity disclosure design should be grounded in research-based knowledge about what consumers care about when choosing among annuities.
      • Several themes show up consistently across behavioral, marketing, and retirement-income studies.
      • p6 - High-Level Takeaway: Consumers care most about income amount, trust in the insurer, guarantees, and simplicity. I hope we can keep that in mind as we think about annuity disclosures.
    • p7 - 2026 03 - Life Insurance and Annuity Disclosures Must Address Long-Term Care Insurance Benefits, by Bonnie Burns, NAIC Consumer Representative
      • p7 - We ask that the Life Insurance and Annuities Working Group consider the impact of life and annuity LTC riders or benefits in its work.
    • p8-18 - 2023 12 - to NAIC (LIAC) - Consumer Financial Literacy vs. Illustrations for Life Insurance and Annuities, Brenda J. Cude and CEJ / Birny Birnbaum
    • p19-34 - 2023 - CEJ / Birny Birnbaum - Re-Engineering Life and Annuity Illustrations and Disclosures for Consumer Protection and Fair 
    • p35-p45 - 
    • p46-50 - 
    • p51-70 - Illustrations - SILAC - 
    • p71-103 - Illustrations - F&G
    • p104-164 - Report - Disclosure: Why it shouldn’t be the default, A joint report from the Australian Securities and Investments Commission (ASIC) and the Dutch Authority for the Financial Markets (AFM)
  • Joint Trades Comment - 3p - ACLI, CAI - COMMITTEE OF ANNUITY INSURERS, IRI - INSURED RETIREMENT INSTITUTE
    • We agree that in order to make an informed decision about the purchase of an index annuity consumers need to understand how the product operates and how it performs under various market conditions. The NAIC’s Annuity Disclosure Model Regulation (Model #245) seeks to address this through a buyer’s guide that describes the various deferred annuities available in the marketplace and with rules governing annuity illustrations.
    • ....  we encourage you to work closely with the Annuity Buyer’s Guide Working Group to ensure alignment between the two groups. 
    • The illustration rules set forth in Model #245 were intended to help consumers make informed decisions about annuities, but the Model has not been widely adopted by states.
    • ...  the Working Group can also explore whether Model #245 is performing as originally expected and whether it does in fact address the concerns raised by the Working Group in the states that have adopted the Model.
      • In connection with that review, we recommend conducting consumer focus group testing to better understand the information consumers want related to index annuities and the value of the existing illustration and disclosure framework would be helpful.
      • Any future work should be grounded in an understanding of how the current framework is, or is not, meeting the needs of regulators and consumers in states that have adopted the Model and states that have not adopted the Model.
    • While we appreciate the Working Group soliciting feedback on the general direction that it should move towards, we think more foundational work on the specific nature of any concerns, and the specific situations giving rise to those concerns, is needed to determine any next steps.
  • Steve Malerich - 2p - Actuary, Retired
    • p1 - I have two identified two areas where current practices appear to be inconsistent with the objective to “ensure … reasonable expectations regarding future performance” of index annuities. Both areas involve the disclosure of returns – likely unsustainable – that are based on past performance of an index.
      1. Price / Earnings Ratios
      2. Back-casting
    • p2 - Even if insurers begin with good intentions, I imagine that they build their proprietary indices from past winners in the market.
    • If, at first, just a few insurers deliberately build their proprietary indices to enhance historical returns, then they will lead the market in illustrated returns. Pressure will then be on other insurers to do the same; to not do so would likely mean to surrender their competitive position.
    • Lacking the ability to look inside today’s market leaders, I can’t say for certain that this explains the extraordinary returns that are being disclosed. But, “if it looks like a duck …”
    • It seems to me that the safest way to protect against such abuse would be to prohibit disclosure based on back-casting of proprietary indices. Any attempt to regulate it otherwise, I suspect, would allow some insurers to find ways around the regulation, eventually leading us into “too good to be true” territory.
  • Dick Weber Comment - 10p - LICAC - Life Insurance Consumer Advocacy Center, Gerard J. Vanderzanden
    • Attachments:
      • p4 1. F&G annuity illustration page
      • p5-10 - 2. “The Answer, Dear Brutus, Lies Not in the Life Insurance Products, But in Policy Illustrations” from the March 2026 edition of The Journal of Financial Service Professionals
    • LICAC is concerned that while annuity and life policy illustrations are intended to show how the policy dynamics (expenses and credits) WORK, illustrations are almost always perceived as a “projection” of policy values. In LICAC’s experience, policy illustrations are often used by agents to create and set buyer expectations.
    • Policy complexity is a problem for most consumers, but policy illustrations are the REAL problem. Even if the agent doesn’t specifically intend to use the illustration as a projection of outcome, the consumer will almost always interpret the illustration as a projection.
    • When the NAIC last broadly addressed the use of life insurance illustrations in 1995, it adopted Life Insurance Illustration Model Regulation #582. Variable universal life was explicitly excluded from that regulation, and Indexed products had not yet appeared in the marketplace and therefore could not be addressed in the Model. NAIC’s Model 245 attempts to similarly regulate annuity illustrations, but the Model has not been widely adopted.
    • 30 years ago, three-page policy illustrations were the norm before the 1995 Model Regulation, but 50+ page illustrations soon emerged to address the Model’s requirements, likely an unintended consequence. The consumer has not been well served by this explosion of data and narratives.
    • In the short-term, we recommend:
      • Incorporate graphic images of accumulating value into illustrations in place of streams of numbers.
      • Determine the 5 scenario criteria and require consistency in use for all carriers and products.
    • In the long-term:
      • Incorporate into such a display user controls that allow the consumer to consider the “what ifs?” of premium/accumulation scenarios for annuities, and as it relates to life insurance illustrations, adjustable for age/rate class/death benefit/premium/withdrawals/loan variations.
    • Attachments:
      • p4 - 1. F&G annuity illustration page
      • p5-10 - 2. “The Answer, Dear Brutus, Lies Not in the Life Insurance Products, But in Policy Illustrations” from the March 2026 edition of The Journal of Financial Service Professionals
  • Utah Department of Insurance - 1p  
    • Past performance is not an indication of future performance.
    • Hypothetical returns should be round numbers, like 0%, 5%, 10% and should be capped by regulators. Showing hypothetical return of 20% serves no purpose, creates unrealistic expectations, and is very likely misleading. Using an illustrated return like 7.83% creates a false perception of precision and knowledge. If an insurance company illustrates a return of 7.83%, consumer is more likely to assume that the return is supported by research and not just a guess.
      • One potential solution would be to limit illustrated returns to whole percentages not exceeding 10%, and to illustrate at a rate selected by a consumer.
    • Regarding past performance, only the actual historical performance should be shown
  • Michigan Department of Insurance and Financial Services - 2p - Danielle M. Torres, Company Market Regulation Manager, Department of Insurance and Financial Services
    • ...  index annuity disclosures shortterm and long-term approaches that may ensure consumers receive reasonable expectations for index annuity concerns at the point-of-sale.
    • Short-term solutions
      • Educational materials and/or alerts could be updated or drafted for consumers. The consumer representatives could be consulted to determine the most effective ways to communicate this information to consumers.
    • Long-term solutions
      • Prior to revising Model Law 245, review existing state and federal regulations for similar products including but not limited to:
      • Current NAIC model laws related to disclosures of life and annuity products
        o Model Law 250 – Variable Annuity Model Regulation
        o Model Law 270 – Variable Life Insurance Model Regulation
        o Model Law 570 – Advertisements of Life Insurance and Annuities Model Regulation
        o Model Law 582 Life Insurance Illustrations Model Regulation
      • FINRA rules for variable annuities and RILAs
        o FINRA Rule 2211. Communications with the Public About Variable Life Insurance and Variable Annuities.
      • Individual state statutory requirements 
      • Investigate tools or other resources that regulators could use to proactively assess the market and identify products that are failing to meet projections.
      • This work could complement the technical work focusing on how consumers perceive and use illustrations.

Mamboleo v. Pacific Life Insurance Company

  • 2026 0224 - ThinkAdvisor - Pacific Life agrees to a $58M settlement in California PDX class action, by John Hilton - [link]
  • 2026 0327 - The And Asset and BetterWealth - The $58.3M Lawsuit That’s Shaking the IUL Industry - Ep. 27 - [VIDEO-YouTube-23:16] 

Securities Lending - AIG

  • Date-? - NAIC - Capital Markets Bureau Special Report - Securities Lending in the Insurance Industry - 9p
  • 2003 - LC - AIG Global Securities Lending Corp. v. Banc of America Securities LLC, 254 F. Supp. 2d 373 (CaseText) -  (S.D.N.Y. 2003). 
  • 2005 0926 - LC - AIG Global Securities Lending Corp. v. Banc of America Securities
    • Court: United States District Court, S.D. New York
    • No. 01 Civ. 11448 (JGK) (S.D.N.Y. Sep. 26, 2005)
  • 2010 - AP - The Role of Repurchase Agreements and Securities Lending in Distressed Financial Institutions, by Irvin Chan - 52p
    • (p4) - We then illustrate a mini-case of AIG and its securities lending business that parallels the repo lending that occurred with Bear Stearns, finding that AIG took on systemic exposure to a wide swath of AAA-rated tranches and mortgage-related investments, which quickly became illiquid and subject to a market freeze of a different sort.
  • 2009 0305 - GOV (Senate) - American International Group: Examining What Went Wrong, Government Intervention, And Implications for Future Regulation, (CSPAN) Government Intervention and Regulation of AIG, Chris Dodd (D-CT)   ---   [BonkNote]
    • (p57) - Eric Dinallo - There is justified concern about AIG's securities lending program, which affects only AIG's life insurance operations.
  • 2009 0305 - GOV (House) - Perspectives on Systemic Risk, Paul Kanjorski (D-PA)   ---   [BonkNote]
    • (p37-38) - Terri VAUGHAN.  AIG did have securities lending operations; a number of life companies have securities lending operations. No life insurance has gone insolvent because of its securities lending operations. The New York Superintendent had been working to address the issue of securities lending in AIG, and the insurance company had reduced the amount, and was in the process of reducing it further,  when it was overtaken by the problems with the credit default swap operation.
      • Credit default swaps led to a downgrade in AIG, it led to liquidity calls in the insurance company. Still not insolvent but there was a liquidity issue.
  • 2007 1129 - FCIC - PWC Notes re Meeting to Discuss Super Senior Valuations and Collateral Disputes - 3p
    • Secondly the issues in AIG Investment around the securities lending and the fact that if the exposure had been known prior to the q2 10Q being issued it is highly likely that the disclosures would have been changed.
  • 2010 0830 - FCIC - Report - Preliminary Staff Report - Governmental Rescues of "Too-Big-to-Fail" Financial Institutions- 43p
    • In addition, AIG was exposed to significant losses from its securities lending operation.
      • That operation pooled investment securities held by AIG‟s life insurance subsidiaries and lent out those securities in exchange for cash collateral.
      • The securities lending operation invested that cash collateral in a variety of securities, including $45 billion of MBS. As the MBS became illiquid in 2007, AIG was unable to sell the MBS to raise the cash needed to repay its securities lending counterparties.
      • In early September 2008, counterparties demanded that AIG return $24 billion in cash, thereby aggravating AIG‟s liquidity problems.110
        • 110 COP (2010b), at 42-46.
  • 2008 0819 - FCIC - Goldman Sachs / FRB emails - Don't Buy AIG: Potential Downgrades, Capital Raise on the Horizon - 20p
  • 2007 1129 - FCIC - PWC Notes re Meeting to Discuss Super Senior Valuations and Collateral Disputes - 3p
  • 2009 0305 - GOV (Senate) - American International Group: Examining What Went Wrong, Government Intervention, And Implications for Future Regulation - aka Government Intervention and Regulation of AIG, Eric Dinallo - [PDF-72p
  • PDF-380p,
  • 2009 04 - JP Morgan - Securities Lending in a crisis environment: Lessons learned, Joshua Lavender - [link]
  • 2009 - Legal Case - American International Group, Inc. 2008 Securities Litigation - Document 95 - Complaint - Case 1:08-cv-04772-LTS Filed 05/19/2009 - 307p
  • 2011 - AP - AIG: Misconceptions, Precipitating Factors in Government Bailout, and Implications for the Financial Industry, Alexis Paulovich - 56p
  • 2011 0708 - NAIC - Capital Markets - Securities Lending in the Insurance Industry - 10p
  • 2013 11 - FRB-NY - Securities Loans Collateralized by Cash:  Reinvestment Risk, Run Risk, and Incentive Issues, Frank M. Keane - [link]
  • 2014 - Mercatus / American Banker - AIG's Collapse: The Part Nobody Likes to Talk About, Hester Peirce - [link]
  • 2014 05 - AP - Securities Lending and the Untold Story in the Collapse of AIG, Hester Peirce - No. 14-12 - 82p
  • 2020 03 - Yale - YPFS - The Rescue of American International Group, Module B: The Securities Borrowing Facility - 18p
  • 2008 0819 - Goldman Sachs / FRB emails - Don't Buy AIG: Potential Downgrades, Capital Raise on the Horizon - 20p
    • Exhibit 3: Potential rating downgrades impact on underlying fundamentals
    • Securities Lending
      • If securities borrowers decide not to roll based on lenders' credit ratings, AIG might have to liquidate (potentially risky) assets to generate the cash to return to borrowers, thus raising the potential for capital hits.
      • AIG is said to be one of the more risky securities lending insurance participants.
  • 2010 01 - BIS / The Joint Forum - Review of the Differentiated Nature and Scope of Financial Regulation Key Issues and Recommendations - 128p
    • Another issue AIG had to face came from its securities lending programme.
      • AIG's insurance undertakings essentially lent securities via this programme to other financial institutions outside the AIG group in exchange for cash collateral.
      • This money was then used by AIG Investments for investments in RMBS and other debt obligations.
      • News on the weakening state of AIG caused increasing numbers of lenders to return the securities and to regain their money from AIG.
      • This caused further liquidity difficulties for AIG.
    • →  Both activities contributed to a strong need for additional liquidity at AIG in September 2008.
      • [Bonk: Both Activities = Securities Lending and AIGFP-Credit Default Swaps
  • 2008 1009 - WSJ - Further Loan To AIG Shows Fed Miscalculated Risks, By Liam Pleven, Carrick Mollenkamp and Craig Karmin - [link] - <WishList?>
    • AIG's securities-lender clients flooded the program for their collateral, creating a "mini-run" on the bank, says Doug Slape, chief financial analyst of the Texas Department of Insurance.
    • The company began drawing down on the Fed loan commitment to cover the collateral requests, it told Mr. Slape in recent conversations, he said.
    • By Oct. 3, Moody's Investors Service said AIG's default-insurance and securities-lending program had experienced "substantial losses and write-downs" due to mortgage securities.
    • The Texas regulator grew concerned about the exposure in 2007.
      • At the time, AIG told Texas it recognized that it needed to retain more cash, Mr. Slape said.
  • 2009 0514 - GOV (House) - How Should the Federal Government Oversee Insurance?, Paul Kanjorski (D-PA)  ---  [BonkNote]
    • As you heard, my name is Martin Grace. ... billion in taxpayer money did go to bailing out AIG insurance subsidiaries and their securities lending program.
  • 2009 0305 - GOV (Senate) - American International Group: Examining What Went Wrong, Government Intervention, And Implications for Future Regulation - Government Intervention and Regulation of AIG (CSPAN) - [PDF-72p, VIDEO-SPAN
    • 15 - Shelby, Securities lending, State Insurance Regulation,  Disturbing Story
    • 33:00 - Eric Dinallo (NY / NAIC) - Securities Lending didn't have anything/much to do with AIG Collapse, run on aig life, <Reputational Risk>, 
    • Securities Lending, RMBS, Liquidity, <C-3, 1980 SOA Paper>, Run on AIG, 
    • Scott Polakoff - OTC, Donald Kohn
  • PDF-380p,
    • (p31) - Joel Ario (NAIC - PA):  But there is a well there where if we are pressed real hard on some sensitive topics, we don't have clear authority to go into the holding company level.
      • And so I do think you need somebody that has clear authority at that holding company level as well.
  • 2009 - Legal Case - American International Group, Inc. 2008 Securities Litigation - Document 95 - Complaint - Case 1:08-cv-04772-LTS Filed 05/19/2009 - 307p
    • 23. On Thursday, September 11, 2008, AIG executives brought in bankers from JP Morgan and a Blackstone consulting group, who determined that AIG would need at least $40 billion.
      • However, on Sunday morning, September 14, AIG's outside advisers discovered that the Company's securities lending business needed a separate injection of as much as $20 billion.
      • As a result, an offer of a $20 billion lending facility that the New York State Insurance Superintendent, Eric Dinallo, had considered establishing for the benefit of AIG became moot since it was becoming clear the Company needed at least $60 billion of financing.
    • 24. Things rapidly continued to spiral downward.
      • On September 15, AIG informed Superintendent Dinallo that it needed as much as $70 billion to avoid failing.
      • Mr. Dinallo responded that the State would not act unless there was a plan in place to provide the rest of what AIG needed to survive.
    • (p77) - 211. On August 7, 2008, AIG held its 2008 second quarter earnings conference call.
      • On the call, Mr. Willumstad acknowledged that AIG's risk concentration in the U.S. housing market had been too high: "[Y]ou see again in retrospect much of the problems that have come about have been a concentration of risk in the U.S. housing market both in the investment portfolio and the credit default swap book."
  • "We were aware of this portfolio but we didn't have transparency on what was in it because it was off-balance sheet" in the company's statutory accounting reports, said Doug Slape, chief analyst at the Texas Department of Insurance, which oversees three AIG insurers that have suffered about 60% of the write downs.

2008 0627 - Reuters -  AIG To Lose Up To $5 Billion From Investments: Report - [link]

2008 0627 - Bloomberg - AIG to Absorb $5 Billion Loss on Securities Lending: Insurance Units Wrote Down $13B Tied To Mortgages, by Miles Weiss  ---  [BonkNote]

2013 - AP - Repercussions: The Impact of the AIG Bailout on it's Insurance  Subsidiaries, Shauna Ferris, Presented to the Actuaries Institute Actuaries Summit - 34p

  • AIG's securities lending program is a centrally managed program by AIG Investments for the benefit of certain of AIG's insurance companies and the Asset Management segment.
    • Securities are loaned to various financial institutions, primarily major banks and brokerage firms.
      • Cash collateral generally ranging from 100 to 102 percent of the fair value of the loaned securities is received and is invested in fixed maturity securities to earn a net spread.
    • To the extent that the collateral received is less than 102 percent, AIG has agreed with its insurance companies to *deposit funds to the collateral pool for the benefit of the insurance company participants.

2008 06 - AIG 10Q - [link]

*[Bonk: deposit funds = AIG - Matched Investment Program - (MIP)?]

  • 2010 0526 - COP - Hearing - Michael Moriarty (New York State Insurance Department - NYSID) - 7p
    • Whatever the AIG insurance companies' losses on securities lending, those losses should not have created serious problems for other financial institutions, which were protected by the fact that they held and could keep the securities they borrowed if AIG could not return the collateral they provided.  (p7)
  • [Bonk: Connect with FCIC Interview - Richard Scott]
  • 2011 - AP - AIG: Misconceptions, Precipitating Factors in Government Bailout, and Implications for the Financial Industry, by Alexis Paulovich - 56p
    • (p11-12) - Securities lending activities for AIG's insurance subsidiaries were consolidated to a special unit that was not licensed as an insurance company, AIG Investments (FCIC, 2010f, 4).
    • (p12) - For collateral, AIG Securities Lending Corporation, a division of AIG Financial Products, lent securities owned by several of the parent company's life insurance subsidiaries to authorized borrowers (Congress, 2010, 43). 
    • Google Search: "aig investment" "securities lending" - 85 results
  • (p36 / 89) - 7.5 AIG's Securities Lending Operations Faced the Same "Run on the Bank" Pressures as Many Other Financial Firms.
  • (a) Bernanke: "Whenever there was doubt about a firm, as in a standard bank run, the investors, the lenders, and the counterparties would all pull back their money quickly for the same reason that depositors would pull their money out of a bank that was thought to be having trouble." (PTX 708 at 79).
  • (b) Deloitte & Touche: "Because of the significant market turmoil caused by the Lehman bankruptcy filing, [AIG] experienced severe financial distress due to liquidity requirements at one of its subsidiaries and its inability to maintain its securities lending relationships." (JX 387 at 2).
  • (c) Between September 15 and 22, AIG's cumulative liquidity outflow from collateral postings, securities lending balance outflows, and downgrades totaled $25 billion. (Cragg: Trial Tr. 5033:23 - 5036:14; PTX 5341 (Cragg demonstrative)).
    •  (d) On September 12, 2008, Mosser sent an e-mail to Geithner and others at FRBNY stating: "Markets are also punishing AIG."
      • "Some banks are already pulling away; some banks are even turning down AIG in the secured (repo) borrowing markets".
      • "AIG's repo book is all investment grade, mostly structured mortgage products. . . . Things that have, in the past, been used as repo collateral. . . . but the combination of being perceived as a weak counterparty and risky, illiquid collateral is resulting in counterparties stepping away . . . .
      • Securities lending (mostly out of the insurance companies) - about $69B in liabilities, and the holding company has only enough cash to fund ½ of that, if sec lending counterparties turn away from the AIG name." (PTX 42 at 1-2 (ellipses in original)).

Starr International Company, Inc. v. The United States - Case 1:11-cv-00779 - Document 428 - Plaintiff's Proposed Findings of  Fact - 573p 

  • 2020 03 - Yale - YPFS - The Rescue of American International Group, Module B: The Securities Borrowing Facility - 18p
    • At some points, AIG accepted collateralization levels as low as 80% (from Credit Suisse) and 73% (from Barclays)7 (Hutchings 2010).
    • (p7) - As markets roiled throughout the summer of 2008, AIG's liquidity problems became increasingly clear to securities borrowers (GAO 2011, 19),

Annuities - Index

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Annuities

  • 2006 0221 - Letter - CEJ to NAIC - Proposed Changes to Life Insurance and Annuities Replacement Model - 3p
  • 2008 0528 - Letter - CEJ to NAIC - Comments on Model Regulation of the Sale of Life Insurance and Annuities to Senior - 4p
  • David Blake, The Geneva Papers on Risk and Insurance. Issues and Practice, Vol. 24, No. 3, ISSUES IN RISK MANAGEMENT AND INSURANCE (July 1999), pp. 358-375
  •  
 

2026 0224 - NAIC - LIAIWG - Call - Life Insurance and Annuities Illustrations Working Group - A

  • 2026 0224 - NAIC - LIAIWG - Call - Life Insurance and Annuities Illustrations Working Group - A  ---  [BonkNote] 
  • LIAIWG - Life Insurance and Annuities Illustrations Working Group - A - NAIC  ---  [BonkNote]
  • 1 - Ben Slutsker (MN), Chair
    • Background
    • Group Charge - LIAC - 
    • 1st Topic - Annuity Disclosure
    • This Working Group is new, the topic isn't. Similar Efforts over the Years.
      • Annuity Disclosure Working Groups - MDL-245
      • Life Illustrations Issues Working Group - 
      • IUL Illustrations Subgroup - LATF - AG49
      • [Bonk: ADD: X]
    • People with different backgrounds
      • Members LATF Subgroup
      • [Bonk: ADD: X]
    • Charge is larger than Actuarial Issues
      • Topics - Actuarial, Market Conduct, Compliance
    • 4 - Coordination with LATF
    • First Topic- Indexed Annuity Sales Materials and Disclosures
      • [Bonk: ADD: X] - What do agents say
      • Primary Issue is Annual Returns of 10-25% per year
      • Downside protection - 0% Flooor
      • Expectations - Frustrations - Lawsuits
      • Annuity Related Lawsuits - Disclosure, Agent Presentations
      • Quantify what is going on
      • Annuity Illustrations Requested from top 25-30 Companies
      • Observation - Highest Illustrated Rates
        • 1/3 Responses - 10% or Lower for highest rate
        • 2/3 Response - Greater than 10%
          • half of those - 11-15%
          • half of those - 16-27%
        • Multiple scales, Guaranteed Scale, Recent History, 
        • ...
        • How the Product Works. Right Balance. Understand what is currently being shown in the market, Reasonable Consumer Expectations.
        • 1/4 - RILA Products - SEC Requirements - some had High Illustrated Rates
        • Most came from FIAs - 0% Floor - Highest Illustrated Rates - BackCasting - Recently Created Indexes (1-2 years)
    • 11 - In Contrast to Life Insurance
      • Similar Designs to FIAs, but Life Insurance has a Death Benefit. Cost of Insurance Charges - Lower Returns
      • Life Insurance - 5-8% Returns
      • Life Insurance Model Regulation - Widely Adopted
        • [Bonk: ADD]
      • AG49 - IUL - multiple interations - AG49A
    • Model 245 - Annuites -
      • Only Adopted by 10 States
      • Retricts Illustrations for Indexes that have been around for less than 10 years.'
      • Not just a few companies - Competition in market - Show higher returns
      • monitoring, reset on illustrated rates
      • Attempt to address the issue with Regulations
      • Concerns that regulators have had
    • Collaborative Projects -
      • Different Interested Parties
      • Different Solutions, Different Perspectives
    • Chair Exposure
      • High Level
      • Guidance Documents
      • Revision to the Models
      • Looking for Collecting Ideas
      • then provide potential paths, Direction to go in
      • Hear from different parties, brainstorming
  • 17 - Others Thoughts - Working Group Members
  • 18 - Danielle Torres (MI) - re: 25-30 Company Illustrations - How prominant was it that there could be years where they could earn 0%?
    • Ben - There were guaranteed scales. <more>
  • 20 - Tomas (Utah) - 25% not very realistic over 25 years, 0% also not very realistic. Consumer - Investments - Theoretically lose 100% - Not a real warning so to speak.
  • 22 - Joshua (OR) - Backtesting Data - Different Philosophies of Backtesting - Different Companies - ? - Where are these numbers really coming from - Historical Data or not? Intentionally misframed?
    • Ben - Expose Draft - Add to 
  • 23 - Nour (MD) - Inflated or realistic. Annuity Model 245 - What are the actual returns if limited to 10 years? Realistic, not inflated, Properly Disclosured. Who looked at 25-30 Company Illustrations? NAIC? Minnesota?
    • Ben - Life Side - Not a NAIC Project. Couple of states get together to look at Life Illustrations - 10 per year - Disciplined current scale testing, AG49 - Observations at Regulator only Sessions - This years asked for Annuity Illustrations - Individual State Efforts, not a formal project. 
  • 26 - Danielle (MI) - SEC - Variable Annuities - 12% - Cap -
    • 27 - Tomas (UT) - Variable vs Fixed products. VUL / VA - Allocation - Return. Performance - Illustration - Different - Projected numbers depend on how you allocate. Hypothetical return - 6%.  
    • Ben - FINRA - 12% - We want to look at Federal Requirements Compared to Statutory / NAIC Requirements, Can some be borrowed from Federal Requirements. Potentional solutions, RILA's vs FIA's. RILA's - Additional Requirements. 12% - Why are RILAs showing 15% or 20% returns? Do RILA's have similar concerns to FIA's?
  • 30 - Bill Carmello (NY) - Other states are ahead of this on this. We haven't looked at Illustrations for Annuities.  I've been an outlier on the Life Side. one year approach.  Long-term - Whatever has been going on has been misleading for many years. There should be a limit on what has been going on with Derivatives on the Life Side. <More>. 
  • 32 - Interested Parties
  • Bonnie Burns (Consumer Representative) - Outside of Expertise. Gives me a headache. LTC Benefits. 101G Products. Underlying Insurance Products - How do people understand them when they buy them? Disclosure. How are they being sold? How will they work throughout their lifetime?
    • Ben - Guaranteed Living Benefits - How we approach those.
  • 34 - Dick Weber (Consumer Representative) - Interested Party in 1994-1995 - Model Regulation 582 - Illustration that we came across - in some ways reasonable - but then every 5 years have 36% and 57%. Consumers Expectations that Illustrations create. Specialty on the Life Side. Reasonableness, agent - Projection, Works, impossible scenario, helping bring the consumer point of view to this issue.
    • [Bonk: ADD] 
    • Ben - Great to have context / Perspective leading up to Model Regulation 582. Similarities and Differences will be helpful.
  • 36 - Larry Rybka (Valmark) - Big believers in Life Insurance and Annuties. We call them Fake Indexes - Marketers would call them Proprietary Indexes - Back-Testing = Cherry Picked - Actual Returns - Real Money - Bobby Samuelson has quantified some of these Indexes - Averaged about 2-3% ove the last 3 years when the S&P is up considerably. 0%. Talk about a Bait and Switch for Consumers. Actual returns from inception. Deceptive, there's no other way to frame it.
    • Ben - Great Point. Illustrative returns and describing them. History of returns versus initial Illustrations. What are we trying to solve here?
  • 39 - Birny Birnbaum - Broad Principles - Show a consumer how the product operates in a manner that a consumer can understand. Bill Carmello. 20 pages of small font tables what they are going to look for is that their 200K investment is going to be worth 200 Million dollars in 30 years - The type of thing we want to avoid. Show History in terms of Changing Caps, Floors and others related to Investment Returns. Systematic reduction in Caps, Best practices of other products, projections, FINRA Rule vs Others, Fiduciary Standard, 12% Rule - Subject to constraints that don't apply to Annuities. Issue has been talked about for many years. Presentations - LATF - LIAC - Summer 2023 (Birny and Brenda Cude - Specialty Consumer Understanding).  Start with Guiding Principles vs Tweaking current Model Regulations, etc.
    • Ben - High Level, Principles, not limiting anything at this point, Any ideas the Working Group could benefit from
  • Bobby Samuelson - Not an Investment, be thoughful, Expectations -
    • What is the Role of Illustration?
    • How it relates to other insurance products vs Investments
    • Way more complex than it seems - AG49, DCS (Disciplined Current Scale), Marketing Piece
    • Exposure Frames the issue in a very particular way
    • FIA - Accumulation - 37%, Clients won't lose money. Income / LTC Benefits - Replacements
    • Exchange - Suitability - Based on Illustrations
    • Life Insurance - Teaser Rates - Supportability 
  • Ben - Reframe the Exposure - What are parts that are not covered here - What is the Universe of the issue? Thinking about this more philosophically.
  • 48 - Sandy (?)  - What percentage of Annuities get filed with an Illustration?
    • Ben - I don't know.  Varies by state.
    • Sandy (?) - Which do and don't speaks to the scope of the issue.
    • Ben - Compact - Illustrations aren't part of their review.  I'd be interested to hear from the Compact. 
  • 50 - Mike Yanachek (IA) - Requirement for Life Products - MDL- 582. Not sure about Annuities
    • Noura (MD) - No, applies to Life, excludes Variable Life and policies under $10,000. Model 582 has the restrictions.
    • 51 - Joshua Blakely (OR) - Oregons process around Illustrations. Compact for Illustrations.  Requires all Ads to be filed for all illustrations. We send objections pretty regularly. So, I'm glad that we look at them.
  • 53 - Jason Robbins (The Standard) - RILAs, FIAs, Indices, BackCasting, returns are oftentimes excessive, Bobby Samuelson - Benefits. VA World, 12% Limit.  Indices seldom meet those numbers. Primary drive is probably these new indices. 
  • 55 - Brenda Cude (Consumer Representative) - Happy to lend my expertise to the work of this group. But, I feel at a real disadvantaged because of lack of research based information. What do Consumers want / look at when they are considering Annuities. Disclosures - with Agents or without Agents.  So, many things I don't know. I can't find any research from the consumer perspective. What consumers need and want when considering annuities. If anybody has that type of information that they can share with us that would be tremendously helpful.
    • Joshua Blakely (OR) - Agents vs Online Tool - Company Disclosure - Traditionally explained with Agents present, but now online without agents.  Drop downs, Premium Deposit, spits out illustration. 
    • Brenda Cude - Agents vs Online Tool - Different - 

Consumer – Index

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Walker vs. LSW – Life Insurance Company of the Southwest – Index

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