American National Annuity Product Training 

• Newly Appointed producers must take the IMG  All-Encompassing Course located in your Learning Plan on 1/1/2021.
• Existing Producers who have already take the IMG All-Encompassing Course satisfy the requirement with the review of the content in this email.

Continuing Education Training 

• For producers in states that have adopted the Revised Model and have already taken the previous suitability model:
      Producers who have already completed the original training requirement before January 1, 2021 must complete either a new one-time 4-hour course or an additional one-time 1-hour course before July 1, 2021.
• For producers in states that have adopted the Revised Model and have NOT already taken the previous suitability model:
  Producers who have not taken the original training requirement before January 1, 2021 must complete the new one-time 4-hour course before selling annuities. 
• Current list of states that have adopted the revised model

Find the 1-hour and 4-hour CE courses on the RegEd website under the state you are licensed. 

• Go to RegEd Website 

The National Association of Insurance Commissioners (NAIC) revised the Suitability in Annuity Transactions Model Regulation 275. Since finalized in February 2020, three states have adopted the Regulation: Arizona, Iowa and Rhode Island. As additional states adopt the Revised Regulation, producers doing business in those states will be required to complete additional General Annuity Training CE. 

The revisions to the Model Regulation require completion of EITHER a 1-hour General Annuity Training CE course available by producers who have taken the previous NAIC Annuity Suitability training, OR a new 4-hour General Annuity Training CE for those who have not taken it previously. General Annuity Training CE must be completed with a training vendor approved by the state of sale. For information about General Annuity Training vendors,

• Training click here .

Annuity cases submitted January 1st & beyond should include the new suitability forms below. These forms will appear in the App Builder online as of December 31st and the previous suitability form will be removed. 

• Annuity Suitability Client Profile
• PRODUCER RELATIONSHIP DISCLOSURE FORM

In February of 2020, the NAIC Membership approved revisions to Model #275 Annuity Suitability & Best Interest Standards. All recommendations by agents and insurers must be in the consumer's best interest, and agents and carriers may not place their financial interest ahead of the consumers' interest in making a recommendation. To date, Arizona, Iowa, and Ohio have adopted the Best-Interest Standard with an implementation date of January 01, 2021. 

• Agent Disclosure Form - For business written in Arizona, Iowa and Ohio, the agent disclosure must be signed by both the consumer and agent and submitted with the application starting January 01, 2021. The Agent Disclosure Form will be in all application packs, except Florida, on the Agent Portal as of January 1, 2021. 
• Suitability Questionnaire - We have also updated the Suitability Questionnaire and will begin using the new form for all states, except Florida, beginning January 01, 2021. 

Effective January 1, 2021

Under the Suitability Rule, agents are required, when making a recommendation to purchase an annuity, to act in the best interest of their clients based on the circumstances known at the time the recommendation is made and to place the consumers interests ahead of the insurers and agents financial interests. The Suitability Rule has been adopted by Arizona, Iowa, and Rhode Island. The rules in Arizona and Iowa are effective January 1, 2021 and the rule in Rhode Island is effective April 1, 2021. We anticipate that several other states will propose and adopt the Suitability Rule in the coming months. 

• SILAC has updated its Suitability Guidelines to assist you in your compliance efforts with the revised Suitability Rule and recommends that you thoroughly review the revised guidelines to ensure that your submitted business can be efficiently processed and issued. Please download the updated Suitability Guidelines on the Agent Portal. 
• As shown in greater detail in the Suitability Guidelines, agents are considered to act in a consumer’s best interest if they have met the obligations regarding care, disclosure, conflict of interest and documentation. Click here for the updated Suitability Guidelines. 

New Materials

1. A new Financial Representative Best Interest Certification     form – required at point of sale with every application.
2. A new Consumer Profile Information Questionnaire –      replaces previous suitability form and is required at point of sale with      every application.
3. A revised Replacement Addendum form – required at point      of sale with every application.
4. Appendix A – a new required disclosure that producers      must make to consumers at the time of the annuity recommendation.
5. Consumer Profile Information Questionnaire
6. Consumer Profile Information Replacement Addendum 

On February 13, 2020, the National Association of Insurance Commissioners (NAIC) approved an update to the Suitability in Annuity Transactions Model Regulation. The updated regulation adds a requirement for producers to “act in the best interest of the consumer when making a recommendation of an annuity”, as well as other associated requirements. Subsequently, Arizona and Iowa became the first two states to adopt the revised model with an effective date of January 1, 2021. 

• Sagicor has implemented the following to comply with the new requirements for producers selling annuities in Arizona and Iowa. Note that all the identified forms: (1) may be downloaded and printed from Sagicor’s Producer Portal; and (2) will automatically be included in all annuity e-application packets. Properly completed forms must be submitted with every Iowa and Arizona annuity application on or after January 1, 2021. NO EXCEPTION WILL BE GRANTED.