COMPLIANCE TEAM OUTLINE



TEMPLATE 1

COMPLIANCE TEAM OUTLINE

Structure

The recommended Compliance Team (Compliance Committee, Market Conduct Team, or whatever your company chooses to name it) should meet regularly, at a minimum of once each quarter. The Team is cross-functional, and should include these representatives:

Compliance officer/General Counsel

IMSA coordinator

Advertising review - primary responsible person

Licensing Manager

Complaints Manager

Head Underwriter

Marketing Manager(s)

Auditor

SIU Manager

Customer Service Manager

Training Manager

Human Resources

Input

The information which should be regularly available to the Team members includes but is not limited to:

Complaint reports (sorted at least by agent, agency, product type, complaint type) and t trend analysis

Customer survey reports and analysis

Results of any focus groups or special surveys

Legal review monitoring problems

Replacement activity (sorted at least by agent, agency, product type) and analysis

Non-disclosed replacement trends (as discovered through customer surveys and policy- service requests such as loans, rollovers, reduced paid-up, reduced term, surrenders, etc.)

Customer Transaction reports by agent : surrenders/withdrawals/not taken

Lapse trends by agent

Internal Compliance Audit results and recommendations

Underwriting exception reports, by agent

Licensing exception reports, by agency or recruiter

Advertising rejection reports, by agent

Disciplinary actions or investigations

Informal, anecdotal concerns

Output

The purpose of this Team will be to review available information and determine at least the following:

1. Recommendations for changes in training or policies and procedures throughout the functional areas impacted by IMSA.

2. Recognition of ‘red flags’ for particular agents or agencies, and recommendations to the appropriate department for disciplinary action.

3. Recommendations for additional types of information to be made available for the Team.

4. Reports and recommendations to Senior Management concerning the adequacy of the company’s ethical market conduct activities.

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