RBC: The Insurance Process
Table of Contents
Chapter 1: Agent Ethics |
7 |
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Definition of “suitable” |
7 |
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Adequate Communication Skills |
8 |
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Investment Vehicles |
9 |
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Why is Ethical Conduct Necessary? |
9 |
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Is it Possible to Teach Ethical Behavior? |
10 |
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What is the Scope of Ethics? |
12 |
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What Does it Take to be a Moral Person? |
13 |
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Providing Quality Work and Services |
14 |
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Creating a Legacy |
14 |
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Example #1 |
15 |
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Example #2 |
16 |
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Example #3 |
17 |
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Example #4 |
18 |
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What are our Responsibilities to Other Moral People? |
18 |
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Required Continuing Education |
20 |
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Compliance Manuals |
21 |
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RBC Wealth Management Financial Services Compliance Manual |
22 |
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1. Introduction |
22 |
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2. Standards of Conduct |
22 |
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2.1 Ethics; |
22 |
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2.1.1. Priority of the Client’s Interests |
22 |
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2.1.2. Compliance with the Law |
23 |
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2.2 Conflicts of Interest |
23 |
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2.3 Privacy |
23 |
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2.4. Anti-Money Laundering |
23 |
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2.5. Personal Dealings in Securities |
23 |
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2.5.1. PRO Accounts |
23 |
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2.5.2. Employee Trading in Royal Bank Securities |
24 |
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2.6. Gifts and Entertainment |
25 |
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2.7. Prohibited Activities |
25 |
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2.7.1. Holding Out and Fronting |
25 |
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2.7.2. Coercion and Undue Influence |
26 |
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2.7.3. Rebating |
26 |
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2.7.4. Tied Selling |
27 |
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2.7.5. Misrepresentations |
27 |
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2.7.6. Twisting and Churning |
27 |
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2.7.7. Induced Lapse |
27 |
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3. Registration and Licensing |
28 |
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3.1. Insurance License |
28 |
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3.2. Dual Licensing for Securities and Life Insurance |
28 |
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3.3. Continuing Education Requirements |
28 |
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3.4. Errors and Omissions Insurance |
28 |
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3.5. Termination of a Life License for an IA |
29 |
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3.6. Termination of Employment of an IA from RBC DS |
29 |
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4. Scope of Business and Approved List of Insurance Suppliers |
30 |
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4.1. Scope of Business |
30 |
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4.2. Approved List |
30 |
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4.3. Foreign Insurance Products |
31 |
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4.4. Out-of-Province Clients |
31 |
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4.5. Non-Resident Clients |
31 |
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4.5.1. Sale of Insurance Products and Services |
31 |
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4.5.2. Servicing of Insurance Products and Services |
31 |
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5. Points of Sale Requirements |
32 |
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5.1. Agent of Record for Insurance Applications |
32 |
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5.2. Disclosure to Clients and Prospective Clients |
32 |
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5.3. Know Your Client / Insurance (KYC) |
33 |
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5.4. Policy Delivery |
33 |
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5.5. Commissions |
34 |
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5.5.1. Withholding of Commissions |
34 |
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5.5.2. Non-Life Licensed Insurance Referral Program |
34 |
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5.5.3. Additional Fees |
35 |
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6. Servicing Requirements |
35 |
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6.1. Updating Insurance KYC |
35 |
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6.2. Replacement of Existing Life Insurance Contracts |
35 |
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6.3. Remittance of Insurance Funds |
37 |
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6.4. Policy Transfers |
37 |
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6.4.1. Foreign Insurance Policies |
37 |
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6.5. Attorney acting under a Power of Attorney Designating a beneficiary |
37 |
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6.6. Limited Power of Attorney |
38 |
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7. Record Retention |
38 |
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Chart |
38 |
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7.1. Separation of Records |
40 |
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7.2. Cautionary Note on Destruction of Records |
40 |
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7.3. Records Documenting Verbal Communications with Clients |
40 |
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7.3.1. Information to be Documented |
40 |
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4.3.2. Where to Document Verbal Communications with Clients |
41 |
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8. Segregated Funds |
41 |
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8.1. On-Book, Off-Book Transactions and Creditor Protection |
41 |
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8.2. Beneficiaries on Segregated Funds in RBC DS Self-Directed Registered Plans |
41 |
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8.3. Guaranteed Minimum Withdrawal Benefits (“GMWB”) |
42 |
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8.3.1. Point of Sale Requirements |
42 |
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8.3.2. Joint Life Payout Option on GMWBs |
42 |
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8.3.3. Reset Transactions on GMWBs |
43 |
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8.4. Canadian Investor Protection Fund Coverage |
43 |
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8.5. EPSs |
43 |
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9. Financial Planning |
43 |
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10. Marketing and Client Communications |
43 |
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10.1 Media Relations |
43 |
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10.2 Advertising and Marketing Materials |
44 |
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10.2.1. Marketing Materials |
44 |
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10.2.2. Content of Insurance Marketing Materials |
44 |
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10.2.3. Approval Process |
44 |
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10.2.4. Securities Related or General Marketing Materials |
44 |
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10.2.5. Client Testimonials |
45 |
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10.2.6. Website Advertising |
45 |
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10.2.7. Client Prospecting and Telemarketing |
45 |
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10.2.8. Co-Branding Marketing Initiatives with Royal Bank |
45 |
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10.3 Team Names |
45 |
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10.4 Sales Illustrations |
45 |
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10.5 Cooperative Funding |
45 |
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10.6. Promotional Items and Activities from Insurance Suppliers |
46 |
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10.6.1. Promotional Items |
46 |
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10.6.2. Promotional Activities |
47 |
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10.7. Separate Stationery for Insurance |
47 |
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10.8. Use of Titles for Insurance Business |
47 |
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Chart |
48 |
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10.9. Advertising for Segregated Funds and Annuities |
48 |
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11. Shared Premises |
49 |
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12. Regulatory Inquiries |
49 |
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12.3. Litigation |
50 |
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12.3.1. Reporting |
50 |
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12.3.2. General |
50 |
Chapter 2 Product Suitability |
51 |
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Ability to Save Adequately |
51 |
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The Reason for the Goal (the Reward) |
52 |
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The Goals |
55 |
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Basic Product Information Requirements |
56 |
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Determining Product Suitability |
57 |
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Product Replacement |
59 |
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Twisting, Churning |
59 |
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Internal Twisting, Stripping |
60 |
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Identifying Suitability Issues |
60 |
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It is Not a Liquidity Issue but Rather a Suitability Issue |
61 |
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Lock-boxing, Longevity Risk |
61 |
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A Comprehensive Financial Plan |
62 |
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Suitability in the Retail Sale of Financial Products |
64 |
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Reputational Risk |
68 |
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Reputational Contagion |
69 |
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Determining Suitability According to the Report |
69 |
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Internet Sales |
71 |
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Annuity Surrender Values and Penalties |
71 |
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Financially Sound Insurers |
71 |
Chapter 3 Product Costs |
73 |
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“Premium”, Actuaries |
73 |
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Adverse Selection |
75 |
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Purpose of the Insurance |
75 |
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Risk Categories |
76 |
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Life Insurance Death Proceeds |
76 |
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The Terms “Insurance” and “Assurance” |
76 |
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Term Insurance |
77 |
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Permanent Life Insurance |
77 |
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Whole Life Insurance |
78 |
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Universal Life Insurance |
78 |
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Life Insurance Surrender Charges |
80 |
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Taxation |
81 |
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Segregated Funds (Variable Annuities) |
82 |
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The Guarantees |
82 |
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Income Segregated Fund Guarantees |
83 |
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Segregated Fund Costs |
84 |
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Less Risk Brings Lower Yields |
84 |
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No-Load, Front Load Commissions |
84 |
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Implicit Interest Rate (i%) |
85 |
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Delaying Annuitization when Interest Rates are Low |
86 |
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Surrender Values and Penalties |
87 |
Chapter 4 Anti-Money Laundering |
89 |
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Abbreviation/Definition |
90 |
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RBC Wealth Management Financial Services Anti-Money Laundering and Anti-Terrorist Financing Policy |
91 |
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Glossary of Abbreviations |
91 |
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1. Policy Objectives |
92 |
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2. Application of Policy |
92 |
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3. Restricted Business and Entities |
92 |
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4. Client Due Diligence (CDD) |
93 |
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4.1 Due Diligence Requirements for Personal Clients |
93 |
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4.1.1. Ascertaining Identification – Face-to-Face |
94 |
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4.2. Due Diligence Requirements New Business Clients |
95 |
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4.2.1. Confirm the Existence of the Client’s Business |
95 |
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4.2.2. Collection of Beneficial Owner and Director Information |
96 |
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4.2.3. Not-For-Profit Organizations |
96 |
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4.2.4. Exceptions to Requirements (Business Clients) |
96 |
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5. When to Conduct Client Due Diligence |
97 |
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6. Enhanced Client Due Diligence |
97 |
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7. Third Party Determinations |
98 |
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8. Politically Exposed Foreign Person (PEFP) Requirement |
98 |
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9. Retention of Client Records |
99 |
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10. Suspicious Transaction or Attempted Transaction Reporting |
99 |
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11. “Red Flag” Indicators |
100 |
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12. Tipping |
100 |
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13. Large Cash Transaction Reporting |
101 |
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14. Mandated Money Laundering Reporting Officer (MLRO) |
101 |
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15. Training / Education |
101 |
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16. The Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations |
102 |
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Appendix 1: Reporting Lines for Unusual/Suspicious or Attempted Transactions |
102 |
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Representative |
102 |
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Associate Director, Surveillance and/or Chief Compliance Officer, DS FS |
102 |
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Manager, AML Compliance and AML FIU |
103 |
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Appendix 2: Reporting Lines for Possession/Control of Terrorist Property |
103 |
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AML Financial Intelligence Unit (via CLF Scanning) |
103 |
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Associate Director, Surveillance and/or Chief Compliance Officer, DS FS |
103 |
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Manager, AML Compliance |
103 |
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Terrorism Produces Insurer Risk |
103 |
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Legal, Reputational, and Operational Risk |
104 |
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Proceeds of Crime (Money Laundering) and Terrorist Financing Act |
105 |
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Object of the Act |
105 |
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Company Objectives |
107 |
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Policy Application |
107 |
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Restricted Businesses and Entities |
107 |
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AML Education |
108 |
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A Change in Thinking |
108 |
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“Integration Stage” of money laundering |
108 |
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“Layering Stage” and “Placement Stage” of money laundering |
109 |
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Product Identification |
109 |
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Permanent Life Insurance Policies |
109 |
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Annuity Products |
109 |
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Any Cash Value Insurance Product |
109 |
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1. Single Premium Life Insurance Contracts |
110 |
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2. Early Policy Redemption |
111 |
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3. Claim Fraud |
111 |
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4. Cash Premium Payments |
111 |
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5. “Free Look” Periods on Newly Issued Policies |
111 |
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6. Collusion of Customer Intermediary and/or Insurer Employee |
112 |
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7. Third-Party Premium Payments |
112 |
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8. Risks Involved in International Transactions |
112 |
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9. Fraudulent Customers, Insurers, or Reinsurance Companies |
113 |
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Money Laundering Indicators not Unique to Insurance Products |
113 |
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Prohibiting Cash Transactions |
113 |
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Use of False Addresses and Other Information |
113 |
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Overseas Business from Higher Risk Jurisdictions |
113 |
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Characteristics of the Money Launderer |
114 |
Chapter 5 Annuities |
116 |
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Annuity Terminology |
116 |
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General Policy Provisions |
120 |
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Planning for Increased Life Spans |
121 |
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Longevity Risk |
122 |
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Variable Annuities (Known as Segregated Funds) |
123 |
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Maturity Guarantees |
123 |
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Death Benefit Guarantees |
124 |
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Performance of Funds is Not Guaranteed |
124 |
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Types of Contracts |
125 |
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Registered Retirement Savings Plans (RRSP) |
125 |
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Section 146 of the Income Tax Act |
125 |
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Non-Registered Annuities |
126 |
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Prescribed Treatment / Non-Prescribed Treatment |
127 |
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RRSP Types |
129 |
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Contributions |
129 |
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Spousal RRSP |
130 |
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Taxation of Deferred Annuities |
131 |
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The Decision to Buy |
131 |
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Life Income Funds |
132 |
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Immediate Annuities |
132 |
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Payout Options |
133 |
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Single Life Payout Option |
134 |
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Joint-and-Survivor Payout Option |
135 |
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Installment Refund Life Payout Option |
135 |
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Variable Annuity Payout Option |
136 |
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Term Certain Payout Option |
136 |
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Other Products |
136 |
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Dollar Cost Averaging |
137 |
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Beneficiary Designations |
137 |
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Contingent Beneficiaries (Subrogated Beneficiary in Quebec) |
138 |
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The Insurance Contract |
139 |
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Deposits |
140 |
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Surrender Penalties |
140 |
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Retirement Savings Plan (RSP) Endorsements |
141 |
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Switches |
142 |
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Investment Options |
142 |
Chapter 6 Following the Sale |
144 |
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Policy Delivery |
145 |
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Confirming Medical History and Conditions |
145 |
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Rescinding a Policy |
146 |
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Returning Telephone Calls Promptly |
148 |
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Increased Liability |
149 |
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Liability Risks |
150 |
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Express Authority and Implied Authority |
150 |
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Contributory Negligence |
153 |
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Servicing Requirements |
155 |
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Updating Insurance KYC or Client Information on File |
155 |
Thank you,
United Insurance Educators, Inc.
Email: mail@uiece.com