2008 Annual Meeting ● Assemblée annuelle 2008 Québec 2008 Annual Meeting ● Assemblée annuelle 2008 Québec Canadian Institute of Actuaries Canadian Institute of Actuaries L’Institut canadien des actuaires L’Institut canadien des actuaires

Distribution Hot Topics PD - 39 Steve Krupicz, FSA, FCIA AVP Special Case Markets Manulife Financial

Agenda Hot topics related to distribution: 1. Rebating 2. Special Quotes 3. Compliance Anti-Money Laundering Business Practices 4. Succession Planning 5. Leveraging and G.A.A.R Annual Meeting Assemblée annuelle Annual Meeting Assemblée annuelle 2008

Rebating My working definition: –Offering clients incentives to purchase coverage from an advisor or carrier –Where that incentive is not part of the policy

Rebating Can be direct: –e.g. “buy through me and I’ll give you back 50% of your first year premium” Or indirect: –e.g. “buy through me and I’ll pay your accounting or legal bill”

Rebating Rebating is legal is Alberta & B.C. –Manulife experience has been relatively quiet in Alberta Lots on concern initially More along the “I’ll pay your bill” approach Some challenges but seems to have settled at a very low level

Rebating Rebating is legal is Alberta & B.C. –Manulife has seen very active rebating in some market sectors in B.C. Has led Manulife to place limits on the flexibility we offer clients post-issue

Rebating Rebating leads to some interesting questions: –Can an advisor deduct a rebate as a business expense? –Is a rebate taxable income to the recipient? A major concern for advisors who are rebating extensively

Rebating Is it spreading? –Rumors of B.C. advisors advertising for clients to come to B.C. to purchase insurance –Advisor request to take applications & do para-med’s at a distance and fly client to Vancouver for delivery

Rebating Will this affect experience? –Will initial lapse rates be higher? Due to advisors rewriting low-rebate sales made by competitors? Due to advisors rewriting their own clients after chargebacks have expired?

Special Quotes My working definition: –Premium or cost reductions or rate enhancements in return for reduced commissions e.g. rate age setbacks paid for via a commission reduction –Fully reflected in contract terms and provisions

Special Quotes A concern for advisors: –Is this a level playing field for all advisors? –Is this forcing advisors to lower their compensation? –Is this a liability issue for advisors?

Special Quotes A concern for advisors: –Whenever we poll advisors we get a near-universal rejection of these programs –Until they are: (a) in competition with another advisor (b) dealing with clients who want to barter

Special Quotes A recent twist: –We’ve encountered some cases where special pricing is allegedly being offered without commission reductions

Special Quotes Is this “micro-pricing” appropriate? –Are assumptions reasonable when we have only one policy per cell? –Is this business riskier than normal business? –Should margins be larger?

Compliance Anti-money laundering provisions: –Causing increased scrutiny of sources of funding for policies –Especially an issue in large case market –More disclosure required corporate- owned policies –More scrutiny on policy transactions E.g. transfers of ownership –“Politically exposed foreign persons”

Compliance Anti-money laundering provisions: –Makes us harder to do business with for advisors & clients –Necessary for regulatory compliance

Compliance Business practices are a potential compliance and pricing issue: –Example: applications by mail Advisor never meets face to face with client Take application by phone or mail it out to clients to complete Have para-med nurse confirm identity Deliver the policy by mail

Compliance Example: applications by mail –Field underwriting? –Anti-money laundering? –Greater risk of fraud? –Policy delivery requirements?

Compliance Example: applications by mail –Know your client? Recent case law in Quebec held that advisors should avoid recommending plans and strategies that they know to be inappropriate for a client Leveraging to invest

Succession Planning Average age of advisors is high and increasing: –Who will replace them? –Few “career companies” left –One of the service extras that have been replaced by higher expense allowances

Succession Planning Manulife is supporting a “associate advisor program” in one distribution channel –Screening, mentoring, training –Many second- or third-generation advisors –Limited success A help, but not the answer

Leveraging & G.A.A.R. A popular concept at the heart of many concept sales: –Clients restructure their financial affairs, introducing borrowing, in order to create tax deductions –Singleton case seemed to confirm that careful planning can drive tax deductions

Leveraging & G.A.A.R. Recent Lipson case raises questions: –CRA used g.a.a.r. to question the validity of the overall result rather than the precise steps i.e. client made his mortgage interest deductible –G.a.a.r. ruling upheld at federal tax court –Now before Supreme Court

Leveraging & G.A.A.R. Ruling could affect sales: –Triple back-to-backs rely to some extent on deductibility –Tax treatment of 8% & 10% policy and collateral loan structures in UL policies may be affected? –Will sales volumes be materially affected?

Leveraging & G.A.A.R. Ruling could affect policy experience: –g.a.a.r. issues are considerably less likely to be grandfathered –Could this impact: Lapse rates Funding levels

Distribution Hot Topics PD - 39 Steve Krupicz, FSA, FCIA AVP Special Case Markets Manulife Financial