2022 Annual Advertising Review Notice

National Life Group (“NLG”) approved advertising and sales materials are an important tool for you to use to help your prospects understand NLG and the products and services available.  NLG is committed to providing advertising and sales materials that are clear, consistent, and accurately disclose relevant information.  Whatever advertising medium you use, the Advertising Guidance Team (“AGT”) within Life & Annuity Compliance is here to help guide you in creating and utilizing content that meets these standards.   As you probably know, much of what you use for advertising or training may be required to be reviewed before it is used.  This communication will help guide you if you are unsure of what needs to be reviewed and approved, and how to get it reviewed and approved.

What Requires Advertising Compliance Approval?

Agents who are not securities-registered – all channels:

Registered Representatives (“RR”) of Equity Services, Inc.:

Assume any financial services marketing, communication, training, or recruiting piece you create or personalize requires the AGT’s prior compliance review and approval, even if it does not mention NLG.

RRs of other broker/dealers:

If you are registered with another broker/dealer, you will need to verify their requirements.  The above chart for non-securities registered agents applies to your marketing and communications for NLG products.

Advertising Defined

The definition of “advertising” is broader than most people believe. Advertising is any material designed to create public interest in NLG (or any affiliated company), NLG’s products, or in you as an agent/RR/Investment Adviser Representative (“IAR”), or any material designed to induce the public to inquire about or purchase a product or service.  This may include, but is not limited to:

• Prepared sales talks and presentations, including seminars and live webinars.
• Videos and recorded webinars.
• Social media, such as LinkedIn, Facebook, Twitter, Instagram, etc.
• Print Ads and other printed or published materials, including form letters and direct mail.
• Business cards and letterhead.
• Websites, website listings, or online presences of any type for an agency, individual or DBA entity.
• Newspaper, radio, television, computer, audio recordings, and billboard ads.
• Descriptive literature, including brochures, circulars, and leaflets.
• Agent training material.
• Telephone solicitations and sales scripts.
• Fact finders, illustrations, and proposals.
• Newsletters, press releases, articles, and reprints.
• Emails
  • For unsolicited sales or recruiting –  Refer to the Telemarketing and Email solicitation compliance section on the Agent Portal of the NLG website under Training/NL Group Compliance/Advertising & Social Media for additional guidance.
  • Signatures – Refer to the “What Requires Advertising Compliance Approval” section above to determine if your email signature(s) meets the criteria for needing advertising review.

IMPORTANT:  Even if the material you are considering using does not seem to meet the definition of advertising, all material that can be reasonably expected to lead to the sale or attempted sale of an insurance or security product or service (as outlined in the standards above) will need to be submitted for review and approval prior to use. In addition, all materials using NLG logos or brand, reference NLG or any affiliated insurance company, its products, or features of its products, or materials used in an NLG 403(b)/457(b) K-12 retirement plan, must be submitted to the AGT even if the material does not seem to meet the definition of advertising or does not fit one of the examples listed above.

Agent Training – Training that will be used with agents to instruct them on the companies or products of NLG or on the sale of such products also requires prior review and approval by the AGT.

Remember:  It is the content of the material that dictates the review, not the audience to which it is directed. The broad definition for advertising includes material directed to the general public, to a targeted group of consumers, to a single consumer, to professional advisors such as Certified Public Accountants (“CPAs”) and attorneys, and to insurance producers and other financial service professionals.

To submit materials for compliance review, please complete the Compliance Review Request Form (note the form has 2 pages) found on NLG’s website under Training/Compliance/NLGroup Compliance/Advertising and Social Media (and also below under Resources) and submit it, along with the materials for review, to AdReview@nationallife.com.

Affiliated and Affiliated Brokerage agents, please work with your agency to submit materials since they need to keep track of your advertising.
Once received, a member of the AGT will look at the material and contact you with questions or any necessary changes.  If changes are required, the reviewer will ask you to send a final copy before giving you an approval to begin using the material.

Special Types of Advertising

Social Media – Affiliated Agents

The following process applies if your social media site is subject to compliance review  (if you are unsure, please refer to the “What Requires Advertising Compliance Review’ section above).  For existing social media profiles, no form is needed, you can just send the link for the page to AdReview@nationallife.com with a message asking for it to be reviewed.  Social media sites allowed for business purposes include LinkedIn, Facebook Business Pages, Instagram Business, YouTube, and Twitter.  If you are planning to create a new page, please use NLG’s templates to submit the information you want to add to the profile for review before publishing it.  They can be found on the NL Group Compliance page when you log into nationallife.com.

Social Media – All Agents Not Registered with ESI

As an agent who is not securities-registered with NLG’s broker/dealer, the AGT does not need to approve your social media or website as long as you do not post NLG content directly to them (in other words, download or copy NLG content or create new content mentioning NLG, then post it. Only affiliated agents with an approved profile and Hearsay account are allowed to do this). You can share content from NLG’s corporate social sites to yours if you have a profile on one of the sites allowed for NLG business content – LinkedIn and, Facebook Business (please note, Instagram does not have a mechanism for sharing posts). You can find content on NLG’s corporate social accounts and then click “share” on specific posts. Sharing NLG content can be done without Compliance review/approval of your social media site, as long as you have not posted any content discussing NLG, NLG companies, products, or unique features.

Websites – Affiliated Agents

Affiliated agents desiring their own website can choose between FMG and Broadridge as approved website providers.  You can find information about both providers on NLG’s agent portal under Marketing/Digital Marketing.  Once you choose a provider, new content and changes come directly to Compliance for approval through the website provider’s compliance tool.

Websites – Independent Agents

Independent agents are free to choose any website provider.  If there is no mention of NLG, its companies or products, or unique product features, then your website is not subject to the Company’s review/approval.

If you would like to add NLG content to your website, the AGT would need to review your website first.  If you would like to do this, please complete both pages of the submission form, include the link to your site on the form, and return it to AdReview@nationallife.com. There may be edits required to the content you would need to make before it can be approved to post to your website.  Be aware – once the AGT reviews and approves an agent’s site, the agent would then be required to submit any desired changes to the site for review and approval before they could be published.

CoBrand on Demand

Looking for a quick way to get your name on professional-looking marketing?  Check out NLG’s CoBrand on Demand marketing system located on the agent portal in the left column after you log in.  This allows you to quickly personalize flyers, ads, postcards, business cards, etc. for delivery to you in either print or email.  The pieces go straight to the AGT – no need to do a separate submission!

For more information on the AGT’s review process, please refer to NLG’s Compliance Manual located on the NLG website under Training/Compliance/NLGroup Compliance.

For specific questions regarding what needs to be submitted, you can email AdReview@nationallife.com, or call the AGT’s main number at (802) 229-3129 and you will be put in touch with a reviewer. Please note – failure to follow NLG’s advertising review process could result in additional training, monitoring, or termination of your appointment with National Life Insurance Company and/or Life Insurance Company of the Southwest.

Tracking Control (TC) Numbers

Most items reviewed are assigned a unique tracking control (“TC”) number to them to help identify the material used.  An example would be TC111234(0821)3.

The numbers in parentheses are the month and date the piece was reviewed, and the final number represents how long the piece is approved for – 1 (1 year), 3 (3 years), or P (Perpetual).  If there is no number at the end it means a piece most likely is approved for a specific date or single use.  If you have any questions about a piece you submitted, please reach out to the AGT – your advertising guidance team member is  happy to help.  Thank you for your business!

Resources:

• NLG Compliance Manual
• Compliance Review Request form
• Guidelines for creating and submitting videos and podcasts
• List of previously approved and unapproved marketing systems

Social Resources:

You can find the links to NLG’s corporate social sites at: www.nationallife.com

Here are the links to the Do Good versions of NLG’s social sites with the NLG-branded content to share to your own social sites:

• https://www.linkedin.com/company/do-good-be-good-make-good
• https://www.facebook.com/DogoodBegoodMakegood
• https://twitter.com/DoBeMakegood
• https://www.instagram.com/dogood.begood.makegood/
• Here’s a flyer explaining the guidelines for sharing corporate social media.
• NLG’s Social Media Playbook for Affiliated agents using Hearsay, and RR’s of ESI
• NLG’s Social Media Guide for agents not affiliated with ESI, not using Hearsay