I know this needs a lot of work. It is still in progress. Emily

The National Council on Aging uses Standards of Excellence as the basis for guiding our partnerships in key initiatives. To meet the Standards of Excellence, partners undergo a rigorous documentation review and training process. NCOA is responsible for ensuring our partners meet all of these Standards, which fall under 7 key areas:

Financial Professional Training and Quality Assurance

Goal: Ensure that consumers are assisted by financial professionals who are highly trained and continually monitored for excellent performance.

 

To achieve this goal, the partner agency will comply with the following standards (in addition to regulations, policies, and procedures that their firm already requires):  

  • Meet state and federal requirements for registered representative training.
  • Train all newly hired financial professionals that includes, but is not limited to:
    • Compliance with FINRA requirements for licensure and continuing education
    • Compliance with state Departments of Insurance requirements for licensure and continuing education.
    • The National Association of Insurance Commissioners’ (NAIC) Suitability in Annuity Transactions Model Regulation.
    • Additional training topics specified by NCOA that may include
      • Working with older adults, including those who are vulnerable
      • How to adequately assess a consumer’s current situation before discussing products When and how to refer customers to medicare.gov and/or State Health Insurance Assistance Programs (SHIPs), Medicaid offices, and/or Area Agencies on Aging (AAAs).
  • The firm will work with NCOA to create a clear, ongoing, and effective process for quality assurances. The partner firm will adhere to regulatory requirements for dealing with infractions by financial professionals.

 

Compensation and Protections Against Steering

Goals: (1) Ensure that consumers are not inappropriately “steered” to buy products because of higher compensation received by financial professionals and/or the partner firm; and (2) Ensure that consumers are not unduly pressured to purchase products.

  • Firm will adhere to all applicable federal and state standards of conduct applicable to investment recommendations by financial professionals including:
    • Regulation Best Interest, which requires broker-dealers (and associated persons) to act in the best interest of a retail customer when a making a recommendation of any securities transaction or investment strategy. The broker-dealer must meet four obligations (Disclosure, Care, Conflicts of Interest, and Compliance) to comply with the rule. (For more information visit: https://www.sec.gov/info/smallbus/secg/regulation-best-interest
    • The National Association of Insurance Commissioners’ (NAIC) Suitability in Annuity Transactions Model Regulation, as adopted by individual states, which requires producers to act in the best interest of a consumer when recommending an annuity and requires insurers to establish and maintain a system to supervise recommendations.

 

 

Manufacturer Representation

Goal: Ensure that consumers can choose from a broad range of diverse options available to them that are offered by the manufacturer.

 

 

Consumer Education and Decision Support (via websites and telephone)

Goal: Ensure that consumers are presented with information about options that is logical, clear, consumer-focused, unbiased, and based on individual needs, preferences, and circumstances.

 

There are two important parts to this process: (1) Understanding the person’s individual situation and how it affects their decisions about purchasing an annuity; and (2) Evaluating, comparing, and selecting a specific annuity.

 

Standards for Part I: Understanding the consumer’s individual situation

In clear and consumer-friendly language, the services should help consumers to:

  • Understand what decisions they need to make about annuities.
  • Identify whether they might be eligible for government subsidy programs that could affect their choices and, if they might be eligible, how and where to obtain more information and/or a definitive determination.
  • Understand other insurance-based solutions that may be available.
  • Understand various features of the annuity.

 

Standards for Part II: Evaluating, comparing, and selecting specific insurance plans

Based on the information from Part I process, the agency should:

  • Help consumers compare annuity options.
  • Provide comparative information in a clear format.
  • Provide information about the next steps in the process.

 

Customer Service and Support 
Goal: Consumers receive excellent service.

 

  • Consumers should experience a streamlined, easy-access phone routing that gets them to a live agent 80% of the time in 30 seconds or less during operating hours.
  • Less than 2% of scheduled outbound appointment calls should be late or missed.
  • Customer service Key Performance Indicators that are measured and tracked should have a 5% or less abandon rate, and 80% of inbound calls should be answered within 30 seconds
  • After call survey, industry standards etc..
    [E2] 

Regulatory Compliance for Partner Firm

Goal: Partner agencies comply with all regulations.
 

  • The partner agency and its financial professionals must comply with all relevant state and federal insurance regulations and notification requirements as outlined in their firm’s policies and procedures.

 

Additional Value-Added Services offered by the Partner Firm

Goal: Consumers will be offered advocacy and referral for assistance with accessing public benefits.

 

  • Once a consumer has purchased an annuity(s) through the partner firm, the consumer can subsequently contact the partner firm for assistance in understanding plan details.
  • When the firm reasonably suspects a consumer may be eligible for public benefits that could help them, they will refer the consumer to NCOA and/or other organizations that will help them apply for those benefits. NCOA will provide training and background materials for this purpose.

 

Periodic Review

Goal: These standards will continue to be reviewed on a regular cadence with the partner firm and NCOA

 

  • These standards will be revised and updated to reflect current federal and state laws and regulations as well as relevant partner firm policies and procedures on a regular basis.
  • This review will be at least annually, and more frequently, if needed, but no more than quarterly.
  • Reviews may include discussions of relevant trends, use cases, partner firm or NCOA changes in strategy or policies.

 [E1]NW is reviewing this language internally and may update this bullet.

 [E2]Nancy’s team at NW will review their KPIs and add language here.