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DOL Fiduciary Ruling – 3 Cs of Compliance
Welcome everyone! Thank you so much for taking your valuable time to join us today to hear more about challenges posed by the upcoming DOL regulations and things you can do now to get ready for the january go date. November 10, 2016 Moderated By: Suzanne Brazeal, VP Operations x112|
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The 3 Cs of DOL Compliance
Welcome & Panelist Introduction Jason Berkowitz IRI VP & Counsel Regulatory Affairs Jeanann Smith DTCC Director, Product Management Mary Anne Durall SE2 SVP Strategy & Corporate Planning Barbara Smith Pershing VP
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The 3 Cs of DOL Compliance
Welcome & Panelist Introduction Susan Fiengo Global Atlantic SVP Operations – Retirement Robert Dearman Jackson VP, Strategic Initiatives Daniel Surber AIG Annuities VP, Operations Eric Silvester LPL VP, Client Compensation (Commissions) Suzanne Brazeal Ebix Consulting VP, Operations
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The 3 Cs of DOL Compliance
The Industry Challenge DOL’s Fiduciary Ruling impacts the Financial Institutions in a way that requires them to provide additional disclosures to their customers that are related to fees, expenses, and compensation assessed on Annuity contracts, when financial advice is provided that would result in a charge to the customer. Carriers face the challenge to provide the financial institution with the information required so that they are able to properly disclose to their customer and remain in compliance with the ruling.
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The 3 Cs of DOL Compliance
Industry Leadership Position Using industry collaboration to achieve Complete, Correct and Consistent compliance information through data standardization and automated communication methods. After many months of meetings and collaboration with distribution and vendor partners, insurance carriers are poised to offer an industry standard solution that has been sanctioned by key distributors and manufacturers. A guiding principal in the development of this standard solution was its feasibility to function for the broader insurance community, regardless of size or technological savvy.
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The 3 Cs of DOL Compliance
IRI DOL Fiduciary Rule Implementation Work Streams 17 Sub-groups meeting on a weekly or bi-weekly basis More than 900 individual representatives More than 120 organizations
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The 3 Cs of DOL Compliance
IRI DOL Fiduciary Rule Implementation Work Streams
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The 3 Cs of DOL Compliance
Global Atlantic – Carrier Perspective Carrier Perspective on Enabling Distribution Partner Compliance Easy access to data Accuracy of Data Prohibited transaction exemption agnostic data exposure
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The 3 Cs of DOL Compliance
DTCC’s Collaboration Efforts Full Work Task Force – 2/weekly meetings representing 40 Carriers, 47 Distributors, 22 Solution Providers Full Work Task Force – Scope & Focus Exemption Disclosures Requirements – Data Needs Fixed, Index and Variable Annuities Fee Inventory – 700+ fees
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The 3 Cs of DOL Compliance
IRI DOL Fiduciary Rule Impact Matrices
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The 3 Cs of DOL Compliance
IRI DOL Fiduciary Rule Disclosure Templates
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The 3 Cs of DOL Compliance
Complete, Correct, Consistent
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The 3 Cs of DOL Compliance
Global Atlantic – Carrier Perspective Carrier Benefits of Industry Standard Formats One source of truth Cost/Complexity control Distribution Partner Satisfaction – one stop shopping
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The 3 Cs of DOL Compliance
Complete, Correct, Consistent Current Coverage - DTCC’s Existing Services Firm Coverage Insurance Carriers – 220 - Distributors – 275 Solution Providers – 35 Product Coverage Positions & Valuations (POV) Commissions (COM) Financial Activity Reporting (FAR) 2015 Total I&RS Transaction & Settlement Volume Transaction Volume – 13,957,073,112 Settlement Dollars - $46,697,488,869
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The 3 Cs of DOL Compliance
Global Atlantic – Carrier Perspective Global Atlantic Preparation New Business – Product Modeling Inforce – Positions and Financial Activity Reporting updates Legacy – Map to Fee & Expense Transmittal
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Call to Action – Group Discussion
© Ebix Inc. All rights reserved.
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Getting Started – Available Resources
© Ebix Inc. All rights reserved.
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The 3 Cs of DOL Compliance
IRI DOL Fiduciary Rule Implementation Tools Industry-Wide Solutions FAQ for Financial Advisors Training Solutions for Advisors and Home Office Personnel* Advisor Compensation Survey* Best Interest Contract and Disclosure Templates* *In development
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The 3 Cs of DOL Compliance
IRI DOL Fiduciary Rule Implementation Tools Interpretation and Analysis Practice Guides on Treatment of Existing Business, Definition of “Fixed Rate Annuity Contract” Operational Resources Roadmap for Changes to Insurer and Broker-Dealer Policies and Procedures BIC Compliance Officer Job Description Template* *In development
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The 3 Cs of DOL Compliance
IRI DOL Fiduciary Rule Resource Center
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The 3Cs of DOL Compliance
DTCC’s Resources DTCC: Concept Paper – DTCC Initiative Support the DOL Fiduciary Rule (July 2016) Insurance Profile - Documentation Library – User Group Information Record Layouts, Data Dictionary, Standard Usage
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© Ebix Inc. All rights reserved.
Questions and Answers © Ebix Inc. All rights reserved.
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The 3 Cs of DOL Compliance
Moderated By: Suzanne Brazeal, x112 Panelist Contact Information: Jason Berkowitz Susan Fiengo Mary Anne Durall Daniel Surber Robert Dearman Jeanann Smith Barbara Smith Eric Silvester
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© Ebix Inc. All rights reserved.
Thank you! © Ebix Inc. All rights reserved.
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