December 30, 2019
NY Regulation 187 is coming
Here's what you need to know to prepare.
The New York Department of Financial Services (NY DFS) released the final version of best-interest Regulation 187. The final regulation, now called “Suitability and Best Interest in Life Insurance and Annuity Transactions”, will require producers and insurers to implement a process ensuring they’re acting in the consumer’s best interest when recommending an annuity or life insurance policy issued in New York.
The new regulation takes effect on:
- August 1, 2019 for annuity contracts
- February 1, 2020 for life insurance policies
NEW for Life
Life Training Requirements
- NY State Training Requirement is currently available through RegEd:
- Visit RegEd at: https://secure.reged.com/TrainingPlatform/
- Available courses are 484_NY (5hr) and 485_NY (1hr)
- Agents can choose which course to take
- Either course satisfies the state requirement
- 484_NY applies toward NY state CE credits
- These courses satisfy the requirement for both life and annuity business
- Available courses are 484_NY (5hr) and 485_NY (1hr)
- Visit RegEd at: https://secure.reged.com/TrainingPlatform/
- National Life Group Life Product Training Requirement:
- This is currently in development and an additional notification will be sent with more details once this is available.
- The annuity product training is currently already available on the Agent Portal and available through e-contracting for new agents.
- This is currently in development and an additional notification will be sent with more details once this is available.
Life Application Requirements
Starting February 1, 2020 any application dated 02/01/2020 or after will need to include the Confidential Financial Questionnaire (form 1392) and Illustration. Both of these will need to be completed on or prior to the application date.
- For Whole Life and Universal Life products:
- A signed and dated illustration will be required at the time of application submission.
- For Term Life products:
- The Statement of Policy Cost and Benefit Information must be signed, dated and submitted with an application.
- Term Life illustrations will require a signed and dated illustration at the time of application submission.
- The Home Office will conduct a suitability review for all life insurance policies. This will be above and beyond our traditional Underwriting review.
- Confidential Financial Questionnaire form 1392 is being modified to include suitability information.
- This form will be required for all cases issued in New York as well as for post issue transactions that are reviewed by Underwriting (i.e. Term Conversions).
- Suitability of Life Insurance will be conducted within our Underwriting department.
- Producers will be required to inform applicants of various features of the life insurance product and potential consequences of the recommended transaction.
- A New York Suitability Disclosure Checklist (form 20660) has been created to comply with this disclosure requirement.
- There is an additional disclosure requirement for Full-Time Agents (Career Agents).
- Disclosure Pursuant to New York Insurance Department Regulation 187 (form 20659) has been created to satisfy this portion of the regulation.
Future communications will be sent with additional information regarding the product training and the required forms.
If you have questions regarding…
Product Training contact: Contracting@nationallife.com
