NY Regulation 187 Refresher

Since February 1, 2020, New York Insurance Regulation 187 (“Reg. 187”) has applied to life insurance. Reg. 187 requires producers and insurers to implement a process ensuring they are acting in the consumer’s best interest when recommending an annuity or life insurance policy issued in New York.

For Life Insurance

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

• National Life Group Life Product Training Requirement:
  • Prior to soliciting the sale of a life insurance policy or annuity contract, producers must complete the most recent version of National Life Insurance Company’s product training, available on the Agent Portal and available through e-contracting for new agents.

Life Application Requirements

All applications need to include the Confidential Financial Questionnaire (“Form 1392”) and Illustration, both completed on or prior to the application date.

• For Whole Life and Universal Life products:
  • A signed and dated illustration that matches the application is required at the time of application submission.

• For Term Life products:
  • The Statement of Policy Cost and Benefit Information which matches the application, must be signed, dated and submitted with the application.
  • Term Life illustrations require a signed and dated illustration that matches the application at the time of application submission.

• The Home Office conducts a suitability review for all life insurance policies applied for with New York situs.
  • Confidential Financial Questionnaire Form 1392 includes suitability information.
  • Form 1392 is 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 is conducted within our Underwriting department.
  • Producers are 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) is available via Merrill and recommended for all New York situs applications.
  • There is an additional disclosure requirement for Full-Time Affiliated Agents.
    • Disclosure Pursuant to New York Insurance Department Regulation 187 (“Form 20659”) satisfies this portion of Reg. 187.